ML20099D317

Forwards marked-up Testimony of Jj Lipinsky & Jj Norris Re Protective Coatings Program.Related Correspondence

ML20099D317
Person / Time
Site:	Comanche Peak
Issue date:	11/17/1984
From:	Watkins M BISHOP, COOK, PURCELL & REYNOLDS, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Bloch P, Grossman H, Jordan W Atomic Safety and Licensing Board Panel
References
CON-#484-184 OL-2, NUDOCS 8411200306
Download: ML20099D317 (1)

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- REATED CORRESPONDENCEi

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100CKETED 4

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' JCISHOP,l' LIBERMAN, COOK, PURCELL di. REYNOLDS :. t -.

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,i2oo SEVENTEENTH STREET, N.W.

400V 19 A!0 :48~ New v0R-

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wAs HIN GToN D.C.2 0 036,

SISMOP, LIBERMAN & COOK ~

(202)357 3300' ryp 7 -p r: r,4rSS AvtNUC or THE AMERICAS

. ' T E LE x 440 5 /4 I NTLAs# U t..

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NEW YORK,NEw YORM #00361 w -

(282)704-O:00 TELCx 222767 wsalTER'S DIRECT DIAL (2 02)

November 117,f 1984

. Peter ~B.~Bloch, Esq.-

Dr.' Walter H. Jordan '

9:

-Atomic: Safety.and Licensing-881: West Outer Drive

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Board OakiRidge,. Tennessee 37830 U.S. Nuclear; Regulatory'

. Commission.

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Washington, D.C..

20555:

Herbert Grossman, Esq.-

Atomic Safety and Licensing Board-U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Texas - Ut._lities Electric -Company, Ion 7 Re:-

et'al.

(Comanche Peak Steam Electric Stat Units 1 and 2), Docket Nos. 50-445-2,.

50-446-2 Gentlemen:

In reviewing trial preparation documents for production today, Applicants discovered that the only copy in our.

possession of the document identified as item 3 in our' letter-dated' October 18 contains annotations of counsel.

The under-l signed consulted _with Mr. Gallo, and it appears'that he does l

not have a copy of the document in Washington.

We have notified the. Board Chairman that we are producing'a ' copy of this document, which we enclose, with l

the annotations of counsel deleted.

The markings remaining on the enclosure could not be removed without obliterating the text.

Respectfully

ubmitted,

[0g6 g4 0

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McNeill Watkins II Counsel for Applicants Enclosure cc t " (w/ enc. ) :.. Service List' SO3

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UNITED-STATES"OF AMERICA 1

, NUCLEAR REGULATORY COMMISSION'-

k BEFORE 'THE ATOMIC ^ SAFETY AND LICENSING BQkRD i In the' Matter.of

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TEXA8 UTILITIES GENERATING

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bDocket;Nos. 50-445 and.

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COMPANY, _et - _al. -

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50-446'

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.(Comanche. Peak' Steam Electric-

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'(Application for.-

station,"Unitsc14 and 2)

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Operating Licenses)

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TESTIMONY OF.-J. J..'LIPINSKY AND J. J. NORRIS-REGARDING~ PROTECTIVE COATINGS' PROGRAM Ql'. :. Mr. Lipinsky,:please. state your name, bu.siness address and

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educational and professional qualifications.-

A1.

(Lipinsky) My name is Joseph J. Lipinsky.

-I.am~ employed by O.

B. Cannon & Son, Inc., 5600 Woodland Avenue, Ph'iladelphia, Pennsylvania 19143, in the position of

. = A statement of my educational and professional qualifications is attached to this testimony.

Q2.

Mr. Norris, please state your name, business address ~and i

educational and professional qualifications.

A2.

(Norris) My name is John J. Norris.

I am employed by O..B.

Cannon,& Son, Inc., P.O.

Box 166, South Houston, Texas 77587,'in the position of Vice President, A

statement of my educational and professional qualifications is attached to this testimony

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103. iMra Norris, when~did O'.iB.

Cannon &LSon first become involved at the: Comanche Peak.' site?:

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A3. f(Norris)) Our. ocumpany. had no' involvement at Comanche. Peak until" we' were retained last ' stunner to - evaluate ~certain

aspects;of the coatings program.

Q4.. What was the scope;of-the' consulting services you-were

retained.to-perform?.

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~ A4'.

(Norris) ~ We were.to observe ' and Janalyze the following activities:. production,7 work procedures, scheduling, i,

. training and painter qualifications, Equality. assurance, management of coating efforts..and' specifications.

Q5.

How did your, company proceed to perform these services?

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l' A5.

(Norris).

We made several trips to the Comanche '. Peak site.-

2 during the summer to conduct an evaluation of these l

activities.

I was the O.

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Cannon officer in charge of'the efforts, and as such had overall responsibility for Cannon's j

efforts on site.

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. 06.

Mr. Lipinsky, when.did you become involved. in the Cannon -

i efforts?

1 A6.

(Lipinsky) In early July, I was-instructed by the President of O. B. Cannon & Son, Mr. Roth, to become involved and i

visit the site to provide input.to the Cannon effort.

r Q7.

When did you first visit the site?

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I A7.

I was on site July 26 through 28, 1983.

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QS.- (Please~ describe What;you did and with,whom you met during-

-that site visit..

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AS.

(Lipinsky)'On July-26;;I metfMr. C.,T.{Brandt'and,several

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other individuals involved with the coatings program. : _We discussed ther purpose of my(visitfandLI described how we -

would proceed.- Iithen. proceeded.to tour the-site and.

observe.'various activities-- related to : the coatings program. -

I. talked with'severalvindividuals.to familiarise myself'.with.

the activities. -Wehdiscussed. the job status,1 project.

j conditions and-work activities...The' majority.of my time on July 26 was spent in the-containment building for Unit.1.

on July 27, I returned to the site-and continued with m'y' i

review in'the containment building for Unit 1..

'I observed-n work on the polar crane and dome.

I then had about a 10-l minute meeting with Messrs. Tolson and Brandt.

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On July.28, I met with Mr. Norris to discuss my 1

observations.

I then reviewed the FSAR commitments and l

l other documentation..

Finally, I participated in an exit i.

i interview.

I expressed a few concerns regarding material

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storage, painter qualification, compliance with ANSI' requirements and possible coating integrity.

Mr. Tolson asked me to provide specifics on these points, and I told f

him that I was unable to do so without conducting an in-i depth review.

The meeting was then concluded, and Mr.

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'Norris, Mr. Merritt and I met with Mr. Joe George, the TUSI j

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'vice Presidentfin charge of construction..

(I mistakenlyj l identified-Mr.JGeorgeias1Mr.. Church.in.my August,8-.

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! memorandum.)

Mr. Merritt susemarized the ' exit interview for'

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Mr. George..

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09h !What1did you do.theh?-

A9.

(Lipinsky) ?I' returned f to ' my office 'in Philadelphia on' July 1

28. - I then -drafted Trip Report OBC Job No.f B8301i(cmanahe Peak Unit.lE-Glen Rose.'TX) and provided copies to(Mr. froth-

'and Mr. Norris.:

QlO.

When were Applicants provided. a copy of your Trip Report?-

A10'.-

(Lipinsky) To my knowledge, Applicants were not aware ~ o'f-the existence of my Trip Report until mid-October.. At'that time, Mr. Merritt called.Mr. Both and asked for a copy.

Mr. Roth sent Mr. Merritt-a-copy of the Trip Report'on October 12.

011. ~ When you prepared the Trip Report, were you aware'that it would be distributed publicly and the subject of '

evidentiary hearings before the NRC?

All.

(Lipinsky) No I was not.

Had I been aware of tbAiM..

, -of edre ease.and the rmaifications of my Trip Report, I would have more carefully and aggressively pursued the concerns I expressed in that Report before memorializing those concerns in writing.

I also would have been more assertive in my dealings with site management so.that my.

concerns were known and addressed to my satisfaction..

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Finally, had?I known that th'e Trip Report'might?b'e p-qq W

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p-L considered to se: my ' final'. views 'on thef adequacy of: tho' '

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' Comanche Peak progren,' : Ilwould ;not havc prepared ? the Report

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!b'ecause I did not have 'sufficientiinformation toimake[ final.

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. judgments.1.In fact,; at - the 4 timkI( received my assigunent 4

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-tonvisit the! site in late 1 July,,.I-believed-that three days:

Lwa's insufficientitime for-me to; evaluate Ndsguately the f4 -

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coatings program.

T a-Q12.

Do you know howiyour, Trip. Report bocame pd.dlic? y-g

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A12. 1(Lipinsky) No, ' I do' not. - Iiunderstandithai the. NRC has v

concluded that-it was!" surreptitiously" takengby'someone-who provided it.to the NRC. :I assume that:ti$ phrase;

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" surreptitiously" taken means that it.wasistolen.

If the Report were taken from me, it.was so taken without my:

knowledge or consent.

Q13.

Please-summarize whether you now hold the views and concerns reflected in your Trip Report.

A13.

(Lipinsky)

As I discuss in my testimony below, I believe i

today, with the information that has been presented to me,

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that my concerns are unfounded and I am satisfied based on D

I my understanding of the situation that the quality of the s

coatings at Comanche Peak-is adequate.

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~What information did you obtain subsequent to your August 8 Q14.-

' Trip Report that has' led you to change your views?

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lA14.- i(Lipinsky) f wa[r providedLdetailed infonnationnin-response-E

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toimypbncernsby[Applig4nts,--andithdtinformation; glows:

pie % concIude thatjtheiquality o'f the coatings ~ at.. nn=fnahe:

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N..,.k U adequate.ULILconducted:an' additional site visit' in

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'earlyl November, at whichi ime, in exte'nded~ conferences,.

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-Applicants provided malwith)deJd14ed..information relating to each of-the' issues"that"I hadLearlier identified in)my Augusti' 8' Trip ' Report.

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Q15.- Please list those issues.'

A15.

(Lipinsky) Those issues are material ~ storage', workmanship, ANSI requirements, coatingLintegrity,and' inspector morale, y

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These issues all-involve compliance with-ANSI requirements.

016.

Does that~ list-cover all items with Whih you were concerned jh in your August 8 Trip Report?

A16.

(Lipinsky).Yes, it does.

l Q17.

Are there other issues regarding the Comanche Peak coatings I'

program not addressed in your Trip Report that are of i

concern to you?

l A17.

(Lipinsky) Yes.

I have attached a copy of the Trip Report to this testimony, and the testimony that follows relates to: specific statements contained in that Report A.

Material Storage

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018.

Mr. Lipinsky, regarding your statement that " Comanche Peak

- has problems in areas of material storage," please describe the problems with which you were concerned.

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-(Lipin$ky) When I visited the Comanche Peak site,-I was

'A18.

looking for certain_ things that wouldlindicato to me. good 7

materiali storage. prac'tices.

1. looked'for such things as status indicator. tags, reject areas, and hold areas'.

lRejact-. areas are loca'tions were coating-material that-has beenirejected is stored.. Hold areasLare-locations where coating mat.:orial of:indeterminatie quality. is. stored'.

- I saw-no indication of the-use of tags and I saw no reject. areas

or hold. areas. ~ Further; regarding the control of coating.-

material-in general, I saw no system for tracking.for-control of mixed' material.

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- Q19.

'Does the= fact that'you did not'see'thes. items personally establish that the' methods and procedures ' at Comanche Peak are inadequate to accomplish the objectives?-

A19.

(Lipinsky) No, I am not saying that. - What~I am'saying-is that-I did not see these items.

They may be there, or Comanche Peak may have another way of.-implementing these practices.

For example, I understand that they have a traveller system that provides control for mixed coating material.

Q20.

Mr. Norris, are you familiar with the traveller system

-employed at Comanche Peak for the control of. mixed coating

. material?

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!(Nohris)hYes.

While I-was examining;a coating. container I

1 ins'ide'the containment, I. noticed that,it'had a.. form tapedz

<to,it vhich indicated When th'e' material ~was mixed, batch numbers, type of material,'etge.

In.short, all~of~the

'I information you' would expect per ANSI-101.4 was reflected.

Q21.

Mr. Lipinsky, does'the traveller: system that:Mr. Norris describes adequately. substitute ifor the-status-~ indicator tags that you expected to see?

A21.

(Lipinsky). Ye s.

This method of. trac'ing mixed material.is adequate'in my judgment.

Had.I known of-this traveller.

. system before I wrote my August 8 inemorandum, I'would have had no basis to criticize the method.of handling of mixed materials.

Q22.

Are. you familiar with Mr. 'X's testimony regarding the.

procedures'at Comanche Peak for handling rejected coatinggJ

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or Mbere, deatinge are isolated from use?-

. Lipinsky) Yes.

' 'iead Mr. X's testimony.

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A22.

Q23.

In view of that testimony, do you continue to believe that there are problems at Comanche Peak regarding the'. absence -

of reject areas and hold areas?

A23.

(Lipinsky) No.

The description in Mr. X's: testimony.of the procedures at Comanche Peak to handle rejected coating' P(

material'and coating material of indeterminate quality

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Again, had I been l

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. familiar with these procedures, I would not have criticized 9

these' aspects of material'. storage'in my August'8 4

memorandum.

Q24.

Then in; sum, do you remain critical of the Comanche Peak.

procedures for. material storage? '

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A24.

,(Lipinsky) No.

Basedion my understanding of tho' Comanche-Peak program for material storage, Ii have no criticismai.

B.

Workmanship 025.

Mr. Lipinsky, what are the -specific areas of workmanship that you believe raised problems-at: Comanche Peak?.

A25.

(Lipinsky) I saw indications reflecting 'on'the quality of coatings application such as sags and runs.in applied fi$n.

I should say, however, that what I saw was really no different from what I have seen at most other job sites

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' involving construction of nuclear pwer plants.

Sags and runs are typically encountered in cured films.

They may be acceptable or. unacceptable, depending on-the procedural /

1 specification requirements.

They are routinely inspected-by QC inspectors for compliance with these requirements, and if rejected, would necessitate either rework'or a-l disposition by engineering as acceptable.

-026.. Were there any other areas of work that formed the basis i

for your statement in the August 8 memorandum?

A26.

(Lipinsky) No, my memorandum on this point was based on my 4

observation of' sags and runs in cured film. -

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'Q27s Are there_other issues that' led to your criticismoof

-workmanship ~overall?

A27. - L(Lipinsky) Yes, -I was : concerned about the qualification and indoctrination of the craft involved in the' coatings-

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program.

.I was led to believe ' that : there was no practical.

. testing of: skills during:the training process for the':

craft.

This was based on conversations I had with a few

-individuals..However,TI understand'that the training and:

indoctrination program at the sit'e does include the actual-application ~of the coating material by the craft as a test for competence.

Given that fact, my concern regarding this-.

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aspect'is satisfied.

I also was concerned that there was no monitioring by.QC.

of the qualification: process for the craft.

I now understand that QC conducts a visual examination of-test results of the film' applied by 'the craft during the qualification and indoctrination program.

I think that this. input by OC i.s impor Lant because it assures that the -

applicator can apply the. film in a manner that would meet quality requirements.

Q28.

'What is the basis for your understanding reflected in your previous answer that the craft are qualified by test and Y;

that QC conducts visual inspection of those test results?

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.(Lipihsky) I. observed. thel craft i undergoing " such testing

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Lwhen I was on site. oh_ugust 9--10.

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testing:.on my prior" trip to the1 site.

.My understanding

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.pp Tregarding theJvisual'QC inspection ~'is based upon-my review of the. testimony of ' Mr' :X.'.

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Adequacy of Documentation 7 Q29.. Mr. Lipinsky, please: describe.your concerns regrding.

. adequacy of documentation'at Comanche Peak y,.

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-A29.. -(Lipinsky) The areas on which I focused were painter.'

qualification forms and the adequacy of daily! inspection reports. -In order to meet ANSILatandards, the program must j

assure that the pertinent data is recorded regarding both -

painter qualifications-and-daily inspections.

I:was-t concerned ~ based upon my conversations with a few individuals that there were not provisions for. recording all pertinent information.

I do not recall specifically-what documentation there was for my concern,.but just that I was left with the impression that the documentation was-p not completely adequate.

Bear in mind that my visit to the.

Comanche Peak site was very short, and that this-prevented me from conducting any,in-depth review of their program.

For example,- I did not pursue this specific concern due to T

the short duration of my site visit, 030.

Do you have any reason now to be confident that the ANSI g

requirements are being met in these areas at. Comanche Peak?

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A30.. 1(Lipinsky) L'Yes.

As a result of'furtheradiscussions that'I-.

ad with personnel ~ on the project site,. I believe' that audits of. sufficient depth and incope would have uncoveredL q

s problems.with compli~ance'with ANSI' standards ifLsuch1 -

-l problems: existed.'

My.understandingL.is that there have been-

[I many audits with-no significant findings-relating-to these

matters.

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- Q31.

Mr. Norris,Ddo you have'any concerns regarding-compliance' by the Comanchei Peak project - with ANSI requirements? '

A31.

(Norris)=No.. Based on my entry interview with.Mr. Tolson and subsequent meetings 1.with Messrs. Tolson.and Merritt,:

and others connected with the construction o'f Cotianche

Peak, I-have 'a high degree of confidence that the work is being done -in. accordance. with the standards.

There may be.

~ some difficulties at-Comanche Peak.similar to those being' experienced at most nuclear projects under construction in 1983, but I am confident that they are being adequately addressed.

D.

Coating Integrity Q32.

Mr. Lipinsky, please describe your specific concern regarding coating integrity.

Q32.

(Lipinsky) Based on my observations of the power grinding h.

of previously applied zine paint (CZtil),

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'that~ an excessive amount of sanding was being performed that could result in poor adherion of the top coat.

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I believe:t}iatithe nost important3 thing is'that manag'ement?

j is aware.of it andi:is?.taking stepsito rectify it.

F.

Observations / Opinions Q35.

Mr. Lipinsky, -' What iwas : the basis,for your statement-drawing '

a. parallel between Comanche Peak and Zimmer~"to some1 extent?"'

A35... (Lipinsky) Based ' on my initial -impression, fas refleeted.in my August 8 ' memorandum,= I-felt that~ Comanche cPeak might be--

developing ~into afZimmer-typeTsituation, that is, perhaps;

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requiring the rework of; coatings.' Again,_ based.on

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information.andiconversations I have had with site.

personnel subsequent to my August 8 ' memorandum, -I believe that my-conclusion was in. error.~ Based.upon my understanding now of the program and procedures in place'at' Comanche Peak, I.believe that there is no parallel between Comanche Peak and Zimmer.

036.

Mr.'Norris, do you see any parallel between Comanche-Peak and Zimmer in the' coatings arena?

A36.

(Norris) Not at all.

I believe that the coatings program at Comanche Peak is in accordance with 10 C.F.R.

Part-50, Appendix B.

The coatings program at Zimmer was not.

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August' 8 memorandum that management at Comanche Peak was disinterested in quality and actually attempted. to discourage

efforts.to report quality problems?

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(Lipinsky)~The1answerfto that. question is'in two parts.'

1 A3 7.'

iFirst,. in my brief discussion with Mr.. Tolson, :I, attempted.

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to express my concerns regarding certain'. quality matters.

~(I learnedLlater.that-he~ understood my concerns-to relate-to licensing : questions.)

He stated that he. was not

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concerned'with licen' sing questions, but my impression ~was

.that he was expressing disinterest-in-quality matters.-.I-was frankly very surprised by his answer--(as Irinterpreted'

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l it at that' time),- but did not pursue it with him then..

Subsequent discussions with Tolson have convinced me, that :

my original impression (reflected -in the Trip -'. Report) was incorrect, and that he is'in fact sincere and concerned F

about the quality of' the project. - '

Second, with regard to my original observa". ion that management,at Comanche Peak attepted to discourage efforts to report quality problems, the bases for this were the fact that. inspection reports (rather than non-conformance

. reports) are used routinely for coating inspections and the -

7 fact that Oc was not participating-in applicator qualification.

On the first point, I was led to believe by L

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a few inspectors with whom I spoke that irs did not

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adequately documentinon-conforming' conditions.

I did;not:

review the. specific 1 procedure forLissuing irs t'o varify.the

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(inspectors' claiSts.

However, based' upon my--un Srstanding

.of lthe. procedures ~

ployed Lat Comanche Peak-in' the. use of :

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irs ; to; document' non-conforming conditions, I..now ~ have.

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concuded that this approach.is acceptable-from a; quality.

assurance standpoint.I'The~ basis for my understanding is:

the; testimony of Mr. X.-

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Regarding my original impression that-QC waa not-involved.in,the inspection'of: test results for applicator.

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. qualification,Ta's noted earliar in this' testimony, I now-understand-that Oc in fact does visually-inspect these. test results, and that satisfies my' con'cern'in this area ~.

038.

What is your conclusion.today with regard,to the attitude of management at comanche Peak regarding quality in general and the reporting of non-conforming conditions specifically.

A38.

(Lipinsky) Subsequent to my August 8 memorandum and based on conversations with site management, I now-believe that site management is in fact concerned and interested in.

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maintaining quality in the project and that management encourages the reporting of non-conforming ' conditions or b:

any other quality concern.

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Q391 ~What is the' basis'for your statementithat Brown &. Root;is hostileito an audit and' that no.~ action would -be taken

by

Brown.E Root' even. if problems L were. detected in.: an Laudit.-

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Q3 9.

~(Lipinsky)LFirs't,JIiwould like;to_ correct'myself.

Where 1

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. referred ; to. Brown &' Root, 'I '.should have referred ; to ~ TUGCO.

I thought.that Mr. Tolson was/ employed ~by Brown & Root, but.

I now know he 'is ' employed by TUGCO.

During - the exit'

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meeting :on July 28 and subsequent mee' tings on site, Mr..

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Tolson repeatedly stated-an audit by me would be redundant.

I took this_to mean that.he was hostile to an audit.

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Q40.. How do.you feel 2 about it today?

A40.-

(Lipinsky) As recently as November. 10,'1983 Mr. Tolson:h'as l

- again. stated his opinion that an audit by me. would not be.

productive.

Mr. Tolson's confidence is;very high based'on the fact that the Comanche Peak program has be'en subjected to numerous internal and external audits..

F 041.

Do you believe today that an audif of'.the. Comanche Peak'QC program as it applies to paint is necessary?

A41.

(Lipinsky) No.

In view o'f the past audits and ongoing NRC

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review of that program, I agree with Mr. Tolson that an additional audit is unnecessary.

042.. What was the basis for your suggestion that a rework contract was necessary and that the paint already applied l

was not " salvageable to any meaningful extent?"

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L (Lipinsky) The basis. for. that'; statement was my overall conclusion,-based upon the'information' reported in my'

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August 81 memorandum, that the coating.. program' at Comanche

-Peakifrom'a quality standpont-hadLserious problems.-: My

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' impression wa's thatEinia' rework.sitnation, it would.be easier.to perform a complate' rework rather than attempt to-

' salvage portionsof the existing _' work.

2 LI believe today, with theLinformationfthat has been pre'sentedito'me,Lthat rework activities are not necessary_

at Comanche Peak. :My concerns h' ave. proven to be-unfounde'd'.

and_I am satisfied based-upon my understanding of the

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situation that-the quality of the coatings at: Comanche Peaka

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is adequate.

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043.

What-is the significance of your observation that " Brown ~&-

Root estimates only 34 out of 452. individuals are of any value as-painters?"

A43.

(Lipinsky) That statemement in my TripqReport'merely repeated what I had been told on site.

I am not sure that it was a Brown & Root estintate but someone did provide

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those numbers to me.

The statement has.no significance from a quality standpoint as long as the individuals.

actually applying the coatings are qualified.

I understand y

that the painter category includes individuals who perform various services such as sweeping, scaffolding erection and i

t masking.

From my perspective, if there is only one i

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' individual who'isl qualified;to.'applyz coatings',' it makes'no' J

Edifference from.a:qualityystandpoint..-;In sum, the. number-I

of qualified individual's applying

coatinga : affec'ts. the ~ rate of production, ;but does not'. affect Ltheiquality of the ~

applied coatings ~.s l

044.- You state'in your Trip Report'that'"if-quality work is put in place ' then th'ey will-be. a long--way to resolving site problems.'"

P1 ease explain what you?mean by that statement.

044.

If-the craft is carefulTin its application of coatings,-

then the ' job oflthe QC inspector becomes. routine and simple. - -If the craft is careless, then the inspector's : job '

-become's more difficult.- Obviously, the more desirable approach is to have the craft apply coatings-in a quali b -;-

conscious manner.

Q45.

Does your state' ment imply that you believe coatings have been improperly applied or applied without regard to j -

quality?

A45.

(Lipinsky) No.

My statement simply reflects my philosophy.

of coatings application and the role of the quality inspectors.

I did not intend by the statement to imply that tha practices at Comanche Peak are not compatible with my philosophy.

Q46.

Please explain your observation that "there is currently a 7

' no win' situation on site between the craft and QC inspectors."

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'A46.

'(Lipinsky)JMy impression.was'that;the craft'and, inspectors-

<were not functioning asia l team but.rSther;each seemed to bd

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Idoing :its job.without. regard for an: integrated : approach.

" '. My philosophy isithaticraft:and inspectors should. work' tog' ether in1 a harmonious': relationship to ack:omplish the objective.. I questioned ~ whether. that objective' was' being met'at Comanche Peak based.upon my'assessent at the? time Lthat the morale of thelinspectors,was: low and that the-attitudes of the craft.and in'spectors were in conflict.

As-1r.

I noted.above, I.. expressed this point to site: management, i

A'ch. acknowledged that morale was' not high and stated that

-they were taking steps to rectify'the matter.

i Q47.

Please explain the matter. involving the quality of air -

supply that was Ldiscussed.in. your Trip Report.

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' A47.'-

(Lipinsky) The -craft was experiencing problems on site with the. air supply for' spray paintiing or sand blast'ing.

The l-air apparantly-contained water or oil which renderedLit.

- unusable for these purposes.

Mr. Norris'later provided site management with a description of equipment that'would solve the problem, and my understanding is.that that i

-equ pment was purchased.

I have no reason to believe that-the air supply problem adversely affected the quality of y

applied coatings because management was aware of it and took appropriate steps to rectify it.

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'Q48.

Please: describe tho' significance ofl your statement that 0.B. Cannon satisfies applicable ANSI requirements..

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A'4 8. = (Lipinsky)j Mr Norris expressed at -th6 meeting that ANSI' I

requirement's whenetaken literally are' impossible to:

satisfy.

On the i other hand, I believe that~ Cannon does

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satisfy ANSI requirements on. those7 job : sites wheral Cannon

' performs - contract: services.

This'issu~e does not relate _to

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the: performance of Cannon's' consulting' services at Comanche-

. Peak, and was' included in my Trip Report merely_to advise my superior, -.Mr. ' Roth, that a difference of opinion existed _

- between Mr. Norris and me.

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049.. In your summary of the Trip Report, you observed that "B&R wanted to buy the 'right' answer."

Please' explain what'you.

i meant by that statement.

A49.

(Lipinsky) that statement relates back to-my initial impression that Mr. Tolson was disinterested in~ quality c

matters.

Again, my reference to "B&R" in the Trip Report was erroneous.

Further, I'am now convinced that my original impression of Mr. Tolson's attitude was also erroneous.

050.

By way of summarizing, do you have any other statements that you wish-to make regarding your involvement in O. B.

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' cannon's review of the coatings program, or your

- participation in this administrative proceeding.

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(. Lipinsky)- ITwould restate that Ethis 1 Trip Report reflects

A50.,

my' initial impressions conveyed'during,a very short1. visit?

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to-the' site d'uring which'I had~_littie opportunity:to-

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discuss:my c'oncerns with site;managament.

My sub' sequent -

in-depth. discussions 1with-site management haveEdemonstrated' 4

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to me that:my initial impressions were-incorrect.

'I have-r.

not. been induced' in~ any way ~ to retract my Trip ' Report, : and

~ I have not' been subjected to any haras'sment,._ intimidation

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orithreats by my employeri the. Applicants or anyone

- associated with this proceeding.~ - Indeed,. I was ' asked by.

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the_intervenor;'Mrs. Ellis, to' testify on hef'E5H&Tf'Tr~~ 7 -

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this proceeding and 4.t k.td i 1

-p..J. 'My testimony [

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would have been.the same had I testified for Mrs. Ellisf

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...'It is unfortunate that a Trip Report innocently prepared by.

me to advise my superior of my-observations and concerns in early-August has become the focus of a major challenge to 1

the~ adequacy of the Comanche Peak coatings program.

As I j

have stated earlier, the Trip Report 'was-based on incomplete information.

Further, it was not,-nor was~it intended. to be, a final view of my company.

It was merely input to the broader deliberations that my company needed

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E to undertake in order to fully evaluate the' adequacy of the Comanche Peak coatings program.

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