ML20073J851

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Sworn Statements of Vh Tennyson & Re Roam Taken on Behalf of State of CA Re HP Foley Const Co Responsibilities at Plant, Including Electrical Work on Instrumentation.Certificate of Svc Encl.Related Correspondence
ML20073J851
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 04/05/1983
From: Roam R, Tennyson V
HOWARD P. FOLEY CO.
To:
References
NUDOCS 8304190428
Download: ML20073J851 (91)


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8 VIRGIL H. TENNYSON and RICHARD E. ROAM 9

10 11 l 12 13 Taken before BONNIE L. WAGNER 14 CSR License No. 5881-

_. 15 A Duly Qualified Notary Public-

'16 State of California .

17 18 19 20 April 5, 1983 21 g 22 23 1

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A P_ P E A R A N_ C_ E E ,

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3 .. YALE I '. JONES, Attorney at Law, representing the

-4 law offices of' JONES, BROWN, CLIFFORD & McDEVITT, 100 Van Ness 5 Avenue, 19th Floor, San Francisco, California 94102.

ie 7 SUSAN L. DURBIN, Deputy Attorney General, represent-

.8 ing the office of the ATTORNEY GENERAL, 3580 Wilshire Boule-9 vard, Los Angeles,-California 90010.

.10 11 PETER H. KAUFMAN, Deputy Attorney. General, repre-12 senting the of fice of the ATTORNEY GENERAL, 3580 Wilshire L

13 Boulevard, Los Angeles, California 90010.

14

- 15 ---ooo---

16 17 VIRGIL H. TENNYSON a_nd RICHARD E.-ROAM, 18 having been first duly sworn by the Notary Public ,

i 19 to testify the truth, the whole truth, and nothing  !

l 20 .but the truth, testified as follows:

21 l .

! .. 22 MR. KAUFMAN: On the record. My name is Peter 23 Kaufman and I'm a Deputy Attorney General with the State i

24 of California.

25 I have with me today Susan Durbin from the Attorney 26 General's Office as well. We're here on behalf of Governor 27 George Deukmejian as part of our role in representing him

  • ~

28 and the State of California in the ongoing Diablo Canyon JACK EG AN REPORTING SERVICE see anno **erno carve

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3 1 licensing proceedings.

2 One of the principal issues involved in those pro-3 ceedings is quality assurance in the construction of the r 4 Diablo Canyon plant. In reading press accounts of the con-5 struction of Diablo Canyon we became aware that you gentlemen 6 had a role in quality assurance at the plant.

o 7 We would like to ask you some questions today about 8 your job with The Howard P. Foley Construction Company.

9 Why don't you state your names for the record, first.

10 MR. TENNYSON: Virgil H. Tennyson.

11 MR. ROAM: Richard E. Roam.

12 MR. KAUFMAN: Both Susan and myself will be asking 13 you questions.

14 I think I will take the lead in asking these ques-

-- 15 tions and Susan may step in from time to time where I falter.

16 The questions I ask I will ask of both of you and 17 you can decide amongst you whether you want to answer each 18 question separately or you can come to a consensus answer 19 or you can elaborate on an answer that either one of you gives.

20 MR. JONES: Why don't we, as a matter of procedure, 21 have Virgil answer primarily since he was the senior person 22 there both in terms of posi tion and years of service and then 23 if Mr. Roam has anything to add, he can go ahead and indicate 4

24 to you that he wants to indicate something.

25 Also, if you have direct information or direct per- .

26 ceptions that Virgil didn't have, then you pipe in.

27 MR. ROAM: Okay.

28 MR. KAUFMAN: Mr. Tennyson, let me ask you first, JACK EG AN REPORTING SERVICE see annowME Ao on:vt LAFAYETTE C ALaPORM A 9454 9 8415i 283-3172 a

4

1 - as a preliminary matter, what is your occupation?

t 2 MR. TENNYSON: I was the. quality manager, both '

.s.

3 quality controlDand quality assurance..for a few years at '

) 4 Diablo.

5 MR. KAUFMAN: How many years was that?

6 .MR. TENNYSON: A total of nine years that I was 7 with the company.and eight of those years was as quality con-e 1 8 trol and quality assurance. ~

'9 MR. KAUFMAN: So you began working at Diablo at i

10 what time?

11 MR. TENNYSON: February 4th, 1974.

12 MR. KAUFMAN: At that time what was your position?

13 MR. TENNYSON: I was hired as a quality engineer.

14 M R .' KAUFMAN: And you advanced to the position you i

4

, , , 15 last. held?

16 MR. TENNYSON: Yes. I advanced to chief inspector 17 and then to quality manager which was quality control manager 18 at that time.

19 MR. KAUFMAN: Before I ask you what each of those 20 entails, what. positions have you held prior to that time, i 21' prior to your working with Diablo?

. 22 MR. TENNYSON: I worked with Litton Industries in l

i 23 the ship building portion of the company as sort of a quality s

j 24 engineering coordinator which encompassed. reviewing all the t-25 purchase documents that were to go out for bids prior to them

, 26 being let out to a company to insure that they had all the 27 quality requirements within them. It was in coordination 2d with engineering quality assurance and all of that.

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5 1 MR. KAUFMAN: liow long were you employed with 2 Litton?

v 3 MR. TENNYSON: A total of about a year. ,

4 MR. KAUFMAN: And before that?

5 MR. TENNYSON: I was with Todd Shipyard for about j , 6 13 years, approximately.

7 I went to Todd as an electrician and then advanced e

8 to management over the electric shop and fabrication and did 4

9 some engineering and was awarded a quality control stamp from 10 the Quality Control. Department at that time.to stamp and 11 inspect material through the shop going to the ships to be 12 built which was on Navy vessels and civilian.

l 13 .MR. KAUFMAN: Thank you.

14 Mr. Roam, can I ask you the same series of questions.

15 When did you first start working at Diablo?

16 MR. ROAM: First started working there in July or 17 August of '73. Then I left in August of '74 after I brought 18 Virgil Tennyson.

! 19 In between I spent several years at different jobs.

I 20 You want them too?

21 You know, I worked at Diablo twice.

. 22 MR. KAUFMAN: So you left in '74 and when did'you 23 come back again?

i *

.- 24 MR. ROAM: Come back about August 24th of '82.

25 MR. KAUFMAN: Why did you come back?

26 MR. ROAM: Why?

27 MR. JONES: I don't think that is relevant .

28 MR. KAUFMAN: All right. I'm just curious.

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_1 You were in a_ senior position in '747 -

2 MR. ROAM: Yes.

3 MR. KAUFMAN: What was your position at that time?

4 MR. ROAM: Assistant manager.

5 MR. JONES: Quality?

,- -6 MR.. ROAM: (Witness nodding.)

7 MR. JONES: She cannot take down nods of the head.

8 You have to use words. '

9 MR. ROAM: Oh. Assistant manager quality control, 10 yes.

11- MS. DURBIN: What was your position at Diablo just 12 until recently?

13 MR. ROAM: Well, until recently it was assistant -

14 manager quality control working under Virgil Tennyson.

'-- 15 MR. KAUFMAN: What are the Foley Construction 16 responsibilities at the Diablo Canyon plant?

17 MR. TENNYSON: They are subcontracted by PG&E as 18 the general contractor.

19 They were up until, I would say, around '77 or some-20 thing-like that, they were just an electrical contractor.

' 21 Since that time they have acquired the tail ends 22 of contracts of Guy F. Atkinson which is a structural steel 23 builder out there and Ss0 Corporation which was the instru-s 24 mentation group. Also from W. Becker which was mechanical, 25 you know, pumps and things of that nature.

26 MR. KAUFMAN: So from '78 on the Foley Company was 27 doing the electrical work at the plant for some or all of 28 instrumentation?

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7 1 MR. TENNYSON: All of the instrumentation.

2 MR. KAUFMAN: All of the instrumentation?

3 MR. TENNYSON: With the exception of what PG&E might 4 do on its own out there and their operations group.

5 I guess Foley was exempted from some of the work

, 6 and it depended on management deciding what was to be put 7 or let out to the Foley Company to work on.

8 MR. KAUFMAN: Well, can you give me an example of g some of the instrumentation that Foley was responsible for?

10 MR. TENNYSON: Can you, Rick, name anything right 11 off the top of your head?

12 MR. ROAM: What we was working on when we left was 13 the rivulet system for Unit 1 and Unit 2.

14 MR. KAUFMAN: Can you tell me what that is?

- . - 15 MR. ROAM: No, I couldn't, to tell you the truth.

16 MR. TENNYSON: It was a little hard for the quality 17 control and quality assurance department to determine certain 18 systems out there due to the fact that we had procedures which 19 told us how to inspect a certain joint or configuration, things 20 of that nature.

21 We did not file our documents or we did not document

. 22 things per a system. So it was a little hard to tell exactly 23 what system you were working on at all times because the paper-s 24 work that the engineers -- well, the engineering section would 25 be able to take you and lead you right into a system and tell 26 you when they would complete a system but Foley QC department 27 could not do this.

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1 documentation being separate in the file and we didn't put 2 it together as a system.'

3 MS. DURBIN: You were working to inspect various 4 components or various systems without really understanding 5 the working of the system you inspected?

, 6 MR. TENNYSON: Yes.

7 MR. KAUFMAN: All right.

8 MR. ROAM: Well, if you're through with that I was 9 just going to say the other system we were working on.

10 MR. KAUFMAN: Why don't you.

11 MR. ROAM: The other system was our modifications 12 and design changes that were created due to safety changes 13 from other plants.

14 MS. DURBIN: In other words, you were kept updated s_ 15 and if something didn't work over at one plant you would change 16 that so you wouldn't have that same problem at Diablo?

17 MR. ROAM: That was basically it.

18 MR. KAUFMAN: That was for instrumentation?

19 MR. ROAM: Yes.

20 MR. KAUFMAN: So the Foley Company was doing the 2* work mandated by the Nuclear Regulatory Commission, the correc-

  • 22 tion work mandated by the Nuclear Regulatory Cow '.o n , as 23 far as instrumentation was concerned?

s 24 Would that be a fair characterization?

25 MR. TENNYSON: Through PG&E. We didn't work with 26 NRC or anybody else. They might have communicated that to 27 pG&E and PG&E would redesign something or say, " Change this."

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.1 took our directions f rom l'C&E. -

2 MR. KAUFMAN: You were working on change orders 3 then?

4 MR. TENNYSON: Right.

5 MR. KAUFMAN: There was an instrumentation system 6 there and Foley was going in and changing an existing system?

7 MR. TENNYSON: Correct.

8 MR. KhDFMAN: Is that correct?

9 MR. TENNYSON: Yes.

10 Also the installation of new systems too, such as 11 the rivulets. Some of them were changes. Some of them were 12 for new systems.

13 MS. DURBIN: I'd like to ask a couple questions.

14 I'm interested in what you said about taking over 15 the tail ends of various people's contracts.

16 What did you mean by that?

17 MR. TENNYSON: Well, it was like Guy F. Atkinson 18 more or less completed the big portion of their work but there 10 may have been outstanding smaller portions of work to pick 20 up like a few minor modifications or just anything that would 4

21 have to be done.

.' 22 It would be impossible for a company to kind of 23 close out their books and their records and not have something s

24 outstanding.

25 What I mean by that is there may have been little 26 platform changes or things that PG&E maybe had not gotten 27 any design or engineering done on it prior to the contractor 28 moving out of his position and someone would have to pick J ACK EG AN REPORTING SERVICE see aseownsao Omevt L A, AV E T TE C ALIFORNI A 94 54 D se t SI 2 8 3-3172

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2' I-don't know how this came about but our company,

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3 ' evidently, was awarded what we call the " cleanup contract" -

4 to clean up the tail ends of other various types of work.

5 MS. DURBIN: I'see.

6 Had Foley had much experience in the past in doing 7 work on structural steel contracts?

8 .MR. TENNYSON: That I really could not tell you.

9 MS. DURBIN: How about instrumentation contracts?

10 MR. TENNYSON: I know nothing about roley other

-11 than being connected with them at Diablo Canyon.

12 MS. DURBIN: I see.

13 MR. TENNYSON: So 1 couldn't really say what they 14 were involved in or capable of prior to that.

-- 15 MS. DURBIN: Let me ask you something else. It 16 sounds like to me that most of your prior past experience 17 has been in the electronics field for --

18 MR. TENNYSON: No.

19 MS. DURBIN: That is not correct?

l 20 MR. TENNYSON: No.

21 MS. DURBIN
I'm sorry.

j . 22 MR. TENNYSON: I did work electronics, electrical

- 23 shipboard and in the aircraft company.

l l.

24 Also I worked structural with Todd Shipyard fQr r

25 many years in designing and angineering the installation of 26 equipment, foundations, inspecting, welding, things of this 27 nature.

28 I have had numerous years of structural steel, you I

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11 1 might say, because on ships there is quite a bit of it and 2 also with structural aircraft. I worked for Douglas. .

- 3' 'MS. DURBIN: And I assume the same would be true 4 of pump systems tha,t Foley was working on in Diablo. Had 5 you worked with pumps before?

  • 6 MR. TEENYSON: Yes, installation of pumps, valves,.

7 piping, small tubing.

8 Yes, I think I was very familiar with that.

9 MS. DURBIN: Were you inspecting anything at Diablo,

. 10' any types of systems with which you had not worked before?

11 MR. TENNYSON: I would say no, th'at I had been 12 familiarized with most of the things that I was involved in 13 due to the --

14 Well, I was in the Air Force for four years and

_ 15 I had an extensive training course in A&E which covers all 16 that.

17 MS. DURBIN: You'll have to tell us what A&E is.

18 MR. TENNYSON: Aircraft and engineering mechanics.

19 I completed the school during the four years in the service 20 which covered hydraulics, pneumatics, instrumentation, 21 electrical and skin, you know, fabrication of the plane.

~

22 So I was familiar with it even'though maybe I hadn't 23 had " hands- on" in some areas.

24 MS. DORBIN: Your experience seems very broad.

25 Were the other inspectors, the people who worked 26 for you at. Diablo, similarly qualified or were people inspect-  ;

27- ing things with which they had no previous experience or

~

28 familiarity with?

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12 1 MR. TENNYSON
Well, I would say that there must

~2 have been some situations where people were involved in their

. 3 inspection that had no prior experience in it other.than the j 4- training period we might have put them through'.

5 MS. DURBIN: Is that your experience? Did you ever.

1 , 6- have that experience that you were working on a system you 7 had no previous familiarity with or types of equipment with i . .

8 which you had no familiarity about?

9 MR. ROAM: Me?

10 No, most everything I've touched at one time or 11 another.

12 MR. KAUFMAN: Now, you indicated earlier that you 13 had three positions as engineer, chief inspector and quality

14 . manager.

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-- 15' What's the full hierarchy of that, if you understand J '

16 my question, starting from the bottom to the top?

17 MR. TENNYSON
Rick, why don't you start. You 18 started in the very beginning of '73 and take it through that 19 portion as to who you were working for, what you did.

20 MR. JONES: 'Do you want to go off the record for 21 a second? Maybe I can save some time here.

-: 22 MR. KAUFMAN: Yes.

23 Off the record.

24 (Discussion off the record.) ,.

1 26 MR. KAUFMAN: What is the entry level position in i 26 your department?

27 MR. TENNYSON: You mean, as far as qualification 28 or requirement to become an inspector?

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13 1 MR. KAUFMAN: Well, is an inspector the -- I guess, 2 for want of a Latter term -- the lowest position in the

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3 . quality control department?

4 MR. TENNYSON: Well, we tried very hard to set up 5 a program and did have it set up to have a trainee inspector

. 6 trained.

7 When I would bring a trainee in we would put them 8 with a qualified inspector, one that had been in the field 9 enough times where we felt that they could handle their job 10 properly out there and do the procedure well enough.

11 We always tried to indoctrinate a new inspector 12 or a trainee, you might say, with the proper procedures and 13 procedures that you would expect and put them with a qualified 14 person in the field until we felt they were ready to go on 15 their own in the inspection field.

16 MR. KAUFMAN: What kind of background did you look 17 for in hiring a trainee or in undertaking to train someone?

18 MR. TENNYSON: In some cases we really didn't have --

19 we didn't have any background search on it.

20 Numerous times someone was just brought into the 21 office and they said, "This is going to be a new inspector 22 for you."

23 I would put them to work after a little questioning 24 to find out where they were best fitted and I tried to work 25 them into the areas that I could work them into, as best I 26 could.

27 MR. KAUFMAN: Who would bring these people into 28 the office for you?

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l 14 1 MR. TENNYSON: That would be my project manager wh'o '

2 was my boss, Skip Moses. f i.

MR. KAUFMAN: These were other workers within the

~

3 4 Foley Construction Company?

5- MR. TENNYSON: No. They would be new hires from

.- 6 various places.

7. Foley did bring in some of their own people: Sons, 8 daughters, things of that nature, from the Martinez office 9 and they would be brought in and used in various positions.

10 MR. KAUFMAN: Did some of these people have no 11 previous construction background?-

12 MR. TENNYSON: It would be hard for me to say at 13 this point. Sometimes I didn't even see their application 14 or resume or whatever, if they had one.

s- 16 That went straight to the front office file and 16 they were given to me to train and make an inspector out of.

17 MR. KAUFMAN: What were the qualifications for an 18 inspector?

19 MR. TENNYSON: There were no written procedures 20 as to what qualifications had to be.

21 I was told numerous times that we were not trying

- 22 to hire the inspectors in accordance with the ANSI 4526 docu-23 ment or in accordance with 10 CFR 50 because we were not 24 obligated, evidently, to those documents at that time.

25 MR. KAUFMAN: That was at what time?

+ 26 MR. TENNYSON: Well, that was during, I would say, 27 hiring up until the last year and a half or so.

28 MS. DURBIN: Until 1982?

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4 15 1 MR. TENNYSON: Up until approximately that time, 2 yes.

3 MS. DURBIN: You'll have to forgive us for-our ,

4 ignorance.

5 What is that ANSI document, whatever, that you

. 6 referred to?

f 7 MR. TENNYSON: Your ANSI doct ments are the more

-8 pronounced versions of the 10 CPR 50 which is your 18-point 9 criteria for building of a nuclear plant.

, 10 MS. DURBIN: So the ANSI requirements are published 11 by the Nuclear Regulatory Commission?.

l 12 MR. TENNYSON: I'm sure it is.

1 13 The plant inspectors were to be qualified to certain 14 levels or degree of levels by ANSI 4526 and your audit team,

'~

15 which is an audit of your quality assurance group, were to 16 be qualified to' ANSI 45223.

17 Wasn't it, Rick?

18 MR. ROAM: Yes.

19 MR. KAUFMAN: What is your understanding of the 20 specifics of those requirements?

21 MR. TENNYSON: Well, up until, like I say, approxi-22 mately the last year and a half, until we started getting

  • 23 audits from Pacific Gas & Electric's OA team who, at tnat j4 24 time, Mr. Dick Twitty was in charge.

25 Well, we were really not complying with the AMSI 26 -

26 requirements because we were told by Pacific Gas & Electric _

27 that we didn't have to.

28 MS. DURBIN: Who told you that?

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16 1 MR. TENNYSON: Well, this was numerous times from 2 the beginning since I went to work in '74.

s-3 Everyotime it would come up through the QA depart-4 ment, "Should we level our people?" Well, we would mention 5 ANSI 26 and we would mention Appendix B of 10 CFR 50.

6 Well, it was either by PG&E inspectors or by their 7 resident engineer up there, who was a coordinator with us 8 between PG&E add the Foley Company.

9 It was by word of mouth that we were not subject 10 to all of those rules and regulations and that PG&E would ,

11 tell us what portions of it we had complied with and they had 12 the option to comply with the rest of it.

13 MS. DURBIN: Who was the most recent resident 14 engineer who told you something about that? Do you have a

~

15 name?

16 MR. TENNYSON: That would be Mr. Don Rockwell.

17 MR. JONES: Do you want to add something, Rick?

18 MR. ROAM: I was just going to say that in 1974 19 when we first started the program Virg and I and the others 20 tried leveling people, ABC-type inspectors.

21 MS. DURBIN: Could you explain to us a bit more 22 what " leveling" means?

23 MR. ROAM: In other words, more qualified inspectors.

24 In other words, you got a trainee like a D or an E inspector 25 and after a certain amount of time, testing and checking out 26 then we can level him to A, B or C or D-type inspector.

27 In other words, he's qualified to do certain types 28 of inspections and only those. After a cert 7in period of JACK EG AN R EPORTING SERVICE se e AnnoWMEAD DRIVE L AFAV ETTE C ALIFORNIA 94549 14 t S e 2 8 3 317 2

17 1 time,;he can go to another step.

2 We started that and what it was, if PG&E - .well, 3 we'wfote it ~into a procedure and if they didn't like it they 4 would take it out of the procedure.

5- This was one of the ways of telling us what we will -

6; 'and will not have to do.

7 See, like Virg said, sometimes in the process of

. 8- saying, "Well, we don't want you to do'something."

9 Instead of coming out and telling us they would 10 write a new procedure. That's one way how they did some of 11 that.

12 MS. DURBIN: Were you ever dissatisfied, 13 Mr. Tennyson, with the performance of any of the employees 14 that were presented to you as opposed to the ones that you

-- -15 had hired yourself, the ones whose qualifications you really 16 couldn't check on?

17 MR.' TENNYSON: I don't think I could honestly answer 18 that.

19 MS. DURBIN: Okay.

20 MR. TENNYSON: No more so than any of some of the 21 others I might have brought in myself.

22 But that's kind of a general thing.

23 MR. KAUFMAN: Off the record for a second.

. 24 (Discussion off the record.) - -

1 25 MR. KAUFMAN: Back on the record.

i' 26 You indicated that until recently you were not 27 qualifying inspectors to the standards set forth in Appendix B 28

[ of the Nuclear Regulatory Commission's regulations for quality J

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1 assurance.

2 What standards were you using prior to 1982?

3 MR. TENNYSON: If I may correct you on that.

4 Really, other than 10 CFR 50, Appendix B require- ,

5 ments, it would have been ANSI 4526 which would be your

, 6 leveling of your personnel. 26 for quality control people 7 and 223 for quality assurance auditors, lead auditor and so 8 on.

9 MR. JONES: I think what he's asking you though, 10 before that point in time where you started in the last year 11 and a half complying with those regulations, what standard 12 did you use to guage the experience of new hires?

13 Is that correct?

14 MR. KAUFMAN: Correct.

15 MR. JONES: Or did someone else do that for you?

16 MR. TENNYSON: I had to more or less base, I guess, 17 my opinion based on the supervision that I had over those 18 personnel to keep me filled in as to whether they were quali-1? fying properly or not, if they could handle the position that 20 we had put them in.

21 There was no written procedure or basic steps that

. 22 you had to qualify to other than your documentation was to 23 be filled-out properly and you knew your procedure, you

, 24 inspected to your procedures.

25 MR. KAUFMAN: Would it be fair to say then you based ,

26 it on your judgment?

27 MR. TENNYSON: Yes.

28 MR. JONES: And I think you said the judgment of J ACK EGAN REPORTING SERVICE see AmmowwE Ao onive L AF AYETTE C ALIFORNI A 9454 9 64150 283 3172 h

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'1-the supervisory people working for you?.

2 MR. TENNYSON: Right'.

3' MR. KAUFMAN: The next position above inspector 4 is what?

, 5 MR. TENNYSON: Supervisor.

6 MR. KAUFMAN:

~

And let me ask the same question about f.

7 .

that: Did you apply similar judgment standards as to the 8 qualifications for supervisors?

9 MS. DURBIN: Before 1982?

10 MR. TENNYSON: .Yes. It was pretty much the same 11 as qualifying inspectors.

12 MR. KAUFMAN: How many years' experience did super-13 j- visors have as a rule, if you can answer?

14 MR. TENNYSON: Some not too many.

i 15 MR. ROAM: A lot of it deals with the fact that 16 you only get what you pay for.

17 If you give a guy seven, eight dollars an hour you 18 ain't going to get anybody with any experience. The person 19 with experience is going to go down the road and get fifteen, 20 twenty dollars an hour.

21' That was one of the handicaps we had. There was

. 22 no judgment.really on salaries.

' 23 We had a maximum of -- what did I hire in at?

24 Well, I think it was $9.83.

25 MR. TENNYSON: $9.86, I think.

26 MR.-ROAM: Yes. That was top wagus.

27 MR. KAUFMAN: 'How much were the people whose work l 28 you were inspecting, how much were they making?

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, .-e - - , -, n - e ,,-

20 1 MR. JONES: You mean like welders and craftsmen?

2 MR. KAUFMAN: Correct.

3 MR. TENNYSON: With benefits some, on an average 4 of $20 an hour or more.

5 MR. ROAM: Better than twenty plus a per diem.

. 6 MS. DURBIN: You indicated that salaries you were 7 hiring people in at were not up to some other companies' t

8 salaries.

9 Were they up to an industry average based on your 10 experience?

11 MR. ROAM: Everybody wanted to switch and go to 12 work for Pullman. They were making about $15.45 an hour or 13 so.

14 MS. DURBIN: And Pullman was working where?

s- 15 MR. ROAM: At Diablo.

16 MS. DURBIN: At Diablo?

17 MR. ROAM: Yes.

18 MR. TENNYSON: During this time, speaking on this 19 salary range here, during the time the big push on the modi-20 fications came out there, we could not hire inspectors nor 21 make supervisors fast enough to cover the influx of welding 22 personnel, iron workers and other craftsmen that were in the 23 field. ~

24 The quality department was so small at that time.

25 They were hiring a hundred, like a hundred or a hundred and 26 fifty a day of iron workers alone and in trying to put a 27 program together to get the quality -- well, the quality 28 control department was responsible for qualifying these JACK EGAN REPORTING SERVICE see Ammownt AD Daivt L AF AY ETT E C ALIF ORNIA 9 4 54 9 141Ss283 3172

21 1 particular welders.

2 In trying to get enough people in the field to do 3 all of these functions plus cover the everyday work that we 4 had already been saddled with, well, you had a lot of inexper-5 ienced people out there, inasmuch as inspectors. I mean, 6 they were just not used to that kind of pressure and push 7 and the enormous amount of people that were calling them for 8 inspections.

9 We had to call in a subcontractor by the name of 10 Cataract.

11 Cataract started sending in --

12 MR. KAUFMAN: Excuse me. Is that spelled like the 13 eye cataract?

14 MR. TENNYSON: Yes.

__ 15 Cataract started sending in people to us.

16 I know nothing of the contract negotiations or any-17 thing or how this came about. This was all taken care of 18 by Skip Moses.

19 But the people started coming in to me with a 20 certification paper that qualified them, leveled them to an 21 ANSI 4526 level.

22 These people were put into the field with a very

.* 23 brief indoctrination period and were to start inspecting iron

' - 24 workers' weldments and other various functions out there.

25 MS. DURBIN: We'd like to really ask in detail about 26 that period.

27 When did the " big push," as you described it, begin?

28 MR. TENNYSON: Let me finish first about what Rick i

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22 s

1 was tal' king aboutLconcerning wages and it may explain a little 2 bit about the disgruntled personnel out there.

3 I was sitting there myself making $21.80 an hour.

4 Rick, as a supervisor,~ was making 15.

5 MR. ROAM: 15.50. i i

6 MR. TENNYSON: 15.50 an hour and we h'ad this l

7 Cataract Corporation sending in inspectors to us who were  !

8 .relatively new people.  !

9 They had to be broke in, indoctrinated and so on.

10 They came in with a rate of 15.50 an hour paid by our company. ,

11 MR. ROAM: Plus 27.50-per diem.

12- MR. TENNYSON: Was it 27.50 a day per diem?

13 MR. ROAM: Something like that.

. 14 MR. TENNYSON: These men came in new. We had to 15 put them with an experienced inspector that had been in the 16 field prior to them coming in.

17 It wasn't long until the word got around the 18 tremendous amount of wages that Cataract was making versus 19 the wages that our own Foley people were making.

20 We had quite a problem with that in trying to deal 21 with it because the people were very upset.

. 22 MR. KAUFMAN: I can imagine.

23 MR. ROAM: Same way with me. Here's a guy that's 24 an inspector and I'm supervising him, telling him what I need 25 to have done.

26 IIe's making more than me and I'm the one getting 27 chewed up every time something goes wrong.

28 After a while you just say, "Well, what's the use,"

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i 23 I 1 you know.  ;

2 MR. KAUFMAN: What kind of ratio of inspectors to ,

l 3 workers did you have in 1973? Do you recall?

l 4 MR. ROAM: 1973 when I went there, I think, I was  !

i I

5 the fourth person.  !

l 6 There was a manager, assistant manager, two or three l 7 inspectors, something like that in 1973.

8 MS. DURBIN: Inspecting how many people's work?

9 MR. ROAM: Well, at that time all we had was 10 electrical. It must have been two or three hundred electri-11 cians.

12 MR. KAUFMAN: And that ratio continued for how long?

13 MR. ROAM: Until 1974, first part of '74 when the 14 AEC performed their first audit on Diablo Canyon.

15 As I understand it, they told PG&E to shape up.

16 Basically it was the fact that there was no real effective 17 quality program at Diablo Canyon in the electrical aspect.

18 I understand, as was told to me, that they gave 19 supposedly Foley 30 days to write a quality program, develop 20 a quality control program, implement some program or they'd 21 be removed from the site. That was the first part of '74.

, t 22 That's when I called Virgil and a few of the other 23 guys I knew of and we sat down and started developing a 24 quality control program.

25 MR. KAUFMAN: At that point, Virgil, when you came 26 on how many people did you bring with you?

27 MR. TENNYSON: No. I didn't bring anyone with me.

28 MR. KAUFMAN: How many did you bring in?

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o 24 1 MR. JONES: liow many came on with him, would be 2 a better question.

3 MR. ROAM: I hired him.

4 MR. KAUFMAN: All right.

5 MS. DURBIN: liow much did the staff expand at that 6 point?

7 MR. XAUFMAN: I knew he left in '74.

8 MR. ROAM: I left about the end of '74.

9 MS. DURBIN: llow much did the staff expand at that 10 time? An estimate is fine.

11 MR. TENNYSON: Some of those records that you have 12 there might show.

13 Was there an old crganizational chart with them?

14 MR. JONES: No.

1b MR. TENNYSON: None that old? Well, I don't think 16 my department ever was over 45 people.

17 MS. DURBIN: So it increased perhaps tenfold?

18 MR. TENNYSON: Yes.

19 MR. JONES: No. That's not right. That would be 20 up to 400 when you left.

21 MR. KAUFMAN: Well, prior to 1974 there were four 22 people in the quality control department and now we're at --

23 MR. JONES: You got up to 45. When did you jump 24 from 40 or 45 to over a hundred that they were when you left?

25 MR. TENNYSON: That was in '82. December, October, 26 November it started.

27 MR'. ROAM: What was it when I came in there? I 28 was only about the sixth or eighth inspector of electrical.

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25 1 So your department when I came in was about 30 some 2 pecple?

3 MR. TENNYSON: Close to 40, I think.

4 MR. ROAM: Really?

5 MS. DURBIN: What year was that?

6 MR. TENNYSON: 1982.

7 MR. ROAM: I came on in August 24th so somewhere 8 around tnat period.

9 MR. TENNYSON: From August it started increasing 10 and when we left in March '83 it was probably standing at --

11 Well, I don't know if the totals are on there or 12 not but a hundred and forty or a little better.

13 MR. ROAM: There's quite a few on there that does 14 not show which was more documentation control and record 15 systems.

16 All I was interested in was the inspectors.

(

17 NR. KAUFMAN: All right.

18 Now, let me go back to 1973. What kind of program 19 did you have for quality .issurance?

20 MR. ROAM: hell, one day I'm sitting there in the 21 office and Virg comes up to me and says he had a phone call.

22 He says, "There's a guy here from PG&E who wants 23 to talk about NCR's."

24 Nell, he's talking to Virg and Virg says, "Well, 25 why don't you talk to the man who was there. Maybe he can 26 explain why."

27 Anyway, his question was, "How come there was no 28 NCR's prior to 1974?"

J ACM EG A N REPORTING SERVICE see annon-can onive LAFAVLTTE C ALIFORNIA 94549 e4ISI 283 3172

26 1 MS. DURBIN: Could you tell us what an NCR is?

2 MR. TENNYSON: Non-conformance report.

3 The only thing we ever wrote is against a vendor 4 if a piece of equipment came in damaged. So that will give 5 you an idea of what kind of program it was. ,

6 MR. KAUFMAN: Okay.

7 I take it there were inspectors out there who were 8 checking the work. Is it that there are no records kept for 9 non-conforming work or what?

10 MR. JONES: Well, maybe you should answer first 11 whether his assumption is correct that prior to 1974 there 12 were inspectors out there inspecting the work.

13 MR. ROAM: Yes. We did certain types of inspections.

14 MS. DURBIN: What types of inspections did you do?

_ 15 MR. ROAM: Just cable pulls, cable pulling wire, 16 some foundations and stuff.

17 That was about it. Very general.

18 MR. TENNYSON: Electrical equipment, foundations.

19 MS. DURBIN: What proportion of the work that was <

20 done, would you say, was inspected at that time in 1973?

21 Did you inspecc ten percent of the work, 20 percent, 22 a hundred percent?

23 MR. ROAM: Some percentage but I couldn't tell you 24 nov.' wha t it was.

25 MS. DURBIN: Less than a hundred percent?

26 MR. ROAM: Oh, yes.

27 MS. DURBIN: Less than 50 percent, would you say?

~ '

28 MR. ROAM: Yes. We didn't even have calibrations JACK EG AN REPORTING SERVICE see AmmowwE AD omivt LAFAY ETTE C ALIFORNI A 94 54 9 141S t 2 8 3 317 2

27 1 set up, did we?

2 MR. TENNYSON: You set it up when I came in.

3 MR. ROAM: So it was less than that.

4 MR. KAUFMAN: Can you give us an example of the 5 kinds of things you did not inspect?

6 MR. JONES: In 1973?

7 MR. KAUFMAN: In 1973.

8 MR. ROAM: Tool calibrations, probably a hundred 9 percent of the raceway installation.

10 MR. TENNYSON: You might clarify and say electrical 1

11 raceways.

12 MR. ROAM: Material receiving, there was no control 13 on that. No control on the material itself coming into the 14 plant to be used for installation.

15 Rail rod control, welding procedures, welding 16 applications, all that we didn't do.

17 In fact, that's what we set up in '74 as one of 18 the first three projects I put Virgil on was welding 19 procedures: rod control, terminal blocks.

20 MR. KAUFMAN: After 1974 when you were required 21 to adopt a detailed quality control program, what kind of 22

, a program did you adopt?

23 MR. TENNYSON: Well, in the beginning, right at 24 the beginning we started establishing procedures in accordance 25 with the specifications, the PG&E specifications for building 26 the plant.

27 MR. ROAM: And 10 CFR 50.

20 MR. KAUFMAN: All right.

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28 1

MR. TENNYSON: And in doing this the specifications 2

called out certain codes and standards to be f611 owed which 3

we had to research and develop the procedures based on, you -

4 know, the codes and standards, too.

5 So as procedures were established, I think, there 6 was -- s

-7 Well, we had an interim period of time that we had

. 8 a strike, a labor strike out there which put us off six months.

9 I say "put us off," it put the production forces 10 off.

11 The quality control department, not being in the 12 union, crossed the line and came on in and performed their 13 functions and research and evaluation and procedures and so 14 on, as the procedures were written, to cover all aspects of 15 the job that we were told to write.

16 They were submitted to Pacific Gas & Electric and 17 Pacific Gas & Electric would approve them or tell us how they 18 wanted them changed, you know, certain portions of them.

19 By the time the production forces came back to work 20 l

! we pretty much had all our procedures established and inspec-21 tion criteria set up.

j 22 I'

We had probably enough inspectors at that time, 23 I'd say, to --

. 24 Rick, you were still there after the strike, weren't 25 you?

26 MR. ROAM: Yes, I think just a few days after that 27 I quit.

20 MR. KAUFMAN: The program that you eventually JACK EGAN REPORTING SERVICE see annowngao on:vt L AFAV ET TE C ALIFORNI A B4 54 9 a415 s 2 8 3-317 2

29 1 adopted did not meet the requirements of 10 CFR 50 Part B, 2 did it?

3 MS. DUREIN: You mean his understanding of it?

4 MR. KAUFMAN: Okay.

5 Your understanding -- if I can testify here for 6 a second -- the way I understood you to say it was you started 7 with an attempt to meet the requirements of 10 CFR 50 and 8 PG&E specifications for the plant and during the course of 9 your attempt to adopt this program you had discussions with 10 Pacific Gas & Electric Company and they made modifications 11 to the program that you had proposed to them?

12 MR. TENNYSON: Yes.

13 MR. KAUFMAN: My question then is: Did those 14 modifications result in a program which required less than 15 10 CPR 50 Part P?

16 MR. TENNYSON: The reason I hesitate to answer this 17 is because of not knowing or never seeing a contract between 18 Foley Company and PG&E as to what our contractual obligations 19 were to PG&E.

20 PG&E claims that they could appoint the contractor 21 for a certain portion of 10 CFR 50 and they could absorb or 22 be responsible for other portions through their monitoring 23 of The Howard P. Foley Company with their own people.

l .

24 MS. DURBIN: You weren't sure if your program had 25 to meet all of the requirements independently or if PG&E could 26 satisfy some of those requirements apart from what Foley did?

27 MR. TENNYSON: Right.

28 MR. ROAM: Right.

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30 1 MS. DURBIN: You mentioned before that PG&E 2 instructed you to write quality control programs for certain 3 portions of the work. .

4 I assume that means they instructed you not to write 5 quclity control programs for other portions of the work?

6 Am I stating that correctly?

7 MR. TENNYSON: No. I didn't mean it that way.

. 8 Anything that The lloward P. Foley Company was 9 awarded to work on did require a procedure and procedures 10 were established and inspection forms were drawn up and put 11 with these procedures and documentation was required upon 12 the completion of an inspection of a certain item.

13 For instance, a termination procedure was written 14 and there were various forms within this procedure which --

15 depending on the portion. That's what I meant by the portion 16 of work you were doing to the procedure because it did cover 17 many portions of work within the electrical termination.

J 18 If you were terminating a wire to a terminal block 19 you would use one particular form or if you were installing 20 a jumper you would use another form because there may have 21 been six, eight forms.

22 MR. ROAM:

At that time, right.

23 MR. TENNYSON: That would cover different portions

. 24 of the work.

25 MS. DURBIN: Thank you.

26 9

MR. KAUFMAN: lias that procedure been changed, the 27 procedure you were utilizing after 1974?

28 Is that procedure still being utilized now?

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31 1

MR. TENNYSON: Yes.

2 That procedure is being utilized. It's been changed 3

many times and all of the changes are on record, in most 4 cases, as to who requested the change and in some cases why.

5 Those would be found in the procedure files along 6 with the most current one.

7 MR. KAUFMAN: Have you ever received any instruc-

. 8 tions from anyone to deviate from the written or adopted 9 procedures?

10 MR. TENNYSON: Yes.

11 Skip Moses directed me to pull some red tags on 12 structural steel work that was in the field which were the 13 result of a non-conformance or many non-conformances written 14 regarding various non-conformances with weldments or maybe

. 15 modification plate installations, things of that nature.

16 The red tags were written by the inspector and hung 17 on a particular area which was considered by the quality con-18 trol department to be non-conforming at that time either to 19 design or to procedural requirements.

20 1

These red tags, in essence, did slow down the work 21 because maybe the red tag would cover only one weld out of

22 maybe ten, fifteen welds or would restrict a person from 23 installing a plate possibly closer to that or in relation

. . 24 to it.

25 The new personnel had not enough field work to know 26 the procedures well enough te work on or through a red tag 27 and this would cause a lot of confusion in the field and was

-, 28 possibly slowing the work down.

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32

-1 We were told to pull the red tags down and don't 2 write red tags on anythinzg that we could possibly have

. w 3 ' answered from Pacific Gas & Electric engineering department ,

4. .through another method like an engineering disposition ,

i 5- ' request -- EDR -- or writing up a certain problem you had j.. 6 run onto and could possibly be answered by'PG&E through their 7 engineering division, evidently in San Francisco.

8 These things were easier.and much quicker to process  !

9 than a non-conformance was because of the signatures that to had to be applied to it and the agreement between the two l

11 companies.

12 So, in essence, the red tag was accused of slowing

13 the work down.

14 MR. KAUFMAN: Let me see if I understand this

- 15 correctly. You were told by Mr. Moses to remove red tags 16 that were placed on otherwise non-conforming work because

! 17 it'would slow down the work of --

18 MR. TENNYSON: Production.

19 MR. KAUFMAN: The construction people who were not i

20 experienced enough to be able to work around the red tag?

i 21 MR. TENNYSON: Yes.

i

[- 22 MR. KAUFMAN: You were still, however, to report i

! 23 the --

i*

24 MR. TENNYSON: Non-conforming items?

25 MR. KAUFMAN: Yes, to PG&E's engineering-department. ,

i l

[ 26 for them to determine whether they could correct it in some 1

27 other fashion?

'~

j 28 MR. JONES: You've got two things confused here j l

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'33 1 actually because, I.think,'what he's saying -- correct me 2 if I'm wrong in my understanding -- what you're saying :is 3 with respect to thos2 particular non-conformances that the .

4 red tags related to they were still taken care of, isn't that 5 right?

o 6 MR. TENNYSON: Yes.

7 MR. JONES: And it was also said to you by 8 Mr. Moses that if it was possible not to write red tags or 9 NCR's at'all but'to go directly to PG&E's engineering depart-10 ment he would prefer that?

11 MR. TENNYSON: Yes.

12 MR. JONES: So those were two separate things.

13 MS. DURBIN: So when you hung a red tag the work

! 14 actually was fixed?

a s- 15 MR. JONES:

You want to ask him about the work that 16 related to that particular set of red tags that were pulled?

17 MS. DURBIN: That's what I'm trying to ask about.

18 If you hung a particular red tag, was that work i

19 fixed later?

20 MR. TENNYSON: Yes. The work was fixed.

L 21 MS. DURBIN: Just a difference in how you were going

.. 22 to get the work fixed?

23 MR. TENNYSON: A matter of procedure when the red i 24 tag was to be removed and that was after the work had been

{ 25 reworked and the inspector had inspected or approved the situ-l 26 ation.

27 New documentation would be made showing the r.esults 28 of this inspection and this rework and the non-conformance e

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34 1 would be signed off and at that time be ready to put-in the 2 file and the red tag'could be pulled off of the item which

~-

3 would clear the 'non-conforming item. -

4 MS. DURBIN: What happened when you reported it 5 to PG&E's engineering department instead?

6 MR. JONES: That assumes that he followed that pro-7 cedure.

8 I don't know if his department ever did that.

9 MS. DURBIN: Thank you for that correction.

10 Did you, in fact, stop hanging red tags and contact ,

11 PG&E's department instead on some items?

12 MR. TENNYSON: I didn't personally. Our engineering 13 department did which was within The Howard P. Foley Company.

14 We had a group of engineers who were working in

~; 15- the field on problems between production and quality control  ;

16 and they, in turn, would write up a problem on an EDR -- we 17 called them that -- and they would'be taken to PG&E for quick 18 disposition as to how they wanted to accomplish this situation.

19 MR. JONES: Those people didn't work for you?

20 MR. TENNYSON: No. They were working strictly under 21 Mr. Moses and Mr. Ray Lathrum who, at that time, was the 22

. assistant project manager.

23 MS. DURBIN: However, people continued to hang red 24 tags, didn't they?

25 MR. TENNYSON: Yes.

26 MR. KAUFMAN: How did you make a determination that 27

__ y.m sorry to be slow about this. This is a significant 0

item. I just want to make sure we're all clear on this.

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35 1 You received instructions from Mr. Moses to deviate y

2 from.the program and to, in fact, establish another' program i-3 or parallel program for certain types of discrepancies. .

4 A separate unit was established for dealing and '

5 reporting these kinds of discrepancies to PG&E's engineering

~

6 department; is that correct?

7 MR. TENNYSON: Yes.

e.

8 MR. KAUFMAN: And these people were not under your 9- control, they were under Mr. Moses' control?

10 MR. TENNYSON: The engineering group that wrote 11 the EDR's you're speaking of?

^

12 MR. KAUFMAN: Yes. The group that reported these 13 types of errors to PG&E's engineering department?

14 MR. TENNYSON: Yes.

'-- 15 I don;'t $hink you wrote any, did you, Rick?

16 MR. ROAM: No.

17. -Strictly an engineering function.

How were these decisions made to not

~

18 MR. KAUFMAN:

19 red tag but'do an EDR?

20 MR. JONES: Again you're assuming he made that

' 21 decision or anyone that worked for him did.

22 MR. KAUFMAN: I'm sorry about the question.

Let 20 'me try it'again.

24- 3-

.Were all these requests made by Mr. Moses? Was 25- .he the-one who made this determination?

26 MR. JONES: I'm not trying to be difficult but --

27 MS,. DURBIN: Let's go off the record for just a 28 moment. ).

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.g 4 .

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+

36 1

-(Discussion off the record.)

[. 'O  ;

2 MR..KAUFMAN: Back on the record.- n 3 And the question 1is: Did you follow the procedure.

.that Mr. Moses-.-asked you to. follow?

1 4

_c .

f 5 MR. TENNYSON: Yes, I think:I did.. #

-6 No,.no. I'm sorry.

7 Not'the one Mr. Moses asked me to follow. I 8 followed the procedure which was established and is a QCP3  ;

9 reporting of non-conforming conditions. I 10 MR. KhUFMAN: So your department continued to red 7.

11 tag everything that was non-conforming?

12 MR. TENNYSON: Yes.

+

.13 ,MS. DURBIN: And Mr. Moses' department'apparently 14 . carried on a parallel program at the same time?

15 MR. TENNYSON: -Mr. Moses was over -- he is.the 116 project manager of The Howard P. Foley Company.

17 MS. DURBIN: Well, other people who reported to 18 Mr. Moses who did not report to you engaged in other procedures 19 that Mr. Moses had suggested of reporting certain items as 20~ engineering deviation rather than as non-conforming work?

21 How was it decided who would evaluate which work

~ 22 or certain types of work assigned to you or certain work 23 assigned'to other staff?

I* 24 MR. TENNYSON: I think that could be determined 25 by.-- well,-if the quality control department were to be called i.' 26 out on a particular installation and found something non-o 27 conforming we would write a non-conformance on it, if it 28

~

warranted it.

JACK EG AN REPORTING SERVICE see AnnowME AD onivt LAFAYETTE. CALIFORNIA 94549 14tSB281 3172

37 1- Now, if the quality control department had not been 2 called out on that particular function yet and it maybe was

  • 3 reported to PG&E or.to one of our engineering staff the deci-4 sion was made somewhere other than in the quality control 5 department to.make that an engineering disposition request. I 6 MS. DI1RBIN : So, in other words, you red tagged 1 7 everything that was not conforming that you saw but there l 8' were many items of work your department did not see and the '

9 decision as to what you would see and what you would not see 10 was not made by you?

11 MR. TENNYSON: No. It is strictly determined by 12 the procedure as to when you would be called for a particular 13 type of inspection.

14- MR. ROAM: You'd be called in by production, "We 15 finished X amount of work. Come look at it."

16 MS. DURBIN: So they decided when to call you in?

17 MR. ROAM: By procedures, yes.

18 In other words, you can't go from Point A to Point B 19 without somebody in there looking-at it.

20 MS. DURBIN: What I'm trying to get at is: When 21 did the engineering staff go out and write up an EDR and who 22 decided that they would look at the work rather than you look-23 ing at the work?

24 MR. ROAM: Well, their looking at the work would 25' not buy-off that work. We had to buy-off the work whether

^26 right or wrong.

27 In other words, we had final say. Engineering might v

28 be there and say, "Oh, we got a problem. Write an EDR and JACM EGAN REPORTMG SERVICE nos anerowmaan omsvg LAF AYETTE C ALIFORNI A 9454D f 415t 2 8 3 3172 t _

38 1 clear it."

2 When our people come out they might show us this I 3 EDR which accepted the change and we just attach it together ti 4 with our paperwork and.put it in the file.

5 MR. KAUFMAN: In oth'er words, nobody in the construc-15 tien end deviated from the procedures of calling you in. You 7 saw everything. ~It's just that there'was an_EDR going on 8 independently as well?

9 MS. DURBIN: Before you got there?

10 MR. JONES: As far as you know?

11 MR. TENNYSON: We think that's the situation.

12 Now, we had no way of knowing what we weren't called 13- in on.

14 MR. ROAM: Correct.

> 15 a MS. DURBIN: Obviously.

16 MR. ROAM: Because we don't know the whole scope 17- of what all is going on becaur --

18 MR. TENNYSON: Our procedures governed us. That's 19 why --

20 MR. ROAM: Like you asked me: "What's the rivulet 21  : system? What does the rivulet system totally contain?"

.. 22 Do you see?

, 23 MR. KAUFMAN: Well, my next question on that is:

-24' For this program what percent.:ge of the work are you looking 25 at when production calls you-in?

Are you examining 100 per-

'. 26 cent of the work or are you examining a portion of that work?

27 MS. DURBIN: I've gotten a little lost here.

~

28 What point in. time are we talking about? Pre '82 1 JACK EGAN REPORTING SERVIOE see AmmoweerAo omivt LAFAY Ef f E. C ALIFORNIA 9 4 549 04t Si 2 8 3 3172

,_ + _., , .. , , - , , , . ,

, - - . ,- +

39 1 or post '82?

I 2 MR. KAUFMAN: 1974.

ss 3 MR. ROAM: 1974.

4 -MR. KAUFMAN: Yes and on until the present you're 5 using the same program up until -- well, my understanding

, 6 is that you're using the same procedures as in 1974?

7 MR. ROAM: 'Not the same procedures. The same 8 phil'osophy possioly but the procedures change like the first.

9 procedure I. wrote was writing inspections.of raceways.

10 We're now on 11 or 12 revision, somewhere in that 11 area and since the time we wrote it there have been many, 12 many changes.

13 To say that we're inspecting the same way then and 14 now or now as then, no.

s, 15 MR. JONES: I think what Mr. Kaufman's question 16 went to-though is what percentage of the production work was 17 inspected once these. procedures and philosophies were 18 established?

19 MR. ROAM: Oh.

20 MR. JONES: If you know.

21 MR. TENNYSON: In some cases like weldments, welding

.: 22 on Class 1 installations a hundred percent of the installations 23 were inspected that we were called on.

24 We have no idea whether we were called on all of-

.25 .them or not because of, like I say, we did not work to a 26 ' system.

27 -

Production triggered us as to when they had com-

~

28 p1'eted something or by the procedure it required an inspection JACK EG AN REPORTING SERVICE LAFAY&TTE C ALIFORNIA 94549 4415s 283 3172

i I

40 1

and then they would notify us that they were ready for an

2. inspection in the field.

3 MS. DURBIN: Could you tell us who in production. p 4 we might talk to to find out when you were called and when 5 you were not called?

6 ' MR . TENNYSON: I can give you superintendents' names.

7 MS. DURBIN: That~would be nice.

8 MR. TENNYSON: Mr. Harold Roland.

9 MS. DURBIN: For whom does he work?

10 MR. TENNYSON: Howard P. Foley Company, electrical 11 superintendent. He works for Howard P. Foley Company, Skip 12 Moses.

13 MR. JONES: Would this be a good time to break for 14 lunch?

-- 15 MS. DURBIN: Yes. Fine.

16 (The luncheon recess was held from 12:30 until 1:45.)

. 17 18 MR. KAUFMAN: Back on the record.

19 . What I'd like to explore now are the circumstances 20 in which you were asked to deviate from the described pro-21 cedures for quality assurance.

22 i

- Now, you've already indicated the instance where 23 Skip Moses asked you to stop putting tags on work. You've 24 indicated that you did not comply with that request and con-25 tinued to follow the QA procedures and tag the work.

26 Are there any ot.her instances where you were asked 27 to deviate from procedures?

28 MS. DURBIN: Could I stop you for a moment.

e JACK EGAPd REPORTING SERVICE SSS ARROwMC AD Omsvg LAFAYETTE C ALIFORNIA 94 54 9 e415e 2 83-3172 l

L

k 41 1 Off the record for a second.

2 (Discussion off the record.)

3 MR.. KAUFMAN
On the record.

4 Let me strike the last question and start over. -

5- Were there any other circumstances in which red 6 tags were pulled, any other circumstances?

2 7 MR. TENNYSON: Yes.

8 There was a situation where Skip Moses asked me 9 to pull some red tags down so that production could work on ,

i 10 those non-conforming. items.

11 I refused to pull the red tags until the conformance 12 or disposition was to the point of where corrective action 13 could be taken.

14 Later, I don't know if it was a day or two later, v- 15 my night-assistant quality manager -- they called him night 16- shift -- was evidently called into Mr. Moses' office.and.

17 informed that he was to go out and pull the red tags'so'that 18 production could perform work on them, on the non-conforming 19 items.

20 Can we go off the record?

21 MR. JONES: Yes.

22 (Discussion off the record.)

23 MR. KAUFMAN: We're going to go back and start from 24 the beginning with this thing because I'm confused now.

25 MR. JONES: I got confused there, too.

26' MR. KAUFMAN: Let's start where we were, I believe, 27 before we adjourned for lunch.

28 Sometime before that the question was asked: Were JACK EGAN REPORTING SERVICE See annowME AD DAtWE LAFAV ETTE C ALIFORNIA 94549 14151 283 3872

42 1 you ever asked to deviate from'the established procedures?

2 'And you answered initially that Skip Moses had asked you to w

3 pull red tags from non-conforming work because the production _,

4 workers were.;too inexperienced to be able to work around those 5 red tags.

6 Now, I'm going to ask you on what date was this 7 conversation with Skip Moses, approximately?

8 MR. TENNYSON: It couldn't have been over three 9 weeks before we left, could it?

10 MR. ROAM: No. It was recent, within three weeks.

11 MR. JONES: February?

12 MR. ROAM: Yrs.

13 MR. TENNYSON: llad to be in February.

14 MR. KAUFMAN: 1983?

s- 15 MR. TENNYSON: Mid-February 1983.

16 MR. KAUFMAN: All right.

17 What was the result of that conversation with 18 Mr. Moses?

19 MR. TENNYSON: Well, I refused to pull the red tags 20- until'they were at proper -- or by procedure at the proper 21 point of corrective action.

. .22 Then just shortly after that, a day or two, I.found 23

.the stack of red tags in my office where my assistant manager, 24 Bob Carter, who was the night man, found the stack of redLtags 25 in his shelf.

26 .

I asked him what they were and he said that Skip 27 Moses had. called him in the of fice and told him to pull all 28 those red tags down and keep them in the shelf back there so JACK EGAN REPORTING SERVICE see AnnowntAD oneve L AFAV ETTE. C ALIFORNIA 9454 9 s e t 51 2 9 3 317 2

\

43 1- that production could work on'the non-conforming items out 2 there.

- n 3 MR. KALTMAN : What did you do after that? o 4' MR. TENNYSON: There wasn't'a lot-I could do at t

5 that point.

6 I Knew I was treading on thin ice. My full inten-7 tion was -- and there was no way to avoid it in any way --

8 Well, the fact the red tags were pulled was a pro- -

9 cedure violation but the non-conformances_could not be closed 10 ' out and accepted by me until the corrective action had been 11 performed.

12 MR. KAUFMAN: Am I correct in assuming that when 13 a tag is placed on work a record is made of the fact that 14 the tag-has been'placed on the work?

sa 15 MR. TENNYSON: Yes. The non-conformance. procedure 16 establishes the fact that you are to hang a red tag on a non-17 conforming item when possible.

18 That red tag is to remain on that item until a pro-19 - posed disposition is made either by the customer or agreed 20 to by the customer.

21 When the non-conformance is written the proposed

. ~ 22 disposition is typed in and a werk _ copy sent to production.-

'23 That's their authority to work on that particular item with 24 the red tag on it to perform corrective action.

25-When_the corrective action has been performed they 26 are to notify quality control department.

Quality control 27 will then go out inspect to the proposed disposition and the

=-" 28 work in accordance with the procedures and at that time either JACM EGAPd REPORTING SERVICE

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44 1 accept it or reject it.

2 If it is accepted the non-conformance is sent back s- ,

3 into the quality control department or quality assurance 4 department, whomever is in charge of the non-confcrmances 5 at that time, and they will type it up and officially the 6 corrective action will be signed off by various people.

7 When the last signature is on it PG&E signs off Q-6 the non-conformance and then the red tag can come down.

9 The non-conformance is filed in its official place.

10 MS. DURBIN: May I interrupt?

11 MR. KAUFMAN: Yes.

12 MS. DURBIN: How long.does all that usually take?

13 MR. TENNYSON: It could go through -- I've seen 14 them go through in a day's time on an item.

s- 15 In fact, the one that we were -- the reason Rick 16 and I was terminated -- well, it went through in one day's 17 . tine, didn't it?.

18 ,M R . ROAM: Yes.

19 MS. DURBIN: What was the average time for such 20 an item to be handled?

21 MR. TENNYSON: Depends on Pacific Gas & Electric

. 22 .and their agreement with the proposed disposition that we 23 put on it to correct the situation.

24 In most cases we would negotiate with them before 25 we put the proposed disposition on it so that there may be 26 no delay in getting it processed.

27 Sometimes when it got_to PG&E for their acceptance

~

- 2,8 of the proposed disposition it might stay up there for a JACK EG AN REPORTING SERVICE See A RROMMEAD Daavt LAFAYETTE C ALIFORNIA 94549 14 t Si 2 8 3 3172

45 1 month. It could stay up there for two months or it could

'2 come back down that day.

3 It depended on whether they had to go to 4 San Francisco to acquire the information they needed or the 5 approval to accept it.

, 6 MR. KAUFMAN: With respect to these red tagged items,

~

7 what corrective actio'n, if any, was taken with respect to 8 them?

9 MR. TENNYSON: The particular c:tes that were found?

10 MR. KAUFMAN: The ones that were pulled,.the pulled 11 red tagged items?

12 MR. TENNYSON: We have no way of knowing that at 13 this point.

14 That happened and just a few days later we were 15 terminated.

16 MR. KAUFMAN: And what were the portions of the 17 plant -- what systems were those that the red tags were hanged 18 on?

19 MR. ROAM: It basically looked like tags from the 20 fuel-handling building.

21 MR. KAUFMAN: Do you recall what systems?

.. 22 MR.. ROAM: It would-be probably the structural steel.

23 I just looked at the tags and wondered why they.

24- was there.

25 Virg told me and I put them back on the desk. It's 26 not my problem. I got enough of my own. That's his'n.

27 MR. KAUFMAN:If the tags were on structural steel 28 . . what could that involve? What kind of --

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46 1' MR. TENNYSON: That was modification, 2 MR. ROAM: Modification, seismic support.

.3 'MR. KAUFMAN: Strictly welding?

4 ~ MR . ROAM: And probably' material, too. Welds, 5 reinforcine gussets, plates, could have been any one-of the 5.

6. things ~that the modification involved and.what they. called

-7 tho' modification, the big push on this last annulus steel

~~ ~

8 modification.

9 MR. KAUFMAN: Subsequent to this first instance 10 ~in which Mr. Moses asked you to deviate from procedures, was 11 there another instance'in which he came to you and asked'you 12 -tc deviate from procedures? l

, '13 MS. DURBIN: Do you really want to ask subsequently?~

8 14 MR. KAUFMAN: Off the record.

15 (Discussion off the record.)

MR. KAUFMAN:

16 - Back on the record.

17 Did Mr. Moses' request _to you about the red. tags
- 18' reflect standing orders from him with respect to the way the'.

19, quality assurance. operation should be' conducted:at Diablo?

20 MR. TENNYSON: No, it didn't.

21 MR. KAUFMAN: Let me ask'the question another way, 22 then.

I 23- Did --

-' 24 .MS. DURBIN: Let me try it.

25 MR. KAUFMAN: 'All right.

26 MS. DURBIN: Mr. Tennyson, did Mr. Moses ever 27 express to.you any desire that you work faster or that you 28 ~ find fewer errors?

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47

1. MR. TENNYSON: Well, generally the subject of most 2 of the meetings that we had in his office was over the fact

~..

3 that the quality control department was slowing down the job.

4 MS. DURBIN: What would be the substance of a 5 typical meeting of that type? What would usually be discussed?

, '6 MR. TENNYSON: Normally it was due to a non-7 conformance that had been written which had possibly slowed 8 the job down or someone in production disagreed with the 9 subject and at that time it would be discussed more heavier 10 that they wanted non-conformances lightened up on.

11 You know, less things written up on non-conformances 12 and more problems covered on EDR's.

13 MS. DURBIN: Did Mr. Moses ever tell you you should 14 write up fewer non-conforming reports?

-- 15 MR. TENNYSON: He indicated this very strongly.

16 I don't know if he told us directly.

-17 MS. DURBIN: How did he indicate it?

18 MR. ROAM: "You're holding up the job, man. We 19 got to perform. We got to get it done. We got to get it 20 done."

21 MS. DURBIN: You repeated those phrases several

- 22 times. Does that mean it was repeated to you over again on 23 many occasions?

24 MR. TENNYSON: Yes.

25 MR. ROAM: Yes.

26 MS. DURBIN: Did Mr. Moses ever indicate to you 27 that your job might depend on how quickly production moved 28 or how much the NCR's slowed it down?

JACK EG AN RE PORTING SERVICE see Ammoweet Ao oneve L AFAYL TTE C ALIFORNIA 94549 14151 283 3172

~48 1 MR. ROAM: How much my job depended?

2 MS. DURBIN: Did he ever' indicate to you that his

3 job might depend on how quickly production moved?-

4 MR. ROAM: I can't think of any.

5 MR. TENNYSON: I.wasLtold numerous times that if 6 we slowed down the job, if we didn't -- that is, The Howard P.

7 .Foley Company -- didn't perform as PG&E thought we should 8- there was a good. chance we were all out and down the road.

9 MS. DURBIN: Does "down the road" mean out of a 10 job?

11 MR. TENNYSON: Yes.

12 I was. told by Mr. Moses-that if the chances were 13 that he was going down the road that I was going down'about 14 ten minutes before he did.

15 MS. Dt!RBIN: Which you took to'mean he would fire 16 you first?

17 MR. TENNYSON: Very definitely.

18 MS. DURBIN: How much control did you feel that 19 the production = department or how much' influence did you feel 20 -that the production had over Mr. Moses and'the directions 21 he gave you?

' 22 ~ MR. JONES: -You've got it backwards. He was head 23 of production.

24 MS. DURBIN: He was your boss and head of the 25 production department?

' . 26 MR. TENNYSON: Yes.

27 ' MS. DURBIN: He put pressure on you to help him 28 speed up production by writing fewer NCR's or being a little JACK EGAN REPORTING SERVICE see AmmoWMEAD Desvt LAFAVETTE. C ALIFORNIA 94549 44951 283 3172

49 1 less careful than you-felt you should be, is that true?

2 MR. TENNYSON: My feeling it-is, yes, w

3 -M R . KAUFMAN: ,Did you feel --

4 MS. DURBIN: Wait a minute. I have one other 5 l question.

6 Did you ever get-that feeling from any person other 7 than Mr. Moses? Was there any pressure put on you or.any 8 dissatisfaction indicated to you about your performance in

'9 that you were being too careful?

10 MR. TENNYSON: Yes, many times.

11 MS. DURBIN: By-whom?

12 MR. TENNYSON: By Mr. Don Rockwell of Pacific Gas-13 & Electric.

~14 MS. DURBIN: -What was his position?

s- 15 MR. TENNYSON: Electrical resident engineer and' 16 contract administration.to Howard P. Foley.

17' MS. DURBIN: Anyone else?

18 MR. TENNYSON: Mr. Forrest Russell.

19 MS. DURBIN: Who was he and what position did he 20 hold?

21 MR. TENNYSON: Civil resident engineer of PG&E, 22 Pacific Gas & Electric.

23 Then I have to name a Mr. Vick Smart who I dealt 24 with quite extensively for the last nine years.

J ' '

25 He was under pressure to get the job done and,,in 26 turn, did cause me to be under a lot of pressure and my 27- department.

28 MS. DURBIM: How much pressure did you feel you JACK EG AN RE.s*ORTING SERVICE see ammownE AD omsvt LAFAYETTE. C At IFORNIA 9454 9 1415s 203 3172 2

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4 , ++ - ,- - , - , - -------n- - --

50 1 were under? Can you compare it with other jobs you have held?

2 MR. TENNYSON: I feel that the pressure was more --

3 much more than any job I've ever been on before.

l 4 MS. .DURBIN: Have you ever been on jobs where_you 5 were under intense pressure other than Diablo?

6 MR. TENNYSON: Yes.

7- MS. DURBIN: What type of job would that ba?

8 MR. TENN? SON: Would have been aircraft, Douglas

. _ g ~ Aircraft Company in meeting production schedules.

p J..

10 Also Todd Shipyard, working on ships for commercial 11 and military vessels.

l

! 12 MS. DURBIN: How would you compare the degree of 13 pressure to get the job finished that you experienced at t

14 Diablo with your other situations?

15- Would you say'it was as intense, more intense, much 16 more intense? I' realize lthis is qualitative.

17 MR. TENNYSON: Much more intense.

18 MR. JONES: At Diablo?

19 MR. TENNYSON: At Diablo.

20. MS. DURBIN: Did you feel your department of quality 21- control was truly independent there?

, 22 MR. TENNYSON: Not in any way.

23 MS. DURBIN: Did you feel that production was very (6-24 much in control of.your department or slightly in control?

25 MR. TENNYSON: I feel that production's influence 26 - on the project manager det.crmined pretty much the pressure s 27- that were put on the quality control department.

'~

28 MS. DURBIN: Where did the pressure from production JACK EGAP4 REPORTING SERVICE see anaownt Ao Omivt LAFAY ETTE C %IFORNI A 94 549 14155 28 3-3172

51 r -f e .

l 1 come?- Was it from Foley internally or did PG&E exercise any.

I.

2 influence?

3 MR. JONES: If~you know.

4 .MS. DURBIN: Yes, if you know. .

5 What was your impression?

6 MR. TENNYSON: Rick, what do you think?

7 MR. ROAM': Well, I think a lot of it had to come 8 from-PG&E because every morning at 7:30 sitting there is 9 Forrest Russell.

~10 He's badgering me, how come I'm still hanging tags?

11 How come I haven't removed any red tags? How much did I 12 remove?

13 MS. DURBIN: Who was Forrest Russell, by the way?

14 MR. ROAM: PG&E's civil resident engineer who was

._ 15 evidently hounding production and hounding me so that they 16 can get the work done, production can get the work done.

17 MS. DURBIN: How often did that happen that he put

'18 pressure on you to not hang so many tags?

19 MR. ROAM: 7:30 every. morning.

20 MS. DURBIN: Every morning?

21 MR. ROAM: Yes.

22 MS. DURBIN: What a lovely way to start your morning.

23 MR. ROAM: You bet and I'd come down and cry on 24 Virg's shoulders.

25 MS. DURBIN: What time period was this that this 26 was happening? Was it. on an extremely regular basis?

27 MR. ROAM: Whenever I made assistant.

28 MR. TENNYSON: LHad to be two months after Christmas JACK EGAPd REPORTING SERVICE see anno

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I 52 1 o; before.

2 MR. ROAM: After Christmas.

3 MS. DURBIN: Christmas of 1982?

4 MR. TENNYSON: Yes.

5 MS. DURBIN: So this is the beginning of 1983 when 6 you experienced this intense pressure?

O 7 MR. ROAM: After Christmas is when they started 8 the build-up.

9 MS. DURBIN: What was it like during 1982? Did 10 you experience much pressure in that year?

11 MR. ROAM: Me?

12 MS. DURBIN: Either of you.

13 MR. JONES: Rick only started in August of ' 8 2 ,-

14 isn't thai right?

15 MR. TENNYSON: IIe came in under pressure though.

16 MS. DURBIN: During the last half of 1982?

17 MR. ROAM: In the last half of '82, yes, pressure 18 was etarting to build as I was going to Virg explaining to 19 him, "We need the people. We know what is happening and we 20 need the people now to get them prepared and ready for the 21 influx."

22 Virg said, "licy , my hands are tied. I can't do 23 anything. Do the best you can."

24 So the first thing we did was start trying to train 25 the people, upgrading them, keeping them f amiliar with pro -

26 cedure changes, philosophies of inspection as to how it was 27 to be done.

~ 28 MR. KAUFMAN: Did either Skip Moses or the peopie JACK EG AN R EPORTING SERVICE see AmmoWME AD ORIVE LAF AVETTE C ALIFORNIA d4549 14158 2 8 3 3 t 72 J.

'53 1 from.PG&E, who you talked to about the red tags, attempt to 2 distinguish between the kinds of items that you were red

w 3- tagging?

4 Was there one particular kind of NCR that-they.

.5 didn't want you.to hang a tag on whereas others-they would 6 .' allow you to hang a tag on?

a

.7 MR. ROAM: No. Just red tags in general.

~

8 MS. DURBIN: Any distinction made between Clpss 1 9 and Class 2 equipment in regard to --

10 MR. R O.A M : For Class 2 we'did no inspection. On 11 Class-1 we did an inspection.

12 On Class 2 I should take that back except'for 13 Class 2 raceways.

14 MS. DURBIN: Electrical raceways?

- 15 MR. ROAM: 'We'd only check those if they crossed 16 "over a class 1 raceway or piece of equipment and then.we would 17 just' walk it down and if there was no Class 1 under it wo 18 forgot about it.

19 MR. KAUFMAN: Let's get to the types of NCR's that 20 you were finding.

21 Where did you find the majority of NCR's?

. 22 MR.. ROAM: Structural steel welding.

23 .MR. KAUFMAN: Could you assign a percentage to that, 24 say, 50 percent of your errors, 60 percent of your errors?

f, 25 MR. ROAM: I would say about 65 percent.

26 MR. TENNYSON: Probably was.

i- 27 MS. DURBIN: What kind of errors were you seeing 28 there?

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54 1

MR. ROAM:

In fact, I'd say it was about 80 percent.

2-We didn't have that much administration when --

3 MR. TENNYSON: Yes, that's when the big influx of 4

non-conformances started during the big push and the heavy-5

- -push on the structural annulus steel modifications.

6 MS.'DURBIN:

., Which started when?

7 MR. TENNYSON: Actually it started before Christmas

^

w 8 but:the buil'd-up got bigger and the influx of-new people that 9

we're talking about -- when it went to like, I think, they 10 said 700,-800 iron workers and the company went up'to some-11 where around close to 1900 people in just a matter of a couple 12 of months there.

13 MR. KAUFMAN: From the time that big push started 14 to the time just before you left the site, had the error rate 15 changed'in any way?

.16 MR. TENNYSON: Not to my estimation.

6 17- MR. ROAM:

Well, not until the last couple of days.

18 They was trying to change it.

19 We was trying to get the foreman to do his job, 20 inspect the work before he called QC.

21 In other words,.you're the foreman and you got a

' 22 welder.

a You'should'be sure that your welder did the work 23 right then call QC.

. '24 QC would inspect it and if he was satisfied with.

25 -

it, accept it or if not, reject it.

26 But the foremen would not check the work. They 27 called QC so QC would come up and no choice; it's either right 28 or wrong.

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55

.c-

1 If it's wrong, you write it up. If it's right,

~

2 we had-to-write it up also but accept the. work and then go p- -3 to the next stage of work.

. 4 MR. KAUFMAN: .How many times had you. approached 5 the foremen on the job?

v* -6 MR. ROAM: To do that?

7' MR. KAUFMAN: Yes.

8 MR. ROAM: We didn't approach the foremen. We 9 approached management which was Skip Moses and get their

- 10 PeoP l e to.do their side of the work first; 4

' 11 Then when they were satisfied call us and that would 12 cut down your red tag situation.

13 In.other words, until it's turned over to us it's 14 in process and, therefore, they didn't do virtually anything

15. with it to make it right.

16 -If the guy has burned through, undercut or whataver, 17 he can go ahead and repair that but once we have looked:at 18 it it.'s out-of the. process. It's now into the final stage 19 of that' portion of the work.

20 At that ' time it's either. right or wrong.

21 MR. KAUFMAN: What was their reaction to your

,. . - request?

L 23 MR. ROAM: "Yes, that's what we're going to do."

24 MS. DURBIN: And did they do it?

-25 MR. ROAM: No .,

26 Therefore, it stayed the same and the other thing 27 was PG&E had me write a procedure called a " quick fix design 28 change" because the designs were so bad in a lot of cases and JACK EG AN REPORTING SERVICE See Annownt AD Desvt LAFAY ETTE C ALIFORNIA 94 549 1415 283 3172

56

- 1' what was supposed to be there was not there and what wasn't 2 supposed.to be there was there.

3 MR. KAUFMAN: What time frame are we talking about? -

4 MR. ROAM: At the end.- In fact, the EDR -- you 5 signed it, didn't'you?

o 6 . Well, the day before we got fired was the fact that 7 they was going to put a resident engineer in the field with 8 our QC people which he would then give it the magic wand.

9 MS. DURBIN: What does that mean?

10 MR. ROAM: Magic signature. PG&E accepting 11 responsibility, relieve Foley of any responsibility of any 12 ' design changes or modifications that have to be made in the 13 field to get the iron job done.

14 MS. DURBIN: That was not c normal-procedure, was s- 15 ' it?

-16 MR. ROAM: No.

17 What it did then was exempt the_ implementation of 18 QCP3 which was the NCR-type process.

19 As long as my inspector had that change and they 20 worked with that change, you put it with his report and it 21 went in our file.

  • - 22 MS. DURBIN: How many of those were you seeing on 23 an average day?

?

24 MR. ROAM: We hadn ',t ' seen any because we got-f, ired 25 the day after.

26 MS. DURBIN: The' day after this started?

27 MR. ROAM: Right.

28 So I don't know what they're doing now but I talked JACK EG AN REPORTING SERVICE see Ansownsao easvg LAFAYETTE C ALIFORNI A 94549 14151 283 3872

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57 1 to -- well, just what people have told me.

2 MS. DURBIN: Off the record for a moment, please.

s--

3

.( Discussion off the record.)

4' MS. DURBIN: What was occurring right before you 5 left? What happened the. day before you left?

. 6 MR. KAUFMAN: Could you explain the procedure that 7 was being used just before you left with respect to NCR's?

8 MR. ROAM: To eliminate writing an NCR they used 9 a cour!9 different memos.

10 One of them was the " quick fix design change" a

11. method.

12 MS. DURBIN: Was that what it was actually called, 13 the quick fix?

14 MR. ROAM: Yes.

15 What it is, it is a process used by PG&E to expedite-

_161 field design changes required to get the job done on schedule.

1/- This was,versus waiting to send the information 18 back up to San Francisco so they said, "We're going to 19 as-built the job here because what you showed us on the draw-20 'ing don't match. We cannot do it."

21- MS. DURBIN: What does "as-built the job" mean?'

o- 22 MR. ROAM: Well, it's like you. design that door 23 there to be six foot tall but along the way you find you got 24 an eight-foot door. So you put in an eight-foot door.

25 I'm going to make up another sketch now showing 26 an eight-foot door instead of a six-foot door.

27 MS. DURBIN: So you change the drawing to conform 28 :to what's physically there?

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58 1 MR. ROAM: Right.

2 You see, this is an as-built situation.

3 MS. DURBIN: So just before you left the resident-4 engineer would, when he saw something that would otherwise 5 be a non-conformance, write up a new design, okay that design 6 and you would then inspect the work on that new design rather 7 than the original design?

8 MR. ROAM: Correct.

9 MS. DURBIN: Thank you.

10 MR. KAUFMAN: Do you know what PG&E's procedure 11 was for sending the new drawing back to its headquarters?

12 MR. . ROAM: This is part of what we put into the 13 procedure, that it would be done onsite this way..

-14. Whatever way they had drawn up was sent up to PG&E

- 15 in San Francisco and incorporated into the drawing and they 16 -had supposedly gone through their calculations and.then their

- 17 final as-built drawing was made and then sent back down to 18 Diablo Canyon.

19 ' At that time to assure ourselves I talked with Virgil 20 about it. I said, "We got to assure ourselves somewhere that 21 it is done."

g 22 So we left a clause in the procedure that we will

- 23 check our records against these as-built drawings to assure 24 ourselves that that's what we really got.

25 In other words, that as-built sheet did not get 26 left out of the master drawings.

27 MS. DURBIN: You were obviously taking great pains 28 to niake sure this was done correctly.

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59 1 Did you get the feeling within the company that 2 your work as quality control and quality assurance people 3 was valued?

4 MR. TENNYSON: Pardon me?

5 MS. DURBIN: Did you get the feeling in your own

. 6 company that your work was being valued, that your work was 7 a value and appreciated?

8 MR. TENNYSON: No. I never did have that-feeling.

9 MS. DURBIN: What feeling did you get?

10 MR. TENNYSON: I've always had the feeling that 11 the only reason the whole quality department was there was 12 merely because it was a contractual obligation on Foley's 13 behalf to have, I guess, a quality department.

14 The contract required Foley to establish a quality s- 15 program. That's the way it was.

16- I felt the only reason we were there in the first 17 place was to fulfill those obligations.

18 MR. KAUFMAN: What kind of errors were you finding 19 in the instrumentation work that you were looking at?

20 MR. ROAM: Errors?

21 MS. DURBIN: We use that term generically.

b 22 MR. KAUFMAN: What kinds of NCR's were you finding 23 in instrumentation?

24 MR. ROAM: Very little because there was really 25 not anything to go by. You had a standard set of details 26 and if it didn't meet the detail you just tell engineering 27 and engineering would draw up some new details.

~

28 So you never had anything wrong.

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60 1 MR. KAUFMAN: Could you give me an example of that?

2 MR. ROAM: Supports for tubing, instrumentation 3 tubing. There was never'any type of a layout or sketch to 4 say how you're going to get- from Point A to Point B.

5 You -just go from Point A to Point B. How you get t 6 there, I don't give a darn. 'Just put it in.

7 MS. DURBIN: How long did that'go on? .Was it a 8 standard operating procedure since -- well, since when?

9 MR.-ROAM: Yes, since '73-74 until recently. Vance 10 Parker,.who I put in charge of our welders' certification 11 program for a while and --

12 You won't see him on that work chart there.

I 13 switched him over.to instrumentation engineering because that 14 was.his major background was hangar-supports.

~

'15 With his aid and me constantly trying to pressure

-16 construction they were starting to come up with sketches to 17- show not only construction but our_ inspectors what they're 18 doing.

19 You know, a detail, a sketch to go by of what you 20 need to do, what they intended to do and where we're going 21 to put in a new tubing or change things.

  • 22 Prior to that there was no sketches.

.23 MS. DURBIN: How could you possibly inspect work 24 when you had no sketch to compare it to?

25 MR. ROAM: They had like a similar type isometric 26- drawing but it doesn't really show you much.

4 27 It was just for typical installation of equipment 28 which is: "Put this equipment on a wall and install it this JACK EG AN REPORTING SERVICE see AmmowwtaD oneve

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61 i

l' 1 way." That's'the typical installation.

2 Now, not each installation is the same or was it-

.w shown as to how it.is. It was just typicals. Everything' l 3.

4 was typically-done.

5 MR. KAUFMAN
Did you use the same procedure that

.- 6 you used with the structural design changes?

7 Did you wait to determine whether these design 8 changes had been incorporated into the master. design for the g plant before you signed of f on the NCR?

10 MR. ROAM: Well, we never had any real NCR's in 11 the instrumentation that I knew of while I was there in charge 12 of it.

13 Most everything in that case was -- well, we was 14 working with production engineering and if we saw a problem .

i- '-

15 or a problem coming up we would inform them before we'd get

.16 .there.to get the situation corrected or something to' cover

17. the situation.

18 In other words, we had a little more lax time in 19 instrumentation to look farther ahead than we did in the civil 20 or structural steel work.

21 Therefore, we could sort of try to see what was 3

6 22 happening a little bit ahead of time instead of hindsight.

23' MR. KAUFMAN: Mechanical; what kind of errors were 4

24 you finding, what kind of NCR's were you finding in mechanical

25 work?

26 MR. ROAM: Well, mechanical, there again we didn't i

27 have too many NCR's that I knew of because if we would come s_

28 to a situation where thern was anything wrong we would just

-_ . - - - - - - - . - - ~ ~ ~ . - - - -

JACK EG AN REPORTING SERVICE see AnnowntAo omsvt LAFAYETT E. C ALIFOftNIA 9454 D j setSi 203 3172

62 1

hold.up inspection until they corrected it.

2- If it's right or wrong we're not going to buy it.

3 Therefore, if we're not going to buy it they can't sell it

[ 4 and they have to rework it to make it satisfactory.

5 So then they would_either rework it, scrap whatever-6 they'.re doing and start over or seek PG&E engineering waiver 7 'of whatever it.is saying, "Yes, that's okay. We'll buy that."

8 So if we buy it that's fine. We put it with our

.9 report and we put it in the files and say, "Here it is. It's 10 yours."

h 11 MS.-DURBIN: How often did that occur?

12 MR. ROAM: I don't know. Maybe 20 percent of'the 13 time, w

'14 MS. DURBIN: Again, what time period are we talk'.ng

_ 15 about?

16 MR. ROAM: I can't give you the date. Whatever 17 the date was that Virg put me over in instrumentation.

l'8 - MS. DURBIN: That's fine.

19 MR. ROAM: I can't tell you that exact date.

20 MS. DURBIN: But in the latter part of 1982?

21 MR. ROAM: Latter part around Christmas time. '

a'

~

, 22 MR. KAUFMAN: Let me ask you the same question hbout 23 the pumps. Same things? ~ %j_

a

. ~24 MR. ROAM: Well, rotating equipment was a lie 31'g 25 bit different. See, we had rotating equipment which was main-

.- d.*

26 ly just torques and modifications or maintenance. .'f-s 27 There was more on the maintenance side. Remember, ~

~~'

28 everything'was virtually at Diablo Canyon alrejdyg That?was' I 5-J ACK EGAN REPORTING SERVICE , e see ammownrap on:vr V LAFAvtTTE CALIFORNIA 94549 ,k?,

tel56 293 3972 /

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63 i 1 about the most smoothest running deal we had in rotating equip-2 ment =_. y 3 MR. KAUFMAN: How about strictly electrical work?

'4 MR. ROAM: Strictly electrical, well, electrical, L

5 'all we did was installation. We did nothing on checking, g 6 testing operations or anything like that.

7 In other words, any of the megor tests.

8 MS. DURBIN: What does that mean?

9 MR. ROAM: You test continuity or test the insula-10 tion in your wire.

11 MS. DURBIN: And that's so you don't --

12- MR. ROAM: To make sure you don't go to ground or 13 have a fault in your system.

14 That was done by PG&E directly themselves. They s, 15 were responsible for that.

MR. MAUFMAN:

+ -i ,

1,6 So the result of all the work you 17 Acre inspecting at the plant, the principal area in which 18 ' you were writing NCR's was in welding?

'19 MR. HOAM: Correct.

20 MS. DURBIN: But often that was because that was l'

21; the only area where you had an objective standard or objective 22 drawing to which to compare work you were seeing, isn't that 23 true?

24 MR. ROAM: Well, no. We had standards for raceway 25 supports.

26 And in electrical we'd have a raceway support and g .

. 27 they'd put a detail on it and it would say Detail S-269.

.f 28 tha would try to look at the sketch and yes, that's JACK EGAN REPORTING SERVICE see menowngap peryg t L AF AVEf f E C ALIFORNIA 94549 1415) 203 3872

2 is e

64 1 an S-269.

~

'2' It's bolted and it looks okay and doesn't look like

. v - >-

3. it's going to fall.down. -

o s . .

4 Then we'd completc the. documentation and that was, ,

5 it basically on electrical. The conduit was there.- It.was a 6 the right size and right color-code and went from Point ~A-7 to Point B.

e 8 MR. TENNYSON: I think the reason it was' smoother s 9 in clectrical is because everyone was more familiar with it 10 because we start'd e there as the electrical contractor and 11 the electrical details were much clearer as to how the raceway 12 under the -- the notes and so on were clearer as to how the 13 raceway was to be laid out, what sequence of events was to 14 take place and procedure was clearly defined, more clearly

- defined than the others as to what you were looking for.

~

16 Also the people were more familiar with it because 17 they.had worked longer with it.

18 So consequently it did go a little smoother in that 19' respect.

20 MS. DURBIN: Do you think your people were more 2i able to use their own judgment and experience in evaluating

  • 22 electrical rather than going purely by drawings and so forth?

23 MR. TENNYSON: Yes.

24 Well, not so much, no. I'm sorry.

25 It did go strictly by the drawing but the drawings 26 and details were clearly defined to us as to what uach indi-27' vidual support was to consist of, how many bolts, how many 28 . cross-members, what size the cross-member was, exactly what JACK EG AN REPO'tTING SERVICE seeAnnownsAoontva LAFAV E TTE. C ALIFOftNIA 94 54e 44151 283 3172

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65 1

it was to look like.

2 I mean, they were drawn on a book that was like 3 six inches thick and had 634 pictures i.n it of various types .

4 and each picture _was clearly defined _with notes on it of 5 substance-and so on, type of material, the whole works.

6 MR. KAUFMAN: Am I correct in understanding that 7 the-design' work was better for electrical, therefore, it made t .

8- your job and the job of those people who were installing 9' electrical work easier?

10 MR. TENNYSON: Yes.

jj MR. KAUFMAN: And you would not say that for the 12 structural stael aspects of the job?

13 MR. ROAM: They were good drawings probably but

i. 14 they still tried to use the mirror image.

15 MR. KAUFMAN: They were still using the old drawings?

i 16 MR. ROAM: l'ou had a lef t and right power plant.

17 MR. KAUFMAN: At what time were they using the mirror

! 18 image drawings?

,, 19 MR. ROAM: At what time?

t.

20 MR. KAUFMAN: Were they-using it in 1982? Did they l

21 ever stop using the mirror image drawings that you knew of?

l . 22 MR. ROAM: They continued.

23 MS. DURBIN: They were still using the mirror i

! ~' 24 image drawings when you left?

i.

f 25 MR. ROAM: That's what it appeared to me, a left l

l 26 and right.

i.

27 They used -- maybe I'm using the wrong terminology.

28 They make up a typical and this typical could be JACK EG APA REPOETING SERVICE SGS ARROwME AD ORIVE t- LAF AYETTE C ALIFORNIA 94$4 D

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1 used seven different places within that plant or within this

2. building.

w 3 Now, you take that typical to this installation 4 and.you.could be looking at it from the inside or looking 5 at it from the outside, in which case if we found the whole

._ 6 thing wrong getting ready to put the whole thing together 7 we'd say, " Darn, we did it on the wrong side. We were supposed 8 to be standing inside the building looking out when actually 9 we were on the outside of the building looking'in."

10 Anyhow, we'd rip it out and redo it.

c 11 MR. KAUFMAN: Whose responsibility is it for apply-12 ing the drawings to the jobsite?

13 MR. ROAM: Well --

14 MS. DURBIN: If you know.

s- 15 MR. ROAM: I really don't know.

16 I know we got drawings from PG&E but they come to 17 our engineers and what our engineering department.did, I could 18 not tell you.

19 MS. DURBIN: Who was responsible for furnishing 20 you with the drawings against which you compared the work 21 that you inspected, the standards against which you compared

. 22 the work you inspected?

23 MR. TENNYSON: The customer, which would be PG&E, 24 was responsible for all design to us.

25 ' MS. DURBIN: And up to the time you left they were 26 still furnishing you drawings which were not absolutely clear 27 as to whether they were left-hand or right-hand Unit 1 or

~

28 Unit 2?

JACK EGAN REPONTING SERVICE see AtmowME AD Dasyt LAFAYETTE C ALIFORNIA 94549 e41$3 2 53 3172 1

F 67 1 MR. TENNYSON: I ' ta not familiar with that portion 2 of it because of the fact that, I think, the. situation that-3 Rick is talking about -- and I did overhear a certain conver- a

.4 sation out there when we called the engineer over to ask him L5 for clarification on it.

. 6 Anyway, Rick Brun is the engineer who-is the-civil f

7 engineer at The Howard P. Foley Company. He was called over 8 for discussion on a drawing that Bob Carter found.

n MR. ROAM: I think it was Bob.

10 MR. TENNYSON: Bob Carter found it along with one 11 or two other people and they had gone out to inspect it.

. 12 It was found to be not like the installation or 13 it was the wrong drawing and that's about all I know about 14 it.

15 MR. ROAM: We fabbed up some T-braces.

16 MS. DURBIN: Can you answer my question, Mr. Roam?

17 MR.' ROAM: What?

4 18 MS. DUREIN: Were you cver supplied with drawings 19 that were consistently right-handed or left-handed for the 20 appropriate units that you were inspecting or were you con-21 ~stantly working with mirror image drawings up until the time

. 22 you lef t?

23 MR. BOAM: I can't really say because I think I 24 got it confused with a typical detail installation.

25 MR. TENNYSON, Could we go off the record for a 26 second here?

27 MS. DURBIN: Of course.

28 (Recess taken.)

JACK EG AN REPORTING SERVICE see Ammownrap omive L A F AT E:TTE C ALIFORNIA 9(S49 14 t S e 2 4 3 19 72

68-1 MR. KAUFMAN: Back on the record.

2 During the break Mr. Roam wanted to clarify about

.3 the mirror image drawings no let me see if we can clear this 4 up.

5 When we're talking about the design sketch and the 6 errors coming from the design sketch where are those errors

. .7 occurring?

8 MR. ROAM: Where? Well, in some cases the structural 9 steel members that. were not of a configuration engineering 10 thought they were for these modifications.

11 MS. DURBIN: Is it sometimes unclear from the design 12 sketch whether you should be looking straight at the member 13 from the inside or whether you should be looking at the-member li from the outside of-the building?

15' MR. ROAM: True.

16- .MS. DURBIN: I think we got that clarified.

17 Let's go on.

. 18 MR. KAUFMAN: Let me go on to a slightly different b

19. topic.

! 20 -Have you or any of the people working for you been 21 harassed by workers at the production end of the Foley 22 Censtruction Company?

23 MR. ROAM: Yes.

24 MR. KAUFMAN. Could you give us some examples of 25 that harassment?

26' MR. ROAM: One was of the new Cataract people that 27 came in -- well, Richard Spencer, a welding inspector that 28- I had on the mechanical side, was harassed quite a bit by JACK EG AN REPORTING SERVICE see annoweetao onsva

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69 1 construction at first.

2 He was inforcing them to try to meet code and the

~

3 Procedure and they didn't want to because it was costing them j 4 X amount of rework.

5 MR. KAUFMAN: When you say "them," who?

17, 6 MR. ROAM: Construction.

7 MR. KAUFMAN: Who specifically?

e 8 MR. ROAM: -You mean the construction foreman?

J 9 MS. DURBIN: Either that or a company name?

10 MR. ROAM: Well, it's Foley. We were all Foley 11 people there.

12 MR. TENNYSON: What su'erintendent p would be in charge 13 of'that?

14 MR. ROAM: I don't know. I wcs just trying to think

~- 15 of the guy's name.

16 MR. KAUFMAN: When this harassment occurred 17 Mr. Spencer, I take it, reported this to you?

18 MR. ROAM: Correct.

19 MR. KAUFMAN: And what did you do when you received 20 his report? '

, 21 MR. ROAM: Went up and talked with the foreman,

, 22 told him, "He's here to do his job. We will meet code. We

, 23 will meet the specifications."

~

24 They didn't really like it but realized that they 25 had to try to meet some of it.

26 The thing that was bot.hering them was that the 27 inspection intensity was not that strong before.

28 Now, all of a sudden, how come it is?

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.1 MS. DURBIN: What time was this? What year? What 2 month?

e 3 MR. ROAlt: First part-of '83.

4 MR. TENNYCON: Voc.

5 MR. KAUFMAN: Did anything change after you talked

. 6 to the superintendent?

'7 MR. ROAM: Not really. They just more or less e

8 . tolerated each other but they managed to work some things 9 out.

i 10 When I finally had to remove Richard and put him

{. 11 over at the welders' certification program, they was very 12 ' upset with it because they learned that he was picking out l 13 things in advance to help them so they wouldn't have a delay.

14 Then we had the situation with Roger Meek and I ,

i- 15 really don't know.

16 MR. TENNYSON: lie was a quality control inspector 17 for civil at that time inspecting on welding and structural.

18 He had been in tho' field numerous times and been 19 harassed by a production person, unknown to me.

20 MR. KAUFMAN: Could you indicate what type of 21 harassment that was being done to him?

. 22 MR. TENNYSON: Roger -- it's kind of touchy. I 23 think they were playing with him.

24 There was an iron worker out there evidently that 25 would go around patting him and calling him " fat boy" and 26- threatening to kiss him on the cheek and things of that nature.

27 Roger tried to avoid him and he finally told him

' 28 that if he didn't leave him alone, he was going to have to l

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l- 71 i 1 tell.his foreman.

l'

! 2 .lle finally did have to go to the foreman and tell

3- him that the man was harassing him or' bothering him.

i 4 Roger had many inspections to perform out there-t 5 and he was limited in the time that he had to do them.

( *

'6 Anyhow, t'he production man was quite upset, I guess, i

7 because Roger Meek had gone to the foreman on him and he told

?* 8 him if he ever went to the foreman he was going to whip.him i

9 or something, threatened him in some way.

l 10 Well, he kept grabbing him or holding onto him and i

11 Roger kept trying to get away. Finally he did get away from 12 the man and he come into the office to explain it to me.

! 13 So I, in turn, took the situation up to Mr. Moses.

14 Moses, as far as I know, did absolutely nothing about it.

.- 15 It was dropped at that point and Roger was left 16 on the job and I changed him around, put him in another area

, 17 or something.

18 MR. ROAM: You put him in another area to get him

'19 away from the guy to divert the situation.

20 MR. KAUFMAN: Was harassment a problem for your 21 people in preventing them from doing their job?

22 MR. ROAM: We just found ways of getting around it.

23 MS. DURBIN : It was a problem, though?

24 MR. ROAM: Oh, yes. Basically with the new people 25- coming in it was.

26 The old-timers that had been there for years, they 27 understood the situatior. in some aspects. They didn't like 28 it but they knew they had to live with certain things.

JACK EG AN REPORTING SERVICE see ammownrao oneve LAFAYETTE C ALIFORNIA 94549 sen Se 2 A 3 317.1

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'1 But a lot of new travelers coming in did have 2 Problems.

3 MR. KAUFMAN: What was your relationship to the

-4 Nuclear Regulatory Commission inspectors?

f 5 MR. JONES: Could you be'a little more explicit.

[ a 6 What do you mean by that?

7 .MS. DURBIN: .Did you ever meet any Nuclear Regulatory

-8 Commission inspectors? Did you ever see them?

9 MR. TENNYSON: Well, I understood that we had two 10 resident NRC people at Diablo but, I think, the only time 11 .they ever came to see me or to negotiate at any time with 12 me was during a time when we had an NRC audit.

13 Then they might come along with the offsite NRC 14 people or in one or two cases they came down with PG&E quality 15 assurance personnel on an audit.

16 Other than that I had no communication much at all s

17 with them.

18 MR. KAUFMAN: The only time that either of you saw 19 the NRC inspectors or anyone from NRC was during these audits; 20 is that correct?

21 MR. TENNYSON: Yes.

J 22 I had many more dealings with Dennis Kirsch, who 23 was an offsite Nuclear Regulatory Commission inspector and

. 24 John Burdoin. They were fairly regular to come in every few 25- months and weeks in some cases to either do an audit or a 26 follow-up on a previous audit to see if we conformed to certain 27 -- well, maybe it was design changes and things of that nature.

28 How they determined what they're going to audit JACK EG AN REPORTING SCRVICE see annowMEmo omivt L AF AY E TTE C ALIFORNIA 94 S4s 1495i 253 3t72 o

rm 73 1 ,when they come in to see un 1' don't kn'ow.

I We are told what they're going to audit.

2-

. s-3 - MR. KAUFMAN:. Did the NRC individual inspectLactual

4 work or only the records?

5 MR. TENNYSON: They did go out and inspect actual

6. worx and then in most cases balanced ~their inspectlons against 7 the findings in the documentation.

.8 'MR. KAUFMAN': How much.of the work did they look-9 at'when'they did this? -

10 MR. TENNYSON: Normally they're down~there a couple 11 days,'three or four days'at a time when they came.

12 They would pick a particular area out. I mean,

, 13 ~ one individual NRC man 'would pick 'a particular area like termi-14 nations or'maybe welding or something.

~- . 15 Then he would go into that'particular phase and f 16 go out and inspect. How much really in regard to pe'rcentage-17 or anything I couldn't say. I wouldn't have the slightest

,, 18 idea.

j 19 I'd say the percentage is pretty small.

20 'MR. KAUFMAN: Did they ever consult with you about 21 areas in which you were'having a particularly high_run of t

2'2 NCR's?

23 MR. TENNYSON: No, not to my knowledge. I don't

~-

24 recall anything like that.

! 25 MR. KAUFMAN: Before 1974 did the NRC inspectors I

L 26 coming out to the site --

i 27 MR. JONES: Before when?

28 MR. KAUFMAN: 1974.

JACK EGAbd R1 PORTING SERVICE see aneowngao onive LAFAYETTE C ALIFCRNIA 94549 1415 e 2 8 3 3 t 73 1

p-a, _. _

74 1- -- to review your work --

2 MR. JONES: I don't-see how he can answer that.

3 l MR'. KAUFMAN: I was asking Mr.. Roam.

4~ MR.-ROAM:- I remember'one time when the AEC came 5 out. . At that. time it was.AEC -- not NRC -- that brought about

'* 6 the original'~ change.

7 MS. DURBIN: In the procedures?

. 9-

_ 8- MR.. ROAM: In developing a quality program.

g At that time what they looked at.I. don't know because 10 1 didn't talk to them.

11 MS. DURBIN: Were these audits or inspections 12 announced to you in advance? Did you know when they were 1'3 coming out?

14 MR. TENNYSON: Most times we knew they were coming

.- 15 in.

16 MS. DURBIN: Was anything special done to prepare 17 for these audits?

18 MR. TENNYSON: I can only answer for my department 19 and nothing special was done at that time that hadn't already 20 been'done to satisfy any requirements or anything.

21 Our documentation was there'and open to them.

P-*- 22 MS. DURBIN: Do you know if production knew in p

23 24 advance which particular work the NRC inspectors might be looking at ?

.25 if you don't know, you don't. know.

26 MR.' TENNYSON: I don't know.

27 MR. KAUFMAN: Did the NRC inspectors ever find any 28 NCR's in areas where you hadn't found them?

JACK EGAN REPCHTING SERVICE som annowMEAD Onwt LAFAY ETT E C ALIFORNIA 94S49 141S1293 3172 6 -

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75 1 MR. TENNYSON: They have picked up -- well, what 2 they did was, they would do an audit.

3 They have picked up minor problem areas and through i 4 an' audit.given them back to PG&E. PG&E, in turn, would write 5 their own non-conformance aga inst The floward P. Foley Company

, 6 for not. documenting certain problems.

7 They have been very minor, as far as non-conformances 8 go.

p 9 One.particular that'I remember.was a detail of the l

1(L way an electrical support was installed. Out of numerous i-l- 11 welds, which were called out by size and configuration, one L

l 12 weld was left off of the PG&E document not stating the proper-l 13 size.

14 The man who bought that weld, along with the rest i

i - 15 of the welds, which were supposed to have been typical was I-

16 questioned and at that time we did go back a year in the files 17 and check out the work that he did and everything as a result 18 of.the audit.

19 MR. KAUFMAN: Do you have a procedure for checking 20 the work of your inspectors?

21 MR. TENNYSON: I don't think there was. No, there o 22' wasn't.

23 MR. ROA'M: Basically just trying to get the super-24 visors to get out there to check to see the man is doing the 25 job.

26 .MR. TENNYSON: The way the system was set up really 27 was through a document system and the supervisor I had over 28 document control and management.

I JACK EGAN REPORTING SE* VICE see annownrap oneve LAFAT ETT E. C ALIFORNIA 94 54 9 letSe 253 3172 L

76 1 .

l 1 lie would , inspect all of - the necessary paperwork 2 and review it to.see if the necessary documentation was with 3 that particular package and all the requirements were fulfilled 4 on it so that it could be signed off.

S' Then there was.a Oc stamp that went on it.before

- 4 -6 it went into the file and signed off by the supervisor of 7 that department.

e

-8 MR. KAUFMAN: Did you have any contact with the 9 independent design verification program for Diablo?

10 -MR. TENNYSON: Not to my knowledge, no.

11 MR. KAUFMAN: So they were not reviewing.any of 12 your work?

13 MR. TEN!;) SON : They could have been under another

! 14 Program but as far as me being connected with that portion f b 15 of it, .no.

+

16 MR. KAUFMAN: I think someone mentioned earlier

'17 ~ that you did review the quality of materials that were coming l

18 to the site; is that correct?

19 MR. TENNYSON: Yes.

20 MR. ROAM: Yes, materials received, yes.

21 MR. KAUFMAN: What kind of material is that?

i 3 22 MR. TENNYSON: Anything that had a Class 1 require-23 ment placed on the purchase order of which could be used in 24 a Class 1 installation.

p

'25 MR. KAUFMAN: What were you checking? What standards 26 were you checking that material with?

27 MR. TENNYSON: Well, in most cases the material 28 was checked for an approved vendor to buy from. Also certain 4

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77 1 requirements concerning the steel, that the requirements be

~

2 listed on the purchase order to call out the' type of steel 3 it.was and the configuration.

4 We could check for a letter of compliance on the 5 material and mill test' reports in areas where they were A 6 required.

7 These requirements are pretty well spelled out in

.e 8 the various specifications depending on the particular job 9 that you're doing in the field or buying the material for.

10 So each specification calls out the requirements 11 of the material to be. bought.

12 MR. KAUFMAN: Were you finding a large number of 13 NCR's with respect to quality of the material to be bought?

14 MR. TENNYSON: No. Any material that came in we 15 had a procedure set up that if the material came in and did 16 not meet the requirements of the purchase order it would be 17 red tagged at that time and placed in a holding area until 18 it was completely approved.

19 This was done either by returning it to the vendor

, 20 or the necessary paperwork and proper paperwork was received 21 before it would be released, in most cases.

22 MR. KAUFMAN: Were you ever asked to accept material 23 that did not meet the appropriate standards?

O 24 MR. TENNYSON: Yes, we were.

25 MR. KAUFMAN: When was that?

26 - MR. TENNYSON: The year I cannot tell you. It could 27 have been a year and a half, two years ago.that we started ss 28 receiving material in from the Bostrom Bergen Company.

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78 1 MR. KAUFMAN: What kind of material is.that?

y.

.2 MR. TENNYSON: That was fabricated steel and steel 3 shapes and configurations for various installations in the 4 plant.

5 These were fabricated to Pacific Gas & Electric's 4 6 design drawings which were sent to Bostrom Bergen and also 7 negotiated through their San Francisco office back and forth 8 with the company.

9 The materials were coming in in some cases-without 10 the necessary paperwork that we were required to have:for.

11 the installation.

12 MR. KAUFMAN: What kind of paperwork was that?

13 MR. TENNYSON: In some cases it might have been t

1 14 (your letter of compliance. In some cases a mill test report,

- 15 test results of the steel and showing the type that it was 16 and so on.

.17 This material was released to the field to speed 18 up production -- prior to receiving the proper paperwork on 19 it - by memo from Skip Moses, signed by him, which overrode 20 my_ authority to hold it.

21 Now, where he got his information or direction to 6 22 release, I'm not real sure of.

23 There was an audit performed by the NRC, I thirk,

.h 24 and there war, an allegat. ion m.ide by somebody saying that this 25 had happened. I don't know how it came about.

26 But they came out to look for this particular 27- situation where items were being released prior to paperwork ,

28 received and they did find all of the memos in the file -- as l

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1 I~had-in my documentation -- signad by Mr. Moses releasing 2 the materials to-t.he field.,

3 We set _up quite a review program and reviewed all 4 of the purchase orders at the request of the NRC and pulled out 5~ all of the memos releasing items and getting with Bostrom 6- Bergen, dealing back and forth with them, getting all of the 1 7 necessary paperwork brought up to date to close out this'non-M 8 conformance.

9 We had to write a non-conformance against The 10 Howard P. Foley C'mpany o for doing this. That's about all 11 I can remembcr about that part of'it.

12 It was finally closed out by the Pacific Gas &

13 Electric Company.

14 MR. KAUFMAN: By ti:at you mean it was determined 15- that the material met the standards?

.!, 16 MR. TENNYSON: Yes.

l' 17 MR. KAUFMAN: But you haven't seen the documentation 18 for_that, have you?

=

19 MR. TENNYSON: Yes. We reviewed the documentation 20 'as it came in and I had help from our engineering staff in 21 correlating the paperwork back and forth from Bostrom Bergen 22 to The Howard P. Foley Company and in building the necessary 23 packages with the necessary paperwork to satisfy the require-24 ments of it.

25 MR. KAUFMAN: Off the record.

26 (Discussion off the record.)

27 MR. KAUFMAN: Did you have a relationship with the 28 quality assurance management of the other companies at the J ACK EGAN REPORTING EEf*VICE see ammowngap on:vt LAFAYETTE C ALIFORNIA 94$49 e4tSt 243 3s/2 L.

80

-1 site? -

. 2 MR. TENNYSON: No.

3 MR. KAUFMAN: - You didn ' t talk to' them at . all?

~

'i MR. TENNYSON: No.

5 MR. K4UFMAN: I don't think 1.have any more-questions

.. 6 other than the catchall question ~, that is, at the time you-7 left the site, how many NCR's were outstanding? If you can-e 8 answer.that question.

9 MR. TENNYSON: .I would say in the neighborhood of 10 80, wouldn't you?

11? MR. ROAM: Somewhere in that area. ]

MR. TENNYSON: We had a hundred and twenty-some u 12 ~

~

13 when we were working on that Saturday and by working on them 14 we brought them down.

MR. ROAM:

~

v 15 Sunday.

16 MR. TENNYSON
Yes, Sunday.

r- - ,

,- 17 MR. KAUFMAN: Could you give us a breakdown of where 18 these NCR's were located? What areas do they involve?

19 -MR. TENNYSON: You wrote them.

20 MR. ROAM: Virtually all disciplines that we handled.

21 The majority of them were in the civil structural site.

.i 22 MR. KAUFMAN: You're going to have to break that 23 ' down a little bit for me.

, c.

24 MR. ROAM: Some in termination and calibration which 25 would have been along the electrical side.

.26 Then some mechanical, some on the instrumentation, 27- old ones that weren't in the limelight.

28 Then Lhe rest were like on the civil structural JACK EGAN RE. PORTING SERVICE see anaowestac omsvt LAFAT ETTE CALIFORNIA 94549 setSt 283 3072

81 1 site.

2 MR. KAUFMAN: Had you been asked by your own produc-3 tion management or-PG&E to remove any,of these tags?

4 MR. ROAM: No. Not on the electrical or mechanical 5 and stuff like that, no.

6 MR. KAUFMAN: Thank you.

7 MS. DURBIN: I have a few more questions.

s-8 You said-you were-working on a Sunday. Was it 9 common for you to work on weekends?

10 MR. TENNYSON: We were working quite a few hours 11 at that time. Myself, when I started in with the overtime 12 I was putting anywhere from 60 to 65, 70 hours8.101852e-4 days <br />0.0194 hours <br />1.157407e-4 weeks <br />2.6635e-5 months <br /> a week.

13 " hen it went up to 70 and 75 in a week or so. One 14 week or two I put in 80 some hours, 85.

15 MS. DURBIN: What time period was that?

16 MR. TENNYSON: Right after the first of the year, 17 January,-February.

18 MS. DURBIN: Were your people working for you putting 19 in equivalent hours?

20 MR. TENNYSGN: Yes.

21. MS. DURBIN: You were all putting in 60, 70 hours8.101852e-4 days <br />0.0194 hours <br />1.157407e-4 weeks <br />2.6635e-5 months <br /> 22 a week on a regular basis?

23 MR. TENNYSON: Well, no. All of the inspectors 24 were putting in a 60-hour week.

25 . MR . ROAM: Yes.

26 MR. TENNYSON: They were required to work -- it 27 was mandatory to work ten hours a day, six days a week.

28- MS. DURBIN: Is this common in the construction JACK EGAN REPORTING SERVICE see me.oweegap on vt LFAvtTTE C AllFORNIA 94549 84156 2 n3 3,?2

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\

1. ' industry?
2 -NR. TENNYSON
.Oh,

) I think it does-happen throughout

. 3 che- construction industry if t. hey get a big push on something L -4 I' but this'one lasted so long people:were getting pretty' tired.

..: 5 i MS. DURBIN: 'Did you ever feel that your people

6
-- were working when they oughtn.'t to have been? They were i

3

7e overlyftired-or' overly stressed?

~ '

8' M R '. TENNYSON: It.was hard for me to tell. I was 1

9 ' pretty tired myself.

'10 It would be hard'for me to answer. It's hard to

11 put a time limit on how long a person can stand up. Sone

~21 people can do.60, 70, 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> a week for weeks after weeks

[ 13 and others will break.down-under the strain.

14 MS..DURBIN: Lawyers have the same experience.

15 MR. TENNYSON: Everybody was showing -- including 16 production forces in'the' field -- which you've seen in the 17 newspapers -- where-they refused to go into work.

18

. They were tired of six and seven days a week.

19 MS. DURBIN: Was it' common to have a night shift 20 of quality assurance : people also?

21 MR. TENNYSON: Any time there were production people

, 22 doing Clast 1 installation or non-Class 1 that would require

.23 inspection, yes.

24 MS. DUHBIN: Is ihat common in the construction

. 25 industry?

26 MR. TENNYSON: Not generally in construction, I 27 don't think.

  • 28 MR. ROAM: When you say " construction industry,"

JACK EG AN REPORTING 5'iRVtCE LAFAve TF CAL

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. . - - . , . , , _ . . . _ . -- m_ - _- .. . . . - - . . . . .

p.,w m%ae --mwe'-

83 1 you mean nuclear power plant construction industry or construc-2 tion industries in general?

3 MS. DURBIN: Nuclear power plant construction.

6 4 MR. ROAM: -Most of them would have a requirement J

5 for that.

v 6 MS. DURBIN: How about construction in general, 7 non-nuclear' power plant construction?

i

(*

ri 8 MR. ROAM: Then it depends totally on the contract.

'. 9' Some requ' ire; some don't.

10 MS. DURBIN: Sounds like construction was really 5 11 at a feverish pitch by the time you were leaving?

t 12 MR. ROAM: Still is.

13 MR. TENNYSON: Yes.

14 MR. ROAM: They just now wound down and went back t.

!- 15 to a 40-hour week recently.

L 16 After we quit they went to a 70-hour work week.

17 - MR. JONES: This is based on information otherc 18- have told you?

19 MR. ROAM: Yes. Sorry. I wasn't there so --

20 MR. JONES: Let me caution you to answer of your 21 own knowledge. That will keep things shorter, too.

22 MR. KAUFMAN: Let me ask you this:

, We also are 23 involved with OSHA. We are not representing them in this 0 24 particular i nstance, but 1 feel some aced to just ask you 25 a few questions about the other reports we've seen in the 26 newspapers about high amounts of ozone from welding at the 27 site.

28 Were your people -- and you in particular -- required JACK EG AN REPORTING SERVICE sea ammowntAo omsvE L AFAY E TTE C ALIFORNIA 94 54 9 totSe 2 9 3-3172

'84

'I to work in' circumstances where it was difficult to breathe, 3

}' g .

~2: where you were wheezing and coughing during your inspections?

3 MR. ROAM: .Yes. I had lost time'by. inspectors of 4- being sick from being up in there.

5 MR. KAUFMAN: When did these problems start?

.- .. s

-16 MR. ROAM: When they.3 tarted welding in there. .They I 7 started from then.

o _.

8 MR. KAUFMAN: And that's welding in .the fuel-handling 9 building?

10 MR. ROAM: Yes.

11 MS. DURDIN: Has that been a consistent problem?

12 MR. ROAM: Consistent with crafts as well as our 13 own people. They get sick and you just-try to shuffle them 14 around, put somebody else in there and let him clear his lungs

~~

15 out.

16 MR. KAUFMAN: Do you believe this had an, impact 17 on the qualit.y of work t h. i t. product. ion was performing?

18 ~ MR. HOAM: No, I don't. I really don't want to 19 answer that.

20 MR. JONES: If you don't know, you don't have to ,

21 answer.

o 22 MR. KAUFMAN: That's right.

23 Well, did it have any impact on the quality of work c

24 that your own peopic were doing?

~25 MS. DilRill N : Was it substantially harder for them 26 to do their job?

27 MR. JONES: That's a different question, u

28- MS. DURBIN: I was just t.rying to help.

J ACM EGAN REPORTING SERVICE see AnnowngAO canvg L AF ATE TTE C ALIFORNI A 94549 14156 283 3172

. . - - ~ . .-

85 1 MR. ROAM: Only from the grumblings of the people 2- themselves but -as to say whether they did it good or bad, 3 I could not say.

4 All I can do is listen to their grumbles and com-5 plaints to me. .

.a 6 MR. KAUFMAN: Okay. One last series of questions.

7 Are you familiar with the intake cove at the plant?

8 That's where the water comes in from the ocean to the cooling 9 pumps that sends the sea water through the plant?

10 MR. ROAM: I'm 'not real farailiar with it. . I've 11 been down there several times.

12 MR. KAUFMAN: llave you been there during the storms ,

13 which have recently. occurred this year? That's a convoluted 14 question.,

15 MR. liOAM: Well, I've been down there once during.

16 the storm, yes. It was the earlier part of the storms.

17 MR. KAUFMAN: Were waves breaking over the revet-18 ment?

19 MR. ROAM: I really wasn't paying mucn attention 20 to the waves.

.o 21 I was looking at the w'ater coming down the goddamn 22 conduits and wondering about all the connections inside. I

- c. 23 wasn'L worried about the waves outside.

24 MS. DURBIN: You didn't happen to see how far up 25 towards the plant the waves were breaking on the shore?

26 MR. ROAM: Most of them were breaking on the break-t 27 water themselves.

y-20 I wasn't paying that much attention to whether they JACM EGAN REPORTING SERVICE

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, - ~,

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L, 86 1 was carrying in there at'the screens.

=2 MR. KAUFMAN: Off the record.

3 (Discussion off the record.).

(( 4 MS. DURB'IN: When you were-hiring people fairly 5 close to the end of the' big push were you hiring some people a

6- who had no previous; experience as quality control inspectors?

, c.  ? MR. TENNYSON: You're saying near the end. What-8 I was referring to a while ago was, you know, earlier.

9 MS. DURBIN: At any point during the time'you worked a

10 .there, did you hire' people who had no experience as inspectors?

11 MR. TENNYSON: Yes.

MS. DURBIN:

12 Did you hire people who had no previous 13 experience with construction or-in the nuclear industry?

14 MR. TENNYSON: Yes, in some cases, yes.

< w 15 MS. DURBIN: How much training.did they get?

16 MR. TENNYSON: Other than possibly maybe some 17 ' schooling along the way,-engineering training or something 18 to that effect?

19 MS. DURBIN: Well, how much training did you give

< '20 -them?

21 MR. TENNYSON: They were trained with an experienced c.

L 22 inspector for nometimes maybe 30 days before they were really g 23 I tirned out by thomnolven to p rform inspections and not then 24 if we fe l t. that they were still weak in certain areas.

25 MS. DURBIN: Okay. Thank you.

' 26 MR. KAUFMAN: I promise you, just this last ques-27 tion.

28 Is it common practice in quality assurance programs JACM EG AN REPORTING SERVICE w e A m en***E AD OmsvE LAFAYsT1E C ALIF0FNIA 94549 54198 . 83 3172

,s,. - - ,- , . , , . -

-- - - - - - - + -

_ __ _ _ u _ i _. - - . ..

87 1- to check'the work of the~ inspectors on a formal basis,;the.

'- work fthat ' th'e ' inspectors ' have done on .a formal basis?

3 In other words,.does the quality assurance program-

~

~

4- in most industries require that the work the inspector does-5- .is, in turn, inspected by someone else in the quality assurance a

~6" organization?

C 7 MS. DURBIN: .'Is there any' quality assurance for 8 quality assurance?

MR. ROAM: You got two phases.- You got quality 10 control and quality assuranco.

11 That's where everybody is. mistaken. Quality control 12 is the inspection. Quality ansurance is the assurance that 13 the inspection and procedure is correct.

14 There's no quality assurance of the quality assur-

- 15 ance.

16 MR. TENNYSON: Your quality assurance is the monitor-117 ing device to see to it. tinat you're adhering to. your procedural 18 requirements.

19- MS. DURBIN: Well, is.there quality control of 20 quality control?

21 MR. ROAM: What you're saying basically: Is there o

22 direct supervision or monitoring of inspectors? ,

,A 23 MS. DURBIN: Right.

24 MR. TENNYSON: Yes. /

25' MR. ROAM: Yes. Not per se. It's written.up and

, , 26 .that's your job, you know.

27 MS. DURBIN: To go out and do it?

v 28 MR. ROAM: Right.

JACK EG AN REPORTING SERVICE -

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1~

M R '. KAUFMAN:-- Do you do that on a' judgmental: basis 2- or do you have any --

3 MR. ROAM: Same as'you'would do with your secret'ary, 4 working for'you~is how you.do it. The same thing.

5 MR. KAUFMAN: Are there any areas in which yo'u

  • - 6 inspect more than others?..

J

-7 MR. ROAM: Depends.on the position of the. man. If 8

I'm~ strapped behind a desk.I'm trying to look at'all the paper-9 work and judge it'from that.

10 MR. KAUFMAN : All right.

11 Thank you very much for coming. We appreciate all 4

12 the time you have taken to help us in this matter.

4 13 MS. DUHBIN: The statoment is now closed.

14 (The sworn statements concluded at 3:30 p.m. )

, c 15 ---oOo---

16 17 18 19

, 20 7

9 if e

- 21 5 4 ~22 23

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-24

, 25 s

26 27 3-- - ' 28 JACM EGAN REPORTING SERVICE e se ammow rao Oeive L AFATETTE C ALIFORNIA 94S49 84151 2e3 3872

q 89 1 STATE OF CALIFORNIA )

) ss.

2 COUNTY OF MARIN ) '

3 4 1, BONNIE L. WAGN Elt , a Certified Shorthand Reporter, 5 License No. 5881, and duly qualified Notary Public of the 6 County of Marin, State of California, do hereby certify:

e 7 That the foregoing transcript of sworn statements 8 of Virgil M. Tennyson and Richard E. Roam, taken on Tuesday, 9 the 5th day of April, 1983, is a true, accurate, and complete 10 transcription of my shorthand notes.

11 12 DATED this 12th day of April, 1983.

13 14

s. - 15 16 N AN , R #5881 17 18 19 20 21 6

22 t 23 24 25 26 27

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28 J ACK t o A P. Mt PORTING D E RVIC E

  • er . . ive r ao omrwg LAFA16 IT, 4 4 Lit ORNI A 94S4 9 ,

8415 283 3172

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UNITED STATES OF AMERICA -

NUCLEAR REGULATORY COMMISSION '

C?.I!\" y - "

In the Matter of

.g g m 130.04 ,

PACIFIC GAS AND ELECTRIC COMPANY ) Docket No. 50-275 7 ~

~

) Docket No..500323 .

Diablo Canyon Nuclear Power ) lEU };,jj C' [

~~

Plant, Units 1 and 2 )

. ~

)

CERTIFICATE OF SERVICE ~~

The following document of the State of Calitornia has been served today on the following by deposit in the United Sta'tes mail, properly stamped and addressed: /

Judge John F. Wolf Mr. Frederick Eissler - '

Chairman Scenic Shoreline Preservation Atomic Safety and Licensing Board Conference,.Inc. .

U.S. Nuclear Regulatory Commission 4623 More Mesa' Drive Washington, D.C. 20555 Santa Monica, CA 93105 Judge Glenn O. Bright Mrs. Sandra A. Silver Atomic Safety and Licensing Board 1760 Alisal Street U.S. Nuclear Regulatory Commission San Luis Obispo, CA 93401 Washington, D.C. 20555 Mr. Gordon Silver Judge Jerry R. Kline 1760 Alisal Street -

Atomic Safety and Licensing Board San Luis Obispo, CA 93401 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 John Phillips, Esq.

Joel Reynolds, Esq.- '

Mrs. Elizabeth Apfelberg Center for law in the Public c/o Betsy Umhoffer Interest 1493 Southwood 10951 West Pico Boulevard San Luis Obispo, CA 93401 Suite 300 Los Angeles, CA 90064 Janice E. Kerr, Esq.

Public Utilities Cummission David F. Fleischaker, Esq.

State of California P.O. Box 1178 5246 State Building Oklahoma City, OK 73101 .

350 McAllister Street San Francisco, CA 94102 Arthur C. Gehr, Esq.

Snell & Wilmer Mrs..Raye Fleming 3100 Valley Bank Center 1920 Mattie Road Phoenix, AZ 85073 Shell Beach, CA 93449 .

t #

- amm

y- y ^ ,

6' f 3 a ~ ~so -

f1 p ;r  ;;

lChairmanL .

- Judge.W. Reed Johnson. -

Atomic' Safety'and Licensing Atomic Safety and Licensing 1  ; Board Panel Appeal Board - ,

if U.S."l Nuclear :-Requatory Commission - U.S. Nuclear. Regulatory Commission, g'

,J (Washington,jD.C. 20555 Washinaton, D.C. 20555 ,

. Judge John 1H. Buck Secretary ,.

P JU.S. Nuclear Regulatory Commission Atomic Safety'and Licensing '

Attention: Docketing'and Servicing U.S. Nuclear Regulatory Commission-Section ~ ,

Washington,LD.C. 20555 ,

Lawrence J. Chandler, Esq. Commissioner Nunzio J. Palladino ,

. Jack R. Goldberg, Esq. Chairman U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Office of Executive Legal Director 1717.'.H Street, N.W. "

' Washington, D.C. 20555 Washington, D.C. 20555 Mr.' Richard B. Hubbard Commissioner John R. Ahearne MHB Technical Associates U.S. Nuclear Regulatory Commission

  • 1723 Hamiton Avenue, Suite K 1717 H Street,.N.W.

San Jose, CA 95125 Washington, D.C. 20555 --

Commissioner Victor Gilinsky . [

Mr.-Carl Neiberger U.S. Nuclear. Regulatory Commission ,

. . Telegram Tribune 1717 H Street, N.W.

. P . th Box 112- Washington,.D.C. 20555 l l-San.Luis Obispo, CA 93402 Commissioner James K. Asselstine ,

Commissioner Thomas M. Roberts . U.S. Nuclear Regulatory Commission 1 U.S. NuclearLRegulatory Commission 1717 H Street, N.W. .{

20555

~

17.17 H Street', N..W. Washington, D.C.

' Washington, D.C. 20555 r f

PG&E P.O. Box 7442

~

. Judge Thomas S. Moore I Cnairman . San Vrancisco, CA 94120

' Atomic. Safety and Licensing. Board

'.S. Nuclear Regulatory Commission U Bruce Norton, Esq. ,

Washington, D.C. 20555 Norton, Burke, Berry &

French, P.C.

P.O. Box 10569 Phoenix, AZ 85064 DATED: April 14, 1983.

naa Wfdst[-

SUSAN L. DURBIN i

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