ML061460291

OI Interview Transcript of Witness, Dated 03/03/2004, Pages 1-69

ML061460291
Person / Time
Site:	Salem, Hope Creek
Issue date:	03/03/2004
From:	NRC/OI
To:
References
1-2003-051F, FOIA/PA-2005-0194, NRC-1364, nxp
Download: ML061460291 (70)

Text

Official. Transcript .of Proceedings NUCLEAR REGULATORY COMMISSION Title: Interview V -i -I

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£~ ~%. WV Docket Number: 1-2003-051 F C> t ,

Location: Salem, New Jersey Date: Wednesday, March 3, 2004 Work Order No.: NRC-I1364 Pages 1-69 NEAL R. GROSS AND CO., INC.,

Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.

Washington, D.C. 20005 7 (202) 234-4433 Information in this record was deleted inaccordance with the. Freedom of Information Act, exemptions IC. ,,

1 1 tnUItt StIATES 6P i4ERICA 2 NUCLEAR REGULATORY COMMISSION 3 4-4-4 + ++

4 OFFICE OF INVESTIGATIONS 5 INTERVIEW 6 x 7 IN THE MATTER OF:

8 INTERVIEW OF Docket No.

9 1-2003-051F 10 (Closed) 11 ---------------- x 12 Wednesday, March 3, 2004 13 14 Resident's Office, Salem 15 Hope Creek Station 16 17 The above-entitled interview was conducted 18 at 2:42 p.m.

19 20 BEFORE:

21 Special Agent EILEEN NEFF 22 23 24 25 NEAL R. GROSS COURT REOCRERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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2 1 P-R-O-C-E-E-D-I-N-G-S 2 (2:42 p.m.)

3 SPECIAL AGENT NEFF: Today's date is March 4 3rd, 2004. The time is approximately 2:42 p.m.

5 Speaking is Special Agent Eileen Neff with the NRC 6 Office of Investigations, Region I. What follows will 7 be an interview with 8

9 . .'As agreed, the interview is being taped 10 recorded and the location of this interview is the 11 Residence Office at Salem and Hope Creek.

12 The subject matter of the interview 13 concerns alleged discrimination involving.%.,-.l 15 allegations that he was discriminated against for 16 having engaged in protected activity. The events 17 allegedly occurred on or about the year 2000. The 18 allegations involve potential violations of 10 C.F.R. 19 50.5 which is deliberate misconduct and 50.7 involving 20 employee protection.

21 f as been advised that you are 22 being approached as a witness to this matter. You are 23 not the subject of this investigation. You are 24 strictly being approached as a witness and you 25 understand that.

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3 1 wwv That is correct.

2 SPECIAL AGENT NEFF: Okay. I should point 3 out that at this point in time we've had the 4 opportunity to interview you recently on another 5 matter. In that matter we picked up your identifying 6 information and I'll let that stand for the record.

7 In a moment I will briefly summarize your 8 employment history with PSEG nuclear and you can 9 correct me as I go through it if I'm wrong. But what 10 I would like to do is place you back under oath. If 11 you would raise your right hand, please. Do you swear 12 that the testimony you are about to provide is the 13 truth, the whole truth, and nothing but the truth so 14 help you God?

15I do.

16 SPECIAL AGENT NEFF: Okay. Prior to going 17 on the record, what I showed you in that these events 18 we're discussing will be around the year 2000, pretty 19 much now four years ago, late 1999 into 2000. We are 20 looking at about four years ago.

21 I gave you organizational charts and they 22 are dated May 1, 2000. One is for plant support. At 23 that time -- One is dated 24 2/28/2000. It shows Hope Creek operations. And the 25 other one dated May 12, 2000, which shows Hope Creek NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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4 1 operations from the -- who at that 2 point in time wai ind the positions under 3 him. That was to help jog your memory in terms of 4 place in time and the people involved.

5 Then I also showed you and you reviewed 6 three memorandums. One of them is dated November 4, 7 1999. The subject of that is, "Best Work Week Ever 8 Picture." The author lb, 9 The letter was going to..

10 12 The next memo that you reviewed was 13 February 8, 2000. That subject is, "Performance 14 Review Clarification of Expectations" going from, 15 16 17 T 18 19 SPECIAL AGENT NEFF:

20 3 You took a look at that. Then 21 there was a June 1, 2000, memorandum entitled, "Your 22 Accountability for the Best Work Week Ever Team."

23 That was written by -- coming from 24 25 j NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W (202) 234-4433 WASHINGTON. D.C. 2000D-3701 www.nealrgross.com

5 1 These are what you reviewed mostly to 2 refresh your recollection for that time frame and the 3 issues that were going on in terms of the Best Work 4 Week Ever and your role in that.

5 What I would like to do at this point is 6 just briefly summarize where you've been with PSEG 7 Nuclear. It's a lengthy career.

8 9

10 11 12 13 . i 14 SPECIAL AGENT NEFF:

15 16 17 18 That is correct.

19 SPECIAL AGENT NEFF:

V 2 0,°"

21 22 -.

23 24 -I 25 I believe your title then would have been NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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6 1

2 3

4 5 was your title for that?

6 7

8 SPECIAL AGENT NEFF: Okay. And then that 9 was reorganized yet again.

10 ii 12 13 14 15 16 17 II 18 *- That is correct.

19 SPECIAL AGENT NEFF: Okay. That is the 20 basic rundown of the positions that you've held over 21 those years. What I would like to do is ask you, 22 first of all, do you knoa 23 Yes, I do.

24 SPECIAL AGENT NEFF: How long have you 25 known.

-L -"1--

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7 1 I kne for a 2 number of years. I remember when was a 3 We worked together at Hope 4 Creek I would probably estimate at least six years 5 fairly close. Not just with plant operations but also 6 outage work, scheduled development, and online work.

7 SPECIAL AGENT NEFF: So when you first met 8 him while he was a 9 I think he may have been a 10_ -_ I can't be sure.

11 SPECIAL AGENT NEFF: Do you know what year 12 you would have met him?

13 No. I can't recall the year.

14 SPECIAL AGENT NEFF: Okay. But you said 15 six years?

16 I would say at least six 17 years I knew i 18 SPECIAL AGENT NEFF: Okay. In terms of 19 working here on site you think it was about six years 20 or so?

21 Correct.

22 SPECIAL AGENT NEFF: So if he left in 23 January of 2001 that would put you back to roughly 24 1994/1995 time frame? Does that sound accurate?

25 At least. I think so, yeah.

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8 1 SPECIAL AGENT NEFF: Okay. So your 2 interaction with him then, did you have fairly regular 3 interaction with him or how would you describe it?

4 - Well, when he was on shift I r --

5 probably would only see every couple of weeks 6 because of the schedules and all but we had fairly 7 regular interaction. Discussions about work, you 8 know, and personal life.

9 SPECIAL AGENT NEFF: Okay. Did you have 10 a work relationship? I mean, did you have any 11 relationship outside of work?

12 L ] Other than maybe occasionally 13 seeing him at a fair or something off site.

14 SPECIAL AGENT NEFF: A PSEG related 15 affair?

16 L_ J Yeah.

17 SPECIAL AGENT NEFF: Not like a separate 18 social arrangement offsite.

19 L.] No.

20 SPECIAL AGENT NEFF: Have you had any 21 contact with him since he left?

22 46 No, I have not. I did have 23 contact -

24 25 SPECIAL AGENT NEFF: Okay.

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9 1 name was I worked 2 with* # before was l --MONISM 3 1 I did 4 know 5 SPECIAL AGENT NEFF: After he left the 6 site.

7 Correct.

8 SPECIAL AGENT NEFF: Okay. But no direct 9 contact?

10 :i No direct contact.

11 SPECIAL AGENT NEFF: In working with him 12 did you form an opinion, or were you able to form an 13 opinion? Do you have any basis for evaluating what 14 his reputation was on site? I'm looking at that from 15 three different views, by his peers, by his 16 subordinates, and by management. Did you have enough 17 of a working relationship to make that type of 18 observation what his reputation was?

19 From my perspective.

20 reputation?

21 SPECIAL AGENT NEFF: You would more or 22 less be a peer. You may have been a manager at that 23 point in time to him?

24 .I There was time that he was at 25 a lower level of the organization. When I was an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS

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10 1 he may have been a 3

4 SPECIAL AGENT NEFF: Okay.

5 As far as my opinion of 6 very knowledgeable. Highly motivated, especially at 7 work, you know. High sense of ownership for tasks he 8 took on. He was very instrumental in outage planning.

9 He had a good knack for understanding the operational 10 plant interfaces and scheduling of the work around 11 that. His expertise was always sought out by the 12 outage group or whatever. He was seen as, I would 13 say, like an expert in that field.

14 SPECIAL AGENT NEFF: For outage planning.

15 . Yes, especially.

16 SPECIAL AGENT NEFF: Okay. So from that 17 perspective you are looking at it as your view of his 18 work in terms of a supervisor.

19 Yes.

20 SPECIAL AGENT NEFF: Okay. Do you have 21 any basis to assess how he was seen by his 22 subordinates as a .. ........ .. *'.*or as an 23 " I probably don't have a good 2'l 24 perspective there from a subordinate's point of view.

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11 1 kind of interaction or any input?

2 wk No.

3 SPECIAL AGENT NEFF: What about his peers?

4 M I think everybody respected 5 for his knowledge and expertise. I think 6 sometimes they may have thought he was not very 7 flexible on some issues. Maybe he was a little 8 steadfast on his opinion. You know what I'm saying?

9 He may have been a little bit harder to work with from 10 that point of view. He may not have been willing to 11 give in on a particular issue if he felt strongly 12 about it.

13 SPECIAL AGENT NEFF: Can you think of any 14 issues that he would have been seen that way as being 15 inflexible?

16 . Maybe on a sequence of work 17 activities. I would say to take a diesel out, get it 18 tagged, do the work, when to bring it back. There may 19 have been other people that would have wanted to 20 modify how we were doing that like the tag outs or 21 whatever.

22 SPECIAL AGENT NEFF: Okay.

23 A He may not have been real 24 easy to convince that there may be another way to do 25 it and still meet all the objectives.

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12 1 SPECIAL AGENT NEFF: Reasonably so or 2 unreasonably so?

3 I think reasonably so but 4 sometimes here if.you don't give in, if you know what 5 I'm saying, to everybody's wish, then some people 6 might think that' s unreasonable. I would sa had 7 the best interest of the overall work plan in mind 8 when he was making those types of decisions.

9 SPECIAL AGENT NEFF: So he may have been 10 a stickler for some of the details and the order of 11 events?

12 Yeah.

13 SPECIAL AGENT NEFF: And adverse to taking 14 a shortcut maybe?

15 That I would say, yeah.

16 SPECIAL AGENT NEFF: Okay. So in terms of 17 working with him, he may have been seen as a bit 18 steadfast and inflexible on certain issues.

19  : Yeah, but I would say maybe 20 that was a very small percentage.

21 SPECIAL AGENT NEFF: Okay. And he had 22 reasons for being so is what you're saying.

23 Absolutely.

24 SPECIAL AGENT NEFF: Okay. What about any 25 other perceptions about what his relationships were NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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13 1 with his peers? Are you talking about in later years 2 when he was in M or --

3 I'm talking about when he was 4

6 SPECIAL AGENT NEFF: Okay. So at the 7 level.

8 Right.

9 SPECIAL AGENT NEFF: Okay. Do you have 10 any other perceptions on what his working 11 relationships were like? What his reputation was?

12 No.

13 SPECIAL AGENT NEFF: What about from the 14 perspective of his management chain which would be his 15 W which at the later 16 point in time while he's'it would have been[ w 17 Do you 18 have any basis to assess what they thought of him in 19 terms of his work and their relationships with him?

20 For awhile there OWN!

21 was like a peer to me.

22 SPECIAL AGENT NEFF: Okay. He held what 23 position then?

24 He was the for the 25 operating like the MOW for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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14 1 all the operating shifts.

2 SPECIAL AGENT NEFF: Okay.

3

• So"Wmay have reported up 4 to him for a while. I don't ever recall o on 5 a particular issue where he may have had a problem.

6 SPECIAL AGENT NEFF: Positive or negative?

7 %ANE*aeh.

8 SPECIAL AGENT NEFF: Okay. What about 9 Do you have any knowledge of the 10 working relationship between II This would be at any point in time while he 12 is Wwhile he's in 0 13 The only thing I knew with 14 lwas I knew he had people he wanted to get off 15 shift, Fthat he wanted to 16 remove off shift.

17 SPECIAL AGENT NEFF: Do'you know why?

18 He didn't fill me in on the 19 particulars.

20 SPECIAL AGENT NEFF: What did he tell you?

21 How do you know that?

22 Because at the time when 23 h had taken over operations the department was 24 kind of like having manpower problems, I believe.

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15 1 back up to operations at the time. They were short.

2 People with operations background. This was like the 3 '95/'96 time frame.

4 SPECIAL AGENT NEFF: Okay. When you were 5 doing the work week schedules?

6 Correct. They were just 7 short for people. As a matter of fact, when I was 8 doing the work weeks the position held on that 9 org chart I had I think two direct reports and two 10 control room operators for tagging. I had like four 11 people when I had that position. Maybe five.

12 SPECIAL AGENT NEFF: When he has it, at 13 least by this chart in May of 2000, we're looking at 14 the work control group that he supervises as 16 15 operators. That would be primarily for tagging?

16

• Tagging and work schedule 17 development.

18 SPECIAL AGENT NEFF: And the WIN team 19 which has three more operators on it. You had two 20 operators in that time frame.

21 One shift sup. No, no shift 22 sups at the time.

23 SPECIAL AGENT NEFF: Okay. So this 24 evolved quite a bit between '95 and '99 then.

25 Yes, it did.

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16 1 SPECIAL AGENT NEFF: These all came under 2 in 1999 and they weren't part of yours?

3 There was a transition I 4 think about eight months before he relieved me in that 5 position that put three shift sups over there for me 6 but that was like at the tail end.

7 SPECIAL AGENT NEFF: Okay.

8 It was starting to grow just 9 before I left.

10 SPECIAL AGENT NEFF: Okay. To support 11 some of these changes that you were looking at with 12 the work management center -- that were coming into 13 the new work management center?

14 We were not providing enough 15 input to the actual scheduled developments on a weekly 16 basis and filling all the roles that the operations 17 people should have because we were short handed so we 18 were kind of like doing two or three weeks at a time.

19 SPECIAL AGENT NEFF: So this was the 20 correction staff. They started to staff it.

21 Correct.

22 SPECIAL AGENT NEFF: Okay. When you are 23 sayin from what you knew he knew he had 24 people that he wanted to move off shift.

25 Correct.

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17 1 SPECIAL AGENT NEFF: Is that what you're 2 talking about when they staff this or is it something 3 else?

4 .I think there may have been 5 some other reasons. I think they may have made 6 promises'to move some people off like, "You guys hang 7 around. Stay with me for another two years and then 8 I'll get you off shift. I'll have enough replacements 9 at that time." There may have been promises like that 10 made.

11 SPECIAL AGENT NEFF: Do you know it 12 affected? Who were the people that he wanted to move 13 off shift?

14 Iname may have 15 come up in that a couple of times. is one of 16 them because I thi k was probably one of the guys 17 that was on shift the longest.

18 SPECIAL AGENT NEFF: Okay. So this is a 19 move into what organization, when he replaced you or 20 later on?

21 - Well, he replaced me. He 22 took over that position and I got moved out to the 23 work management.

24 SPECIAL AGENT NEFF: Okay. And you 25 thought that was a promise to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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18 1 I see it as a positive thing. You're 2 describing him like a favor.

3 A commitment that if people 4 would have stayed for a period of time like whe 5 took over that he would promise them that he would get 6 them off shift if that's what they wanted.

7 SPECIAL AGENT NEFF: Okay. So that was 8 when -- you're thinking this is when he replaced you 9 in 1999?

10 Um-hum.

11 SPECIAL AGENT NEFF: You thought early 12 1999.

13 I think some other guys came 14 off shift, too. (phonetic)) who was a is 'was one of the guys that was 16 assigned over to me after the work week SRO.

17 SPECIAL AGENT NEFF: Okay.

18 I'm trying to think if there 19 were a couple of others that came off at that same 20 time. They got more people through license class and 21 license training and they started taking some people 22 off shift.

23 SPECIAL AGENT NEFF: Okay. Just so I 24 don't assume, can you explain why that is a positive 25 thing that is seen as a favor that 3would NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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19 1 be taking care of them?

2 wj Only from the standpoint that 3 he had made that commitment because what they were 4 trying to do was hold on to the few SROs they had so 5 it wouldn't impact the license operations. They can 6 continue operating the plant. The understanding is in 7 two years we'll get you off and get you out doing 8 something else that you want to do. It's basically 9 coming through on the commitment of it that he had 10 made.

11 SPECIAL AGENT NEFF: But to get somebody 12 off the shift is that like a time and hours kind of 13 thing? That you are on a dayshift position as opposed 14 to the shift work?

15 Correct.

16 SPECIAL AGENT NEFF: Is that the positive 17 in all that?

18 W That was the positive. Some 19 people at the time did not want to be working shift 20 work.

21 SPECIAL AGENTNEFF: Okay. Orrotationof 22 what you would actually be doing just for the change 23 of it or something?

24 IW I think some people had 25 worked shift work 10, 12 years or longer and they were NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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20 1 looking to get out and do something else and not have 2 to work shift hours anymore.

3 SPECIAL AGENT NEFF: Okay. So that placed 4 tbehind where you were.

5 That may be one of the 6 reasons, yes.

7 SPECIAL AGENT NEFF: You think that.

8 Okay. When he became the .for work management right 9 behind you?

10 Um-hum.

11 SPECIAL AGENT NEFF: Early 1999. Okay.

12 What I was asking you about is if you had any 13 knowledge of the working relationship between M 14 a Let's look at that time 15 frame and forward. Do you have any basis to assess 16 their working relationship in that time period? It 17 sounds as though it's positive as though 18 19 I think at that point it may 20 have been positive.

21 SPECIAL AGENT NEFF: Did that change at 22 some time?

23 I think at some point I 24 recall that there was some friction wit o probably 25 a year or two later because I think -- I could bee NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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21 1 totally wrong here but my understanding was they were 2 trying to reassign him. level was outage work.

3 I think they were trying to reassign him to something 4 else maybe or bring him over to a different work area.

5 I don't know that that transition was 6 going real smooth. I'm not sure i was involved 7 in that or not. I think it may have been after 8 took over work management. He was no longer the 9 I can't be sure.

10 SPECIAL AGENT NEFF: But you have some 11 recollection of them changing whatA.. would 12 be doing coming, I guess, off shift and going to --

I'm not sure if they were 13 14 trying to put him in work management. I can't 15 remember. Sometimes you're no longer directly 16 involved that close with the activities of those two 17 individuals.

18 SPECIAL AGENT NEFF: Right.

19 Jill Through the grapevine you are 20 hearing there's an issue there with work 21 assignment or something.

22 SPECIAL AGENT NEFF: Did you have any role 23 in roughly inl June of 2000 is placed under 24 the reorganization of the work management 25 organization? He now is in that role. My NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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22 1 understanding was that a team was developed for the 2 Best Work Week Ever. !name comes up as 3 being part of this team.

4 1 Correct.

5 SPECIAL AGENT NEFF: Do you know how he 6 got into the Best Work Week Ever? How he was selected 7 for this?

8 I know that when we were 9 doing the Best Work Week Ever, they were soliciting 10 input from a lot of people on who should be on that 11 team.

12 SPECIAL AGENT NEFF: Okay.

13 9MO so it was more or less people 14 were -- names were given toq* I believe. -

15 SPECIAL AGENT NEFF:

16 Right. Input from different 17 people as to who should be on the team.

18 SPECIAL AGENT NEFF: Okay.

19 I think that's how they went 20 about making the selections.

21 SPECIAL AGENT NEFF: Do you know ho W 22 came to be selected for that?

23 Specifically I can't recall.

24 SPECIAL AGENT NEFF: Would he be somebody 25 that you would have recommended to put --

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23 1 , Myself?

2 SPECIAL AGENT NEFF: Yes.

3 Absolutely.

4 SPECIAL AGENT NEFF: To place him on the 5 Best Work Week Ever?

6 7 SPECIAL AGENT NEFF: Based on what you 8 said before about the expertise that he had 9 particularly in the outage planning?

10 jOutage and online work. I 11 mean, *was a good scheduling person. He could get 12 a lot of work done.  ;"was the kind of guy that 13 could find ways to get work done, not find ways of 14 avoiding work.

15 SPECIAL AGENT.NEFF: Would it have been 16 your decision -- if it was your recommendation that he 17 would be a good person for that, would it have been 18 your decision to place him on the Best Work Week team?

19 I did not have that authority 20 to select people and say they have to go on here.

21 SPECIAL AGENT NEFF: Where would the 22 authority for that be?

23 That would have to come 24 either from whoever reported to it, if it was! or 25 it was NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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24 1 SPECIAL AGENT NEFF: And the 2 at the time?

3 Um-hum. I think he may have 4 still been over at Hope Creek.

5 SPECIAL AGENT NEFF: Okay. But it 6 wouldn't have been your decision to make his move?

7 No.

8 SPECIAL AGENT NEFF: Okay. And my 9 understanding--

10 -I may have been asked like, 11 "Who would you like?" I'll tell you the names. It 12 goes down that list. There is not a name on there 13 that I would have said no to.

14 SPECIAL AGENT NEFF: Here. You're reading 15 it upside down. Let me help you out a little bit.

16 What you're looking at is Attachment 1 to the memo 17 dated June 1, 2000.

1.8 1 Um-hum. The people that I 19 know definitely on this list that I would say definite 20 in my mind wer 22 23 SPECIAL AGENT NEFF: So most of the people 24 on here are people that you would have selected 25 yourself. They were placed here for some skill or NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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25 1 some expertise that they had that they would bring to 2 the Best Work Week Ever.

3 71Yes.

4 SPECIAL AGENT NEFF: Did you have any 5 discussions yourself with -- Mwas th-"

6 at the time. Did you have any discussions at 7 that point in time with him regarding the placement of 8 ion here that you recall?

9 An exact meaning or something 10 like that?

11 SPECIAL AGENT NEFF: Any recollection of 12 any conversation or meeting.

13 I really can't recall.

14 SPECIAL AGENT NEFF: Now, that was for 15 June 2000. At this point in time it's my 16 understanding at the same point in time the 17 reorganization occurs with work management. It is now 18 the work management organization and in that time 119 frame, Wis moved from his position here as 20 the for work management into the new organization.

21 Do you know how he was selected for that position?

22 If my recollection serves 23 correct, he would have been reporting to#"**

24 in that position.

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26 1 in that.

2 *. To tell you the truth, I 3 don't recall picking those positions. What I remember 4 is there was a lot of talk of reorganizing the 5 organization and at the time I was over in TB 2 6 working on the revision of the procedures. I was on 7 that team with We were over in TB 2 8 working on revising the whole work management 9 procedure guidelines.

10 We knew what the positions and all were 11 going to look like but it was very hush hugh about it 12 who was being considered for what positions from my 13 perspective because I didn't find out that I had a 14 position in that organization until like when they 15 made the announcements but I believe at that point all 16 the positions were filled. Do you know what I'm 17 saying? It wasn't like --

18 SPECIAL AGENT NEFF: It was that hush hush 19 you didn't know either and you were a manager.

20 I was going to be a manager, 21 yes.

22 SPECIAL AGENT NEFF: Did you have any 23 involvement in the selection of wit.If for the 24 work management organization?

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27 1 had or someone asked me if I thought he would be good 2 in that role, I would, of course, said yes.

3 SPECIAL AGENT NEFF: So for input or for 4 corroboration in terms of, yeah, you think he's be 5 somebody good, but decision making, what you're saying 6 is it wasn't your decision to make. Whose decision 7 would it have been to place him there?

8 I think it would have either 9 been somewhere around because he was going to be 10 the 11 .SPECIAL AGENT NEFF: Anticipated.

12 . Anticipated.

13 SPECIAL AGENT NEFF: He's still the 14 but he's going to be the 15 Well, when we were on that 16 team during the procedure rewrites, it was clear in my 17 mind at that point whether told me. I think it 18 may have been who told me that he was going to 19 come over and replacef 20 SPECIAL AGENT NEFF: It was a matter of 21 months it looks like. From June to October I think is 22 the time frame.

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28 1 he would be the. M..

2 Correct. So he was kind of 3 like the team that we were running out there he was 4 put as like the team lead during that time for the 5 rewrite and everything. _ was the sponsor.

6 SPECIAL AGENT NEFF: To your knowledge did 7 anybody else have input or any body else have any 8 involve and have any decision making authority over 9 9. being moved from his one position to the 10 other in the work management organization at that time 11 in June 2000?

12 .i The only other one I think 13 had a lot of influence wasps 14 SPECIAL AGENT NEFF:

15 Yes.

16 SPECIAL AGENT NEFF: Okay.

17 Because I found out later on 18 after I had the position for about two months, 19 came into my office one day and told me that he was 20 going to do my job for a couple of weeks because he 21 didn't think I was the right guy for the job when they 22 picked him. He was going to run the long-term 23 planning and find me a special project to run.

24 SPECIAL AGENT NEFF: This was -

25 who told you?

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29 1 . Yes.

2 SPECIAL AGENT NEFF: Okay. So you were 3 going to be moved. That was at the point where you 4 were going to be moved again?

5.. Like I say, it was probably 6 in the December time frame.

7 SPECIAL AGENT NEFF: Of 2000?

8 Yeah, when we did these 9 reassignments. I just found out I had the job. I was 10 in it for about two or three months andS came 11 over one day and told me that he didn't think I was 12 the right guy for the job from day one but he had no choice in the matter kind of. Now he wanted to push 14 me into a temporary assignment running a project 15 somewhere while he ran my part of the organization.

16 SPECIAL AGENT NEFF: This is after he is 17 theI AN 18'Cret 19 SPECIAL AGENT NEFF: So ye has more 20 control of the organization at this point obviously?

21 He's now in place.

22 Ys 23 SPECIAL AGENT NEFF: Okay. In your view, 24 in June of 2000 who would have established the role 25 and responsibilities that had in that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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30 1 organization?

2 M When we drafted procedure for 3 this new organization, we kind of drafted those roles 4 and responsibilities as part of the redraft of the 5 work management organization. Every position in the 6 new organization had roles and responsibilities 7 specified as part of the rewrite of the program.

8 SPECIAL AGENT NEFF: Okay. What is the 9 time frame for that, When were you doing that 10 procedure?

11 1 That was mid-2000. It was 12 supposed to be ready to implement by September. I 13 would say around July, August, September time frame of 14 2000.

15 SPECIAL AGENT NEFF: Ready to implement 16 August/September 2000?

17 Right. Then I think that 18 pushed by a month or so.

19 SPECIAL AGENT NEFF: So at this point 20 while you were working through the summer of 2000 you 21 are reporting t-1" 22 Urn-hum.

23 SPECIAL AGENT NEFF: When you are working 24 on these procedures?

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31 1 took just a handful of us. It was about five or six 2 people. They took us out of the day-to-day firefight 3 and we reported TB 2 for like four or five weeks to 4 just do nothing but work on rewriting the work 5 management process using INPO as practices, other 6 utilities.

7 SPECIAL AGENT NEFF: Okay.

• And hours.

8 9 SPECIAL AGENT NEFF: Were you working with 10 low at that point in time?

11 I don't know if was on 12 that team or not. To tell you the truth I can't 13 recall. I don't think, was.

14 SPECIAL AGENT NEFF: Who would have 15 established the role for people? People I mean-16 individually for Who would have 17 established and assigned his role and responsibilities 18 at the point in time where he moved from thew 19 to the work management 20 organization in June 2000?

21 If the procedures are being written and 22 they are not really aimed to be ready until September, 23 who established these rules and responsibilities? Do 24 you know anything about that?

• • No, I don't.

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32 1 SPECIAL AGENT NEFF: Do you know anything 2 about what his duties were at that time frame?

3 Specifically, no.

4 SPECIAL AGENT NEFF: Okay. You mentioned 5 before under this structure he's reporting toi 6

7 I believe, yeah, because I 8 think he was going to be in the implementation group, 9 which is what that group was called. was the 10 for that group.

11 SPECIAL AGENT NEFF: Okay. In that arrangemen as the supervisor there, how 12 13 did you view that? Did that strike you as 14 questionable in any way?

15 At first, no. You mean him 16 getting that position?

17 SPECIAL AGENT NEFF: Him getting the 18 position.

19 I worked directly with 20 years before that. I knew he was -- he went out to 21 training and I knew he had a rough time when he was 22 out there in the training department. I know a lot of 23 feedback I had gotten from SROs some of the exams were 24 like unreasonable and unfair.

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33 1 a challenge. There was a big to do over that.. I know 2 prior to tha had been hoping to get thea 3 there at Hope Creek. I know he got turned 4 down for that and he was disappointed.

5 SPECIAL AGENT NEFF: And he put in for the 6 *job whe got it or after?

7 _It was before. We had gone 8 through a period over there where we did not have a 9 direct ops manager and I thinkfwas *a 10 SPECIAL AGENT NEFF: Okay.

11 I think he was kind of hoping 12 that after six or seven months that he was in that 13 role as 14 SPECIAL AGENT NEFF: He might slide into 15 it.

16 -- he might slide into it.

17 SPECIAL AGENT NEFF: Okay. When I asked 18 you if you saw it as unusual or questionable that he 19 would be the supervisor of this implementation group, 20 you said at first no. Did that change? Did you see 21 it differently later?

22 Personally I did, yeah.

23 SPECIAL AGENT NEFF: Why is that?

24 . Well, I'll be honest with 25 you, I didn't see that there was a lot of structure NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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34 1 over there. We had procedures that we probably were 2 not really strictly adhering to. There was a 3 reluctance. I think it was more "let's bulldog 4 everything through" than actually trying to help the 5 people to get the work done.

6 SPECIAL AGENT NEFF: You didn't like the 7 way it was being run?

8 _ Personally, no.

9 SPECIAL AGENT NEFF: So that is something 10 that you put with the supervisor, You 11 had issues with that?

12 Um-hum.

13 SPECIAL AGENT NEFF: What about -- from 14 what you observed of-- and 15 their placement in this organization, did it surprise 16 you- that Would be placed as his 17 supervisor? I guess I'm not asking you to think about 18 it right now and go back in time. What I'm wondering 19 is at the time did something like that strike you as 20 odd in any way? Was it acceptable or was it odd or 21 how did you see it? Did you ever notice it?

22 me I don't think I gave it too 23 much thought. 0 _had been off shift for awhile.

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35 1 filling in as like an outage lead or something. I 2 don't know. I guess he was perceive d as a leader.

3 Him going into a role like that lidn't seem as 4 peculiar at that point.

5 SPECIAL AGENT NEFF: Okay We'll take a 6 quick break. It's 3:23 p.m.

7 8 (Whereupon, at 3:23 p.m. off the record 9 until 3:24 p.m.)

10 SPECIAL AGENT NEFF: We'1 re back on the 11 record. It's about 3:24 p.m. One th!Lng I wanted to 12 ask you about involved the selection 13 for the work management organizatio]n. These are 14 individuals on this memo June 1, 2'000. You are 15 agreeing with their selection. You pi.etty much said 16 everybody on this list is somebod, 17 (phonetic) I don't know if we said. Did you --

S(phonetic) I 18 19 don't recall that well myself.

20 SPECIAL AGENT NEFF: That would be your 21 endorsement to get on the Best Work We ek Ever or move 22 into the work management organization?

23 Right.

24 SPECIAL AGENT NEFF:

25 (phonetic)

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36 1 (phonetic)YJ 2 know, yes. yes.

3 SPECIAL AGENT NEFF: And 4 M Correct.

5 'SPECIAL AGENT NEFF: So other than 6 nmaybe these are individuals that you could 7 see being placed on the Best Work Week Ever.

8 . Absolutely.

9 SPECIAL AGENT NEFF: Okay. When it came 10 to creating the work management organization, were 11 there others considered from *position?

1 12 Were there others considered in-moving? Do you know 13 if it was just , r if there was anybody 14 else that was being looked at as potentially valuable 15 in that organization?

16 I think at one point they 17 were looking at (phonetic) but that 18 may have been after From Hope Creek -- do you 19 have that org chart for Hope Creek?

20 SPECIAL AGENT NEFF: Yeah, here you go.

21 .i My guess just from knowing 22 individuals, I know ad filled that role 23 before I got there. I don't know if he may have been 24 thought of as a candidate. Or maybe That 25 would be my guess.

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37 1 SPECIAL AGENT NEFF: You're guessing but 2 you don't recall a discussion about these people or do 3 you?

4 I don't recall a discussion.

5 This was a very busy time, especially for me, because 6 I had this other organization that we were trying to 7 get motivated moving. I really didn't spend a lot of 8 time understanding who and what they were selecting 9 for the other group, if there was a selection process 10 going on.

11 SPECIAL AGENT NEFF: Right. You made it 12 pretty clear that you would have endorsed 13 for the organization for the position that he was 14 placed in but you had nothing to do with the decision 15 making process that put him there.

16 . That is true.

17 SPECIAL AGENT NEFF: How is a move like 18 that seen when you're in A work management and 19 moved? It's a new organization for work management.

20 How is that seen? I'm looking at it in terms of 21 promotion, demotion, lateral. What is that viewed as 22 organizationally?

23 think of ar 19'c oming off 24 shift going there. Depends on timing and everything 25 else but I would say that's a demotion.

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38 1 SPECIAL AGENT NEFF: And why would that 2 be?

3 Typically the., "onshift 4 have been a very high commodity and they would be 5 coming off looking to go more to a manager type 6 position than just being moved over and reporting to 7 a manager somewhere else, if you know what I mean.

8 SPECIAL AGENT NEFF: Manage type position.

9 You mean with subordinates?

10 I In other words, a manager 11 level rather than being a superintendent somewhere.

12 AntS, an operations superintendentrn shift is very 13 high level in the company.

14 SPECIAL AGENT NEFF: Okay. So to move out 15 of the position what you're saying is they are looking 16 for something at the manager level.

17 In most cases. Some cases 18 like a lateral. Like a planning manager is a grade 19 level 18 which is the same as an 4operation 20 superintendent.' Some of those other superintendent 21 positions were considered grade level 16.

22 SPECIAL AGENT NEFF: Is that what the work 23 management organization would have been?

24 Sometimes it depends on who 25 they want to put in there. If there is someone they NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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39 1 want to put in there and they are trying to lure them 2 over, they may keep it as an 18. They may make it on 3 the books as a 16 and keep it that way depending on 4 the situation.

5 SPECIAL AGENT NEFF: It's seen as a lesser 6 graded position then. More as a 16 as opposed to the 7 18 that goes with an on-shif tOS or ops superintendent 8 on staff?

• • Correct.

9 10 SPECIAL AGENT NEFF: Okay.

11 I think that is more true at 12 Hope Creek than it is at Salem.

13 SPECIAL AGENT NEFF: Why is that?

14 I don't know. When we 15 started the work management organization up, if you 16 look on here there is a gentleman's namemlon 17 one of those other org charts. He's been in the work 18 management organization --

19 (Whereupon, the end of Tape 1, Side A.)

20 SPECIAL AGENT NEFF: If you could just 21 repeat what you were last saying, that., is 22 here on the -- he's shown under the Salem ops org 23 chart.

- -.

24 I ýW Right.

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40 1 management. You said he's been there for years.

2 ARight. He is seen as a role 3 player in that position over here. When they decided 4 they were going to move that position over to this 5 building, came over and jumped right in. We've 6 always had difficulty getting people from Hope Creek 7 to come over and participate here. They stay over at 8 Hope Creek.

9 SPECIAL AGENT NEFF: Just the two sides 10 are different, the work management?

11 Yes. Work management is not 12 seen as a positive organization around here.

13 SPECIAL AGENT NEFF: Okay. So in terms of 14 status or respect or prestige associated with it, an 15 OS on staff or shift is going to be seen as higher 16 ranking than would be somebody assigned to work 17 management. Particularly, you're saying, for Hope 18 Creek.

All Correct.

19 20 SPECIAL AGENT NEFF: Okay. Did you have 21 any contact with 'after his move into the 22 new organization?

23 ISO W- The only contact I may have 24 had with' is right outside this building where the 25 is. Because of that I have, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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41 1 you're out there a couple times a day and you.do see 2 people coming out. You chat and talk. More informal 3 conversations of that nature.

4 SPECIAL AGENT NEFF: Did you get any 5 understanding from him how he felt bout his move into 6 the work management organization? Did you even 7 discuss that?

8 I would have to say my best 9 recollection is that he may have been frustrated with 10 that move.

11 SPECIAL AGENT NEFF: Do you know why,?

12 In particular why? Any 13 specific reason? I think part of it could have been 14 to do with working for because, as I quickly 15 found ou 9 was not an easy person to work for.

16 SPECIAL AGENT NEFF: Okay.

17 IJ_$ was basically way or no way.

19 SPECIAL AGENT NEFF: ,So he might have 20 expressed some concerns about that or some angst over 21 working with -,directly as a supervisor?

22 I think in most of his 23 time here enjoyed some freedom in managing his work.

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42 1 situation where you are no longer told how to do the 2 assignment. That's something where ;would not --

3 knowing o ldemeanor, that would be a problem from 4 what I recall.

5 SPECIAL AGENT NEFF: In what regard? In 6 that it wasn't necessary to tell him that or he would 7 just resent that?

8 I don't think, first of all, 9 it was necessary to tell him that. Then I think there 10 may be some resentment there if you told him every day 11 not only what to do but how to do it. You are taking 12 what you brought him over for out of the equation.

13 SPECIAL AGENT NEFF: Did you get the sense 14 that there was the need to do that with him? I mean, 15 in the new organization with procedures being written 16 and the changes that they were going through was there 17 some -- is it possible there was some need fof 18

• to have that kind of control with him?

19 The only thing that I could 20 think of that could come up is they may not -- because 21 you are getting a new procedure thrown in front of 22 you, you may not agree with all the steps. But what 23 I would think is you work with your management to say 24 I don't agree with this and I think we should change 25 it and get it changed or you follow it. You know what NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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43 1 I'm saying? Get that issue resolved.

2 That I'm not clear on as to whether or not 3 they had that type of issue. That, to me, is where 4 you would end up, "I don't want to do it this way.

s That's what the procedure says to do so I need to get 6 the procedure fixed." If I was. the manager I would 7 direct to get the procedure fixed. You know what I'm 8 saying? Or comply. I don't know if that was the 9 issue, though.

10 SPECIAL AGENT NEFF: You don't know if 11 that was the case?

12 Yeah.

13 SPECIAL AGENT NEFF: Was there any other 14 frustration that he was expressing to you? I mean, 15 your sense was that it was working with "7 16 Is there anything else that he didn't care for at that 1.7 time?

18 Not that he may have 19 expressed directly to me that I recall right now.

20 was always kind of a quiet guy. He kept personal 21 issues to himself. He didn't come storming out of a 22 meeting about how, "That no good dirty..." He was 23 very quiet. He held a lot in.

24 SPECIAL AGENT NEFF: When the organization 25 first reshaped in that summer of 2000, do you recall NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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44 1 where everybody was located?

2 A After the reorg?

3 SPECIAL AGENT NEFF: Yeah. How many 4 people did that involve roughly? I can't expect a 5 head count from you now.

6 It was quite a few people.

7 There was a bunch of us that moved over to the Salem 8 B building. They put us all in long-term planning and 9 scheduling in the B building so we had people moving 10 from this building at Hope Creek over to the Salem B 11 building. The planner went over to the B building.

12 Most of the schedulers were moved to this 13 building. A small group of planners were moved to 14 this building. Work week managers were moved to this 15 building along with .moved over at that time, or 16 right around that time, from Salem ops. I can't 17 remember i moved over here or not. To be honest 18 with you, that's the one -- I try and think about it 19 all the time and I can't remember if he ever got over 20 here or if he didn't.

21 SPECIAL AGENT NEFF: Were there others 22 that didn't make the move coming into -- I mean, 23 you're saying NOSF housed it seems like most and then 24 there was some at Salem.

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45 1 pretty much was supposed to be housed here.

2 SPECIAL AGENT NEFF: fll 3

4 SPECIAL AGENT NEFF: Okay. So they were 5 supposed to be housed here.

1wCorrect.

6 7 SPECIAL AGENT NEFF: Did most of them make 8 it over here?

• • .* I think so.

9 10 SPECIAL AGENT NEFF: Or did all of them 11 make it over here?.

12 .- Just about all.

13 SPECIAL AGENT NEFF: And you just don't 14 recall if- was here?

15 You see, the whole issue is 16 we have always had trouble getting SRO participation 17 from Hope Creek. Do you follow what I mean? So I'm 18 not sure but I think did come over. Then later 19 it was a decision made that they could work out of 20 Hope Creek again but I think that was after 21 placement.

22 SPECIAL AGENT NEFF: After he left?

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46 1 saying? It's pretty clear in my mind that " was 2 the guy. *came over. He worked with me 3 over in the long-term planning group so he moved right 4 over there. Never had a Hope Creek ops guy up in 5 long-term planning and scheduling like we were 6 supposed to.

7 SPECIAL AGENT NEFF: At the Salem B 8 building you were talking about.

9 "M W Correct.

10 SPECIAL AGENT NEFF: So with 11 ,*crew, though, do you recall that they all 12 moved as a unit?

13 Pretty much, yeah.

14 SPECIAL AGENT NEFF: Apart from 15 is there anybody else that you can recall if-16 they made that qiove?

17 Not that I can recall.

18 SPECIAL AGENT NEFF: Do you recall there 19 being any issues around space availability?

20 ow There has always been some 21 issues around space availability like size of offices.

22 There are so many changes they've made to that office 23 structure down there I can't recall.

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47 1 and about do you have any discussions with him about 2 where he is physically located? Now the reorg has 3 occurred, do you recall talking to him, or do you 4 recall any issues about where he was located as 5 opposed to where crew, the rest of the 6 team were located?

7 For some reason I seem to 8 recall that spent a lot of time walking back and 9 forth to Hope Creek.. Now, whether it's because he 10 didn't have a place here or he had a place here and he 11 was still having to go back to interface with his 12 people, that I can't recall. I'm sorry.

13 SPECIAL AGENT NEFF: Okay. So you just 14 don't know if you made that move with 15 and he probably was going back and forth a lot to Hope 16 Creek.

17 I do recall like seeing him 18 out back quite a bit.

19 SPECIAL AGENT NEFF: Where would out back 20 be?

21 w '*w Out back is where the 22 is for this building.

23 SPECIAL AGENT NEFF: Behind this building.

24 Behind the building. On the 25 river side of this 'building.

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48 1 SPECIAL AGENT NEFF: Oh, okay.

2 Typically everybody that goes 3 back and forth to Hope Creek, especially operations, 4 goes out that back door.

5 SPECIAL AGENT NEFF: And straight across.

6 i. Straight across by the 7 maintenance shop is the shortest distance. If you are 8 out there, you see a lot of Hope Creek ops guys 9 traversing to go back and forth to meetings in this 10 building. Most of the time it's for work management 11 meetings.

12 SPECIAL AGENT NEFF: Okay. You don't have 13 a recollection of if he wasn't here, you don't know 14 why he wouldn't be here. It could have been his 15 choice. It could have been somebody else's choice.

16 You don't really have any knowledge of why that would 17 be?

18 Other than things we've 19 discussed like choices, not enough space. There was 20 some issues later on --

21 SPECIAL AGENT NEFF: With space?

22 5. Yeah.. Office space.

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49 1 being a situation where other than the people that 2 went to Salem B building that the work management 3 organization is moved into the NOSF all but for 4

5 Sknow, who had 6 the short-term planning, he and" oand planners.

7 They were all in one area of the building.

8 SPECIAL AGENT NEFF: The Salem B planners 9 and schedulers were here?

• : Here.

10 11 12 SPECIAL AGENT NEFF: Okay.

13 That. was one part. I'm 14 trying to remember the area that was set up back by 15 Ilkwhere had his office. It wasJ 16 office and then there was some office space along that 17 wall. Now today it's all work management in that area 18 but before some of that other space back there was 19 another department so those offices weren't available.

20 SPECIAL AGENT NEFF: Okay.

21 I'm trying to think back to 22 who was back there and how many rooms were available.

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50 1 have definitely been a shortage of spaces.

2 SPECIAL AGENT NEFF: Okay. I'mjust going 3 to go off so there's no dead space.

4 (Whereupon, at 3:44 p.m. off the record 5 until 3:45 p.m.)

6 SPECIAL AGENT NEFF: Back on the record.

7 We took about a one-minute break. It's 3:45 p.m. I 8 wanted to ask you, going back in time to when SAP was 9 rolled out and that was about mid-1999 for Hope Creek 10 operations that had an impact roughly late 1999 going 11 into early 2000.

12 The impact that becomes relevant to this 13 allegation is the way it affected the work clearance 14 module in that at that point in time they are 15 preparing for RF 09 which was going to be February to 16 April. Does that sound accurate to you?

17 Um-hum.

18 SPECIAL AGENT NEFF: For 2000, February to 19 April, around that time frame. Are you aware of how 20 that went when SAP was rolled out and the work 21 clearance module went into that program, are you aware 22 of how that occurred? How that went?

23 owl Not any of the particulars 24 but I am aware of how SAP went. There was like no 25 option. "It's coming, it's going. You're going to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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51 1 implement. Get over it."

2 SPECIAL AGENT NEFF: Where was that 3 direction coming from?

4 That was pretty much the 5 party line on the island for the implementation of 6 SAP. Nobody was allowed to get in the way.

7 SPECIAL AGENT NEFF: How did you get that 8 message though?

9 UM?

10 SPECIAL AGENT NEFF: How did you get that 11 message? I mean, was there a whole management chain 12 associated with that? Was there one individual 13 associated with that?

14 I There was a management chain 15 associated with that.

16 SPECIAL AGENT NEFF: Who was in your chain 17 at that point in time that would have given you that 18 message?

19 20 SPECIAL AGENT NEFF: He was?

21 When I was in the -- I'm 22 talking about when we were first getting SAP.

23 SPECIAL AGENT NEFF: So when you were in 24 the work management center?

25 Work management center.

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52 1 Correct.

2 SPECIAL AGENT NEFF: Okay.

3E7 I know they had 4 implementation teams and people that were on the team 5 that were bringing up concerns were actually removed 6 from the team.

7 SPECIAL AGENT NEFF: In what time frame is 8 this now?

9 This is like early '99.

10 SPECIAL AGENT NEFF: Okay. Now, what are 11 the concerns and who are the people that were raising 12 them?

13 One person I know of, and I 14 can't remember because we're going back a couple of 15 years, he had some concerns with the implementation of 16 SAP and the guy's name was I think at 17 the, time he may have been like a safety review 18 engineer or in the engineering department.

19 SPECIAL AGENT NEFF: Do you recall what 20 his concern was?

21 MN I don't recall what the 22 concern was.

23 SPECIAL AGENT NEFF: He was on one of the 24 implementation teams?

25 Correct.

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53 1 SPECIAL AGENT NEFF: Do you recall what it 2 affected? Was it maintenance? Was it operations?

3 What aspect of SAP affected what?

4 ,. I can't help you. I can't 5 remember the exact --

6 SPECIAL AGENT NEFF: Okay.

7 If it comes to me, I'll get 8 back to it with you.

9 -SPECIAL.AGENT NEFF: It sounds like there 10 was more than one.

11 Yeah. I think the 12 implementation teams were set up to basically sell 13 SAP. In other words, if people did have issues, they 14 would try to get them rectified but because of the 15 limitations of what they could actually do, it was a 16 decision already made at the top that we were going to 17 go to SAP so the implementation teams were really put 18 together --

19 SPECIAL AGENT NEFF: You said sell it.

20 Sell it. If you are on the 21 team and you didn't look like you were going to be a 22 seller, off the team you went.

23 SPECIAL AGENT NEFF: Whose decision would 24 that have been?

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54 1 the team leader at the time or maybe a little bit 2 higher.

3 SPECIAL AGENT NEFF: How many teams did 4 they have here? How many implementation teams?

5 - There was like a few. I 6 think they broke it up like work management, 7 maintenance, planning to address all the particular 8 concerns of particular departments.

9 SPECIAL AGENT NEFF: Did they have an i0 overall lead on this?

11 It all rolled up to _

12 'who was the ..... " at 13 the time. I can't remember if they have another one 14 below him.

15 SPECIAL AGENT NEFF: So this would be the 16 1999 time frame.

17 Right.

18 SPECIAL AGENT NEFF: When it started to be 19 rolled out.

20 AWe were planning, I think, on 21 going live in June and like the first part of the year 22 was these implementation teams. One of the reasons I 23 recall it so specifically is because two of my 24 coworkers in the work management team -- let's see 25 here. I think it may have been and a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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55 1 Hope Creek SRO. If I think of his name, I'll let you 2 know what it was.

3 What happened was there was some other 4 software programs out there that were more geared 5 toward nuclear. They thought they had a compelling 6 argument to go to and try and sell not getting 7 SAP for the island because it really wasn't geared 8 toward our type of work here for regulations and tech 9 specs. This other system is perfect.

10 SPECIAL AGENT NEFF: Was it in respect to 11 one application or everything?

12 No, the whole thing.

13 SPECIAL AGENT NEFF: Because I know this 14 affected payroll and all the way through.

15 Right. Well, this was like 16 for working on the island. They wanted to sell this.

17 They thought they had a very compelling argument and 18 they came back 15 minutes later and said, "I'll never 19 make that mistake again."

20 SPECIAL AGENT NEFF: What happened?

21 They were basically told SAP 22 is it. There wasn't even like a discussion point.

23 SPECIAL AGENT NEFF: That was pretty quick 24 in 15 minutes.

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56 1 particular safety concern.

2 SPECIAL AGENT NEFF: Right.

3 4 You know what I'm saying?

4 They were looking at other systems like Indice or 5 whatever that was out there at the time that was 6 really beautiful for a nuclear plant application.

7 SPECIAL AGENT NEFF: They thought it was 8 more suitable than SAP.

-M ýw . Ri Aght.

9 10 SPECIAL AGENT NEFF: Why is that? Did you 11 ever get sense for why would no discussions would be 12 entertained on going with something that would work as 13 opposed to something that was not working so well?

14 %I just think it was -- you 15 see, the corporation, I think, had made a decision 16 that even though we were using LMIFs and we were very 17 structured, the rest of the company was using all 18 different kinds of software and some weren't using 19 anything.

20 They wanted to bring the whole company 21 under one umbrella. They sent a specialist out and 22 they came back with the same thing. That was the 23 tool. They didn't want to have anymore of these 24 little pockets of different softwares that the system 25 couldn't interface with basically for the financial NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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57 1 end of the business.

2 SPECIAL AGENT NEFF: They were going to 3 make it an universal system that you could go to one 4 source for trouble shooting, program writing, and that 5 type of thing.

6 R ht.

7 SPECIAL AGENT NEFF: And that would affect 8 everything from Newark all the way and I guess other 9 operations.

10 -s.

11 SPECIAL AGENT NEFF: Okay.

12 3 So I can understand why they 13 wanted to do it but it was going to be like they might 14 as well just have come out and said, "Look, we're not 15 going to have a choice in this. This problem is there 16 and we're just going to have to figure out how to get 17 them solved," rather than all the salesman shit.

18 SPECIAL AGENT NEFF: It might have been 19 easier.

20 Everybody picks a different 21 way to try and skin the cat. -7 22 SPECIAL AGENT NEFF: What about somebody 23 else? Anybody else who raised a concern about while 24 on the team and got bumped off the team after they had 25 an issue?

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58 1 - .1 None that I can specifically 2 recall.

3 SPECIAL AGENT NEFF: Do you recall was 4 i a safety related concern?

5 7.3I can't recall.

6 SPECIAL AGENT NEFF: Okay.

7 Probably today people would 8 look back at some of the issues they had perceived 9 with SAP coming on board and look back and laugh and 10 say, "I was worried about this." You know what I'm 11 saying? But, I tell you, when SAP was coming, there 12 was a lot of apprehension on site.

13 SPECIAL AGENT NEFF: Because it was going 14 to be so very different or for some other reason?

15 V.1 Mainly because I don't think-16 people knew what it could do at the time. You are 17 very comfortable to what you're doing every day.

.18 SPECIAL AGENT NEFF: Right.

19 Somebody is going to come in 20 and throw something entirely new at you and you've got 21 to relearn it. All in all I don't think it did as bad 22 as people expected it would do.

23 SPECIAL AGENT NEFF: Do you have any 24 knowledge of any affect the changeover in SAP had on 25 the work clearance module? Did you have any NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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59 1 information or exposure to that at the time that 2 occurred?

3 I knew there was concern. I 4 think at the time we were using TRIS (phonetic).

5 SPECIAL AGENT NEFF: I think so.

6 I think what they were 7 writing was an interface program to work with TRIS at 8 the time. I can't recall. I knew there was going to 9 be a work clearance module in SAP. Whether they were 10 trying to use that and then there was enough problems 11 where they wrote an interface maybe to use TRIS for a 12 longer period of time. I don't think we turned work 13 clearance module on right away. I thought it was a 14 pretty long time after we got into this.

15 SPECIAL AGENT NEFF: I think it was 16 supposed to be late 1999 just before the outage during 17 outage prep. My understanding was it was ruled out in 18 late 1999, that application. At that point in time do 19 you have an understanding of how that went, 20 specifically to the work clearance module?

21 I think there was another 22 issue, too, at the time. I can't remember because we 23 were using TRIS for the plant lineups. I don't 24 recall. There was another issue where TRIS crashed 25 and they didn't have a backup. They couldn't get it NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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60 1 back up. I think Salem was in an outage so now you 2 have a challenged configuration. If Salem was in an 3 outage, that had to be late '99.

4 SPECIAL AGENT NEFF: This is a TRIS crash?

5 . *Yeah 6 SPECIAL AGENT NEFF: Okay.

7 But they had stopped 8 maintaining TRIS.

9 SPECIAL AGENT NEFF: Because they had gone 10 to SAP?

11 They were planning on going 12 to SAP so when the one computer crashed, the other 13 drive was unavailable to backup the file and they kind 14 of lost the whole file. We had to come up with an 15 alternate plan to go out there and reestablish and 16 verify all the plant lineups at Salem. I'm pretty 17 sure one unit was in an outage.

18 SPECIAL AGENT NEFF: Configuration control 19 issue?

20 Um-hum. If that was Salem, 21 that would have been in the fall when TRIS was still 22 up. You're right *then it may have been for that 23 spring outage that they were going to go to the work 24 clearance module.

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61 1 side specifically do you recall any issues, any 2 concerns raised regarding the application, SAP and the 3 work clearance module specific to Hope Creek?

4 I don't recall specifics.

5 SPECIAL AGENT NEFF: What about with 6 Do you recall his having to handle any issues 7 at that time frame?

8  !

• j A I remember I got 9 involved when we had the TRIS crash and recovery from 10 that. After that I'm not sure. I can't be positive.

11 SPECIAL AGENT NEFF: What about 12 notifications written about it? Does that do anything 13 for your recollection? Do you recall any issues 14 surrounding a notification written specifically 15 regarding the work clearance module?

16 3MV I know there were issues with 17 work clearance module. I know that operations people 18 had concerns. What the specific concerns are I don't 19 recall.

20 SPECIAL AGENT NEFF: Okay. So if a level 21 1 notification was issued around January of 2000 would 22 you have any knowledge of what went into that?

23 January of 2000. I probably 24 would have seen it at work management center. -

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62 1 recollection --

2 It was screened by us.

3 SPECIAL AGENT NEFF: Do you have any 4 recollection of the initiation of a level one 5 notification regarding that? I know you were on a 6 different side of it. It sounds like you wouldn't 7 have been on the input side of it. You would have 8 been on the screening side of it after it was 9 documented.

10 Right.

11 SPECIAL AGENT NEFF: Do you have any 12 knowledge about how that was initiated? Any 13 conversations with anybody at that point in time about 14 how the level 1 came out?

15 I tell you what, if I could 16 see it, it probably would jog my memory.

17 SPECIAL AGENT NEFF: Okay.

18 I would have to call it up.

19 See if I can call it up and read it again. That may 20 job my memory.

21 SPECIAL AGENT NEFF: From a screening 22 perspective when you saw the level one would you have 23 had interaction with operations management about --

24 Absolutely... -

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63 1 you recall that having happened?

2

• We would always notify the 3 operations manager at either site if there was a level 4 1, especially on something that was an active issue.

5 However, sometimes the ops managers aren't here and 6 their second in command could be here. I don't know 7 who I may have talked to on a particular notification 8 that long ago.

9 SPECIAL AGENT NEFF: It might be helpful 10 if you took a look at it, though?

11 ....

• Ye h.

12 SPECIAL AGENT NEFF: Take a look at the 13 notification.

14 Mal..*I may even have put some 15 notes on it. I don't know.

16 SPECIAL AGENT NEFF: Okay. Maybe we 17 should give you the opportunity to do that and that 18 would help. I mean, there is a time stretch here.

19 Yeah.

20 SPECIAL AGENT NEFF: It may help you to 21 review the issues.

22  :* I don't know if I can call it 23 up on a normal screen or if I have to go back to an 24 archive. That I may have a little problem with 25 searching by time frame. Do we know a specific time NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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64 1 frame?

2 SPECIAL AGENT NEFF: January 2000.

3 iJanuary 2000. Would you like 4 me to take some time to go?

5 SPECIAL AGENT NEFF: Is it something that 6 you can--

7 I can let you know in five or 8 10 minutes if I can find it.

9 SPECIAL AGENT NEFF: I don't have it with 10 me so why don't we do that.

11 Okay. I'll go back to my 12 desk and try calling it up.

13 SPECIAL AGENT NEFF: If you can take the 14 time. It's 4:00.

15 Yeah, that's fine.

16 SPECIAL AGENT NEFF: Okay. We'll take a 17 brief break then. It's 4:02 p.m. We'll go off the 18 record.

19 (Whereupon, at 4:02 p.m. off the record 20 until 4:16 p.m.)

21 SPECIAL AGENT NEFF: Back on the record.

22 It's about 4:16 p.m. What you did was take an 23 opportunity to look up on SAP the notification which 24 we found to be dated February 13, 2000. Prior to 25 going in there, did you know who originated -- could NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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65 1 you recall who would have originated that

.2 notification?

3No 4 SPECIAL AGENT NEFF: And it looked like 5 when you were looking at it the author would be noted 6 a but it was input, actually physically 7 input, it looked like, b yJ 8 That's correct.

9 SPECIAL AGENT NEFF: Okay. Now, in having 10 reviewed that, does that help you recollect? What I'm 11 looking at is its origination, how that level 1 came 12 to be recognized as a level I and how that was 13 originated.

14 . Other than what it states in 15 the notification, we were having, I guess, numerous 16 probleml -implementing the tagging module. A lot of 17 those things came back to light, yes, about how to go 18 in and verify what we were doing. Having to take 19 extraordinary measures to go in there and fake the 20 system out a little bit so we could see what we needed 21 to see. That also could introduce additional errors 22 with tags being implemented in the field.

23 SPECIAL AGENT NEFF: Okay. You recall the 24 issues that were there. Do you recall where the 25 concerns were coming from? I mean, that's written by NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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66 1 the operations manager at the time. Do you recall 2 where the concerns were initiated?

3 I'm sure that the concerns 4 were coming from the work management oversight people 5 and the people that were either putting together the 6 work weeks or writing and developing the tag outs and 7 trying to implement them. Probably most likely the 8 outage group.

9 SPECIAL AGENT NEFF: That takes on quite 10 a few people, work management.

11 At both sites.

12 SPECIAL AGENT NEFF: So that could involve 13 planners, schedulers, operators, outage group people?

14 I think it's more the 15 operations personnel who are responsible for ensuring 16 that the tagging is adequate to do the work because 17 the way we were set up is they would develop the tag 18 outs as part of the work week preparations and then 19 the shifts would hang them but you were reviewing that 20 those tag outs were adequate and then if there's 21 problems with the system and making sure the right 22 tags are getting to the field, those guys were feeling 23 responsible for making sure that the workers were 24 safe.

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1 getting the numerous concerns, do you recall any 2 issues surrounding the level 1 notification? Just 3 going to a level 1 notification do you recall that 4 there was any resistance in writing the notification 5 in that, as you described it before, it's SAP, it's 6 here, and you're going to deal with it? Do you have 7 any recollection that there was any sort of resistance 8 to doing that?

9 o Not that I can particularly 10 recall.

11 SPECIAL AGENT NEFF: Do you recall 12 s - "ciated with any concerns regarding the work 13 clearance module and SAP?

14 Iknow M was -- when I 15 looked at this notification I noticed that" -was on 16 the root cause team who evaluated these. My 17 recollection would be is that" would have more 18 than likely been involved in taking implementation at 19 the time so he would have had a concern for these SAP 20 issues or work clearance module and probably had 21 enough expertise that he was asked to be part of the 22 root cause team to come up with the resolutions.

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68 1 engagement with him regarding what his issues were.

2 Knowing role at the 3 time he would have probably been someone that would 4 have been selected to be part of fixing that problem.

5 SPECIAL AGENT NEFF: Okay. The allegation 6 that I'm talking to you about involves specifically to 7 allege that 'was retaliated against for 8 having engaged in protected activity, specifically 9 that he raised concerns regarding the SAP 10 implementation and its effect on the work clearance 11 module. Are you aware of any information that would 12 indicate that allegation has some validity to it?

13 Very broad.

14 That's very broad but other 15 than what I told you, I mean, when it came to SAP 16 implementation they didn't want to hear anything 17 negative. It was march and go forward and make it 18 happen.

19 SPECIAL AGENT NEFF: But in terms of 20 tagging anything directly to don't 21 have any specific knowledge of on this date he raised 22 a concern and on this date X, Y, 'and Z happened to 23 him?

24 No, I do not.

25 SPECIAL AGENT NEFF: Okay. It's more that

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69 1 your impression was that there wasn't to be -- nobody 2 wanted to hear anything negative about the SAP 3 implementation?

4 That is correct.

5 SPECIAL AGENT NEFF: Okay. Anything 6 further? Do you have any other information that would 7 either tend to verify or to refute that allegation?

8 No, not at this point.

9 SPECIAL AGENT NEFF: Okay. I don't have 10 anything further to ask you at this point. What I'll 11 do is run through some closing questions. Have I or 12 any other NRC representative offered you any promises 13 or reward or threatened you in any manner in exchange 14 for your information today?

15 No.

16 SPECIAL AGENT NEFF: Have you appeared 17 here freely and voluntarily?

18 *Yes; I have.

19 SPECIAL AGENT NEFF: Okay. At this point 20 I'll go off the record. We'll close the interview 21 and, again, I have to thank you for the large amount 22 of your time today. Thank you.

23 You're welcome.

24 SPECIAL AGENT NEFF: It's 4:23 p.m.

25 (Whereupon, at 4:23 p.m. the interview was concluded.)

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