ML20095C145

Deposition of ST Hoggard on 840801 in Glen Rose,Tx. Pp 74,000-74,016.Personal Resume Encl

ML20095C145
Person / Time
Site:	Comanche Peak
Issue date:	08/01/1984
From:	Hoggard S TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
Shared Package
ML20095C073	List: ML20095C069 ML20095C081 ML20095C093 ML20095C111 ML20095C114 ML20095C120 ML20095C127 ML20095C140 ML20095C145 ML20095C159 ML20095C169 ML20095C180
References
OL-2, NUDOCS 8408220396
Download: ML20095C145 (23)

Text

,

74,000 e

1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 2 ggt,:g7gg U5tRC 3 BEFORE THE ATOMIC SAFETY & LICENSING BOARD

'84 AGO 20 P5;10 4

5 -________________

j@f ,, ,; y In the Matter of:  : %W 6 .

TEXAS UTILITIES ELECTRIC  :

7 COMPANY, et al.  : Docket Nos. 50-445 Od-b

50-446 OL-2_ -

8 (Comanche Peak Steam Electric  :

Station, Units 1 and 2)  :

9 --__ _ _ _ __________

10 Room 46 11 Glen Rose Motor Inn Glen Rose, Texas 12 August 1, 1984 13 ,

14 15 Deposition of: SAMUEL T. HOGGARD 16 called for examination by counsel for Applicants, 17 taken before Margaret Schneider, Court Reporter, 18 beginning at 9:50 a.m., pursuant to agreement.

19 I I

20 s

21 22 23 24 8408220396 840820 25 PDR ADOCK 05000445 T PDR

'74,001 W

1 APPEARANCES:

2 for the Applicants, Texas Utilities Electric Company, et al:

3 McNEILL WATKINS, ESQUIRE 4 Bishop, Liberman, Cook, Purcell'& Reynolds 1200 Seventeenth Street, Northwest

'5' Washington, D. C. 20036

,6 For the Deponent, Saauel T. Hoggard, Personally:

7 R. JEFFREY COPPOCK, ESQUIRE Vinson & Elkins 8 First City Tower Houston, Texas 77002 9-10 - * *

• 11 12 -

13 . .

14 15 16 17 18 19 20 -

i 21 22 23 24

.15 '

74,002

/9W 1 INDEX 2 DEPOSITION OF: DIRECT CROSS REDIRECT RECROS$

3 Samuel T. Hoggard 74,004 -- -- --

4 5

6 7

8 9

10 E_ X H I,B I_ T S 11 NUMBER FOR IDENTIFICATION 12 Hoggard Exhibit No. 1 74,004 13 .

14 l

15 16 17 18 l 19 21 22 23 24

MS/ch 74,003 1

PROCEEDI{GS 2

9:50 a.m.

3 MR. WATKINS: We'll go on the record.

4 Good morning. My name is McNeill Watkins.

5 I'm counsel for the Applicants in this proceeding. This 6

is the deposition of Sam Hoggard, senior safety supervisor 7

at Comanche Peak Steam Electric Station.

8 Applicants are taking Mr. Hoggard's deposi-9 tion as part of an offer of proof which Applicants will 10 submit to the Board in this case.

11 Because this is an offer of proof, Mr.

12 Hoggard's deposition will consist solely of direct examina-13 tion by Applicant. There will be no cross-examination by 14 other parties.

15 Madan Reporter, would you swear the witness, 16 please?

1 17 l Whereupon, i

18 l SAMUEL TRUESDELL HOGGARD, JR.,

19 having been first duly sworn, was examined and testified 20 .

upon his oath as follows:

i i

21 MR. WATKINS: I wonder if counsel could 22 , identify himself?

23 MR. COPPOCK: Yes. My name is Jeff Coppock.

24 I'm associated with the law firm of Vinson & Elkins in 25 Houston. I'm here today representing Mr. Sam Hoggard, a

74,004 1 Brown & Root employee.

2 For purposes of the record, I'd like to 3

note that Mr. Boggard is appearing here voluntarily and not 4 under subpoena.

5 EXAMINATION 6 BY MR. NATKINS:

7 Q Please state your full name.

8 A Samuel T. Hoggard, Jr.

9 Q Mr. Hoggard, where are you employed?

10 A Brown & Root Construction Company at 11 Comanche Peak Steam Electric Station.

12 Q What is your title? '

13 A Project Senior Safety Supervisor.

14 MR. WATKINS: I'll ask the reporter to mark 15 this document for identification as Hoggard 1.

16 (The document referred to.was 17 marked for identification as 18 Hoggard Deposition Exhibit 19 No. 1.)

20 BY MR. WATKINS:

21. Q Mr. Hoggard, I show you this document which 22 i has been identified as_Hoggard 1 and ask if you can identify

%l it.

24 A Yes, sir. It's a photostatic copy of my M resume.

74,005 1 Q Did you prepare that resume?

2 A Yes, I did.

3 Q Is it accurate and up to date?

4 A Yes, it is.

5 MR. WATKINS: Applicants move the admission 6 of Exhibit Hoggard 1. If you will bind that into the 7 transcript, please, Ms. Reporter.

8 BY MR. WATKINS:

9 Q Mr. Hoggard, please describe your duties as 10 Project Senior Safety Supervisor.

11 A Well, my duties consist of the inplementation 12

'of project safety and concerns for employee protection, 13 employee health environments. I prepare documents for rules 14 and regulations pertaining to work. It's safety-related, 15 l non-nuclear for the project employees.

16 I also maintain the medical staff, fire t

17 l department, safety inspectors for the project.

18 I do work with the Environmental Protection 19  ! Agency, Texas Department of Public Health, Department of 20 l Public Transportation.

I 21  !

O Are you responsible for a compliance program 22 with those agencies?

23 A Yes, sir, I am.

-24 Q Are you also resporsible for the Comanche 2 Peak Compliance Program for the Occupational Safety and

74,006 1 Heaalth Administration?

2 A Yes, sir, I am.

3 Q How many employees do you supervise?

4 A Twenty-one.

5 Q Would you describe their functions, please?

6 A I have line safety inspectors, both days 7 and nights, that continually walk the plant. They do 8 continual safety inspections of areas of construction..

9 I have five medics, both days and nights.

10 And their main function is first-aid treatment. Two of those 11 personnel are Registered Nurses.

12 I have five firemen, consisting of a fire 13 chief and four firemen und_er him, both days and night shift.

14 i Their total responsibility is for fire safety inspections 15 l of the project, to answer fire calls on the project, to fight i

16 those fires officially. They are also, at the present 17 time, supplying the fire brigade for TUGCO for fuel building 18 l where fuel is stored.

19 Q To whom do you report, Mr. Hoggard?

20 l A I report to Eddie Greer in Houston at the s

21 Power Division Safety Offices. I work closely with Mr.

22 Franklin on the project and answer to him as project leader.

%I

, Q And who is Mr. Franklin?

24 A Mr. Franklin is the Project Manager for 25 Brown & Root.

74,007 1 Q Can Mr. Fanklin fire you?

2 'A No, sir.

3 Q How do you and your safety inspectors enforce 4 safety rules?

5 A Well, if a saftey inspector and myself come 6 up on a situation where there is imminent danger to employees, 7 we have the power to shut that operation down 'til such 8 time as corrections have been made, as necessary.

9 Q Is it usually necessary to use that' authority?

10 A No, sir, it is not.

11 Q If you see an unsafe condition, however, that

'12 in your judgment would threaten the safety of an employee,

'13 would you immediately shut.that operation down?

14 A Yes, sir, I would.

15 Q And if that included access to a particular 16 part of a building, would you restrict access to that part 17 of the building?

18 A Yes, sir, I would.

19 Q Is the Safety Department subject to cost 20  ! considerations and construction schedules?  !

, l 21 A No, sir.  !

i Zt Q Are you familiar with the rotating access

! 23 platform ring in Reactor Containment Building 2?

24 A Yes, sir, I am.

25 Q Why are you familiar with it?

l

- 74,008 1 A During the time that the platform was 2 installed, I was' on the project. Also, at the time that 3 the work was having to be performed and installation, I 4 was responsible for having the lifeline system installed 5 in the building.

6 Q Did you suggest that the lifeline safety 7 system be installed on the platform?

8 A Yes, sir, I did.

9 Q Please describe the rotating access platform 10 ring in Unit 2.

11 A The rail is at approximately a thousand foot 12 elevation. It runs completely around the interior of the 13 building, attached to the , stainless steel liner wall by 14 means of a large basin.

15 The rail itself is approximately two, two 16 and a half feet in width with a railroad type rail running 17 through the center of it.

18 Q Approximately how far from the liner wall 19 is the rail?

3) l A Approximately five feet.

21 Q And where is the safety cable located?

22 A .The safety cable is attached to the liner 23 wall by means of braces. The lifeline's approximately

24. between 36 and 42 inches high from the base of the top 2 base of the rail and is approximately four, four and a

- 74,009 1 half feet from the liner wall itself.

2 Q For a person standing on the rotating access 3 platform rail, at what height, body height, would the cable 4 be located?

5 A For the normal, average-sized person, 6 approximately shoulder height.

7 Q And how far would the employee have to 8 reach to hook into the cable?

9 A Approximately arm's length or less.

10 0 Could you describe the method by which 11 employees working on the rail attach themselves to the 12 cable? .

13 A All employees working at that height are 14 required to wear a safety belt and lanyard. The safety 15 lanyard is attached to the belt and then to the wire rope i

16 cable.

l I

17 Q Do you have particular reason to recall your 18 assessment of the rotating access platform ring?

19 l A Yes, sir, I do.

20 Did you receive an inquiry.or inquiries l Q 3  :

21 regarding the safety of that ring? I 22 A Yes, sir, I did.

23 Q Do you remember the date?

24 A It was on or about March 8, 1982.

25 Q How do you remember the date?

74,010 i A I have-- had writtcn myself a memo concerning 2 the incident that took place.

3 Q Who inquired of you regarding the safety of 4 the rail?

5 A The first inquiry that I had was from a 6 QC supervisor by the name of Meil Britton.

7 Q What was Mr. Britton's inquiry?

8 A Mr. Britton called me by phone and asked if 9 the lifeline system that we had at the rotating platform to rail was safe.

11 Q What was your response?

12 A My response was that it was safe and did meet 13 ,

requirements. ,

i 14 Q on what did you base your response?

15 A Well, the fact that I had been up there in 16 I the past, that I had safety inspectors that physically been l

17 up there in the past, also that the foremen of the crews l

18 that were working up there were responsible to see that the l

19 i area was safe prior to their employees going to work, and I

%) i we had had no complaints or no employees hurt up 'til this 21 l point.

22 Q Did you receive a second inquiry regarding '

23 the safety of the rail?,

24 A Yes, sir, the following day.

25 Q From whom?

74,011 1 A From Neil Britton's supervisor, Mr. Harry 2 Williams.

3 0 And what did Mr. Williams ask?

4 A Mr. Williams asked basically the same question, 5 if, in fact, that the system that we had up there was a 6 safe and adequate lifeline.

7 And I referred to him that it was safe, it 8 was adequate, and it did meet the appropriate Federal 9 regulations for fall . protection.

10 Q Was the basis for your response to Mr.

11 Williams' inquiry the same basis as your response to Mr.

12 Britton's inquiry? ,

13 A I didn't know the reason for Mr. Britton's 14 inquiry. Mr. Williams did relate to me the reason his i

15 inquiry was that he was having some difficulty getting i

16 QC inspectors to go up there and perform their tasks.

17 Q At the time you talked to Mr. Williams, 18 had you been up to see the rotating access platform ring l

l I 19 within a day or two-day period?

l 20 l A The day prior.

I r

21 l Q Did you, after your conversation with Mr.

22 Williams, personally inspect the rotating access platform M rail?  !

24 A Yes, sir.

M Q Why did you do so?

l

. 74,012 I l

)

1 A Just because of the two inquiries, I wanted 2 to go up personally, put my hands on it, and visually see 3 it myself so that if anything were to arise out of it I ,

4 would be able to say that I had personally inspected the 5 rail.

6 Q Would you describe your inspection, please?

7 A Yes, sir. I went up through using the 8 access ladder, I went up and physically hooked off my 9 safety belt lanyard to the lifeline, reversed it completely to around the lifeline, and I found everything to be in order.

11 Th.' lifeline itself was taut. There was not an excessive 12 amount of slack in it. It was properly secured.

13 Q Approximate.ly how much slack did you note 14 in the cable?

15 A Approximately three to six inches from static 16 position.

17 Q Did you completely traverse the circumference 18 of the rail as it travels around the containment?

19 A Yes, sir, I did.

20 Q Did you notice any oil or grease on the 1

21 rail at that time?

22 A No, sir,, I did not.

El Q Did you, notice any other foreign objects on 24 the rail?

25 A Not on the rail itself, no, sir.

74.,013 1 Q .Did~you notice any miscellaneous ropes or 2- ' cables or other safety equipment hanging from the safety 3 cable?

4 .A No, sir, .the cable was clean.

5 Q Were you looking for those_ items?

6 A Yes, sir, I was.

7' Q How much weight would the cable, the safety 3 cable on the rotating access platform rail,; hold?.

9 A Approximately 10,000 pounds.

10 Q It would easily, therefore, hold the weight

.11 of three men.

12 A Most definitely. .

13 Q After. you performed your inspection, did you 14 _ report the results of your inspection to anyone?

15 A No, sir, I did not.

16 Q The purpose of your inspection, therefore, 17 was simply to satisfy yourself that your earlier judgments US regarding the safety of the rail were correct.

up A Yes, sir, it was.

m 0 on the day that you inspected the rail, did 21 you. observe any Brown & Root or any Comanche Peak personnel n- working on the rail?

23 - A Prior to my going up, I had been in the 24 building on 905 elevation and had observed employees working

_m on both the polar train rail, which is directly below the

74,014 1

rotating platform rail, plus employees working up on the 2 rotating platform rail itself.

3 Q At what elevation is the rotating access 4 platform rail, Mr. Hoggard?

5 A It's approximately a thousand foot elevation.

6 Q Mr. Hoggard, what regulations prescribe th 7

safety features for an item such as a rotating access 8 platform rail?

9 A Well, are you referring to a lifeline- itself?

10 Q Yes.

11 A Okay. There's two different sets of 12 standards, the CFR 29.1926 has a section in it requiring 13 the use of such lifelines and American National Standards 14 ANSI.

I 15 Q Is that A-S-N -- A-N-S-I?

16 A Right.

17 American National Standards Institute, they 18 also have a standard for it.

19 Q Now, does the OSHA standard to which you 20 referred require a particular thickness of cable?

21 A Yes, sir, it does. One-half inch.

22 Q And is the cable on the rotating access 23 platform rail one-half inch?

24 A Yes, sir, it is.

Ei O Mr. Hoggard, at the time that you inspected

74,015 1 the rail, were you familiar with a QC inspector named 2 Robert Hamilton?

3 A NO, sir, I was not.

4 Q Did you know a QC inspector named Joe'.srolak?

5 A No, sir.

6 Q Did you know a QC inspector named Sherman 7 Shelton?

8 A No, sir.

9 0 Your judgment as to the safety of the rail to was, therefore, in.no way related to these three individuals; 11 is that correct?

12 A No, sir, it was not.

13 Q Subsequent to your inspection, did you 14 become familiar with these three names?

15 A Only later.

16 Q In what contaxt?

17 A It was brought to my attention several days 18 after I had received a phone call from Mr. Williams that 19 three QC inspectors had been terFinated because they had 20 failed to go up and perform their duties on the rotating 21 platform rail.

22 Q Do you know whether Mr. Hamilton, Mr. Krolak, 23 and Mr. Shelton took any further action regarding the safety 24 aspects of the rail?

25 A In May of 1982, I received a letter from the i

, 74,016 1 . Occupational Safety and Health Administration where the 2 three QC inspectors that you had mentioned had filed an I

3 apparent employee complaint with OSHA.

i 4 Q What was the result of that complaint?

5 -A The letter to me from OSHA stated that they 6 had dismissed the complaint and that they would take no 7 further action.

8 'MR. WATKINS: Mr. Coppock, do you have any 9 questions?

10 BY MR. COPPOCK:

11 Q Okay. Just one clarifying question in your 12 last remark. .You said that "they" had dismissed the 13 complaint and that "they" would-take no further getion.

14 Does the "they" refer to the employees or to 15

. OSHA?

16 A To OSHA.

17 MR. COPPOCK: Thank you.

18 MR WATKINS: That will conclude Mr. Hoggard's 19 deposition.

8 Thank'you, Mr. Hoggard.

21 We'll go off the record.

'M (Whereupon, at 10:10 a.m., the deposition 23 in the above-entitled matter was concluded.)

24 ___

~25 w

CERTIFICATE OF~ PROCEEDINGS 1

This ~1s to certify.thatsche attached proceedings before the

~

, NRC= COMMISSION. l

.3 In the: matter of: TEXAS UTILITIES ELECTRIC COMPANY, et'al 4 (Deponent: Samuel T..Hoggard)

Date ~ o-f Proceeding: -August 1, 1984 l.

Place of Proceeding: Glen Rose, Texas 6

were. held as herein appears, and.that this is the original ,

7  !

transcript for the. file of the Commission.

8 9

Margaret K. Schneider 10 Official Reporter - Typed .

11 g $ Y 13 Offic 1 R'eporter - Signature 14 .

15 --

-16 17' L .

18 19 20 l 21 l 1

22 t-23 24 i i

25 ,

TAYL0E ASSOCIATES REGISTERED PROFESSIONAL REPORTERS

. _ _ _ . ~ . . - . _ , _ NORFOLK. VIRGINIA

CROUN & ROOT, IMC.

PERSONAL RESUME NAME: Scmuel Truesdell Haggard, Jr.

l' CLASSIFICATI0l: Safety Supervisor (Sr.)

DATE OF BIRTH: May 31, 1944 PLACE OF BIRTH: Fort h*arth, Te,<as FMRITAL STATUS: Married EDUCATION: High Schoni Gradua te R.L. Pascal liigh Sch el Fcrt Worth, Texas 1963 Jet Aircrtift Mer.hanics School Amarillo /,r8 Cl30A/B Amarillo, Texas, 1963

~

Air Iorce Manage:: lent Course Ilickum Af!!

l'avali 1967 Clevelar.J :nstitute of Clet ronics Casic El. ctrical Caurse Cleve'and, Ohio 1969 CSHA Safety P0ll-302 GT  :

OSHA Supervisar Training Brown S Root, Inc.

. Glen Rose, Texas 1

July 15, 1977 Instructors Course OS:IA Standards

] Cons truction & Indus try Brown & Roat, Inc.

November 17, 1970

.i E' NIEli d

t 8 -I- x

7 r e .

i S.T. Hoggard, Jr.  !

Personal Resume (cont.)

MILITARY BACKGROUND: Enlisted in the United St:tus Air l Force. After Basic Training, w.:s ,

assigned to the 6593rd Test Sque.fren  ;

at Hickum Air Force Case in Hav...ii . I My duties included that of Flifr.t I Engineer on HC130-li :i rc r a f t.

. I at- i tained the rank of Sar:edns and was I awarded the following cecorations.

• i National Defense Service Medal Gnod Cnnduct Medal (2) l Air Force Longevity Service Award ,

Ribbon  ;

I received my honorable discharga at the Air Force Flight Training Counand i Center, Edwards Air Force Saxe, C211 f- '

ornia on February 2,1968. '

i t

PROFESSIONAL ASSOCIATIONS:

Member of American Society of Safety j Engineers. ,

t

____..._______________ _..__________..___________________________________________ j i

I PREVIOUS EiyERIE::CE l

' i November 27, 1978 to present Crown a Ruot, Inc. j Glen Rose Texas t Senior Safety Supervisor i I

May 1978 to Nov. 22, 1970 Grown S Root. Inc. t Glen Rose. Texas  :

Safety Supervisor  :

i Oct. 3, 1977 to May 1973 Brown 5 Root Inc. '

Glen Rose, Texas -

I Safety Specialist I?

l  ;

i

, Feb. 1976 to Oct. 3, 1977 Brown & Ecot, Inc.

Glen Rose, Texas .

Safety Inspector Duties were to inspect main olde site, j t to insure that empleyee are workinu ,

in a safe nanner, to make sure Na safety equipment was kept in gc . c;n-dition, and I was a'so resscusi Ie #ce field safety sampling and docunen:ing l same. 1 I May 1975 to Cec. 1976 Las Colinas Security Irv:nq, .eans j i

' drol O r 'icer re a.onsib:e 'or .r:;ri ty,;

I

. , safety of a .::ulti-n.illion dallar .;o;sina

l. area, country, club, and conssrucsion l site.

x -

S.T. Hoggard, Jr.

Personal Resume (cont.)

Previous Experience (cont.)

i September 1973 to April 1975 Leonards Departmen'. Store Fort Worth, Texas l, Security Manager  :

Investigated thefts, fires and :cs also !

Safety Inspector for a departmer;; wi th !

five hundred employee 2. .

6 June 1971 to August 1973 Dynalectrcn Corporation Fort Worth, Texas  !

Aircraf t f*echanic and Safety Insnec:or, i Electrical t'aintenance on aircra f t. As i Safety Inspector, ex.amined tool;, work i areas, and prepared weekly insrecticn reports . Workad with Air Force person' j nel on Fire Protection.

Febrtary 1968 to January 1971 L.T.V. Corporation l Dallas, Texas  !

Aricra f t Rigger, sheet metal me:h. and i department Safety man. .

4 GETAILED PROFESS:0!!AL E.VPERIEilCE l November 27, 1978 to present Brown & Root, Inc. .

l Glen Rose, Texas Project Senior Safety Supervisor l j

t

1. Advise project management, 'oreiren i and sueervisors, of a;l muttars l

pertaining to safety haaards that may occur from day to da/. l

2. Conduct or instruct others ei:5 the j crientation of new employees.

3. Cooriinate local medicai fa ;'ities .

for the treatment and care -f in-  !

jured employees from job si ta.

i

4. :nvestigate all jou site ac;tc2.its. I

5. Work uith the project 2nagar, u-perintendents, and fore::en, c Oc- l minister ccrrective ac: ion for job '

site accidents. '

6. Supervisa medics and Safety see-  !

l- scnnel on the job site.

i i

! 7. "aintain accurate and complete re- ' ,

I cords set forth by Brown & Root,  ;

Inc and the Farfo ral rava rnme n t '

S.T. Hoggard, Jr.

Perscnal Resume Detailed Professional Exp. (cont.) ,

8. Requisition necessary personal pro .

tective equipment for spec 1ric  !

tasks.  !

l

9. Hazardons waste manage::,ent. f

a. Apply to the Federal . L a s and local State ZPA for parper ,

license or permits. '

b. Identification and listin 1 of  !

all hazardous chemicals and j waste used on site.  :

c. Inspecticn, centrol and train- !

inq of hazardous cnemical; l

and waste. i

10. Medical

a. Locate properly trair.ed :nedical l personnel for the project t)  ;

assure proper treatment of in-jured employees.

May 1978 to November 27, 1978 Brown & Root, Inc.

Glen Rose, Texas ,

Safety Supervisor

1. As Safety Supervisor, my duti:s in '

cluded advising the Project h.ior Safety Supervisor on all mattle pertaininq to safety hazards fcund by the field Safety Inspecto .  :

2. Inves tigate and prepare repcrts en j property damage, motor vehicle da- I mage, and :erious accidents invol- !

ving personnel on the job site. j

3. Conduct OS:lA type safety in gct- ,

ions of the job site, weekly. Also i preparc a written enort to me No-l ject Cenior Safety Supervisor, i 3

4. Particip.ite in weekly craf t cafety i meetings.  !

November 27, 1970 to present C rown S P.ac t . Inc.  !

Glen Pose, Texa i Senior Sa fet/ Sucervisor l Comanche Peak Project  :

i i

! i i

l .

S.T. - Hoggard, Jr.

Personal Resume (cont.)

CAREER ACCO.'iPLISHf'E!!TS 1979 - Construction of nt,ciear pa.<ee plant with over 4,000 employees.

1,000,000 manhours wi thout a los t time accident.

1980 - Saue. construction projec' over 1,000.000 manhuurs on two occa-sions witnout a lost time accident.

1981 - Same pro.iect over 1,000.G00 manhours without a lost time accident.

and frcm mid 1900 to January 19'4, 2,300,000 manhours without a last time accident.

1932 - Same project hi t an all t S..a record of 3,800,000 '

. cs without a lost time accident with over 4,000 employees.

Cost due to employee injuries has been reduced since 19,79 by 66.5, resul:ing in a sizeable rebate from the workers

, ccmp. carrier.

i fly major area of interest is in the setting up of safety programs and in I refining existing programs to cer uce ~

employee exposure to hazards.

I liave done scme public speaking, mostly wi th A.S.S.E. , Ft. Worth Chapter.

I maintain all required EPA recard; and supervise removal of all hazardous waste:.

I am also working with the Ped Cros3 Disaster Relief Office in Ft. !!crth, for llood and Somervell Counties.

s 4

t- LA' _ _

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