ML20199H215
Text
7 Janauary 7, 1984 Note to:
Vincent S. Noonan, Director Comanche Peak Task Force From:
Geary S. Mizuno Attorney for OELD
SUBJECT:
HANDLING OF DCAs AND CMCs - EVERT MOUSER DEPOSITION During the January 3,1985 deposition of Mr. Evert Mouser, a former QC inspector at CPSES, Mr. Mouser expressed a concern regarding the handling of Design Change Authorizations ("DCAs") and Component Modifica-tion Cards ("CFCs"). Judge Bloch requested that this concern be brought to the attention of the TRT. Accordingly, enclosed please find a copy of Tr. 22,779-89 of Mr. Houser's deposition, where Mr. Mouser discusses his concern.
1 Geary S. Mizuno Attorney for OELD
Enclosure:
As steted DISTR!PUTION:
.iG5Mizuno ESchristenbury RGBachmann JPMurray CABerry JLieberman SATreby OELD Rdo. #ile MKartan SBurwell DeP 4 aputtR 0/C file Chron file L'. Brown, Reg. IV DFC l0 ELD
- DELL NAME :GSMizuno:ml :
SATQ DATE :01/07/85
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A I think thoy wtnted to haar cbout thsm, but the 2
way they reacted to them discouraged the people.
3 Q
And how was that?
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A They would get upset.
They would kind of give 1
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you cross-examination as to, you know, like we'll say
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" Hey, I looked at this and it looks bad to me."
"Well, 7
what nakes you an expert?"
f 8
Q And who were the people who, from your own 9
personal experience, you had observed doing this?
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10 A
okay.
Mr. Tolson is the only one that I had, t
'een come back on that keel saying:
"We'll take 11 you know, s
j 12 care of it.
That's all right.
Don't worry about it."
i 13 Mr. Tolson is the one that I had seen do that previously.
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14 Q
Had you, at that time, had any interaction with w'
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15 Mr. Merritt and had the tensions between the two of you 16 developed yet?
17 A
Not at that time.
Also, I recall a lot of 18 hearsay from the other inspectors on the site that had 19 been there for some time, you know, as to the different l
20 things that Mr. Tolson had done.
His attitude toward ps' 1
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21 people bringing problems up.
I 22 Now a lot of that is from hearsay from other inspectors.
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23 I dealt with Mr. Tolson twice.
The first time was a total e
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24 shambles and the second time wasn't so bad.
25 Q
What were those?
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1 A
Danign changs, the way wa w3re going to not up 2
design change authority, way to handle DCAs and CMCs and 3
items like this.
4
,Q Well, which one?
You said the first time was a 5
total shambles and the second was all right.
6
'A The total shambles was we presented to him the~
7 way that we felt, from doing an investigation on it, 8
exactly how it should be done.
9 Q
How?
Could you be more specific?
How what 10 should be done?
11 A
'By reviewing each individual DCA, and each 12 individual CMC; and going through and reviewing each one,,
13 categorizing each one into areas, breaking them down by i
14 building and revising the paperwork and verifying that, 15 yes, it was done; and all the requirements are met and it 16 is signed off and everything like that.
17 He, at that point said flat:
"No.
That's not the way 18 I want it done.
You don't have the total concept in 19 mind."
He got all upset about that.
20 JUDGE BLOCH:
Let's slow up a little bit.
I'm 21 sure Mr. Roisman was going to ask what was the job you 22 were doing?
I don't understand.
What was it you were 23 setting out to have Mr. Tolson accomplish on these CMCs?
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24 THE WITNESS:
Okay.
On the job I was doing, I 25 would take a CMC, a component modification card, and I i
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.BRT i
1 would take it end I would pull it out.
If it wao on o
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2 quality item, I would take that on down to the vault, pull 3
the documentation out, review the documentation to make 4
sure that the CMC was noted on the document so that the 5
work was done in accordance with that CMC.
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6 If it wasn't on the card, then they had some backfit 7
operation to do, to go back down and reinspect because 8
there has been a change in design of tha item.
9 JUDGE BLOCH:
So what you were doing was to 10 check to see whether the documentation that was in effect 11 at the time was available to the QC inspector who was 12 doing an inspection?
13 THE WITNESS:
No.
I was verifying that the I
14 documentation that was in effect at the time did indeed 15 cover the design change that was done.
16 In other words, I'd take the CMC, look at it, go down 17 and look at the documentation.
On the bottom of the 18 documentation would be the travelers or the inspection 19 report or weld report or something like that.
And if they 20 put down on the bottcm, " CMC 1492, rev.
1," and I had CMC j
21
- 1492, 2,
nowhere in the documentation was there any I
22 reference in that package for that new CMC 2.
So that 23 meant that they had to go out and reinspect that item to I
24 verify that it was up to the change in the design that was 25 brought out by that CMC.
w
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.BRT 1
JUDGE BLOCH:
So ycur job w3o to find cut 2
whether or not the CMCs had resulted in work that was then 3
inspected?
4 THE WITNESS:
Yes.
And then I was al,so, 5
res,ponsible for some that had been done that, if it did --
6 if it did say " rev 2," I was responsible to go to the 7
field, look at the item, and, indeed, to make sure that it 8
just hadn't been changed on paperwork and not inspected.
9-JUDGE BLOCH:
And was part of your job having to 10 do with seeing whether there was a pattern of problems 11 that were arising with -- as a result of the CMCs?
12 THE WITNESS:
Yes.
13 JUDGE BLOCH:
What was that part of the job?
14 What was the problem there?
15 THE WITNESS:
We were to see if -- like one 16 standard hanger, if they make up one CMC for plant-wide 17 changes.
So we'd have to go back to every hanger of that 18 style and that number and look it up and verify that that 19 was done for every one of them.
20 JUDGE BLOCH:
Okay.
Now, maybe I can understand 21 the next part of what Mr. Roisman -- I'm sorry I couldn't 22 figure it out at all.
23 BY MR. ROISMAN:
24 0
What was it that you had proposed to Mr. Tolson 25 and what did he respond to with regard to that process
BRT i
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1 that you just daccribad?
1 2
A Okay.
We went in and responded to him.
He t
3 asked us what we were doing.
We went in and told him:
4 Thi's is what we have decided to do.
5
,o And that's what you have just described to the i
6 Chairman a moment ago?
7 A
Yes.
8 Q
All right?
9 A
I'll go through it again.
What we had decided 10 to do was make up the computer program.
11 In that computer program to include pertinent 12 information off the CMC, and to verify that by entering 13 the appropriate dScuments that that-CMC affected.
'I 14 The appropriate. documents would be any quality 15 documentation for'that hanger, for that cable tray, for 16 that conduit support.
And we would'go out and look at all 17 the documentation; and then additional things we would do 18 is add, oh, heavens, the location, type of hanger, 19 whichever, pertinent to that CMC.,
AndMr.Tolsonfsays:
"No, that's not the way I want it.
20 21 I don't want it that way.
It won't work.
You don't 22 understand what you have been told."
And that's why I say l
23 it was a total shambles.
He didn't agree with anything we
'i 24 had to say.
25 JUDGE BSOCH:
Did he tell you how he wanted it t
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dono?
2 THE WITNESS:
Yes, that's not how he wanted it 3
done.
t 4
JUDGE BLOCH:
How did he want it done?
5 THE WITNESS:
He wanted it simply just the CMC 6
li$ted and then the design change documents listed.
He 7
didn't want the additional information put on the computer 8
and I don't think he wanted to program it; I think he 9
wanted just a loose-leaf-type list made up of these CMCs.
10 BY MR. ROISMAN:
1 11 0
Is it that what he wanted was to backfit the 12 doedments to the component rather than make sure the 13 component met the documentation?
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14 A
No, it wasn't so much to backfit the 15 documentation, it was to verify that the documentation was' 16 there and did reflect what the CMC said.
17 O
As I understand it that's what the computer 18 program would have done?
19 A
Yes.
20 Q
But his approach to it, that last link never 21 would have been made.
That is you'd never know whether 22 the last design change or last component pod any 23 indication, was in fact in place in the field and had been
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24 inspected by a QC inspector after it was in place in the-25 field?
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A Yeo.
And tho oyotem h2 wantGd, like, cay --
2 what you are saying is correct -- the system he wanted to 3
set up would not draw that last one out; would not show 4
the' final CMO.
5 g
It would also miss the CMCs along the way that 6
had not been properly integrated into the system as well?
7 His approach, Mr. Tolson's approach?
8 MR. TREEY:
Mr. Chairman, I think I'm going to 9
object.
I don't knew how much further we are going with 10 this, but this is certainly way beyond the scope of what 11 this deposition was called for, which was to talk about 12 the Lipinski trip report, various occurrences -- or
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13 conversations before, during, and after Lipinski's trip i
14 and to talk about coatings ma'tters.
We are now talking 15 about a subject totally outside of coatings.
And I guess --
16 JUDGE BLOCH:
That sounds like his response.
I 17 understand your point.
Do you agree?
18 MR. ROISMAN:
No.
It seems to me the question 19 was and is the basis for Mr. Lipinski's views and 20 Mr. Mouser's input to those.
One of those pieces of input 21 was Mr. Mousers perception of Mr. Tolson; and this event, 22 on which I have virtually no more questions beyond the one 23 that's pending -- but that's neither here nor there --
l 24 goes to the b' sis for Mr. Mouser's: statement.
It happens a
25 that his perception of Mr. Mouser arose outside of u
v.
3
ERT I
coatinga -- had nothing to do with contingo; croce outcida 2
the Lipinski trip, so couldn't have had any feelings about 3
Tolson.
But yet it formed the basis of the trip reports 4
and' formed the meeting of the mindo, if you will, between 5
Mr. Mouser and Lipinski on the 28th of July.
6 JUDGE BLOCH:
So it's only this one question 7
that you want to ask?
8 MR. ROISMAN:
Yes.
But my point is that I think 9
that line is legitimate because that's what it is going at:
10 how it is that Mr. Mouser has his views on Mr. Tolson.
11 JUDGE BLOCH:
Mr. Watkins?
Your comment?
12 MR. WATKINS:
Just so long as there is only one 13 question.
I would add this is a discovery deposition, so --
i 14 JUDGE BLOCH:
One question, sir.
Or thereabouts.
15 MR. WATKINS:
No. 1.
16 (Laughter.)
~17 JUDGE BLOCH:
I have never heard a lawyer ask 18 one question.
You have a paradox there.
19 MR. ROISMAN:
To meet Mr. Watkins' concern, 20 would the reporter read the pending question, please?
21 (The reporter read the record as requested.)
22 JUDGE BLOCH:
Would you like to answer that, 23 please?
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i 24 THE WITNESS:
Yes, that is true.
I have to add 25 one other item.
I left Mr. Tolson hanging.
After many m
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1 long discuccions among our cuparvicor and us wo wsnt back 2
down to Mr. Tolson and he did agree to do the system the 3
way that we had originally wanted to do it.
We did 4
confirm to him that that was the best way to do it.
5 BY MR. ROISMAN:
6 Q
Your supervisor then goes back to this gentleman 7
who you mentioned earlier, either Michaels or the person 8
who --
9 A
Peter Bush -- yes.
10 0
-- who replaced him?
11 A
And Mr. Tolson did in fact agree that what we 12 had was a better system than what he had originally set 13 forth.
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14 O
And is that the second meeting that you had?
15 A
Yes.
16 0
You said one was a shambles and the other 17 everything had wor:,ed out all right, and that's the second 18 one?
19 A
Yes.
Yes.
20 JUDGE BLOCH:
Mr. Treby, there's enough here 21 that might be relevant to the work of the task force on 22 documentation so that I hope to just be aware of 23 Mr. Mcuser's views on this.
1 24 MR. TREBY:
I think this is valid information 25 for discovery.
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vvvv - -
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s-1 JUDGE BLOCH:
Wa cro dona.
2 MR. TREBY:
But my concern and the reason I 3
raised the objection so the record is complete is that t
4 the're is a possibility at some point that people may ask 5
tha,t this whole record be put into this -
this deposition 6
record be put into the evidentiary record.
7 JUDGE BLOCH:
Would you object to that?
8 MR. TREBY:
I would think that this subject here 9
appears to me to be outside the intimidation matters, 10 JUDGE BLOCH:
I haven't ruled on that.
11 MR. ROISMAN:
Okay.
Because I think the only 12 arguable matter is whether it's outside the scope of the 13 deposition.
I think it's the heart of the intimidation 14 issues before the board.
15 f JUDGE BLOCH:
I hope the Staf.f working fintimidation)illconsiderwhatMr.Mouserhassaidand
'16 17 his familiarity with these questions.
/r 18 MR. WATKINS:
I'm confused about what that means.
p/Ah0 19 What inforrtation?
gP I.
'20 JUDGE BLOCH:
The last few pages of this i
j4'I'I'y'l 1
21 transcript.
MR. TREBY:
I understand what the Chairman is 22
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23 asking is that we make sure that the technical review team 24 is aware of the information that's being developed in this 25 deposition.
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1 JUDGE BLOCH:
Just this last few questions, 2
questions of CMCs and the relationship between Mr. Houser 3
and Mr. Tolson.
a 4
BY MR. ROISMAN:
5 O
Mr. Mouser, you indicated that at a subsequent 6
time relationships between you and Mr. Merritt -- by 7
" subsequent" I mean subsequent to the time of July, late 8
July 1983 -- that problems developed between you and 9
Mr. Merritt.
And I wondered if you could tell us when did 10 that first happen?
11 A
It happened when I was down in the coatings 12 department.
13 0
What happened?
What was the first event in
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14 which that began to crop up?
15 A
It was kind of a hard th.ing to stick my --
16 totally stick my finger on, but it developed when they had 17 the -- this -- they had a barbecue between the crafts and 18 the OC.
19 Q
Just for coatings or all --
coahings.
The craft for, you know, just 20 A
Just 21 the coatings department for QC and craft coatings.
And 22 noneoftheQCfe1[ lows showed up.
Well, there was one man 23 that showed up.
1 24 And I got the feeling from the reaction that the 25 superintendents and that gave was that they were upset i
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