ML20040D374

Transcript of Rl Cloud Associates Testimony by Ph Anderson on 811231 in San Francisco,Ca.Pp 104-114

ML20040D374
Person / Time
Site:	Diablo Canyon
Issue date:	12/31/1981
From:	Patricia Anderson ROBERT L. CLOUD ASSOCIATES, INC.
To:
Shared Package
ML17083A976	List: ML20040D364 ML20040D370 ML20040D374 ML20040D378 ML20040D380 ML20040D388 ML20040D393 ML20040D397 ML20040D402 ML20040D407 ML20040D408 ML20040D410 ML20040D413 ML20040D414 ML20040D416 ML20040D418 ML20040D419 ML20040D420 ML20040D423 ML20040D426 ML20040D429 ML20040D432 ML20040D436 ML20040D438 ML20040D442
References
NUDOCS 8202010232
Download: ML20040D374 (10)

Text

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1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY CO?dISSION 3

4 INVESTIGATION OF 5 DIABLO CANYON UNITS 1 5 2 6

7 INTERVIEW OF 8 PAUL H. ANDE RSO'I 9

10 Robert L. Cloud Associates 125 University Avenue 11 Berkeley, California 12 Thursday December 31,1981 13 C' The above-entitled matter came on for hearing, 14 15 Pursuant- to notice , at 3:0 8 p.m.

16 17 APPEARANCES:

I j 18 On behalf of the NRC Staff:

i OWEN C. SHACKLETON, JR. , Moderator g 19 j 20 PHILIP J. MO RRILL a

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! ERRATA SHEET Interview of Paul H. Anderson, December 31, 1981 The following correction should be made:

Page 5, Line 21 - Change til to until.

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The above correction was identified by Paul H. Anderson and

Owen C. Shackleton, Jr.

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hh 1 . P_ R Q q E_ E, D, I,1 g E 2 3:08 p.m.

3 MR. SHACKLETON: The date is December 31, 1981.

4 The time is 3:08 p.m. This is an interview of Mr. Paul H.

5 Anderson. Mr. Anderson is an engineer employed by Robert 6 L. Cloud & Associates, Inc. This interview is taking place 7 in the offices of Robert L. Cloud & Associates, Inc., at 8 125 University Avenue, Berkeley, California.

9 This is the second interview of Mr. Anderson and 10 he has already been sworn in.

33 Whe reupon ,

12 PAUL H. ANDERSON 13 was recalled as a witness and, after being reminded he was 14 still under oath, was examined and testified further as 15 follows :

16 MR. SHACKLETON: Do you also understand, Mr.

17 Anderson, that you have the right to have personal legal l 18 counsel necessary?

g 19 MR. ANDERSON : Yes, I do. That won't be j 20 necessary.

f 21 MR. SHACKLETON: Thank you. And again, I request i

f 22 and ask that you understand that we are asking that you keep t

j 23 your testimony confidential.

24 MR. ANDERSON: I understand.

25 MR. SHACKLETON: Very fine. Mr. Anderson, how

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1 h 1 long have you been employed with Robert L. Cloud & Asso-2 ciates, Inc.?

3 MR. ANDERSON: I joined Dr. Cloud's company 4 around November, 1980.

5 MR. SHACKLETON: And are you presently working 6 on the contract on the reverification program for the 7 Pacific Gas & Electric Company concerning their Diablo a Canyon nuclear power plant?

9 MR. NIDERSON: Yes. I've been involved with 10 this contract since it first came about, around October 11.

11 MR. SII ACKLETON : Were you involved in the prepar-12 ation of the October ~21, October 26, November 6 and November 13 12, 1981 draft reports which you people refer to as the 14 preliminary report?

15 MR. ANDERSON : Yes, I was.

16 MR. SHACKLETON: Were you involved in the revi-17 sion of the October 21, October -26, November 6 draf t a

j 18 reports?

g 19 MR. ANDERSON: Yes, I was.

O j 20 MR. SHACKLETON: What were the original instruc-fa 21 tions provided to Cloud employees by Dr. Cloud or by PG&E f 22 to perform the development of the report and the handling 3

g 23 of its commnts?

24 MR. ANDERSON: We received our instructions from 25 Dr. Cloud. Our basic instructions broke down various

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([h i responsibilities to examine the chain of design for various 2 aspects of the plant, breaking it dawn into different types 3 of buildings and et cetera. We formed a little internal 4 task team where each engineer or groups of engineers were 5 assigned the responsibility of developing the flow of 6 information and examining the existing qualification for 7 a number of these areas.

8 We first started out with the intent of searching i

9 thercorrespondence between PG&E and URS/Blume to determine i

p) what controls and what documentation existed. This would ,

y directly relate to the engineering correctness of the 12 analyses that took place. Our interface with PG&E was they 13 were to provids us with documentation as we required it.

k Now in the preliminary stages, from October 11 14 15 to October 21, we essentially set up office inside PG&E 16 in one of their conference roons and went through volunes

17 of file information, trying to document the things we were l 18 setting out to examine, to document exactly what had g 19 transpired in the design flow. One of the problens we had j 20 as far as information available is that this project is of l 21 a magnitude that there is obviously too much material to i

f 22 completely. assimilate in a short time. We utilized PG&E's 23 cognizant engineers to help us locate the specific documents 24 we were looking for at times.

25 Maybe I am saying too much. I don't want to sit 108-4

- _ . , _ . . _ ...__ r_ _. _ -_y . ...____ - _.- y . , . x,. _

x.

7 (h I here and ramble on.

2 MR. SHACKLETON: No. This is very helpful for 3 the Commission to understand exactly what the responsibil-4 ities were for your company and the procedures that you had 5 to follow and the interface that was required in order to 6 obtain the necessary information for your study. So please 7 continue .

8 MR. ANDERSON: Okay. Basically I am talking g about the research done in preparation for the first 10 draft, which is the draf t prepared on October 21. The n results of that draft showed there were several areas 12 which we had either found conflicting information docu-13 mentation or had not found sufficient information docu-C- mentation. In our first preliminary draft of the 21st 34 15 we tried to stay away fron any personal conclusions or 16 conclusions as told to us by PG&E engineers.

+ 17 What we did try to do is state the information j 18 we had received thus far, which sonetimes was incomplete.

g 19 From my own personal standpoint, the effect that seemed j 20 to have was to create a priority withi PG&E to supply us

! 21 with the information we needed. Up til then I could say i

f 22 that perhaps we hadn' t been given a real priority treatment 2

in all of the information we needed. When the October 21 l 23 24 draf t was given to PG&E a lot of these areas which we had 25 just been unable to find sufficient information, these (J

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( 1 areas were commented on by the cognizant PGLE engineers.

2 Now the engineers made several types of comments.

3 They either made comments to the effect of "there:is ~more 4 information and I will help you find this information" or 5 perhaps that is not my understanding of it". Now when 6 they made the comment that there is additional information, 7 we searched the information and, if we found it,,we utilized 8 it and documented it.

9 On the other hand, if someone were to say this to particular area :is just not true, our response was fine, 11 show me the documentation, such that the report of the 12 26th in affect reflected our gathering of a little more 13 info rmation. That is basically the only difference, to my

k. 14 recollection.

15 MR. SHACKLETON: Were all the verbal comments 16 that you received, were they documented? When I say verbal 17 Oomments I am referring to directions or requests or comments l 18 that related to requests for revisions.

g 19 MR. ANDERSON : Basically we had a surprisingly i  :

l j 20 little amount of verbal interface with PG&E. In the

\ a l 21 initial stage, from the October 11 to October 11, we were a

f 22 functioning as our own little self-contained task group I

i 23 and no one seemed to pay much attention to us. Indeed, that

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24 was part of the problem. From the October 21 and subsequent-l 25 work, we performed all of that work in our own office and i

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i 1 primarily formally interfaced through PG&E or interfaced 2 through Dr. Cloud. We had some level of informal communica-3 tion merely following up researching some of the areas"that 4 we had already identified in the first draft.

5 In the first dreft and I believe the subsequent 6 drafts we fairly across the board address all of the holes, 7 all of the areas of concern, either by providing substan-8 tiating documentation, which we should have on file, or 9 in the cases that we don't have enough information we have to stated either that this will have to be addressed in a more 11 detailed scope, such as the ser ;nd phase of the reverifica-12 tion program.

13 MR. SHACKLETON: What you are stating then, if I 14 understand you correctly, Mr. Anderson, these were made 15 open items.

16 MR. ANDERSON: Yes.

g 17 MR. SHACKLETON: Within your draft report.

l 18 MR. ANDERSON: And well defined as open items.

3 19 MR. SHACKLETON: Mr. Anderson, were you encour-j 20 aged at any tine or directed by anyone to change any of your a

la 21 original findings?

f 22 MR. ANDERSON: If you define a finding as somethin a a

j 23 that is wrong, certainly not.

24 MR. SHACKLETON: That's the main point that we 25 are looking towards, b

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h) 1 MR. AMDERSON: The only thing I micht add is 2 there were holes where we did not have information and, 3 in this case, PG&E encineers did make comments and did 4 request that we find the additional information and examine 5 it.

6 MR. SHACKLETON: In the course of writing your 7 sections of the drafts that we are discussing here, did c you ever make any changes without substantiating documenta-9 tion? I'm talking about substantive changes, not just in 10 grammar or punctuation.

11 MR. ANDERSON : I either had substantiative 12 documentation or I explicitly qualified the change, such

.. 13 as pending all subsequent investigation. The qualification

(- 14 would be in the report.

15 MR. SHACKLETON: I understand from testimony we 16 have received that this has been a very intensive effort

17 on the part of yourself and the other engineers here at

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l 18 Robert L. Cloud & Associates, Inc. Do you feel, Mr. Anderson, g 19 that your staff that you are associated with on this reverif--

j 20 ication study for the Diablo Canyon nuclear power plant,

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f: 21 that you have been able to work with a free hand and to f 22 freely express your true findings without any interference?

23 MR. ANDERSON: Within my own company certainly.

24 As a professional, I feel I would have to insist on freedom.

25 I wouldn' t be here if I didn't have the freedom.

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4.

(o j MR. SHACKLETON: Are you satisfied.then, Mr.

2 Anderson, with the contents of the preliminary report dated 3 November 12, 1981?

4 MR. ANDERSON: I am satisfied as to the validity 5

of the facts stated in the report. There are certain open 6 items which are qualified in the report as requiring to be 7 addressed later. There are itens which we did not get 8

enough information on that a subsequent program has been g developed to address. With that exception -- that has some to bearing on my overall impression of the first program, if 33 you can understand my point.

12 MR. SHACKLETON: Yes.

33 Mr. Morrill, do you have any questions?

g MR. MORRILL: Yes. Mr. Anderson, did you receive 15 any verbal comments fron people other than PG&E, such as 16 from Blume or Westinghouse or any of the other contractors'.

17 that you might have interfaced with?

MR. ANDERSON: We certainly had some level of l 18 g 39 interface with both Westinghouse and URS/Blume. As far as a

j 20 the type of interface where they cormented on the contents l 21 of our report or the things that we had found, I wouldn't say I had any of that type of interface.

f 22 23 MR. MORRILL: Thank you.

24 MR. SHACKLETON: Mr. Anderson, going back in 25 review of the questions that wa have asked and the resnonses k.

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( i that you have made, are there any comments that you would 2 like to add to your testimony?

3 MR. ANDERSON: Merely I would like to emphasize 4 or restate that I feel both personally and as a company 5 to have performed a conscientious job in ' preparing all the 6 reports, all the drafts of the preliminary report, and that 7 I feel upon scrutiny of the various drafts it should be 8 an obvious conclusion that the type of development occurring g through the drafts was an actual accumulation of information, 10 accumulationsof knowledge, and that is all.

ij MR. SHACKLETON: Mr. Anderson, is there any 12 additional information relating to this seismic reverifica-

, 13 tion study that you would like to make a matter of record 14 at this time?

15 MR. ANDERSON : I don't believe so.

16 MR. SHACKLETON: Mr. Anderson, on behalf of the

37 Commission, we thank you very much for your testimony here.

l 18 and the time that you have given to us. The time is now g 19 3:27 p.m., going off record.

n j 20 (End of interview) i j 21 i 8

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