ML20238A672

Partially Withheld Transcript of Comanche Peak Task Force Allegation Interview on 841128

ML20238A672
Person / Time
Site:	Comanche Peak
Issue date:	11/28/1984
From:	NRC COMMISSION (OCM)
To:
Shared Package
ML20238A433	List: IA-86-378, Informs of J Beck 841031 Telcon Re Investigation by Texas Utils Generating Co (Tugco) of Potential Misbehavior of Tugco Vendor Audit Group.Ofc of Investigations Will Followup on Matter ML20238A431 ML20238A484 ML20238A514 ML20238A569 ML20238A615 ML20238A672 ML20238A692 ML20238A720 ML20238A726 ML20244D109
References
FOIA-86-378 NUDOCS 8709090383
Download: ML20238A672 (100)

Text

_ _ _ _ _ _ .

m . u a,nnu y o ')'. j UN11ED STATES. ,

.: NUCLEAR REGULATORY COMMISSION

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i IN THE MATTER OF: DOCKET NO:

INVESTIGATIVE INTERVIEW -

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LOCATION FAGES: 1- 74 .

DATE: WEDNESDAY, NOVEMBER 28, 1984 Information Irl this rei6ril wii'deletW

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Aa-FEDERAL REPORTERS, ING.

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444 Street Washington, t 20001 ffj90f8y83070903 (202)347 7/00 GARDE 86-37B PDR NA'DONWIDE COVDtACE , 6y$I$IT(I)

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, COxANCaE FEAx TAsx FORCE l

ALLEGATION INTERVIEW 6

Wednesday, November 28, 1984 4 I

The interview commenced at 6:00 p.m.

8 PRESENT:

I j

JOHN ZUDANS, NRC yy VINCENT NOONAN, NRC BROOKS. GRIFFIN, NRC Office of Investigations 13 14 .

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. psw 1 P, R O,C, E E, D I_, N,G, S 2 MR. GRIFFIN: For the record, this is an 3 interview of How are you presently 4 employed?

5 THE WITNESS:. I'm employed with a consulting 6 firm in 7 MR. GRIFFIN: What's the name of it? .Is that a

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8 problem?

9 okay, we'll forgo that.

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10 They don't need to be involved in it.

11 MR. GRIFF$N: The location of this interview is 12 Florida, the date is November 28, 1984, and 13 the time is 6:46 p.m. Present at this interview -- and

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., 14 I'll let each person as we go around the room just 15 introduce yourselves.

16 THE WITNESS:

17 MR. ANDERSON: -

18 I'm attorney.

19 MR. NOONAN: Vince Noonan, project director for 20 Comanche Peak. -

21 MR. ZUDANS: John Zudans, technical review team 22 staff.

23 MR. GRIFFIN: This interview is being 24 transcribed by a court reporter. if you would  !

25 rise and raise your right hand, I'm going to swear you to I

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- 1 I u 1 the contents of your statement. '

2 .Whereupon, j

[ 3 4 was called as a witness and, having'been first duly sworn, E 5 was examined and testified as follows:

6 EXAMINATION 7 BY MR. GRIFFIN:

B O Briefly I need to examine more your relationship 9 with your attorney here. I your personal 10 representative for this interview?

11 A He's my legal representative for this interview, 12 yes.

13 MR. GRIFFIN: do you represent any v

14 parties -- when I say " parties," any other firra or 15 individual connected with the Comanche Peak hearings?

16 Not even remotely.

17 MR. GRIFFIN: You're here to represen 18 as his personal representative.

19 I'm here solely to represent 20 21 BY MR. GRIFFIN:

22 O that's the end of our formalities here.

23 You can pick any starting point you.like. We're here to 2

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24 listen to what you have to say.

25 A I guess we can start with audit file TCP ,

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- j 4= 1 MR. NOONAN: Would you mind identifying for the record the information you just gave us in these folders?

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i 3 THE WITNESS: For the record, I have provided I 4 the NRC review team a copy of audit file TC TCP a 5 copy of a report on allegations of coverup and

. 6 intimidation performed by Texas Utilities' quality )

1 7 assurance organization, and some miscellaneous documents 8 which are procedures that were used to work by in the l 9 performance of our respective job assignments at Texas

~~

10 Utilities, as well as notes that were sent to me by an 11 auditor presently in their employ f. hat suggests some . type 12 of intimidating action, in my opinion.

, 1? MR. ZUDANS: You want to give us the name of 14 that person?

3, 15 THE WITNESS: Karen Ormsted, That's a copy of 16 the copy that I received. The copy I have is a little 17 more legible than you have, and you're welcome to look at .

~

18 it.

19 MR. GRIFFIN: did Karen mention whether 20 confidentiality was a concern of hers.

21 THE WITNESS: Karen Ormsted jeuggested to me or 22 , indicated to me on the phone last night that she had i 23 planned to go to the NRC on Monday of next week and that '

24 she was interested to know what the NRC's level of

_ .25 interest was in this situation. I don't know if that's 1 A ~

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1 going to influence her decision to go or not, but she i

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'2- planned to go. Anyway, she has gone to corporate security, 3

to the local police, and these notes are still persisting.

4 MR. GRIFFIN: You can direct her wy way in (

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5 Arlington, Texas.

6 Okay.

7 MR. NOONAN: You're going to start with which 8 now?

9 THE WITNESS: I was going to start with OA audit l

~~

10 file TCP entitled " Radioactive Waste Management 11 Systems." As you can see by the date of this audit which 12 commenced on February 7 and.which ended March 27 of 1983, 13 it was a rather lengthy, disturbing and interruptive

.m 14 process of trying to verify quality conformance of the  !

J 15 system.

16 I don't know if you want to give yourselves time to 17 review this or not, but in summation, the activities that -

4 18 we had reviewed during the audit process suggested to both

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4.9 myself and acting team leader -- I was the 20 f record -- that the system as it stands now 21 was not fabricated to either the specification 22 requi::caents or in NCB 31.1 power piping. We know this j a

23 system is nonsafety-related, in that its failure would not 24 result in hazard to the health and safety of the general '

~ 25 public, but it could affect the plant safety worker in the J

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l' 1 plant to perform properly. Specific conditions are noted f

2- throughout this audit. This was the initial audit, dated f'

3 1983.

tl 4 MR. ZUDANS: Maybe if you could refer to each of j;

5 the pages you're talking to, maybe we can see the points .

6 you're trying to make. '

7 TH3 WITNESS: I'm looking at a report dated (i 4

. l 8 April 19, 1983. The first page identified eight 9 distinguish's and one concern. I was on this audit l

10 approximately a week exactly one week; we came up with 11 various conflicting conditions whereby the inspection 12 reports did not correlate with the actual field conditions 13 and vice versa, and the inspection reports did not D' 14 correlate.with the WFMLs or the schematic drawings.

15 You're really going to have to read the audit, I think.

16 As you'll see on the audit report dated May 3, 1983, 17 TCP -- this is the revised report by management -- we

• 18 have six deficiencies, versus eight with various key words  ;

19 i missing and the concerns missing. -j 20 MR. GRIFFIN: Was this audit changed without '

21 your participation? -

22 THE WITNESS: Right. I was kept on the road.

23 It was never discussed with me. was the '

24 acting team leader the.refore unqualified to endorse this ,

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2'S report; an as qualified with respect t es .

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1 capabilities to perforq ob function. "

2 BY MR. GRIFFIN: '

s-3 0 I notice that the May 3 report which identified 4 the six deficiencies, do you know which person was i

5 responsible for doing this? -

l 6 A It was a combination. It was 7 Tony Vega and David Chapman, in conjunction with Ron 8 Tolson.

,, 9 O So they reviewed your audit and changed it to 10 reflect six deficiencies; is that right?

11 A Yes. As you will note, there's a letter in 12 there that went to file dated April 29 that was placed in m 13 the file by disagreeing with the

/ 14 management's revised version of this audit.

15 MR. NOONAN: Were you ever given any reason why 16 the audit was changed? '

17 THE WITNESS: No one would talk to me about it. .

18 I made efforts to talk to bout it. Even 19 the responses to this audit was pulled from my authority 20 and handled by my management rather than myself. I was on 21 this audit approximately a week of this duration between 22 the 7th of February and March 22. After that, they pulled .,

23 me off that first week because we had such a time with 24 this thing. They pulled me off and put me on vendor

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25 audits. They had finish the audit.

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116 .O' 8 MSW 4

1 MR. NOONAN: So I understand where you were at 2 in the organization, did you work in the Dallas office?

3 THE WITNESS: Out of corporate's QA in Dallas, 4 Texas; senior quality assurance officer.

5 MR. NOONAN: You reported to who?

6 THE WITNESS: To who reported 7 to Tony Vega, who reported to Dave Chapman Who reported to 8 Bill Clements, vice-president nuclear.

9 MR. ZUDANS: Was it a routine that once the 10 original report was prepared that you would send it in for 11

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concurrence r is that the way it worked.

12 THE WITNESS: Uh-huh. '

13 MR. ZUDANS: If they had some changes, would

<; 14 they bring it back to you and say, "These are the' areas J

15 that we'd like to talk to you about that maybe aren't the 16 way we want them" or whatever?

17 THE WITNESS: Uh-huh. -

18 MR. EUDANS: But that never happened; all that 19 came out was this May 3, 1983, report signed and delivered 20 the way it is with the changes?

21 THE WITNESS: had to give me a copy 22 of this. I was on the phone when I was out on my. vendor s

23 audits trying to find out the status of the audit, because l 24 of the conditions we had identified and the situation that

- 25 had taken place on site.

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i 1 MR. NOONAN: To the best of your knowledge, do 2

you know whether any of this was ever brought to the i

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3 technical review team that was out there from, say, April i.

4 to July? i.

5 THE WITNESS: I don't believe it has been. I 6

know for a fact that the internal review entitled " Report 7

on Allegations of Coverup and Intimidations," was 8

presented to yourselves, and you had -- this thing is  !

9 whited out throughout, and you requested the names, 10 because Texas Utilities called me two months, maybe two 11 and a half months prior to this date to break 12 confidentiality. This investigation is the end result of 13 this audit, and these two audits combined, TC nd 14 During the course of this TC J

udit we found that the 15 weld symbols on the weld joints did not correlate with the 16 inspection reports, and in many cases weld joints were 17 signed off using an NCR nonconformance report. They 18 accepted the weld that didn't have any weld symbols on it 19 per NCR M-81001680 rev. 1, dated 12/7/82.

20 BY MR. GRIFFIN:

l 21 22 O

A What page are you on, ll Since these pages aren't numbered, the page is 2

23 entitled " Audit Summary" about the fifth page back. The 24 April letter is what I'm rending off of. I

- 25 In that NCR which is not in here, to give you a s .

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li 1 rundown, had identified this condition, or his 2 inspectors had identified this condition back in '82. And j l

3 the condition identified that there was no weld symbols on I l

4 the weld joints or adjacent to them. 'The NCR stated that i 5 it was -- that the weld symbols had disappeared over a i'

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6 period of time, but they.were there at one time, because 7 weld records reflect that there were symbols on there.  ;

O But we couldn't go to any weld records to verify a joint 9 that didn't have any weld symbols on there, and to use as 10 is, acceptable as it was but the NCR itself was 1

11 dispositioned symbol. '

12 The NCR identifies a condition. The disposition of the 13 NCR doesn't state -- well, does in part state what caused

. 14 the condition, but doesn' t state what they are going to do 15 to correct the condition or what they are going to do to 16 preclude it from recurrence. We found weld joints that 17 were put in place as long as two days ago or that day,

• 18 that heat-affected joints on some symbols were still 19 bright blue, no weld symbols visible.

20 We were with an Inspector Stogdill, who was very 21 perplexed that the weld joints on some that she looked at l 22 had weld symbols that were different than what 'she 23 recorded.

24 'O Did she have an explanation for this? "

l - ~25 A No. I felt that she had gone back and she was s

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211hl.0 11

<KSW I consistently keeping, per I think request, 2 abreast of what we were getting into all the 3 time. THe first day, Monday no one up for the pre-audit i 4 meeting; we ought to get that straightened up. Next day, 5 Tuesday, things started to roll. We had QC assistants out 6 in the field looking at these weld. joints and we randomly l 1

7 selected irs, picking one system so we could get a l 8 cross-section of systems and joints and not be down there 9 at the plant all the time I was unfamiliar with the

.. f 10 location of these systems, and it saved time to go out 11 with an inspection group that was wo'rking with that system.

12 Well, after the second day we didn't have any more m

13 inspectors because we started coming up with these 14 questions. I presented these conditions t 15 and I said to him "I have a problem here with the weld 16 symbols not correlating with the oc reports and the 17 NCR." At that time I didn't know what the NCR was, what

• 18 it was alluding to; and the fact that I couldn't correlate 19 the WFMLs to the inspection reports to what was in the 20 field or the drawings. And he said, "What you have is a

. 21 legitimate finding there." I said: "It's not so much the 22 findings that concern me, it's the overall situation.

'd 23 You've generated an NCR, can you give me some history on 24 it?" I'm heading out of town pretty soon. You have

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'25 a legitimate finding; the only thing I can tell you is to n ,

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1 write.it up. I said it's not my intention just to write 2 this up and let it go. I would like to try to get to the 3

root cause of this condition and find out what has 4 transpired.since you identified this thing. He said, 5

I don't give a shit, go ahead and write it up."

6 This was in front of the QC supervisor and QC inspector, 7

and I can't remember his name now.

8 0 What would be the normal approach that'you would 9

take and the appropriate disposition by the utilities?

10 A What was expressed to us by the utilities when 11 you run into a situation like this was to pursue that 12 situation to the extent possible.

13 0 Who would do it?

.s 14 A The auditor.

It was my job to follow through 15 with what I was doing in accordance with management policy.

16 Q So you would identify an audit; you wouldn't be 17 the originator of the NCR, would you?

• 18 A No.

i 19 Q Who would be?

20 A 21 Q Who would disposition that NCR7 22 A Engineer'ing.

2 23 O And you would just simply follow the disposition 24 also? l i

~ 25 A I would ireview the disposition of the NCR '

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2 0- Would you have input as to -- would you have a  !

3 ' decision-making authority over whether it was proper?

4 A only that those actions identified in'accordance 5 with ten CFR 50 appendix B were satisfied. They 6

identified the condition and the cause of the condition:

7 they corrected the condition and identified measures to 8' preclude it from recurrence. That's what I would be 9 interested in.

10 Q What happened in this case?

11- A .In the case of the NCR7 '

12 '

Q Yes?

S 13 A Well, I already had explained that. The NCR was M 14 dispositioned "use as is" the weld symbols had disappeared

'15 over a period of time. But that doesn't satisfy 10 CFR 50 16 appendix B.

17 Q Did you tell '

about some of the other ,

18 instances where people had looked at the hardware a day 19- after, two days after, and found inconsistencies?

'20 A I didn't have the opportunity to go that far I 21 was cut,off.

I 22 Q After he told you that he wanted you to write it t

23 up what happened next?

I 24 A I said okay.

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1 A I left. This is liks the second or third day. d

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2 I was just getting into this thing. I didn't know what to l 3 think. This is the first time this area has been audited. I i

4 We got off into something that was nos part of the audit 5 scope, not part of Our intent. We saw this NCR stamped on 6 inspection reports, blank inspection reports that weren't 1 7 even completed yet, and that's what kind of drew my 8 attention. I saw this NCR, and if you look at the  !

9 inspection reports on this RAD-WASTE system we'll see them 10 on about every other IR inspection report, where they 11 signed this off on the NCR, pulled the NCR, started to I 12 read it, and I didn't agree with its disposition. So we 13 engaged in conversations over this again. I said, "This

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,- 14 NCR was closed in 'S2. Said 'use as is.'" Those were.for 15 some -- no given joint numbers on the NCR, so it didn't 16 relate to any specific item, only in general.

17 0 They were treating it as a generic problem that

• 18 existed then and would exist in the future?

19 A Forever.

20 0 on any work that was ongoing, they anticipated 21 this same problem would reoccur?

22 A They could fall back on the NCR.

v 23 Q They were referring to an NCR that had already 24 been dispositioned on ongoing work?

~ ~25 A Uh-huh. That's what I had explained to e

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. 21161.0 15

'KSW 1 I felt this NCR in its inte.nt was being abused 2 throughout the fabrication of this system. And he said, 1 3 Well, I'll take care of that; I'll issue another NCR and 4 leave it open until the system is done." I said, "That's 5 not correcting the problem. " He said, "It is for me."

6 And the record will show that another NCR was issued with 7 the same identical conditions identified almost verbatim, 8 only another NCR number. Now they took care of it in 9 their eyes.

10 Q Who can we talk to to find out about 11 documentation that contained the NCR number in advance of 12 the inspections occurring? Who else could corroborate 13 that that occurred?

m, _

y 14 A Al'An Kesler, my audit team member, I don't know 15 if Stogdill will come forward and tell you what's what.

16 Bill Doyle, weld engineering, is aware of this situation:

17 was very much aware of it when we talked to him.

• 18 Q Let me ask you, ifIwentandtalkedtol 19 no asked him why he had this second NCR issued, do 20 you believe he would say this was because it was a generic '

21 problem that continued to occur? .

22 A I don't know what he would tell you.

23 0 But it's not a secret?

24 A It was a secret, I think, up until that point.

-25 Q okay.

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21161.0' 16 i "KSW s

1 A No one had ever audited RAD-WASTE before I did .)

2 in 1983. That whole activity has never been audited. At

'3 one. point during the audit process andl 4 were called into Ron Tolson's office wher

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5 as present, Tony Vega, l j

, 6 an 7 MR. NOONAN: You said Vega was present? I 8 THE if1TNESS: i Yes. I thought that the purpose 9 of this meeting was to discuss the conditions and the i

'* i 10 general attitude of the site QC people. We had QC people l 11 for one afternoon, and af ter that we didn't have them any 12 more. We couldn't talk to 13 BY MR. GRIFFIN:

m 14 0 J

You said that beforer I didn't understand that.

15 What does that mean, you didn't have them any more? I 16 A We had quality control people available to 17 assist us in this review process. When we started coming .

. 18 up with the findings, there was nobody areuna any more to l

19

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help us out in the field.

20 MR. NOONAN: Were they pulled out deliberately 21 do you think?

22 THE WITNESS: I believe they were.

23 MR. NOONAN: You don't know that for a fact; all 24 of a sudden you saw --

- 25 THE WITNESS: Stogdill told us'she wasn't h

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p1161.0 17 KSW 4

1 supposed to talk to us any more. That's what 2 told her, and will corroborate t t becaus 3 had talked to Stogdill,'herself.- Everything we looked 4 at went right back t nd they kept an eye on 5 us through this whole review process. "What did they find 6 out? Where are they now? ,W hat reports are they looking 7 now? What weld joints are they on?" They were overly 8 interested in what we were doing, or concerned.

9 This day that we went in to have this discussion with 10 my management and site management, I believe it was Ron 11 Tolson who started out the conversation, the discussion, 12 and asked me what the definition of quality assurance was.

13 What is quality assurance? So I recited the definition of 14 QA out of NC 2, an my supervisor, said 15 "Stop it," like that . "You know what he means." I didn't 16 Know what he meant. I didn't know what was to go on in 17 that room, so I stopped. '

18 aid that the RAD-WASTE system -- there was 19 some discussion that went on; I don't remember it. But 20 what I do remember is that told me that the 21 RAD-WASTE system was 85 percent complete. "We know it 22 doesn't meet the specification or the code requirements.

23 For us to make it comply with the specifications in B 311 I 24 as you've identified, having the weld symbols on there,

~'25 we'd have to rip out every weld joint in that plant, and h .

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1 we're not going to do that for you or anybody else, 3 MR. NOONAN: Pointed his finger?

4 THE WITNESS: Yeah. I sat there and looked at 5 I felt like and I were the only ones in 6 this thing, and I felt the purpose behind bringing us in

'I that of fice was to coerce us or badger us into changing 8 our opinion. Because throughout the audit all we heard 9 was that "It's only RAD-WASTE. It's not safety-related, 10 what are you so concerned for? I said, "If it's only 11 RAD-WASTE, why am I here? I'm here to verify if the 12 system was manufactured in accordance with the

_ 13 specification and code requirements, as minimal as they

,, 14 may be." We didn't do it. It wasn't manufactured that 15 way. There were no requirements for the welder to apply 16 his assigned weld symbol to the weld joint after 17 completing a joint, and furthermore they aren't there in .

18 the field. You can't take them to any WPML. There's j 19 total untraceability.

20 MR. ZUDANS: What is WPML7

]

21 THE WITNESS: Weld fill material log. What f 22 they had told me and the way that NCR's disposition is j 23 i that the intent of B 311 was to assure that the welder was 24 qualified before he performed any weld activities. That's 25 not the intent of B 311. The intent of B 311 having those

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• 21161.0 19 KSW'

. r' 1 weld symbols on there is so you can run it back to WFMLs

2 if you have trouble with welds out in the field and 3 determine what welder welded those in case you have a 4 series of those joints breaking. l 5 As I discussed this with ASME in New York, the same l i

6 thing. I can't remember his name now. I sent him a copy 1 of this and we talked on the phone about it, and this is 8 almost a year later because I don't like to be wrong about  !

9 interpreting a requirement, and 2 felt that it's very 10 obvious what the intent is in that statement, in that 11 standard. 1 12 MR. NOONAN: Can you remember the name of the .

m 13 individual you talked to at the ASME7 d 14 TME WITNESS: I can probably dig that 15 information up for you.

16 MR. NOONAN: I would appreciate it. {

19 BY MR. GRIFFIN:

20 Q does this April audit report reflect -- is I 21 it an accurate reflection of what you found? Does it 22 detail the concerns that you identified in your audit? Is .,

23 it thorough, is it complete, as opposed to.the other one?

l 24 A It's toned down, in my opinion.

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25 0 Is that the result of this meeting -- as a

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1 result of this meeting?

f 2 A This meeting today? l l

3 Q No, the meeting that you were referring to where 4

they called you in and you were talking about what's the I

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5 definition of quality assurance?

f 6 A No, I went ahead wit 1 went 7

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ahead with extreme, vigor trying in best effort. All I q

8 could do is write my " findings up, since it wa 9 responsibility to write the summary; and I read the

~~ f 10 summary and I thought it accurately reflected the 11 conditions and the situations and attitude 'of management 12 responsible over that activity and I think it's important 13 that the audit record show this. i m, {

14 9 In any file, if management is cooperative we're told to 15 put all -- not all kindst we're told to put good words in 16 there. Even if it's bad there's supposed to be some kind 17 of good words in there.

I couldn' t think of any real good -

18 things to say, other than that if it weren't for weld ,

19 engineering and their cooperation this audit would have 20 gone on a lot longer. You really have to read the audit

, 21 report and we can discuss specific situations.

22 Q There's a very good chance we'll need to 23 recontact you telephonically or otherwise after we look at 24 this. I think what we can best accomplish here is if '

- 25 there's something we don't have available to us, you could D -

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71161.0 21 KSW,  !

1 tell us thatt and also if you could, you know, as you're i 2 doing, summarize this so when we take this and the 3 testimony here we'll have a complete record. That's what 4 we're trying to achieve here this evening.

5 A The audit file maintained by Texas Utilities has 6 all of the notes and Xerox copies of notes that 7 no I looked at. I made Xerox copies of everything 8

and there's little notes etched on therer and it was a 9 very -- one of the most trying audits I've ever been 10 involved in.

11 MR. NOONAN: Where's the location of those files 12 now?

13 THE WITNESS: Texas Utilities, Dallas, at the 14 corporate office under file TCP Now I was pulled off 15 of.the site audits, I feel, because of the situation, i 16 because I was doing vendor audits all during this duration.

17 I came back -- I believe my next site audit was August 15

• 18 of '83. So after the first week in February I didn't come 19 back again until -- no, until June on another audit.

20 Which is kind of uncommon. Normally you would do a week 21 of vendor audits, a week of site audits, roll on and off. I 22 MR. NOONAN: You normally do like every other 23 .: i week, and in this case it was like February through June?

24 THE WITNESS 2 It was uncommon because they had

. 25 finish out the audit, ot a team

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'21161.0- 22 Xsw .

4 1 leader.I which isn't even 2 listed in an NC 223. The only way an conduct an 3 audit is with a qua'lified lead auditorr and sas doing 4 it in connection with who was on another 5 audit, and that eally ha rk cut out to 6 And kas on the phone to me almost nightly telling me 7 what was going on today' .

Like at the end of the first l

j 9 week of February we didn't come back again for two weeks.

. ,9

' You know Wat it's like to pick up' an audit trail after 10 you have been off for two or three weeks and stop again -

, j 11 and come back and try to pick it up again?.

12 .

BY MR. G FFIN:

13 0 did dentify any further problems

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. 14 that are not identified in the audit report?

.c 13 A lN b h at'we have identified is in the initial

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li 4-feport ana is .instNe_notgs.

tN Ob.taining the verification of h 17 the information in ih# t'oport became increasingly more

• 1

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18 difficult and strenuouf io acaomplish.

19 h1 NOONAN: E notice W en you said that one-

, . 3

{20 meeting yo'u fiad, Vega was involved in that. To your 21 ,knowle6ge did it ever go any higher than him, to Clements i a , u. .

j 3

3/22' idr George? '

x 3 ..

[ .y C- 12P Tf2 WITNESS: Not until the h'arassment times

.,\ s 2h investigatico ca:Le., up. At one time I talked to

• tony Vega

.c 25' un the pmr.e from the because I had my

o. <

l g s. ,

. f u A_. 1

21161.0 23 MSW ,

1 suspicions about the QC activities and the construction 2

activities and the conflicts between the documentation and 3

What was available and what should be available -- was 4 required to be available. And I talked to Tony Vega about 5 5055.E. I know that applies to safety-related systems, 6 but I said, "I feel there's a breakdown somewhere in the 7 QC program. On 5055 E the information, the documentation 8 that is available does not jibe with the hardware in the 9 field, correlate what's out in the field.

And there's too 10 many questions I can't get answered; I feel I'm getting 11 the runaround on the job. Site people are unavailable 12 that were supposed to be available and that were available 13 the day before."

m 14 And I explained to him What the requirements were in

)

15 B 311 and Tony Vega told me that lllkNCabout311isa 16 standard thet was developed for the non-nuclear industry 17 basically for rot.ating type of equipment to insure that -

18 some. type of standard or construction information is 19 available when they fabricate any type of hardware 20 systems."

as on the other line and I looked i 21 a1 lll and I.said, "I can't believe that stuff." And he 22 sak8 he was going to be out in a couple weekst not to 23  :

worry about it. I said okay. I said, "I'm just letting

• 24 you know." He said he would take full responsibility for i

~ 25 it. can corroborate that story. And that J

'))l

b

, 21161.0 LkSW , 24 r a l 1 was the end of that.

2 MR. ZUDANS: Do you think what you're'saying and '

3, what I'm hearing is this pervades into the safety-related L

4 portions of the plant? Are you saying that or not?

5 THE WITNESS: Ties into the class 3 systems. I 6 know it's a nonsafety-related system. For the most part 7 what concerned me is that the system was to be fabricated

~

8 to an established set of standards and specification 9 requirements, safety,-related or not. I was required to go 10 out and verify compliance to the branch technical position 11 which is endorsed by the FSAR which endorses 311 and 12 certain parts.of appendix B; and.the system does not meet I

,_s 13 those requirements whether it's safety-related or not. '

,, 14 MR. EUDANS: The only reason I mention it is 15 that'I think I can safely say we're looking for more than 16 just the specific incidents. Maybe it's much bigger, what 17

]

you're saying, and that's what we're looking for? '

18 THE WITNESS: I think it may lead into other 19 areas. I couldn't get in to look at. We looked at some i 20 safety-related systems when we were therer I don't 21 remember what they were we pulled some weld symbols off ~

l 22 some class 1 or class 2 piping, and we found documentation 23 for that. But our reviews were-- next to this pipe we '

24 took the spin number off the weld symbols, tried to find I j

25 it. We found it but here we got off into something that i I

1

\ m l

l-/ l l

1

21161~.0

'kSW 25 I

was tota 31y unanticipated and out of the audit scope.

2 e And there was so much there that we felt that it would j 3

be more important to proceed with the verification of what 4 >

we had than to try to spread ourselves too thin and verify 5 3 without a question of a doubt that the documentation does 6 not exist.

7 We went through everything. We talked to everybody and 8 anybody involved with that activity. We went with weld 9

.. engineering and walked down these joints and if you talk 10 to\ Art Smithey, ha told us outright that he's been trying 11 to establish well records for that system ever since he 12 got in therer and he's done a fairly good job, but ycu 13 can't tie the WFMLs to any of the line numbers. They were ji, 14 run out in the field somewhere and then they = tuck them in 15 the dirt: had no idea where they were going to go.

16 BY MR. GRIFFIN:

17 0

. What was the highest level in corporate that ycu' ,

18 discussed your concerns withs was it Vegt?

19 A Eventually it went up to Bill Clements, 20 vice-president of nuclear.

21 MR. NOONAN: What time period did it go to him?

22 THE WITNESS: August 18, 1983.

2 23 This had created some animosity or tension between Ron 24 Tolson and the OA audit group, and particularly myself and

~

~25 as well. When I came back to do another site

• a, 3 =

.j.

i 71161.0 26 KSW ,

i

' si I audit, which is QA audit file TCP 1ated August 15, 1983, 2 entitled "non-ASME mechanical," you'll see that that audit 3

was divided up into raflective insulation in class 5 pipe 4 supports supports. Ano on the fourth page back you see 5 the criteria that I used, the code standards, the

. 6 procedures and the instructions. And again this is an 7 audit that you are really goinh to have to read. I can 8 give you a summation of the situations that concerned me 9 during this audit.

10 )

MR. NOONAN: I,et me interrupt you a second. j I

11 Just give us'the information you think is necessary to  !

12 help us with these documents here, and at the end of this 13 thing I'll explain something we're doing and go into more rs  ;

.j 14 detail with you.

15 THE WITNESS: Okay, I divided it up into two 16 groups. First, it's supposed to have a certified weld l

17 inspector with me from Al Borne's group. He's our release-inspection group out of corporate QA to do the field 18 19 verification, so we didn't run into a situation where I 20 looked at a joint and we felt it didn't conform to the 21 construction requiremen+.s, that construction or site QA 22 couldn't come back and say, "You guys weren't qualified to 23 v look at that weld joint." We were given fillet gauges to  !

24 verify weld buildup by our supervisor.

25 N he was a senior auditor for parts of J i N

21161.0

'KSW . 27

\'

1 the audit team. I divided the audit up into two groups. j 2 I took reflective insulation, as the OA 3 group leader.

He headed up the weld verification process.

t 4

Now during my reflective insulation review I 'was ccaning '

5 up with my own conditions and my own problems, which I'll 6 explain in a little bit.

was out in the 7

field and found a weld he felt had insufficient buildup on B it.

He talked to the craft about it and the craft kind of 9 agreed with hin -- this is all unbeknownst to me, I was 10 somewhere else -- and I guess QC came up there and they 11 had a debate wit as well.

12 Well, told him he was going to have to 13 identify it as a concern in his report anyway. Well, l

j 14 apparently the craft got nervous and issued an IRN. This 15 weld was bought off an item removal notice. All notices 16 go to Ron Tolson for approval. then Ron 17 Tolson. It went t saw it was a

• 18 weld that was previously inspected and bought off. He 19 went to the craft or QC -- I don't know which one -- to 20 find out why they were going to cut out the joint. They l

{

21 explained that there was an auditor up there. ,

22 went to Ron Tolson. Ron Tolson knew I was the team leader a

23 on this audit, he figured he was going to come in and 24 raise some hell about it. '

~25 Well, I didn't know any of this was going on.  !

I was

3. ,

,_.)

1 10 ,

2116 00 2B xsw i sitting at the audit table. i We were preparing our 2 post-audit notes and writing up our findings, and I had 3 not talked to yet. He was busy writing at 4 the end of the table when Ron Tolson came into the offiv.

5 He barged into the office, literally slamned the doors 6 open, came in, seid, "Who's the team leader on this 7 audit?" I said, "I am." And he said, "No auditor will 8 ever request a weld be removed from the field." I said, 9 "I don' t know what you' re talking about. " He said, "You

~

10 liste you work at it hard enough someone is going 11 to get hurt, either physically or politically.

12 you have been here long enough to know what I'm talking 13 about."

f ,

14 was sitting there; 15 There was approxima'tely six to eight other 16 puople in that room.

17 -

MR. GRIFFIN: Are they identified in the

• 18 subsequent investigative report?

19 THE WITNESS: Yeah. The names were all whited 20 out. Now I said, "I don't know what you're talking 21 about." He said, "You are having them remove that weld 22 just like on the RAD-WASTE audit." Then was 23 standing right here to my right, and was standing over me 24 like that, and then he kind of stood back and 25 gs,ok.up.nesa1. zt .as m. eat s up e er..

o -

79  !

= -- - _ _ -

xsW '*

, 1 Ron, it wasn't He said, "I had brought up the 2 subject that we would be going up there." He said, "Well, 3 didn't know it was you." He said, " Yeah, it was 4 me." He said, "I felt that there was insufficient buildup 5 on the weld up there, and I explained what I had just told

, 6 you" -- what he told Ron Tolson. And Ron Tolson left with 7 they went out the door together.

8 MR. NOONAN: Did they make any statement to you?

9 THE WITNESS: Who's that?

10 MR. NOONANs Tolsa before they left.

11 THE WITNESS: Not other than what I told you, no. ,

12 They talked t a little bit.

13 BY MR. GRIFFIN:

14 Q Did you ever get feedback from anybody else 1S above you in the chain of command, so to speak, as to 16 Tolson or disposition toward you and your 17 information in your audits? Did you ever get any feedback *t

. 18 A Not from my upper management. I know that --

~

19 you know, we didn't have kind words for one another. We l

l 20 ' never did. {

I 21 0 Sounds like what you're saying is they were 22 trying to discount your findings on things. Would that be 23 accurate?

24 A Yeah. Everything. I won't say "everything."

25 seems like whenever you came up with a finding they said, 79 h -

31161.0

KSWa 30 4

1 "It's those God damn auditors again, what do they know?"

2 Ever since I +.hink the first grouting audit I was on where 3

I identified the inspectors weren't visually inspecting 4 behind the base plates before grouting because the surface 5 area was too small. And the disposition of that finding 6 was that the instector shall identify one inch outside the 7

area of the base plate before applying grouting.

8 Ron Tolson called me in his office. Be said, "What do 9 you think of this finding -- this response?" I said, "I 10 wouldn't have approved its doesn't satisfy the requirement.

11 Got to look behind the. base plate to make sure it's free 12 of contaminants, moisture, dirt, whatever else." I said, 13 "By looking at the ceiling is like looking around that 7

14 light instead of behind it." I said, "You're not t

-s .

15 satisfying anything; it's a manufacturer's recommendation 16 that you look into that." He didn't say anything.

17 o was the response to deficiencies identified in

• 18 your audits normally handled informally, or did they have 19 to make a formal response to your audit reports?

20 A They make a formal response to the audit report.

21 I didn't ever expect them to disposition --

22 O You're talking about things that occurred, e

23 meetings and statements made to you, that were outside, I 24 presume, whatever the official response was to the

~

'25 deficiencies?

h -

J

+, i,

)116,1,0 31 KSW

.- 1 1 A This was ~ during the course of the audit.

2 O Did you have as part of your concerns -- were I 3

there any improper findings or dispositions of any of the 4 deficiencies that you identified that are part of your 5 concerns?

6 A I never knew how the RAD-WASTE audit was 7 dispositioned.

8 0 You were already gone or they didn't consult you?

9 A I never knew if it was dispositioned or not.

10 0 You gave them the result of your audit and what 11 they did with it was?

• 12 A They're advised the report sent it out on the m 13 street and management took control over dispositioning the

~~h 14 findings rather than the auditors.

15 Qs 5W M O Fasce your job was concerned it was over at the 16 time you did your report?

• 17 A No, well, apparently in this particular .

18 situation it was over it's not supposed to be over until 19 their responses come back and I evaluate their responses 20 against the ident'ified conditions and see if their 21 responses satisfactory the con.ditions identified. I 22 approve evaluate and approve them yes or no. I I never got .,

23 the opportunity nor did management discuss the situation 24 with myself.

~ j 25 O Did they discuss it wit r

. pEt.- . )

l

. 21161.0

XSW, 32 1 A They never discussed it -- well a the 2 person that morals took it away. ,

3 o Did take it on to be the person 4 who reviewed their response to the audit?

5 A I'll never know. It was between I believe that 6 it was between and Tony Vega they 7 dispositioned the RAD-WASTE on it, on the non-ASME 8 mechanical audit I believe I got the disposition and 9 responses on that but the RAD-WASTE audit was such a \

10 complex issue I don't think they wanted me involved in it 11 because of the things we dug up.

12 Q I wasn't clear on how ttc system worked at the j 13 ceiporate QA audit level.  !

Which is what you were doing?

{y 14 A. Right. Well after Ron Tolson had come in and 15 made that statement, never said anything.

16 I have been in this business 11 years and I would have 17 expected something, some type of interjection by

• to 18 Ron Tolson as to hay let's discuss this somewhere else 19 this isn't the time for it this isn't the place for it.

20 There was nothing in fact Tilton Cook and I road home with 21 at evening bac'c to Dallas an d I were 22 discussing it in the car, the situation because it left a a

23 lump in my stomach and tried to provoked some type of 24' response out o is the type ever person

~ ' 25 who won't say anything to the auditors without first A -

u' '

21161.0

• KSW 33 l'

talking to Tony Vega or Dave Chapman and having a meeting 2 about it.

And it wasn't until almost a month later you 3

can see by the date of the report that they discussed 4

anything with the audit group they just let it ity and 5 manifest itself to the rumor portion of it. And the only 6

reason I launched the internal investigation was to quell 7 the rumors, not to satisfy the situation. I felt that Ron 8

Tolson's demeanor is no excuse for his actions. I think 9 what he s' aid in his actions definitely affect the quality 10 the performance quality of your ability to do a job down 11 on the site.

12 MR. ZUDANS: You mean threatening statements he 13 made about somebody getting hurt?

m

', 14 A Either physically or politically that meant

./

15 something to me and he said you have been here 16 long enough to know Vhat I'm talking about this isn't the 17 f4, ret time this has happened. This aan obviously to me -

18 has been used to seeing things happen before. That's What 19 struck me. Leeause of the way he said it. It wasn't I'm 20 going to beca you up outside or I'm mad at you. This to 21 me it demv..trated to me that there was something more to 22 this and just this situation. I wondered how many other 23 people this had happened to other than myself.

24 .

BY MR. GRIFFIN:

25 O Did you ever discover during the year you worked

.M .

J 1b

l

,.21161.0 1) 34 KSW- .

lj .

lN 1

there did you ever hear any stories or talk to anybody 2l 2

personally that-was ever physically harmed on site? l 3 A Uh-uh.

4 Q Did you ever hear of any other instances where 'j I

5 -fkccleAed people were directly thare 'r : d with physical harm? i 6 A Yes, Rose Clements, who was OA manager there. ,-

7 Q Who threatened?

8 A I don't know who threatened her. I know that 9 she went out to her car, there was a rattlesnake in the 10 front seat of her car. I guess it could have crawled in 11 there.

I know a situation where I guess she was d, riving i 12 down it is road and both front Wheels fell off the car no 13 lug nuts on the wheels, not letting her in the gate. I

,,5 14 0 Where is she?

15 A she presently is self-employed. Ehe is in-hoase 16 ton but I don't know. ~

17 Q I don't know that we're able to follow this type

• 18 of information but let me ask you do you know if she ever 19 was able to identify or did she ever say who was 20 responsible for these problems?

21 A You would have to talk to her.

22 Q You never heard her attribute these problems to --

23 A -:

She is talked to other people but never told me 24 directly and you're going to have to talk to I guess you

~'*25 could have talked to Tilton Cook. You can probably talk

211'61.0 35 KSk .

I t T 2 MR. NOOFAN: Hold be the best person hold know 3 of her whereabouts?

4 A 5 BY MR. GRIFFIN:

6 Q Do you know where he is?

7 A 8 0 Is he still employed?

9 A 'His employment was terminated under sorce 10 situation that had taken place there that himself and 11 Tilton Cook were ' involved in and I can't say anything more 12 than that.

13 Q Do you know how we could locate him?

$ 14 A 15 0 okay, that will be stricken from the record 16 anyway?

17 A -

18 MR. NOONAN: Was he terminated rgcently?

19 BY MR. GRIFFIN:

20 0 Let's move on if we can. I don't want to cut 21 you off. Let's go to the.-- well, let me ask one question.

22 The speed memos in this particular jacket here, what's the --

23 A a They normally come with your appointment to do 24 an audit, your assignment. They are sent b

~ 25 m .

J

(,,1e:19

, I21161'.O Esw 36 i

1 1 o Is this who signed it?

2 A did.

3- 0 These are instructions to you regarding the 4 audit?

(

i 5 A Uh-huh.

6 O This led to the investigation by Spangler of?-- 3 7 A Texas Utilities, I 8 O They conducted an investigation? Was it on this '

9 one incident of Tolson's statements to you and others in 10 this meeting?

\

11 A Uh-huh. l i

12 Q Since I haven't had a chance to read that, what m, 13 was the outcome?

N 14 A The outcome was,.from what I can read in this 15 report, that the auditors were unfamiliar with the 16 requirements as stipulated in the FSAR, the confusion 17-existed as to how to interpret their requirements of B-311,.

18 which constituted some tensions between the auditing group 19 and the audited group, and that basietily it was myself 20 an fault for our inability to perform in a 21 comprehensive manner.

22 Q This led to him losing his temper or something? .,

23 A Yeah. You got to understand. Ron Tolson is a 24 pretty craes guy. So this is what I'm supposed to 25 understand, and you know he kind of flies off the handle 3

• 211,61.0

'KSW 37 )

I and says things, and he -- that he really doesn't mean, s 2 and he's real a good guy. You got to get to know him.

3 And he was just having a bad day that day. You understand?

4 O Did Tolson have any line authority over you?

5 A No.

I think that's What really irked him 6 because he had to go to Chapman. Chapman came down there 7

and says, ckay, what's happening now, and I can never 8

understand that relationship, how the project 9

.. sup'erintendent reported to the QA manager, and I report to 10 the QA manager, and I go down and audit the project 11 - superintendent.

12 O So chapman is both supervisor --

._s 13 A Yeah. What referee hat do I'put on today? I

1) 14 don't think you're going to get an objective evaluation of 15 these two guys. They go out to dinner together. They b 16 want to school together. It's pretty complex.

17 0 Did you ever have any discussions with chapman

• 18 about your differences with Tolson?

19 A Uh-huh.

20 Q What was his -- did he make any recommendations 21 to you or have any advise for you?

22 A No.

a 23 Q Did Chapman find your work satisfactory?

24 A He rated me as competent in my performance 25 evaluation, and if you look through my certifications s

.r ' M *

., f J116,1.c 38

..KSW.

l I you'll see that, you know, I have an excellent j 2 understanding as endorsed b of the codes 3 and standards under TUGCO documentation. You'll see 4 everything that says I was a great guy and knew -- that's 5 my certification file. It's all the records pertain to my -

6 capabilities to do or to implement quality assurance 7 auditing functions. If you look under TUGCO, you'll see 8 letters b valuating my capabilities to 9 perform my job.

10 Q Over W at period of time was this assembled?

11 A Over - 'since I started in quality assurance.

12 Q When was that? .

.m 13 A Well, I really put it together Wen I worked for Y 14 NUS back in 1980 and maintained it since then because 15 maintaining documentation of your qualifications and '

16 training is essential to support your certification and 17 continued employment in the industry, provides objective ,

18 evidence that you satisfactorily accomplish various things.

19 MR. NOOHAN: You have copies of all performance 20 evaluations, you personally?

21 THE WITNESS: Not my performance evaluations, no.

22 MR. NOONAN: They didn't give you a copy?

23 THE WITNESS: No, performance evaluations are a 24 joke. In fact, my performance evaluation -

~

25 gave me my performance evaluation after they went

k 211$'1.0 39

.xsw 1 1 out and celebrated Bobby Schumate's tenth anniversary with 2 the company. They want to and drank margaritas 3 and had natchos and.then gave me my evaluation  !

4 5

6 1 ,

7 I said, would you like a piece of 8 gum or something? said, sure, and I gave a piece 9 of gum, and said, thank you, the l

10 and in my old me the 11 percentage rate that they were giving me, which was fair, 12 and that with additional comment thatI 13 Which is very good, and that felt that I hi 14 asked too many questions during the performance of my job 15 and felt that I had -- that I did not always agree with 16 the way they do their business there, and if I had any 17 questions about it we could go in and talk to Tony Vega

• 18 about it right now. And I didn't see any sense in that 19 since my raises had already been decided, wouldn't have 20 done anything to argue anything, aind just left.

21 MR. NOONAN: They didn't give you a copy of that 22 evaluation?

23 THE WITNESS: No.

24 MR. NOONAN: Was that standard practice, not to

~ '25 give copies?

O

[fI

• 21191.0 xSW 40

{

i 1 i THE WITNESS: I don't recall you did your own

2. assessment form, and filled out one, and you gave 3 yours to and compared o yours, your 4 objectives and goals, and I don't recall what happens to 5 it after that. -

6 BY MR. GRIFFIN:

7 0 I think we're ready to move on to the -- you 8

were telling Westerman about the reflective insula: ion.

9 Are we in a position to go to that?

10 A Yes that's the non-ASME mechanical audit.

11 -

MR. HOONAN: I have one question. On this TCP 12 here, I'm looking at the CC list of June 13, 1983 letter s 13 here.

There are some names; Clements, Tolson -- who's-14 McBay, do you know?

15 THE WITNESS: He's still there at the site, and 16 I forgat what he's over now.

17 .

MR. NOONAN: Okay.

18 THE WITNESS: Gordon Purdy is ASME quality 19 control.

Tolson is superintendent and McBay, I forget who 20 he was.

21 MR. NOONAN: Okay, that's fine.

22 THE WITNESS: During the reflective insulation .,

23- audit --

24

, (Recess.)

i 25 THE WITNESS: In this report, it states that.

{4 .

\3 G7C & 19

21161.0 41' KSW',  ;

L 1 MR. EUDAhS: Which report?

2 THE WITNESS: " Report on Allegations of Coverup I

3 and Intimidation"; it states in there that Ron Tolson, one -)

8 4 of the reasons why Ron Tolson said what he said is that l 1

5 the craft was under so much pressure to meet the  !

6 scheduling requirements that he. felt that auditors out 1

7 there poking around, I don't know if those were the exact i 8 words, with the auditors out there looking around or 9 poking around, he felt that the pressure was so great that 10 something may happen that the -- alluding to the craft, 1 11 may, you know, beat you up or hurt you or get in a fight

'12 with you. That was his explanat' ion as to why he said what I

,_ 13 he said.

.j/ 14 But what they leave out in the report is if that's' the i 15 case, is the craft going to affect me politically as well?

16 I . think that was more of an afterthought than What the -

17 true situation was. I think they had to think of 18 something, and craft was under so much pressure to meet 19 the scheduling requirements that if we went out and were i

20 poking around, they might take somebody off and get in a 21 fight with the craft. He didn't want anybody getting hurt;

)1 22' that was what he was concerned about. '

23 MR. NOONAN: Did that ever happen, to your l 1

24 knowledge?

... 4 25 THE WITNESS: Not that I know of. To be honest I 3 , 2 O

+

4 4

211(r1. 0 42 ksw 1 with you, I don't know. But I do know that there is an 2 auditor right now who's presently being intimidated by 3 notes being left on her desk, both on her desk and in her 4 briefcase. I do know of this situation here, and I don't 5 think I can discount that in answering your question.

6 This is. Karen Ormsted, RKO.

7 MR. NOONAN: I know obviously you wouldn't have 8 any direct information other than what she told you, but 9 did Karen tell you who she thought was leaving these notes 10 for her?

11 A Well, we had a meeting in Texas. We all got 12 together, and I can tell my personal feelings, the tone of A 13 those letters, the language in those letters, we all came 1

16 Now, Tilton Cook and Karen Ormsted were doing a review.

17 They were on audit, the and during .

18 that they had to verify qualifications of personnel to 19 verify the -- witness points during the cold and hot 20 functional'at the plant, and 21 during this review p rocess, this 22 audit at the site, identified that the start-up QA group .,

23 had minimal or no qualification records on file, and these 24 same people were in and out of the start-up group and were 25 senior auditors in the Dallas OA group, and I think -- my

,s.G% .

O 4 4

6,16

. 4

~

._,'21161.0 43 fj xsw' '

1 personal opinion is that there may be some animosity or ,l 2 discontent there, that these auditors that were in the ) i 3 same group as they were were questioning their j 4 qualifications, and it was after that that I believe 5 Tilton Cook was still in the process of that audit When he 6 was found accidentally dead.

7 BY MR. GRIFFINS, 8 Q So the references to ease off, or don't start 9 something, or don't get into something has to do with 10 arguments or over qualifications?

11 A No, I'm not saying that. I'm just te131ng you 12 what I think. I'm just trying to give you maybe -- I know 13 this particular person because I worked with him, and I

{'s.

14 may be, you know, I don' t know this for a fact, I can only 9

15 suspect.

16 0 We'll find out pretty soon -- Monday?

17 A. I hope so. .

4 18 I would also like to state that after Tilton Cook's 19 death, this individual that I named, the first one, stated 20 that, that's one down, one to go. And additionally, down 21 at the site, he told somebody else he told somebody in 22 procurement that if they are not dying, they're quitting. .,

l

23. And I know this, I know that you can collaborate this, 24 whatI'mtellingyou,withfparenorastedor or 25 any other auditors that I named who wonlan't mind telling

,Afs ,

4

.,21161.0 44 KSW-1 you this.

2 MR. NOONAN: On the Xerox is a number, 1284. Do 3 you know what'that means?

4 THE WITNESS: Says dead meat, 11/12/84. The 5 copy was cut off. That was found underneath the meat.

6 MR. ZUDANS: Is that an actual weld? Is that 7 what that is?

8 THE WITNESSt I think that's the note folded in 9 half.

10 MR. ZUDANS: Okay, looked like a weld-to me.

11 THE WITNESS: Looks like the meat was on top of 12 the note in her briefcase.

-- 13 BY MR. GRIFFIN:

-' 14 , O Did you discuss Mr. Cook's demise with the 15 coroner?

L 16 A We.never got together. The coroner wanted to 17 talk to us on an individual basis, end I'm still waiting. .

18 Q So the coroner is still looking into Mr. Cook's 19 death?

j 20 A Right. It was turned over to criminal 21 investigation, I guess, in Dallas or Garland, p>1 ice.

I 22 Q .In that where Cook lived, and that's where he  !

23 died?

24 A Yes.

25 0 okay.

~.r \ v

\

ML

21161.0. .45

ksw.. j q

1 MR. EUDANS: Okay, which file are we in? II 2 THE WITNESS:' TCP 3 During the course of this' audit, reflective insulation, 4 the findings will. speak for themselves, we were reviewing 5 . reflective insulation signed off and installed, and'we 6 went down in.the plant.to review, physically observe the ,

7 installation of this material.. It wasn't on the pipe. If 8' it wasn't on the pipe, it was laying on the ground. If it 9 was laying on the ground, it was hauled up onto the 10 scaffolding.

11 I said, this is already signed off. I said, you have 12 an' item removal notice generated or another traveler 13 generated to remove and reinstall it? And he said, no, we

. .;f 14 always do this. When the piping crew wants to come.and 15 look at a pipe joint, we remove the reflective insulation, 16 they look at it, and we put it back on. I said, do you 17 know you're violating a oc because that's been visually .

18 inspected? He said, yeah, but nobody says anything.

19 Another finding I came up with was that the chem techs 20 who do the swipe test on the stainless steel pipe to i

21 evaluate the low flouride ,and chloride content on the 22 stainless steel piping have no procedure to tell them how 23 far apart or how much of a surface area they are going to 24 taka to do the swipe test. I watched them go 10 feet, 20 '

~ 25 feet to do a test, and each time the surface area was 3% .

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ll 1 different andLI. asked them, Vhat method do you use to ,

1; 2 determine'where you're going to do a test? He said, we ,

3 just come down and do what looks like we should do. I [J 4 said, do you have a procedure? No. I said, do you have

~5 - any. certifications for those chemicals? No. All this "

6 reflective insulation has stainless steel pipe has been 7 tested the same way? He said, we have done that ever 8 since we started. This was in the audit report, and I i talked'to my supervisor -- 1 9

- )

q 10 BY MR. GRIFFIN: 1 1

11- *Q Is this audit complete, would you say?

12 A Uh-huh. .That condition -- I,left at this time I

m. 13 never did evaluate the responses. q 14 Q We'll be in better shape to ask follow-up  !

15 questions When we've had a chance to read these.

16 A I think so. There's one vendor I would like to

'17 talk about. .

18 MR. NOONAN: Can I ask you, you said this was a i

19 reflective insulation on a stainless steel pipe? 3 20 THE WITNESS: Uh-huh.

21 MR. NOONAN: Does it identify what pipe that is 22 in here? ,,

I 23 THE WITN2SS: I don't know if the spin number is 1 i

,k- 24 on there or not. The copies of the travelers that we 25 Xeroxed are in the audit file. i

~

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.l21161;.'O. 47 KSW. ' -

1 'MR. NOONAN: Okay.

2 THE WITNESS: I dug'these out of storage.

3 MR. NOONAN:' Go ahead and proceed, and I'll come 4 'back and ask you if ILhave.any questions. '

5 THE WITNESS: That was a primary cooling system.

6 MR. NOONAN: Primary cooling rystem?

f

-I 7 THE WITNESS: Yeah. I have to look at it again '

8 myself. .I)

.. 9 MR. NOONAN: Okay.

10 THE WITNESS: My concern is that, hell, how many I 11- reflective insulation panels did they remove c,so the . craft .n 12 can look at the weld joints and put it back on again? How .( '

13 many Oc sign- off points did they violate and did anything #

.[

'14 during this period on the' pipe? Did we decontaminate the 7 15 piping again? The travelers that were reviewed were ,

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'16 signed off to the point of being swipe tested and ,

17 inspected. The fina,1 walkdown had not been performed but -

/

18 the final walkdown only consist of appearance of dented 'l s 19 packages or whatnot not, to remove them, do another swipe 20 test and put it back on again. ,

21 . MR. NOONAN: Do you know what chemical they were n ,,

22 using? 9 4

'23 THE KITNESS: No. I went back to tho : lab; they 24 told me what it was, but I don't remember what it was, but L 25 there was no certs for it.. no procedure for it', no 1 -~.'\

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A_1_______ - _ - ecm. -

'1161.0 2

48

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4 1 qualifications of the guys doing it.

2 MR. NOONAN: Okay.

3 THE WITNESS: I would like to get onto another

(

4 audit that I did, a bender audit, Weidmuller terminations.

5 MR. ZUDANS: Is that in one of these files 7 6 THE WITNESS: No. TWT-2 it's called -- TWT-1.

7 MR. EUDANS: This would be in the files in the

~

8 Dallas office? l f 9 THE WITNESS: Yes. This is a vendor that I had

'[ 10 yellow-flagged, and told 11 me not to yellow-flag them, to remove it. " Yellow-flag" 12 means we're not to receive any material from them until 1 13 they respond to the audit findings. I'll tell you why.

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m 14 There's also an as you can -- you might want to make a 4 15 copy of this, I' don't know.

I just dug this out.

16 Here's a memo that I generated which I normally do put 17 i* in the fil'e, notify site procurement, Cecil Manning, to'

~

18 put these people on hold, and the reason was pending j l

19 disposition of these audit findings. Point being, this 20 vendor's QA manual was sent to a consultant, Jim Ainsworth. l 21' He works hand in hand wLth Texas Utilities. He's a Texas 22 TUGCO employee Who went on bl.f own maintaining an office

'A 23 in Houston, Texas. He does contract work for TUGCO. He 24 evaluated this vendor manual and wouldn't sign off on it

~25 because he didn't agree with what ,ttua manual stated in it

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., ,d 1 in the general contents of the manual. And I talked to 2 Jim Ainsworth because I knew why he couldn't sign it after l l

3 I read it, but it was given to me to resolve and since we i i

4 couldn't, I couldn't approve the manual.

5 We review vendor manuals to ensure that they comply 6 with those provisions of 10 CFR 50 appendix B, and they 7 identify their product is manufactured in compliance with 8 this standard, and so on. And this manual is just -- it 9 was a nightmare.

,, And What the manual had stated on the 10 front of it in part was that this manual and the contents 11 in it are not meant to comply with any specific standard 12 but is generally laid out in the format of NCN 45.2, but

73 13 not meant to comply with that. Specific contract I3/ 14 compliance will be achieved by suitable supplements, well, 15 we scheduled an audit so we can go to the vendor to see 16 these suitable supplements. There were none wher. I got 17 there. This manual was what they have, and since the .

18 manual states that they don't comply with the NCN 45.2 or 19 any other quality requirements, how can they supply us a 20 cert, a conformance that says this item is manufactured in 21 accordance with NCN 45.27 22 And they said, "We supply that because Brown & Root .,

23 tells us to sign the cert." I said, "Do you know what 24 you're doing by signing this thing? We're getting a 25 product out of here. I said listen, nuclear is 5 percent

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5 ,MR. GRIFFINt What's the name? >

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] 6' A Meidmuller, in Richmond, Virginia. ,

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O Is thnt' lthe why it ended?

• q  %' 8 , A I wrote up the typieni findirigs, .I wrote up my i s ,

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$  : 9 f.indings, and when I got back, I put these people on held; I n .. 4 6

.,1 7

44 J. '? 10 because you know there's definitely a coriflict here t't- 5,

~) 3 11' between this manual and the cert we're getting.

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5 ,12 Q Oc you know what they previously supplied? i Y AN , 13 A Termination blocks.

<14 .O Do you know 'now many or what volumai k

[t I. ry 3 a 15 A I have no idea. l f.g .. -

i's 16 Q- That's not contairar3. in the audit?

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'h They have been supplying them

'17 A Do, had no idea. .  ;

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'18 ..to uc since 1975, I kr.4cw that. They have been on Brown &

,d .19 Poot's. approved venders list. All the time we were going 6 -

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.' g\ 20 >;tarough'a turnover, Brown & Root vendorn told'us, and all

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'S 2L the time these places were a disaster that were on the s 2 2 'i aphrovedvendor6 list, and you talk t' .,

):' 23 M Jnself. God, ' texas Valve 'tnd Fitting, Crossbow Valve, 1' ,

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, 9 24 s you go on ud wi. This is u vendor .I put on hold. They

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25 toldjme;to move the yellow flag and write them a OA plan.

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i 1 o What did Brown & Root impose on this vendor -- f, 2 what requirements? 'i '

3 A Well, there's another problem which I was going

4 to get to. There's a'Gibbs & Hill spec 039, I believe.

• 5 Don't quote me. The specification is a mechanical

)

6 specification, general specification that they invoke,  !

7 just about all their suppliers invoke, 10 CTR 50 appendix z 8 B, 211, I think 209 and 26. When I first got there and 9 started a'uditing, as well a ndTilton{Cookandwe 10 started going out auditing vendors like we did with NUS 11 corporation to specification requirements and we came back 12 with findings using the NC daughter standards as 13 requir <ments, we were told not to use those any more, just h 14 audit to 10 CFR 50 appendix B.

l 15 I said, how can you audit the supplier and state that 16 he complied with the specification if it endorses these 17 standards and you're not showing that they complied with ,

18 those standards? And he said, just audit. They said, 19 just audit to 10 CFR 50 appendix B, and if you do a I 20 history evaluation you'll see that when the audit 21 notification letters go to the auditors, they state 22 evaluatethevendolrtoconfirmorverifyhiscomplianceto .s 23 the specification; requirements.

24 It went from tO t to audit the vendor to verify his i

~

25 compliance with those of appendix B because the letter

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s 211N1.0 ' 52

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1 ' states a. spec, and I pulled those requirements out and ll

2. went down.there and it was a fiasco. These vendors I t

3 'eculdn't meet it, and I saw the same conditions here that 4 I saw in.the South Texas project with the same vendors 5 they had on that project.

And those vendors don't know ,1 6 what level 26 is. They say a piece of paper saying a guy 1

7 is a' level 2 is a cert. When I was there back in 1980, 8 they didn't have anything, and when I went in '83, at 9 least.they had a piece of paper saying a guy was a level 2, i

{

j 10' started somewhere, but they have the same problems 11 complying with the specifications to the letter at j 12 Comanche Peak as they had at the South Texas project.

n 13 O Do you have in this particular case, Weidmuller, -

d 14 do you have any reason to believe that the -- did you call 15- them " termination blocks"?

16 A Yes. They stick a wire in there --

17 0 , That they would not comply? .

18 A That's a question that was put to me. Now the 19 blocks I think are certified to 323 seismic requirements, 20 .and-they do a test on a sample of those blocks, then pump 21 them out, everything stays the same. They are not ,

22 cataloged but they are tested, and I think it's a matter 23 i of technical interpretation of what was invoked on them 24 versus what they were supplying"us. I don't think they '

25 needed -- I don't think that those provisions in the

= ,

',',21161.0'.. 53

.,xsw specification were intended _ for that, you know, were 1

2 applicable to that product. However, I still had the 3 situation here in .the course of 10 CFR 50 appendix B, the -

4 manual has to state what they comply with and it did not i

5 and.I'm getting a cert that says " certified in 45.2" -- '

, 6 'that was my dilemma. . l/

7 You know, we're left with leaving here and going and 8 trying to see if there's any problem here.

^

9' A I don't think the quality of the product is in 10 jeopardy as I do the development and the implementation of 11 a QA program, because it's such a simple product and it is 12 performance-tested, and 7 just thought I would say that.

13 0 All this is identified in the results of your 14 audit?

~

15 A' Uh-huh.. Initial audit will show that my 16 response -- I wrote them a quality assurance program in 17 accordance'with 10 CFR 50 appendix 8. I said, "This -

l

- . 18 should contain this information," and tried to lead them '

19 down the path of developing a manual as instructed by my 20 supervisor. Then my supervisor told me not to oc that, 21 just write up the findings as you identified them. I 22 changed the report to the way it is now, which is fine,

.23 but the point is they should have resolved the manual 24 problem and kept the vendor on hold till they

. 25 dispositioned it. It's probably still that way today.

"21161.0, 54 LKSW.

F 1 MR. NOONAN: At this point in time you're doing 2 this because you're taking'over Brown & Root vendors?

{

3 THE WITNESS: Yeah. b o

4' MR. NOONAN: Up to that point Brown & Root had 5 been doing these?

6 A Right. And as we got nearer to fuel load and .-

'7 system' turnover, we started taking over the ASME suppliers, 8 and Litton Veam', up in -- I don't know if it's Wallingford, 9 Connecticut -- there's another supplier there. They 10 haven't had a OA manager for a year and a half. The 11 president of the company and his secretary ran the place.

12 They make electrical terminations. They supply these

..g 13 terminations, different types of coupling, stainless steel D 14 -coupling, They supply these couplings to Boston Wire and 15 Cable, who we buy our cable from. These guys hadn't 16 invoked a quality requirement on any of their suppliers

\

, 17 for the last two years. I couldn't find any PFOs on their . j 18 suppliers. l I couldn't find any qualification records on j 19 the people who did the calibrations in the lab. They left.

20 MR. NOONAN: Talking about Veam?

21 THE WI'tNESS: Yes. Found nonconformance 22 material with accepted materials,. Meterial from Italy 23 written in Italian. I asked the receiving inspector, how 24 can you tell this is stainless steel? He said, "I can't.

~

25 I can't read Italian." I said, "Neither can I."

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-____-. ___m__- - - - - - - - - - - - - - - - - - -

2116180 55 KsW.

1 MR. NOONAN:

Is this another one of.your audits?' j 2 THE WITNESSe This is Litton Veam.

3 BY MR. GRIFFIN:

4 Q- When you discovered these problems in these 5 vendor audits in these two cases in particular, what was 6 the result? What did the utility do?

7 A Utility told me to write it up with the case of 8 Weidmuller, write it up and submit itt.and it was a long 9 drawn-out process'to try to get this company to 10 disposition that audit report. In the case of Litton Veam, 11 I had left and they're st!.11 trying to disposition that 12 audit today. I left there like 13 findings.

-s . 13 MR. NOONAN: This was in Connecticut J? 14 THE WITNESS: Yes.

15 MR. EUDANS: Does that mean they made them have 16 an established QA program or do you think maybe they 17 haven't done that even today? .

18 THE WITNESS: They have done that in part today.

19 But in dealing with the vendors of Texas Utilities versus 20 the vendors of Houston Power & Light, I worked for NUS as 21 an independent contractor, we had a different set of 22 standards. We had standards for the vendors and standards .,

23 for the sites. You didn't audit to the letter at the 24 vendors _as you would on the site. Hence the removal of

~~

25 the endorsement of auditing to the specifics just using

' . ,21f61. 0 56

. xsw 4

1 10 CFR 50 appendf.x B, and then sometimes they would call 2 you out on,the-carpet.and challenge your findings, which I 3 guess is their. prerogative. But when you don't have 4 objective. evidence of qualifications of an inspector and 5 the management says, did you see any work that that 6 inspector did that led you to believe that the inspector 7 wasn't qualified to do his job, we only know that there's 8 no objective evidence he wasn't qualified. We don't know 9 .that: he wasn't qualified to do the job, so what is the 10 definition of an audit'and quality assurance? And you got 11 to. review objective evidence to come up with the facts.

12 MR. EUDANS: Is there anything in that file that

,,, 13 I could try to make a cop / tonight that might help us to

,_,. 14 develop that area? Since you would like us to look at 15 that, that's my understanding -- '

16 THE WITNESS: You can look at it if you wish.

17 I'm giving you other examples of conditions. If you want 18 to make a copy of this report --

19 BY MR. GRIFFIN:

20 o would.you say this is a -- was this a 21 substantial problem?

22 A This was typical. I think it reflects the 23 quality of the vandors that they have on their AVL, 24 approved vendors list.

- 25 Q We have a division within NRC that handles y

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• J  !

, t 3 31161.0 KSW - 57 1

vendors and-we can rely on them to some degree to give us 2 information from their side on this. Are there any -- I'm l 3 referring to notes taken during your conversation with the 4 NRC representative in region 4. Are.there any other I

{

5 issues that you -- concerns that you had that' we have not 6 covered?. I think we have covered what you told the region 7 4 person.

-8 A Not other than that I would be available for, 9 you know, anything else you wanted to talk about.

10 Q I think that.will absolutely be necessary.

11 Since we just got.the information, we're not really in a 12 position to do much . followup at this time until we can

-.. 13 look -- I need to ask you a couple questions.

_/ 14 A- What I'm indicating to you is some of the 15 ' problems that we have throughout the QA group, which you 1<6 are going to have problems, but I think it's a matter of 17 the caliber of the management and which position they are ,

18 going to take in d,ispositioning and how they ' disposition 19 these. -

20 MR. NOONAN: CanI.abkaquestion? You have 21 been in this. business about *11 years, you said?

22 THE WITN'SS:

E 12 years.

e 23 MR. NOONAN: Looking at the vendors -- you must 24 have looked at them before, right?

~'52 THE WITNESS: A couple of them I've looked at

'D .

J i

21161.0 58

,K5W.

.. 1 1

1 already that I had seen previously.

2 MR. NOONAN: Are you finding the vendors

~

3 associated with Brown & Root to be worse off from a QA ,

4 standpoint than other vendors you normally looked at? I'm 5 looking for a subjective judgment here.

6 THE WITNESS: The vendors -- unfortunately the 7 vendors on HL&P's approved vendors list were Brown & Root 8 suppliers and on TUGCO's approved vendors list they are 9 the same vendors for Brown & Root suppliers, so I can't 10 say that Stone & Webster suppliers were the same as Brewn 11 & Root, and they had different --

12 MR. NOONAN: I was looking for just based on how s 13 you felt about the particular vendors compared to other sd 14 vendors in the industry. Were these better or average or 15 worse? I'm looking for something sub jective here.

16 THE WITNESS: With the way the industry is now, 17 I think they are about average. I think that some of .

18 these suppliers, the deficiencies identified at some of 19 these suppliers should have been caught. There are 20 obvious findings like Weidmuller terminations. They have 21 been an AVL since about 1975, should have been identified 22 a long time ago. Doesn't take a rocket scientist to .,

23 figure that out. You look at appendix B and go through r

24 the criteria and the manual and see where they do and

" ~

25 don't meet those requirements. That's what you do before

.L ' s t

s.

,21161.0 59

'KSW.

1 you go out on the audit.

2 BY MR. GRIFFIN:

3 Q l heither one of these two examples you've 4 given us for Weidmuller or Litton Veam, neither one 5 resulted in a 5055 E, did they? '

l

', 6 A Uh-uh.

7 Q There was never anything identified that would 8 cause the Utility to make a report? i

)

9 A Uh-uh.

10 Q okay. I just wanted to cover that.

11 A I think in the case of Litton Veam, you could 12 take a really close look at that. It's something that you l

,,' 13 don't dare to mention in the office as a 5055 E or part 21.

,,,/ 14 O Then in the case of Litton Veam was there )

i 15 anything in there that you saw that would merit a report?  !

l 16 A I don't think they have a QC program. It's just 17 that simple. They don't have an effective quality control' ,

18 program. You can't tell where the materials come from.

I 19 They don't invoke any quality requirements on their l 20 suppliers, they don't.do sample testing when the materials 21 come in. I don't know if that's a stainless steel 22 coupling or an alloyed coupling.

a*

23 Q I need to ask you a couple questions going back 24 to some of the subjects we were previously discussing that 25 I neglected to ask you at the time. Going back to the d

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1 meeting in Wich Tolson, I think you said, barged in, then i 2 made'the statement about political physical or political.

3 harm, do'you know of anybody that attended that meeting or 4 anybody that was working on site who altered their audits, 5 altered their . reports or failed to report something in an

6. audit as a result of that particular incident? You 7 understand, I'm asking kind of an all-encompassing

8 question.

9 A Do I feel that that affected?

10 0' I'm asking you specifically, do you know if any 11 work was affected? '

12 A No . - I know that we walked cautiously after that, A, 13 and I know I did, and I was more reluctant to pursue a 14 situation than I was before.

15 0 It caused you to be aware of --

16- A What I was doing and d ere I was and Who I was

, 17 talking to and what was over me and What was behind me, or .

18 who was over me and Who was behind me, yeah.

19 Q I understand what you're saying.

20 A I couldn't discount-it as someone having a bad 21 day'or looking out for my best interests.

22 Q Let me ask you this. You've already explained .,

23 about the missing weld symbols, but other than the process 24 of construction, is there any other explanation for Why 25 these weld symbols are missing?

n

S.

21161.0:

KSW* 61 l

1 I'm just asking you if there is something beyond just 2 the' fact that the corrosion or --

3 A There was no requiremera, for the welder to apply 4 a_syrbol.

5 Q Okay. I missed that point.

i' s1 6 A Not that they disappeared over the edge of time ,,

7 or period of time. There was no requirement for them to B

ever apply their weld symbols, and that's in the finding.

9 I think that's What contributed to the condition.

I 10- 0 Okay, I missed that on the first go-around. '

11 A Weld engineering was very much aware of that ,

12 requirement, Bill Doyle, because he tried to implement

. ?g 13 that practice wherever possible. He told us flat out, you

' 5 14 know, it was no big secret to him.

15 0 'It was resisted, putting that in procedure?

16 A I guess so. We hunted all through the 17 procedures. ,When I dug out the requirement and the . '

18 specification for thc RAD-WASTE system and balancing 19 piping period that there shall be an effortless trail of i f

l 20 traceability in accordance with 311 or BSME, an effortless '

21 trail traceable to each specific joint in accordance with 22 the applicable requirements, and I put that spec out, they .,

23 about died. They didn't know that existed and/or that s 24 requirement existed in the spec. And you'll find if you 25 review that spec today as it's referenced in the report,

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' 211ria.O-62 '

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1 that they revised that spec to remove that requirement, 2 from what I understand.

3 0' "They" being who?

4 A Texas Utilities.

5 Q Anybody in particular?

6 A. Whoever has responsibility for dispositioning

7. that finding.

.8 0 okay.

9 A. When you run across a condition where they have 10 been violating or did not comply with this specific aspect 11 of a procedure for like the last five years, the method of 12 correcting the condition is to remove it from the

^

13 procedure: The problem goes away, no more problem.

14 Q -

Okay, I understand what you're saying.

15 MR. GRIFFIN: Vince, do you have any other 16 questions?

17 HR. NOONAN: In your time with Tex'as Utilities, .

18 have you ever seen any indication that management was l

19 trying to improve the situation from a standpoint of, you 20 know, QA/QC being very important in the building of a )

21 nuclear power plant? "Let's make sure we get it right," {

22 that kind of thing? .,

23 THE WITNESS: I'll tell you about a meeting we 24 had with Dave Chapman, our QA manager. They were

.. i 25 concerned about all the findings being written up. Dave l 1

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4 1

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.21161.0 63 KSW -

4 -

1 Chapman stood up in front of all of us I believe it was 2 at the time they presented this report at a meeting, I 3 don't remember -- results of this report. But he said 4 writing up a finding is kind of like speeding: if you 5 catch somebody doing 57 miles per hour in a 55 miles per 6 hour speed zone you give them a warning, you don't give .

7 them a ticket. And if he's doing 59 in a 55 miles per B hour speed zone then you consider the ticket. You guys 9 are policemen out there, but in other words kind of back 10 off from these guys.

11 I think relating speeding to noncompliance to 12 specification you're comparing apples and oranges. He x 13 doesn't say if you're doing 55 here and drop down to 30

/ 14 50 feet down the road what do you do. l i

15 BY MR. GRIFFIN:  !

16 Q Did Chapman specifically say not to report l 17 deficiencies? . s

. 1 18 A No. Wha,t'he was alluding to and what we all 19 felt was to -- wha:t I got out of it was to go easy on l 1

20 these guys. Don't write up everything you see. That's 21 what I remember of! David Chapman.

22' Q That's dhat he expected from you? ., ,

23 A Expected of us.

24 0 While you were there, did any of the supervisors 55 in corporate QA ev:er -- did you ever hear any of them

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.N1161.O' 64 d KSW I

1 instruct auditors not to report deficiencies they i 1

2 identified? ,

3 A Other than management taking it upon themselves i 4 to remove a finding from an audit report or to downgrade'a ]

5 finding in an audit report to make it go over easier, no, i i

6 Not outright say, " Hey, don't write that up."

7 0 In the case where it was downgraded or they 8 dropped out some of the deficiencies as an example that  ;

. t 9 you gave here, does the -- does your original report  ;

10 remain part of the package or part of the audit trail 11 4EE WITNESS: In the file it will.

12 O It will still be there?

-s 13 I know when they'present A Should still be there.

E/ 14 audit reports to the hearings that they only take those 15 audit reports that are approved by management. Your audit 16 - report stays in the file in Dallas. It doesn't go to the 17 hearings, nor do the notes. .

18 MR. NOONAN: To the best of your knowledge, 19 those are still in those files? '

20 THE' WITNESS: To the best of my knowledge.

21 There's another a dit here, TCP . project training and 22 nonconformances. .,

23 We had to wait for the NRC to get done 24 auditing this activity in INPO, or vice versa. We were 25 scheduled to do this, and they said, NRC is in there now,

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r l 41161.0 65 Ksw .

l 1 let them get done, then you go in and audit.

{

2 Well, NRC got done apparently, and INPO got done, and 3 apparently blessed the training program and qualifications 4 program. We had a debate over this when 5 and did the audit. You may want a copy of this audit 6 report and follow up on scoe of the names and the level of 7 qualifications versus the objective evidence available to 8 support their level of qualifications.

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9 MR. NOONAN: I do want a copy of that.

10 MR. ZUDANS: Are you saying the audit results 11 are different than what the NRC came up with?

12 THE WITNESS: Yeah, because Bob Scott said that 13 this qualification program was blessed by the NRC, INPO Q 14 and everybody, including God -- that's what he told us 15 because we ware going to write up these findings. You 16 know, they had some nice packages with names on there with  !

17 . paper in them, but none of these papers in there meant 18 anything. Had someone's name on there and a bunch of '

19 certifications in there, training files in there, what 20 were supposed to be training files relating to a specific 21 subject, specific individual, duration of time endorsed by

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22 his supervisor. The forms were half complete or no forms

• J 23 at all. There was a. computer printout saying a guy was

- 24 certified level 2 in this, this, this discipline and no

• 25 objective evidence to support it. .

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,Dilil..O 66 xsW 1 We found certifications -- here's an example: Level 2, 2 all electrical certified level 2 electrical. Has the guy 3 been indoctrinated into the procedures? Couldn't find 4 anything. Has he been -- is he aware of subsequent 5 revisions to the procedure? Can he do high pot testing or 6 cable pulling? Is he aware of those procedures? This is 7 a clear indication of the type of findings that we saw in

, l 8 that computer printout where a guy was certified 27 9 activities, we found objective evidence supporting 12.

10 MR. ZUDANS: Let me do the same with this, if I 11 may take it downstairs and do a copy of it.

12 MR. NOONAN: What's the date?

.m 13 THE WITNESS ~ December 8, 1982.

14 MR. NOONAN: This was same time NRC and INPO --  ;

15 BY MR. GRIFFIN:

16 0 Do you know for sure that the NRC report missed 17 this, so to speak, or do you know what the CAT team report ,

18 said on qualifications? ,

19 THE WITNESS: No. I knoy that through -- in 20 fact, I did see the cat team report, but it didn't 21 identify unfavorable conditions'because management -- site 22 management was very perturbed that we came up with the ,,

23 findings, and in fact, was out here two 24 days ago, he ran into Cecil Manning at the airport in

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i 25 Dallas, Texas. Cecil Manning maintained these O, . I I

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v 1 qualification records because we talked with Cecil, and i 2 cecil's a pretty knowledgeable fellow. He got -- I don't 3

want to say he got stuck with maintaining those records, i

4 but he got stuck with maintaining them as best he could, 5 and he was being requested to go to Washington D.C.

to 6 talk to the attorneys about that report because he talked 7 to David about this particular situation. He said, you 8 remember that audit? Well, from what tells me that 9

you and did on training qualifications, they want to 10 see me in Washington about this. Apparently something is 11 happening. So I don' t know What -- you're already in that 12 area apparently.

-'s 13 MR. NOONAN: This was two days 69o?

14 THE WITNESS: Yeah. You can talk t nore 15 about that if you would.

16 Also, excuse me, before I forget, back in the RAD-WASTE 17 audit there was one inspector -- Stogdill'was the lady -

18 that helped us in the field. I'll have to look in the 19 other report. No qualification records for that inspector 20 at all.

21 BY MR. GRIFFIN:

22 0 I think I saw that. It was Stogdill? ,

23 A What was the inspector's name? Did I say it was 24 Stogdill that took us out on the field?

25 Q You identified Stogdill as --

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'v 21161 0' 68 KSW 1 A It's Sto11iker -- that's the girl helped us in 2 the field, the inspector with us the first day and a half ,

3 was the inspector that there was no qualification records 4 for available on site, who we found her name on numerous 5 inspection reports. There was no qualifications records, 6- no qualifications available at all at that time of the 7 audit and weren't to be found anywhere. That was Stogdill, 8 and you can understand how it's easy to get the two 9 confused.

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10 MR. NOONAN: I don't have any particular 11 questions. I would like to -- a number of things that you 12 have brought up today, some of the things we re actively

^ 13

, looking into at the present time. I want to ask you if V 14 you would be available to us to talk to you about the 15 details after we go through this and study the reports.

16 Under what conditions, what would be -- like, can you tell 17 me the time you would be available to us and the phone -

18 number we can reach you at? We have one -- is that the .

19 number we should use?

20 THE WITNESS: That's my work number, My 21 home phone is and the time that would --

22 depending on the urgency of it, if it has to be during the .

23 day you are going to have to make arrangements with my 24 employer to do that. I will be available to talk to you 25 as you wish after working hours.

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t 1 MR. NOONAN: I can call this number after j 2 working hours?

3 THE WITNESS: Yes, after five p.m., to 4 mcke arrangements for next day or something like that.

5 And when it gets to be toc auch, I'll let you know. We'll 6 try to do something during the day. You'll have to make 7 arrangements with my employer to do this. They are aware 8 of this.

9 MR. NOONAN: Your employers aware of what you're 10 doing here?

11 THE WITNESS: Yes, I talked to them about it 12 before, and at the time after I talked to the guys in s 13 Arlington, Texas, I came back and told them what I was

.. / 14 involved in and we had a meeting about it and since wo 15 don't have any contracts with these people, I guess it's 16 okay with them. But if it's going to interrupt the I

. . l 17 business day, then I think that they're going to expect ,

18 that they be reimbursed or compensated for my hours.

19 MR. NOONAN: We'll try not to interrupt you I

20 during the day, as a matter of policy. If we need to get '

21 in touch we'll call you, but it will be a short phone call.

22 We won't ask a lot of questions. It will be mostly in the 23 evening we'd talk to you.

24 THE WITNESS: You're going to find some of the i l

25 reports I've dispositioned the items on, some I haven't.  !

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$11 }.0 70 xpw 1 Some are open. I fully expect some questions on the ones 2 I dispositioned and why I dispositioned them.

3 MR. NOONAN: Have you talked to anybody else 4 about this up here that you gave us? Anybody else that is 5 aware of this?

6 THE WITNESS: No. Nobody knew what I was going 7 to say to you or talk to you about. I think there's a 8 couple people knew I was going to talk to you about 9 RAD-WASTE for sure. I didn't know myself how it was going 10 to go until we started doing it. And I think once you 11 talk to the other auditors I mentioned, you're going to 12 find this throughout the QA program on the corporate level.

13 MR. NOONAN: Okay, basically what I'll do, I'll

-- 14 basically hand the records to my technical review team in

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15 QA/oc. There's one group leader and he has n number of 16 people working for him. We will look through the 17 documents and th9 n maks arrangements to come back to you .

18 and ask specific questions as we develop them.

19 I went to ask one other question. Would you be willing 20 to come back to Washington and talk to these people, 21 assuming that we pay your expenses and so forth?

22 THE WITNESS: As long as my employer -- if my .,

23 time is reimbursed to the employer, they will let me go 24 all week. .

25 MR. NOONAN: I was thinking mainly on weekends.

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s21161.0 71 ADM e

1 Would you be willing to do that? We would not interrupt 2 your normal work. We can set it up any way yoa.want.

3 THE WITNESS: I would rather do it 6uring the 4 weekdays, rather than work seven days a week. I'll give 5

the Government a break to a certain extent.

6 MR. NOONAN: Either myself or Mr. Zudans will be 7 getting back to you regarding What we_need to do here.

8 We'll be talking to you. What I'm giving you is my office 9 numbers. You can always --

10 I would like a copy of that 11 transcript.

12 MR. ZUDANS: Okay, I'll get you one.

13 MR. NOONAN:

,,,. You can call the first two numbers

,,,. 14 collect any time. If you have trouble with somebody 15 accepting 'the call, just say we have an agreement to 16 accept the call. The last number is the .NRC operator 17 number. She can reach me on off-duty hours. Just call

• 18 her. Ehe can get hold of me.

19 As far as the transcripts are concerned, do you want to 20 .say anything?

21 MR. GRIFFIN: He's entitled to a copy of his '

22 transcript.

23 I don't care about having one, I 24 want you to have one.

25 KR. NOONAN: We'll make one copy of the j

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,21161.0 KSW

• 72 1 transcript and send it to you. Normally I.make only two 2 copies, but in this case I'll make a copy for Mr. Grif fin 3 here. We'll make thrse copies of this transcript and no I 4 more than that at this point in time. If we do, we'll 1 -

5 tell you what we're doing with them.

6 THE WITNESS: Okay.

7 HR. NOONAN: I have one other question. Based 8 on your interface with t' he QC inspectors at the site, can 9 you tell 'me how you felt about them as to their level of 10 competency in general? I'm not looking for specifics 11 right now.

12 'THE WITNESS: I felt that the QC inspectors

-~, 13 themselves were competent to do their job. I don't feel AJ' 14 that the quality control management -- I think their iden 15 of oc and an inspector's idea of QC are two different 16 worlds.

17 MR. NOONAN: Gkay, I don't have anything else. -

16 MR. ZUDANS: I don't want to go over the[same 19 surface again. Have you talked about possibly coming 20 up to the NRC? ,

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1 21 MR._NOONAN: That's a possibility.?

22 MR. ZUDANS: That includ v 23 MR. NOONAN: Who? Oh,  ;

i 24 MR. ZUDANS: I want to understand what the 25 arrangement is.

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4 1 MR. NOONAN:

We'll make arrangements with you.

2 That would be up to my client.

3 THE WITNESS: I wouldn't go anyway without him.

4. MR. NOONAN: I am limited by certain things I 5 can and cannot do within the Government, but I'll tell you 6 what that is when I decide what we're going to do here.

7 Mainly we're thinking about -- you've touched a number of 8 areas. You talked a little bit about the electrical and 9 about the QC stuff,'you mentioned something on test 10 testing. We have six groups set up to handle what we call 11 basically our technical areas, broken up into six groups.

1,2 Rather than ,trying to fly six people down here, it may be ,

13 better to fly you an ek to us and have'you O 14 talk to us in Washington itself.

15 MR. I think anything you can do to 16 consolidate contacts with my client, he would appreciate 17 it in terms of if your groups can get together and maybe ,

18 make one phone call and let him take turns or something 19 like that, rather than him getting spaced-out calis. l 20 MR. NOONAN: Mr. Zudans usually makes the 21 contact. He might have two or three people on the line at 22 the same time. We do try to minimize. We understand the ., ,

23 impact on you and your home lif'e.

24 MR. ZUDANS: My reaction, though, is that I

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25 wouldn't like a phone call amongst all the people. I l

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7 CERTIFICATE OF OFFICIAL REPORTER

, '*k This is to certify that the attached proceedings before the UNITED STATES NUCLEAR REGULATORY COMMISSION in the i matter of: .

NAME OF PROCEEDING: ALLEGATION INTERVIEW DOCKET NO.:

PLACE:

m. DATE: WEDNESDAY, NOVEMBER 28, 1984 d

were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Conveission.

i 1siat)

[ ffd (TYPED)

KATHIE S. WELLER Official Reporter ACE

• FEDERAL REPORTERS, INC. .,

Reporter's Affiliation e l

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TEXAS'O FILITIES GENERATING COMPANY 3

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OFFICE MEMORANDUM l

y. ' J B . R . Cl ev-ent s a .,

Dallas. Texaa _ Augu s t 23, 1983

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Subject WOP.T pf_ INVESTIGATION OF INTD4IDATION AND COVER-fTf'.,0N Ti!E PART Ci DALLAS QA MANAGEMENI' __

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The attached repori en Allegation of Cover-up and Intimidation by TUCCO, August Quality Dallas 8, 1983;Assurance is' forwarded as requested by your memorandum of After an extensi'+te investigation, the investigative team found no evidence the Dallas QA management.to support eiths an allegation of 'sover-up or intimida The detai.L2 contained in the report. supporting that enclusion are

• 1 i

. e K1 chard E. Kahler i

REK:cp 4 Attachment '

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' formation in this record vtal ddetid '

In accordance with the affam of InformBil0fl

/tct,exem tions .D.

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,'.". $ . r g ,. e INTRODUCTION

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'i, On August 4,198' .1, Dick Kahler, Bob Spangler, and Gil Eeeley were

$[ requested by Bill Cleme.nts to attend a meeting concerning allegations that had been nade to him that there had been intimidation and cover-up 2r ' by Dallas QA manatement. Aleci in . attendance at %e meeting were Dave

, ' Chapman, Tony Vega, Al Boren, and

.d y Clemets indicated chat an investigative team, headed by Kahler with

". gpangler .ind Keeley as members was to be formed to investigate rumors he had heard about intimidation and cover-up by Dallas Q& management. He

.M4 'snted that he wtuld write a meno directing that an investigation be

$ [ corducted and th'at he wanted everyone in Dallas QA to be interviewed. He g said that if the results of the investigation indicate a problem, h4

..g ;would take the necessary corrective action.

.a.

Clements then met separately with Kahler, Spangler, and Keeley and

.. " J indicated the following:

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4. 1. He wanted a thorough investigation with no schedule pressures.

l l '/ 2. If a significant problem was indicated, he wanted to know right away

$, so he can tak1y corrective action 2nd inform the NRC.

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3. He wanted to assure himself that QA is being done properly and per 4 d .n our commitments.

[ Clements issued a meno to Chapman on August 8,1983 (Attachment U. He s; also issued a meso to Kahler on August 8,1983 (Attachment 2) which in y part asked the ed.it tem to ensure thet:

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.. 1. ' All esf oyees l ura schduled for an interview and advised that the intesviews will be in ' confidence.

1 2. 'If they were not comfortable in discussing the subject with the investigators, that they should be advised that they have the right

} and responsibility to discuss their concerns with company officials.

hf 3.

I If they did not wish to discuss their concerns with the management, they were to be advised. that they have the responsibility and

'? i. cbligation to bring those concerns to the attention of the Nuclear

,, j legulatory Commisslos, on Angust 9,196') Kahler issued a memo to Chapnian requesting copies of .

docLcents or personal notes which might have a bearing on the investigation (Attachment 3). Dallas QA management did make available to thef investigative team all documents which they thought might have a bearing on the investiga-

, tion and were very sugportive of the investigation.

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Pegs 2 of 12 I' CONDUCT OF THE INVESTIGATION d

s in order to establish the validity of the allegations and to determine specific instances where intimidation or cover-up eay have occurred, the '

'. team was directed to interview all professional (non-supervisory) Quality 1 Assurance (QA), Dallas personnel (Vendor Inspectors and Auditors). A M standard set of' introductory remarks,. interview guestions and concluding

• $ remarks (Attachment 4) were developed for use by the interview team con-

..'~.jsisting of C. 8. Keeley and R. C. Spangler. Each interview session began

',',g by having the interviewee read a copy of the memorandum from 5. R. Clements 7 to.D. N. Chapman concerning the investigation (Attachment 1). In addition,

.; the interview team informed each interviewee:

1.

that Texas titilities management considered the resolution of these allegations to be of the utmost importance; 2.

that a report would be made to tb NRC should the allegations be established as factual; 3.

that the interviewee's comments would be held in confidence by the intervi,ev team subject to the proviso that identities may have to be discussed with the NRC.

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. Finally, the interview team requested the interviewee to review the team's l

• _ handwritten notes for accuracy. The interviev questions (Attachment 4) i g'  % were used as guidelines tu provide uniform structure to the interviews

(. The i* 4rviewee's answers generated additional followup questions and .

discussions. Question number 7 regarding the interviewee's opinion con-carning the overall effectiveness of the' QA program was addressed only to the audit stoop personnel. At the conclusion, the interviewee was g, requested to contact any member of corporate management, from the Vice

< President, Nuclear to the Chairman and Chief Executive Officer, should

,( their be any matters that they wished to discuss with someone other than

- the interview team. In addition, the interviewee was reminded of his/her

,? tight...to contact the NRC. At this time a handout which included the

'siventotheinterviewee. names and phone numbers of TU Corporate Managers and NRC

.. this manner over a period of A three total of 23 individuals were interviewed in days.

. R. E. Kahler, was briefed following each day's interviews.The investigation team leader The audit

' team did not at any point during tLe interviews consider the weight of

• evidence to be significant enough to require a report to the NRC.

. Discussions concerning the team's findings and their possible deportability were process. held periodically with the Vice President, Nuclear throughout this Based on the colleclective results of these interviews, the inve#stigative

. . basis teamfordetermined that there the development were of a set of two areas of concern and these formed the supervisory and management personnel. scions for interviews with QA R. C. Tolson were subsequently intervt A. Vega, and to comp ete the investigation.

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.? Pa.4e 3'of 12 S There appear to et m ineidents which formed the buiu for the allegations.

The incidents an at11 as cle imestigative' ceam's conclusio'ns are dist:ussed in the following sections.

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['

INCIDENT OF POSSIBLE QA COVER-UP/RADWASTE AUDIT TCP-66 j

The audit of the adioactive We i by an audiryteam ans ement S stem whir.h was conducted yas sing

. . as an e out by a majority of the individuals interviewed e of an audit in which audit findings may have been altered

, , *' or deleted by QA management.

The implication being that QA management

. .. may haw acted to cover-up problems identified by the audit team. As a  !

resul of the above, the investigation team reviewed the audit file for {

. ' TCP nd subse tly discussed the conduct and results of this audit l

Twit and A. Vega.

The seppe of this audi.t included, principally, the field piping and valves associated with the gaseous, liquid and solid radioactive waste manager ent systems (RWMS) at CPSES. These components are unique in that they were originally installed under ANSI B31.1, No QC inspection effort is reqrired under this standard. TUCCO subsequently committed to meet the rec airements of NRR Branch Technical Position ETSB No.11-1*, Revision 1.

This commitment was made after the installation of a significant amount of RWMS piping. ETSB Mo.11-1 requires the limited application of some 10CPR50, Appendix B criteria to the RWMS. The inspection requirements of ETSB No.11-1 were implemented by procedure CP-QP-11.12. " Inspection of Installation of Radioactive Waste Management System." TUGCO, QA Dallas {

' scheduled this audit to ensure that the quality requirements of ETSB

,; ., No. 11-1 were being met.

The interviews and the record reviews conducted by the investigative team produced the following:

1.

The unique history of the RWMS caused some confusion, on the part of the audit team, regarding the appropriate quality ossification. f This was not r so ed until after the audit began, {

' indicated tha was unable initially to determine j e RWM was "Q" or "Non-Q". investigative team believes that question was motivated by Comanche Perk procedures which address stems on the basis of "Q" or "Non-Q". In reality, RWMS is "Non-Q" subject to special procedures to implement the quality requirements of ETSB No. 11-1. This was clearly stated in the FSAR and the reason for the confusion on the part of the audit team is not obvious.

2.

The audit itself started on a disparaging note when no Comanche Peak representatives met the audit team at the scheduled pre-audit raceting.

Apparently the pre-audit notification was filed without routing by R. Tolson's secretary. Ur. fortunately, the fact that the Audit team involved their management in the solution of the problem rather than resolving it locally appeared to be a source of irration to R. Tolson and prastaged further personality conflicts that impacted on the conduct of the audit.

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Early in the audit, the team identified the problem that welder '

identification were symbolt no longer which had been vibro-etched at the RWMS velds legible.

arose. A question of qualified we'1 der traceability j This problem had previously been identifled on NCR H-81-01680, 1 Revision 1, dated January 27, 1982. The disposition of this NCR allowed the acceptance of welds without welder identification symbols by QC inspectors on the basis that welder traceability was provided to at least line level by the Weld Filler Material Log (WFML).

A. Vega indicated he discussed with 'the team their initial concern reg.rding traceability and he advised them that a WFML was in i

~ existance for the RWMS. U1 tely, the team felt the NCR had been improperly d positioned by This position was cosamunicated y the audit team to .

Mr. Tolson.

It contributed to a considerable amount animosityconflicts.

personality among the individuals involved and fueled the existing 4.

. A. Vega indicated that as the team was unable to communicate the ,

exact nature of their findings and personal concerns to him, he spent four days of his time assisting them. During this period they f selected 12 QC inspection data points and indenti ied no blems l with any of them. In addition, he discussed wit I R. Tolson his personal concerns in this area and he condu and audit team. of the

5. The audit team indicated to and A. Vega that they were not receiving adequate QC assistance necessary for the performance of jy the field verificar* a portion of the audit.

initiati At QA management's a meeting between the audit team, R. Tolson, A. Vega, and was held in an attempt to resolve this concern aM the persona sty conflicts.

successful. The meeting was apparently not entirely The audit team did, however, subsequently contact Welding Engineering eceplete the and received the assistance they felt was necessary to audit.

6. A. E. Kesler wrot QA procedures, to ad submitted a draft report, in accordance with j A. Vega. Mr. Veg on t who approved it and forwarded it to i s of his familiarity with the audit determined were that the audit report summary and statement of findings unacceptable.

and findings. He made extensive revisions to the audit summary Mr. Vega directed that the marked up version of the )

draf t audit report be maintained for record in the audit file. A. Vega i signed the report summary and submitted it to D. N. Chapman. The report was subsequently issued.

7. was informed by made to the eport by Mr. ',eg hat extensive changes were x, pressed concern over this and was informed by t ould not have.to sign the final

, report and, if desired could document any disagreement by I

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[ writing a memorandum to file, on reviewing the final audit i

report felt it presented the au a team's findin incidents as opposed to gener* findings. @ gssubsequently as being isolated wrote a memorandum o file expressing tsagreement with the final report.

is no longer employe by T as Utiliti s. The investiga-tive t m c nducted the interview with ver the phone and mailed the material which had been given at resignst interviewees. )

departure, was not related to the radwaste audit. Prior t iscussed her position and the memorandum wit

. D. N. Chapa w

8. as asked b if he desired to discuss the

'reyssed au at report as asue . He ndicated that he had no desire to meet with QA management concerning this report.

The investigative team has formed the following conclusions concerning the above listed findings:

.. 1. The audit file for TCP udit team's raf t report 'as appears to be historically correct. The marked up by Mr. Vega is present.

memorandum is also present. The alterations to the report sunsnary and findings are obvious. There was no indication that QA management attempted to cover-up any of the changes made to the draft report.

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2. ' The principle concerns of the audit team regarding the traceability of qualified welders to specific weld joints and the adequacy of the QC inspection ef fort on the RWMS appears in the final report. The ,

repre remains open as QA management has not completed the ' evaluation of the corrective action submitted in response to audit findings.

3.

QA has no formal written policy or guidance concerning the documentation of differing professional opinions. Some individuals indicated they had received verbal guidance that dissenting opinions could be dor:u-mented by a memorandum to the audit file.

Other individuals made no mention of this and indicated they would document their position in their personal files.

i 4.

All The auditors expressed some knowledge of the events surrounding TCP

' TCP onsnents indicated that a great deal of partial truths regard xist within the audit group. This particular audit was the only example offered as one in which a cover- y have occurred.

With the exception of audit team members, TCP as referenced on the basis of inuendo and hearsay.

5.

All audit team leaders interviewed indicated that audit reporta are usually edited during the review process. Individual reactions to this varied from "no problem as they were normally editorial changes" to " serious problem as they of ten changed the intent of the report from that of the auditor to that of management". However, they all 4'

agreed that this was management's perogative. The report review I

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• process was also discussed with QA management. It appears that there is a difference in philosophy between QA management arJ some cudit team leaders. QA management takes a practical approach to the application of the quality criteria of appendix B. Audit team leaders who also adhere to this philosophy have no problems with the report review process. On the other hand, the purist philosophy of some audit team leaders is directly opposed to that of management.

This may be the source of their problems with the report review process. These team leaders often feel that they must go to great lengths to justify to their own management the validity of their

" findings. Apparently, QA management has not been able to convey their philosophy regarding Quality Assurance to all of the audit -

group members.

Based on the above, we have concluded there is no evidence to support the allegation that QA management had conducted a cover-up either of their own actions or of the identification of quality problems at CPSES.

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[ ALI.ECATION OF INTIMIDATION I

During the investigation in response to question 4 ("Are you aware of any other areas where you believe anyone indicated or took action that suggested you or anyone else should place quality secondary to other

= issues'such as cost and schedule?") and question 6 (" Finally, are there any other issues which you care to discuss that you feel adversely impact your ability to do your job?"), one _ of the persons being interviewed indicated a preference in having Clements contact him on these questions.

On the following day, Clements contacted the individual and was told that:

1. - During a radwaste audit certain people on site were difficult to get along with and the audit team couldn't get their cooperation. (NOTE:

This is discussed in the previous section.) '

2. i During an audit of inculation and non-ASME pipe supports, a certain person on sita indicated to some members of the audit team ine.luding the-team leader that if auditors work hard enough at finding problems and makiwg these known to construction type personnel, someone is

' going to get hurt physically or politically. A list of names was provided of those persons who wereJin attendance. Clements informed the individual that he~ intended to have the investig'acive' team

-f specifically get into this area. The individual agreed with this.

3 .Clements then informed the investigative team of what the individual' g had indicated. ~

All QA personnel in attendance at the insulation and non-ASME audit meeting as well as the person alleged to have made the intimidating statements at

. the aseting were interviewed.

Based upon the interviews, it appears that. the incident was precipitated when one of the members of the audit team, which'was conducting an audit .

of insulation and non-ASME pipe supports, was doing a field verification of a pipe hanger weld. The weld in question was on a pipe support and the weld had been accepted and signed off by QC. The auditor believed

'that there was excessive undercut and the length was in question. The auditor discussed it with the field engineer and QC inspector who both thought it met requirements, but told the auditor they would repair it to the auditor's satisfaction.

but he'd document what his opinion was in his t It@should rt.The beauditor noted told een tha that the auditor was not qualified to perform daual inspections but had attended a basic welding course.

During the exit, the person secused of making intimidating statements ~

entered the office and stated very strongly that he didn't want 44 Personnel telling craf t people to initiate repairs, and if they had any questions or concerns they should work through QC. He further stated

-(e, that craft people were uptight and could be fired for multiple problems j on their part and he didn't want QA people getting harmed physically or Politically because of their dealing directly with the crafts. This was addressed to the audit team leader.

' ' ' 1 ,,

. ; Pcge 9 of 12 !j

.S i

r, At this time, the member of the audit team who had been doing the field 4!

verification broke into the conversation and stated that he was the one who had talked to the crafts and he.had not asked that a repair be-K initiated but had only indicated that it would appear in the report. It s was put in the draft report, but the auditor indicated he later removed j it from the report but only after he asked qualified welding type personnel to review the quality of the weld and they stated the weld met the code requirements.f He indicated he had utmost confidence in the technical capability of these persons. {'

- "The interviews conducted by the investigative team produced the following:

1. The person accused 'of intimidation has a strong personality and all parties who.have had dealings with him indicate that his normal ~

demeanor in meetings and discussions is for him to come on strong and abrasive. Depending on the personality of whom he is dealing with, his manner could be considered intimidating.

,. 2. The person accused of intimidation is not hesitant to express his opinion to anyone. He can be very cure to individuals in whom he has a lack of confidence in the individuals capability or professionalism.

3. Re person accused of intimidation had a sincere worry about the i physical well being.of QA personnel if they dealc. directly with craft personnel on their findings.

.-<C 4.

The person accused of intimidation admits that he was very perturbed q . initially and could have been viewed as intimidating during the meeting. He was poeturbed because he had indications that craft personnel were being given direction by QA personnel. He admitted j

that there was an errar in comununications within his department on this point. Both he and the team leader raised their voices.

5. The person accused of intimidation feels there is a high probability

• of a QA person'being hurt by crafts if QA doesn't work through'QC on QA issues. He feels that he can't let anybody get hurt on the job and this is why he made the statement. Two QA personnel present also indicated that a statement was made that a QA person could be hurt

• politically. The person accused of intimidation stated that this was meant to mean that some auditors, in his opinion, are not professional and are not capable of making judgements on the significance of' problems.

, He has told his people to quit taking issue with QA personnel and wait until an audit report comes out.

6. %ere appears to be a clash of personalities between the team leader and the person being accused of intimidation. De team leader indicated he thought the remarks were made iir an intimidating manner.

,, 1

. j I

~

.. , .l Pega 10 of 12

'f

• The person being accused of intimidation believes that the team leader isn't satisfied with being an auditor, and alienates everyone that he comes in contact with.

I

7. The person accused of intimidation believes that if QA personnel are 1

expected to do field verification they either need help from QC people or have to be qualified in the -area they are verifying. ' This has been expressed to QA supervision.

4 8.

~ Of the five people in the QA group who were present during the

' discussion, two believed that the remarks were made in an intimi-dating manner. The other three indicated that the manner in which the statements were made was consistent with the individual's personality. The three also basically indicated that the discussion, has not impacted their activities and they will still contact con-struction people but will be more careful what they say to them so there will giving beorders.

direct no misinterpretation by craf ts that the QA group is Of the first two, one of them stated that based on the event he felt l i

that the intimidating manner of the person would cause him not to go to that pers w with a problem except as a last resort and he would make sure that he had "all his ducks in line" cr be blown out of the water. The other person, who was the team leader, stated that the remarks were made in an intimidating manner, but regardless, if given X a job to do he will do it.

-l what might happen to him inHe thealso said that he now is more awcre of field.

5"

9. One of the three persons discussed in 8. above who'said the discussion has not impacted his activities stated that he was aware of one other case of intimidation at the site. This was during an audit of a site subcontractor wherein the site subcontractor felt he was being intimi-dated by an audit team member. The particular audit team member is the same individual who is making the accusation that the non-ASME hanger audit team had been intimidated. QC supervision talked to QA supervision and the matter was straightened out.

10. After the meeting on the non-ASME hanger audit, the QA personnel involved discussed it among themselves. QA supervision does not feel that overall, it was intimidating to QA personnel. QA supervision did meet on the following work day with the person accused of intimi-dation and told him that if he had's problem with the conduct of an audit he should come to QA supervision to discuss it.

Based on the above, we have concluded that in spite of the intimidating manner in which the person usually c.onducts discussions and meetings, there was no direct effect of this on how QA personnel perform their QA responsibilities. There is every indication that they will continue to

( , , perform the duties assigned to them. QA supervision met with the person accused of intimidation and informed him that he had not conducted I %

w2

• l

Page 11 of 12 himself properly. The results of this meeting were not consnunicated.to any QA personnel to indicate what was accomplished and to clear the air of any rumors and accusations.

QA management has not provided formal written guidance on interfaces to be' adhered to during audits such as should Dallas QA personnel interface with site QC or with construction personnel on interpretation of findings.

Furtherinore, if the need for QA to perform field verification type audits is deemed necessary, then either QA personnel should be qualified inspectors or qualified inspectors should be made members of the audit team.

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-t, 4 Page 12 of 12 INVESTIGATIVE

SUMMARY

Based on our conclusions, as noted above, the investigative team found no evidence to support either an allegation of cover-up or intimidation.

Furthermore, when asked for. their opinion, all auditors stated they felt that the QA Program was accomplishing its goals and objectives.

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TEXAS UTILITIES GENERATING COMPANY (

F OFFICE MEMORANDUM '

f~

To___ D. N. Chaeman Dallas, Texas - Aueust 8. 1983

+1 5dject Investicati n f Rumors of Intimidation and Cover-up On the Part or Dallas QA Management

~ Within the last few days, I have learned that some Dallas QA personnel believe that their efforts have been constrained by management. This would be contrary to our Company policy and to our committaent to 10 CFR Part 50 ,

Appendix B which says in part " Persons and organizations performing quality assurance functions shall have sufficient authority and organizational freedom to identify quality problems, to initiate, reconnend , or provide solutions and to verify implementation of solutions."

Since the implications are adverse to our company policy and reflect unf avorably upon the mangement of the Quality Assurance Program, I have decided that an investigation is in order.

The investigation is to be performed under the direction of Mr. R. E. Kahler with the assistance of Mr. R. G. Spangler and Mr. C. S. Keely. Please inform all personnel in your department of the investigation and that members of the 4 investigative team will be in contact with them within the next few days to set

', up appointments.

V In addition, please inform your staff that the interviews will be conducted in private and that employee responses will'be held in confidence with respect to the identities of the individuals concerned. They should also be advised that if they have concerns about the subject of the investigation and do not wish to discuss them with the team members, they have the right and the responsibility to discuss those concerns, in confidence, with me or other senior TUCCO officials.

I would appreciate the full cooperation of you and your staff in the conduct of this investigation.

x&A

. R. Clements

, e BRC/pam .

)- cc: R. J. Gary S

R. E. Kahler J

Attachment 1

_ _ _ _ _ _ _ _ ._________m

.. ./. I TEXAS UT'LITIES GENERATING CO.TIPANY  ;

f~- OFFICE MEMORANDUM To Mr. R. E. Kahler Dallas. Teus _. Aurust 8. 1983 Subject Investicati n f Intimidation and Cover-uo i

On the Part of Dallas OA Management Within the last few days, I have become aware of a rumor concerning allegations by TUGC0 QA personnel that their efforts have been influenced by QA Management personnel. While I am confident that the management of the TUCCO QA Program has been carried out in accordance with the Company consnitteent to 10 CFR Part 50, Appendix B and with the Corporate Quality Assurance Program, I believe the existance 'of such a rumor warrants an insnediate investigation to determine if there is any substance to it.  !

As a result. I am requesting that you set up a team under your direction to conduct an investigation into rumors of intimidation and cover-up on the part of Dallas QA Management and to provide me a written report on the findings. If it appears that there are findings which would indicate a significant break down in the Quality Assurance Program, you will bring them insnediately to my attention.

During the conduct of the investigation please ensure that:

d'

, 1. All employees are scheduled for interview and advised that the s interviews will be in confidence.

2. If they are not comfortable in discussing the subject with the investigators, that they are advised that they have the right and responsibility to discuss their concerns with company officials.

3. If they do not wish to discuss their concerns with the management, they are advised that they have the responsibility and obligation to bring those concerns to the attention of the Nuclear Regulatory Commission.

l When you have completed your preparation for the conduct of the investigation, please brief me on the approach you plan to take.  !

j i

-r B. R. Clements

• BRC/pam

.1.'D -

=

d, - cc: D. N. Chapman R. J. Gary

- l l

Attachment 2 l l

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TEXAS UTILITIES CENERATING COMPANY r

OFFICE MEMORANDUM To D. N. Chapman Dalls ,. Texas - August 9. 1983 i Subject Investigation of Intimidation and Cover-up On the Part of Dallas QA Management -

I

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Please provide the investigative team copies of any documents or personal notes which you or your supervisors may be aware of and which may have bearing upon the subject investigation.

If copying these documents would present an excessive workload, please provide a list of the documents or notes and make the material available to the team for their review at a convenient location within your office area.

Thank you for your cooperation. l j

M J . ps/ % '

R. E. Kahler REK/pam i

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O e s

Attachment 3 '

l i

w--_____.--_______..- _

I _ Introductory Remarks 7 ,

'l.

1. Ascertain that the individual has a copy of th from

,,, Clements Chapman concerning the investigation.[e .memor,apdumJ e N et r et,. (o f'.

nm.

',2 .

6" The purpose of this investigation is to determine the truth of allegations made to the Vice President, Nuclear concerning possible cases of intimidation and cover-up by QA Management. Texas Utilities

,9' management considers the timely resolution and correction of these allegations to be of the utmost importance. Should the allegations be substantiated they will be reported per regulatory requirements to the Nuclear Regulatory Commission. Your cooperation during this investi-gation vill be appreciated.

~~

3. Replies will not be associated with individuals and only the investi-gation team wi).1 be aware of individual responses. The identities of

• individuals may be made available by the investigative team to the NRC should the allegations be reportable.

I

4. Notes will be made during the interview and are available for your

. review at the conclusion of our interview.

RGS/GSK j

s/9/83 i I

I i 'Q:) w Attachment 4

.3

, Questions l

' /*

1. Could you describe for us how you go about preparing for an audit once you are assigned to a team.

2. Could you describe the method by which you document your findings or. I

. concerns and how they are reflected in the Audit Report.

3. Has there ever been any occasions where any of your findings or concerns were altered by anyone else to make them appear less significant?

4 . Are you aware of any other areas where you believe anyone indicated or

,, took action that suggested you or anyone else should place quality secondary to other issues such as cost and schedulefCR h /4 M+b M H .s n W A clier t x hm M wp Q.(&

% i n - 4 s,f r-l< M .

5. Based on Yes replies to question 3 or 4, please define what took place.

• a) W o was person or persons who took such action?

i b) Did interviewee indicate disagreement with the person?

c) If so, in what form was the disagreement? (Verbal, documented?)

d) Wat was the persons reply and did the interviewee agree with the

. logic expressed'and the decision made?

e) If not, what further action did interviewee take?

f) Can you give specific audit examples?

g) Was your disagreement about specific issues or rather philo-sophical in nature.

6. Finally, are there any other issues which you care to discuss that you feel adversely impact your ability to do your job?

f

7. D r f h'1, uy pv 4.1 .irse.k

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_____-_______A

i Concluding Remarks hr .

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1. Ask if the individual would care to review the notes of the interview, -

2. Indicate that if there were concerns or issues which they did not feel L. free to discuss during the interview that they can make an appointment

, , with any member of the corporate chain from Mr. Clements to Mr.

.  ;. Brittain to discuss problems. Furthermore, if they are aware of

g probless'and do not want to discuss them with anyone at Texas Utilities then it is their right under NRC Form 3 to inform the Nuclear Regulatory Commission, Region IV - Cive Out Handout -

3. Thank you for your time and cooperation, if you desire to talk with us again you may call.

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1 r Handout Please be advised that it is the policy and desire of the Corporate Management of Texas Utilities to ensure that our Quality Assurance Program is ' conducted in compliance with all rules and regulations and under the highest possible standards of personal integrity. Toerefore, should you feel that events have occurred which are contrary to the above you are encouraged to discuss them with the investigative team. Bowever, you may contact the below listed Corporate Management in this regard. If, for some i reason, you do not desire to do this ycu should recognize that it is your right under NRC Form 3 to contace the Nuclear Regulatory Commission. .

Division of Inspection and Enforcement, Region IV. l Mr. B. R. Clements VP, Nuclear 653-4017 Mr. R. J. Gary Executive VP TUGC0 l 653-2921 Mr. M. D. Spence President, TUCCO

• 653-4620 Mr. P, C. Brittain Chairman, Chief Executive 653-4628 Officer, Texas Utilities

/

_U_SNRC Mr. G. L. hadsen Branch Chief,. Region IV (817) 860-8100 l

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ACTivlTV CODES L/M e LETTER 08 W E WO TC s TELEPHONE CALL susr e INSPECTION MTS

• WETING IMV a INVESTIGATION REP. a REPORT f 5 SUED OFFICIAL USE ONLY 00 NOT DISCLOSE t23 AIZ = T I S R ev. 2

k-NRC FORM 305 U.S. NUCLEAR REGULATORY COMMIS510N INVESTIGATION STATUD RECORD insinuations This form is to be completed wherever significant activity has occurred relative to a case or at least every 30 days, if no change has occurred during the 30 day reporting period, indiate "No Change" in the status block, Keep the origical with the use file and send one copy to Headquarters, Q Office of hvesugetions. j CAIfNU 85R CATEGORY OF FICE o . onR*Tsuo Ri4CToM i . moiv.ovat uCe~se. 01 FIELD OFFICE  !

Q4-84-050 , c g g o,cR . . . 1, R ,,c.,,uu REGION IV V . VENDOR X .OTHER ASSIONtD TO SUBJECT GRIFFIN COMANCHE PEAK STEAM ELECTRIC STATION:

STATUS (Specify dere, and sir fd17/ ,fjdfJiiddLiUn U[ IUbCO QA AU0iLOr5 vy TUGC0 QC Management On November 28, 1984, a former Comanche Peak Steam Electric Station (CPSES) Texas Utilities Generating Company (TUGCO) Quality Assurance (QA) auditor alleged that in the Summer of 1983 a TUGC0 Quality Control (QC) manager interrupted a TUGC0 QA auditor's meeting and threatened the auditors with " physical or political" harm if j they were persistent in conducting their audits in the manner which they have in  !

the past. The alleged stated that it was his opinion, and the opinion of the other audilun , ihai Lhe QC manager in questivn 'elieved v that-deficiencies which Lne audit group had identified were invalid. The alleger explained that he was intimidated and is of the belief that other auditors were intimidated.

ECD: Unknown DATE: December 31, 1984 - Anticipcte this investigation to be initiated during February 1985 time frame. ECD: Unknown DATE: January 31, 1985 - This investigation initiated the last week of January. Anticipate completion of this case during March / April 1985 time frame. ECD: Unknown DATE: February 28, 1985 - Investigation in progress. Anticipate completion f during April /May 1985 time frame. ECD: 3-05-85 ro A-8 P( 78 DATE: March 31, 1985 - Investigation in progress. Anticipate completion q during April /May 1985 time frame. ECD: 5-30-85  ;

G 7,

AtAu w CitC FO;M 306 U.S. NUCLE A3 RESULATO2Y COMMIS$f0N INVESTIGATION STATU3 RECORD susTauctions: Thi. vorm i. to b. compi t.d wh.n.ver .igmf :.nt .etiviiv h.. occurr.d r.i.tiv to e c. or et i. t ry 30 d.y.. et no ch.ng. h.. ocosrr.d during th.

30 d.y r.portsg p riod, indc.t. "No Ch.nge" in the st.tu. blod K.ep th. origin.i with the me. fit. .nd s.nd on. copy to H..dauerters, offic. of Investigations.

can ~uusia canoony omca

""'"*"""" ' "" '"' " ^ ' ' ' ' ' " " ' 01 FIELD OFFICE 4-84-050 -

c REGION IV y "lgga;ga c ___

u .uanainosievet V vtNDOR X OTHER

""dRIFFIN ' " ' '

COMANCHE PEAK: ALLEGED INTIMIDATION OF nn nunTTnx ny Tunen nr STATUS tSpecity dete, and omvial c hnef d cripthon) pgpgg gypp3y

'DATE: Aoril 30, 1985 - This case has been upgraded to an investigation. Field work for this investigation has been completed. Writing of the ROI in progress. ECD: 6/85 DATE: May 31, 1985 - Final draft of Rol has been completed and is being reviewed by 01: Region IV. Anticipate forward final ROI to OI:HQ in June 1985.

ECD: 7/85 DATE: JUNE 28,1985 - FORWARDED FINAL ROI TO 01:HQ ON JUNE 6, 1985 FOR REVIEW. ECD: 7/85 DATE: July 31, 1985 - Forwarded final ROI to 01:HQ on June 6, 1985 for review.

ECD: 7/85 DATE: August 30, 1985 - Final ROI at OI:HQ for final review. ECD: 9/85 DATE: Sept. 30, 1985 - Final ROI at OI:HQ for final review. ECD: 10/85 DATE: Oct. 31, 1985 - Case closed 10/15/85. Report delivered to the Regional Administrator on 10/17/85.

- JYM4A./

3 Fa'm 307 ALLEGATIEN DATA FORM . S. NUCLEAR REGULATORY COMMISSIO11 lu e ineen,ctions on o o.

RECEMNG OFMCE Dockst Number (if applicable)

1. Facility (les) involved: (Nemel (tt more then 3. or if "'f amanchn g W Seam tren 0 S O 4 & R generic, write GENERICI heMWc 3 d cM/ .O 5~ O 4 4 d>

i 8 Functi:nal Area (s) Involved: onsite health and safety (Check oppropnete be deel l operations construction offsite health and safety safeguards emergency preparedness ,,

other (specityl

3. Des:ription: I5 lE INISIflTtFll/ IEl l l l l l l l l I I I I I I I l

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4. S:urco of Allegation:

- (Check (ppropriate box) contractor employee security guard licensee employee news media NRC employee private citizen  !

organization (specifyl other (specifyl MM Do YY

5. D:ta Allegation Received: j g

6. N:ms of Individual (Firet two initions and teet namel i

R:c:iving Allegation:

7. Offico: g 7 g g ACTION OFRCE

8. Acti:n Office

Contact:

mrst two initiets and test namel

9. FTS Telephone Number:

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10. Status: Open, if followup actions are pending or in progress j tchack one, Closed,if followup actions are completed

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11. D:t3 Closed: } ,

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