ML20106D023

From kanterella
Jump to navigation Jump to search
Prefiled Testimony of Gw Chaney Re Author 841002 Exam of Encl Documents.Certificate of Svc Encl
ML20106D023
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 10/23/1984
From: Chaney G
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
Shared Package
ML20106D014 List:
References
OL-2, NUDOCS 8410240454
Download: ML20106D023 (17)


Text

.f

_, V-y-

x 2

d N.

.r-

'l a

s

\\q h

- 4 pgbc0 U5

(.

UNITED STATES OF AMERICA

.g4 00T 23 NUCLEAR REGULATORY COMMISSION

-q BEFORE THE ATOMIC SAFETY AND LICENSING BOARD;*

,,j: :re y r. S[ g

<, t y In the-Matter of:

)

)

TEXAS UTILITIES ELECTRIC

)

Dockets Nos. 50-445-2 and COMPANY, et al.

)

50-446-2

~~

)

'l (Comanche. Peak Steam Electric

)

(Applications,for Station, Units 1 and 2)

)

Operating Licenses)

PREFILED TESTIMONY OF GEORGE W. CHANEY 01.

Please state your name.

A1.

George W. Chaney.

Q2.

By whom and where are you employed, Mr. Chaney?

A2.

I am the principal Questioned Doc'ument Examiner of-s.

James L. Lewis and Associates, 5934 Royal Lane, Suite i

255, Dallas, Texas 75230.

03.

Please briefly describe your employment background.

A3.

I was a Special Agent with the United States Secret Service from 1954 to 1977, and worked in the San Antonio. Dallas, and Washington, D.C.

field offices.

From 1963 to 1969, I was Assistant Special Agent in Charge of Personnel and Training.

From 1969 to 1974, I was Assistant Special Agent in Charge of the Dallas Field Office. From 1974 to 1977, I was Special Agent in l

Charge of the El Paso Field Office.

I retired from the Secret Service in February, 1977.

i hO f0 1

[

Q4.

Have you had any training in the examination of documents?

4 A4.

Yes.

As a Special Agent, I attended 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> of the Secret Service's Questioned Document School.

I later taught at the Questioned. Document School, in the Training Division.

05.

Did your employment with the Service include work with questioned documents?

A5.

Yes, I worked with documents extensively as>a Special Agent.

My duties included the investigation of forgeries and alterations of United States Treasury checks, Savings Bonds, and the counterfeiting of United States currency and other obligations.

I also investi-gated anonymous and threatening letters to the President and other dignitaries.

As Assistant Special Agent in Charge of the Dallas Field Office, and as Special Agent in Charge of the El Paso Office, I was directly responsible for all forgery and other document investigations assigned to those offices.

During my work as a Special Agent, I reviewed and examined thousands of documents for forgery or alteration.

Q6.

When did you begin working with James L. Lewis and Associates?

A6.

In March, 1977.

07.

Please describe your work with Lewis and Associates.

I i

l

?

l i

!I

,IN7. I s a Questioned Document Examiner, I examine documents, A

an such as deeds, swills, promissory notes, checks, leases, 5y and. anonymous writings, for. forgery, alteration, I have

-verification of: typing, and other attributes.

'~

examined thousands of documents during my employment with Lewis and Associates.

3 C8.

Have you testified regarding documents in any judicial s

or administrative proceedings?

A8.

Yes.' As a'Special Agent with the Secret Service, I

'8 testified numerous times in criminal cases as a document expert.

More re

-tly, I have testified in State and Federal courts in numerous cases involving 4

questioned documents.

09.

Mr. Chaney, I show you two documents marked as Attachments 1 and 2 to your testimony.

Have you been asked ~to examine the originals of those documents?

A9.

Yes.

On October 2, 1984, I examined the originals of these' documents under a microscope.

I also directed the photography of aspects of two of the documents.

Q10. Did you add any markings to the documents identified as Attachments 1 and 27 A10. My. photographer made certain marks on the documents, which are copies of the originals, to identify the frame numbers of the film.

On Attachment 1, for example, next.to lines 5 and 6-on-the right-hand side, l

l l

ll it.

A 4

d

,-g

  • 4

-c

+-

e-..--

gg c-

,<-4 y-

,mt

. my photographer wrote "42" and "43" with arrows, to.

identify the frame number and item that he photographed.

Oll. Mr. Chaney, please identify-Attachment 3 to your testimony.

All. Attachment 3 is an enlarged print of part of frame 43, showing a portion of lines 5 and 6 of the original of Q12. Please identify Attachment 4 to your testimony.

A12. Attachment 4 is an enlarged print of part of frame 22, showing an area on the left-hand side of the original of Attachment 2.

Q13. Mr. Chaney, were you given any other documents in connection with your examination?

A13. Yes.

I also examined Attachments 5 and 6 to my testimony, i

014. With respect to the original of Attachment 1, what were you asked to examine?

A14. I was asked to examine the area on lines 5 and 6 of the document where the dates "l/14/84" had been corrected to read "l/17/84."

Specifically, I was asked to l

determine whether the "17" appearing above the crossed-out "14" on each line was made by the same l

person who wrote the full entries on those two lines, and whether the "17" above the crossed-out "14" was made with the'same writing instrument as the other

. entries.

I was also asked whether the initials and dates appearing immediat aly below the signatures and dates on lines 5 and 6 were in the same hand, and by the same writing instrument, as the entries on lines 5 and 6.

Finally, I was asked whether the line-out of the "14" on each line was performed with the same writing instrument as the other entries on those lines.

Q15. Mr. Chaney, do you have an opinion as to whether all of the writing appearing on lines 5 and 6, as enla'ged on r, was performed by the same person?

A15. Yes.

Based on my microscopic and visual examinations, it'is my opinion that all of the writings on lines 5 and 6 as shown on Attachment 3 were made by "JStanford," assuming that this is the person who made these entries.

By "all of the writings," I mean the original dates of "l/12/84," the cross-out bar through the "14s," the "17s" above the "14s," the initials "JS," and the dates "l/17/84" next to the initials.

Q16. On what do you base your opinion?

A16. The signature "JStanford" on lines 5 and 6 is distinctive, and is repeated at several other places, both on Attachment 1 and on Attachment 5.

The initials "JS" that appear immediately below lines 5 and 6, as shown on Attachment 3, conform to the "J" and "S" of 1 -

the signatures.

The intials "JS" also appear at other places on Attachment 1, in the same handwriting.

L

., As to the dates, both the "8" and the "4" of the "84" in this individual's writing are distinctive.

As clearly shown on Attachment 3, each of the "8s" is

  • ormed similarly, especially as to the opening in the upper right-hand corner in each of the "8s," top to bottom.

The "8s" at other places next to the signature "JStanford" or initials "JS" elsewhere on Attachment 1 and on Attachment 5 reflect the same similarities.

The "4s" are also similar, consisting essentially of a check mark with a downstroke to complete the "4."

The "7s" also share points of similarity.

Referring to the "7s" on Attachment 3, each "7"

tends to come to a point, or sharp angle, where the writer makes the downstroke.

This characteristic also appears in the "7s" on Attachment 5.

The top three "7s" on also show a tic at the point where the writer began the figure; the tic is a short downstroke in the upper left-hand corner of the figure.

This tic is more apparent from microscopic examination than in, the enlargement.

The same tic appears in more pronounced fashion in the bars that cross out the "14s" in the "l/14/84" dates on lines 5 and 6 of Attachment 1.

These tics clearly appear on Attachment 3, the enlargement.

l i

l

. 1 Referring to Attachment 1, the same tic appears in'the bottom bar of the Roman "II" appearing to the right of

~ the signatures and dates on lines 3, 4, 5 and 6.

Q17. Mr. Chaney,.do you have an opinion as to whether the

-signatures,-initials, dates, and cross-out' bars on lines 5 and 6 were written with the same instrument?

A17. All of these markings were made with a ball-point pen.

The color is. uniform for each of the writings.

I cannot, however, determine whether all of these writings were.made by the same pen.

Q18. Are the bars through the "14s" and the "17s" above the crossed-out "14s," significantly different.from the other writings on lines 5 and 6 of Attachment 17 i

A18. As shown on Attachment 3, the bars through the "14s"

~

and the uppermost "17" are somewhat darker in shade than the other writings on lines 5 and 6.

This was 1

caused by the writer's bearing down more heavily when he made these entries.

This can be seen from the back side of the original of Attachment 1, where the indentation of the bar through the "14" on line 5 is plainly visible.

The bar through the second "14" is not as apparent.

The "17" above the crossed-out "14" on line 6 is not that much different from the "17" immediately above it.

In my opinion, the principal differences between the bars through the "14s" and the e-,-..

,--~-----w-

,--,,m-~m..

. I "17s" above them and the other writing.on lines 5 and 6 is that the writer pressed down more firmly as to some of these markings.

Q19. Is there any reason, based on your experience as a document examiner, why the writer pressed down more firmly in marking through the "14s"?

A19. Yes.-

Almost anyone who is crossing out something on any document tends to do so firmly, more firmly than that person normally writes.

Q20. Mr. Chaney, what were you asked to examine with respect to Attachment 47 A20. I was asked to examine the crossed-out "13 s and the "14s" immediately above them on lines 3 and 4, and to determine whether the writing instrument used to make those entries was the same instrument used on lines 5-and 6 of Attachment 1.

I was also asked to determine whether the handwritng is the same.

021. Mr. Chaney, do you have an opinion as to whether tne writing instrument used in the entries you have, described on Attachment 4 is the same instrument used in the entries on lines 5 and 6 of Attachmont 17 A21. Yes, I do.

Q22. What is your opinion?

A22. As I have testified, all of the entries on lines 5 and 6 shown on Attachment I were made with a ball-point pen.

The bars through the "13s" and the "14s" above

1 9'-

them shown on Attachment 4,~which is an enlargement of

., were made with a fluid ink pen.

The.

j

-entries on Attachment 4 were made with a fountain pen, a felt-tip pen, or a pen with _ a similar point, - such as a Pental.

The differences are apparent by comparing Attachments 3 and 4. 'also shows that the edges of the bars and the "14s" are not sharply defined.

This feature, which is even.more apparent in a microscopic examination, is caused by the fluid ink soaking into the paper.

All' entries in Attachment 3, in contrast--including the bars--are sharply-edged..

That is characteristic of a ball-point pen.

Q23. Do you have an opinion as to whether the bars and "14s" on Attachment 4 were made by the same person who made i

the entries on linos 5 and 6 of Attachment 17 A23. In my opinion, the individual who made the entries on lines 5 and 6 of Attachment 1 was not the same person who marked through the "13 s" and wrote the "14s" on I base that opinion principally on the l

differences between the "4s" on the two documents. reflects a uniform formation of the numeral "4," which appears there numerous times in the same hand.

The "4s" on Attachment 4 are formed differently.

Q24. Does that conclude your testimony?

A24. Yes, it does.

1 l-l l.

. %.- 9.U M E REQUIRED Attachmant 1

~

g6 affacta cystcm turn-IN$TAtt* TION TO BE' IN

~

4G @fi,

^N IScance must be WOC Scrial No.

    • # 4'"

$ Q191e Startup 5

eer prior to starting WELD DATA CARD Orawing No.

AM6 CO7 kal

^

Weld No.

FiddoG i

i

'e WPS f.

REY #/ICN#

FA8RICATION CCd5 &

//0t10 7/L

'2.AS!/ACC. STD.

.i (dillF-( cato-icore3

/ joy / g g ADIE y t

i T"f&

POSTWELD MEAT TREA P

7 to HT7 A)[1 TIME NA Hrs.. TU4P.

NA F

~ ~ ~ ~

l

~ M. tyn to PCl

>07 i

1

~ ~#

~ P#

/

to P #

/

HEATING RATE NA

/Hr.

NA

~

.473 SPECIFICATION WPS/ CPM 6.9U i

QI-QAP/REV VT

.1-26 10.2-1 MT/10.2 RT/10.2-3 RF(i)

IM.&T.E.

CALIE.

QC WELD FILLER MATERIAL REQUIRED t-I OUE CAi-LQC YERLF.

Ii3.% itweis wmnss nintite+ 1RGOT CLA55 6 w7.

NOATE:

I i

r iFILL CLA55 L W. R.

i i

i CLA55 E-, o d s- << / -< 5-1k

(

l t

i i

CLAS5

'50TE5:. g) Applicaole QC/ANI nota points.snall ca incicatec cy enectmarx v~.

j (2) ANI fnspection points indicated by (X).

(3) Oenote Satisfacter/ inscec-icn bv an "S*

Unsatisfac cre inscections by a "U".

PR00uCTION AELiASE l

,g}

'pFER.

OPERATICM HOLO FOINTS CCN SAT.

[NS7ECTION AE5ULTS (SIGN AND OATE)

.NQ.

WT

.QC ANI or QC or wi.

NDE CERT.

ANI UNSAT.

1.EfEL

..T

't=M

  • r t'n L

!!4 A ls"

,~fh /- 3-PW

[

0:du=2/M I-PB4 2

!.i G thh

?

CleantinesslNA

/

/h

. & //W

/fineggy 1

y'57/, j,q j,).

3 Fttup MA

/

f h,l hpf}Wh],j',yj' gig, f[

Preheat NA

/

i F1nal 1T NA

/

,s)(

)a $G h ) /k f9/;'b 3

& 4 $.

yl' s uv4Tv aA \\

,uc B+/M JJ2lB Ws

&4 Y

d' N~~

iU-z-m F haWR

/-s-n 0

lballn A]k k]0 YhWY//d/97 B-C

~

-GJ.!iJ.,.>) / h 8 4 A u', w / A N l

AuMn !,

N/

l l

if l

l Nli.xbd v eer<r ll% I/u / U S

/t/l' 0 */J2945

/ll

!/

l N/W/lWANIG A an,se8ted i'

ut M W //ic/s4 cc e latt

<41

' Agoroval signatures shalt be affixsd en the'lthe 4 mediately 'belo@4 caw.q1-(2,383-5 gn-3-e i,e

V (4.. rR f9-m m -

-ra;

L._

~

.T o-8 40851 "'

WPs' i g

w0c Serial.vo.

f/ds 0 llMO arnwing.Mo.

AF-l&Rn'7k-(tl.

//olf ws.0 r!u.a :uraIA tea werd ue.

FA) don

\\

WELD WELDER HEAT / LOT'd MT.

M T.

ISSUANCI APPF.0 VAL j

. tc.

CATE SIZE / CUSS SWBCL WPS/ICH f or CCOE i 153.

AT'O.

FW

//

4

  • h t/n K A

lion i

/7%

VA~

N fl'."

Id b9 n os-1.

5 So 4Rsa8ei

/

I

' s/ ~ /,

'/<i*f/"' '$

~

B rioz !

  1. A-. M J
  1. 3 A'0C s ens L s.b 97fd/

so lo fr%-n fia(

Jj/j)). /Eko.92 gN trolo__

Q d -dfLd-v dac

/H h

.s" o q9 cro j

/o 7

, J - 389 S

~

Ka

/

I'*f t - 2st-t pg (M/'AE_

ltoio Y

'fg 3

g -O l 97 Ya /

/0 S

f wY? K doc \\

F-!

'/,,Yr *' n ' W W

/*

sic /o 6*?<mi BA V4:

/r AfY

-s -c c2 c e 22 9 y_o O

(,

y fo c-

~

F2.) //-

46 z.-

//oso

/*;f,4 1 2 L

/ / E nt'- --

/

'/CL 0 L*7eid kNS YO

<~ - n o24G229 O

W ~ACD/

t j,d 7 - }/,N r,% tos-tAAt3 1o l 9Ws /

/o la f'

, i e., e

~ p /~ % g

'LLm y,fra gk,,Ypus-z. kO

"~7 - 0 i

rs

\\

AV- --ey---

dc 9WO/

ja

/'d

_ 72 (s f o

n.

g,lw

,"s es-e-na iais occ.m

<wm oe s.

9-c f,,,,.p- >, :1 ef pa n l

,ec L t-

\\

i r

I l

1 l

I i

i

.i i

l l

f l

i 3

I i

-[

l I

i i

s

  • e k

l

  • ~

" n;,:

6,

) i n

, (f

/

A' G;

( /YVh'

[

I, t=:acat:

f(hl

/

V' I

~

I,.

-?

)

,y J

.i

)

Wt.LM NO.

CATE S"ZE/ L 85 5k C

9 70 3 &

W I

2 3

31 OC hY X7CLS '.2 (tu. fd, E- ?osi doc 84 3e 3

fia.

I,'

(<- g o m

dec

. Ug+

F' K

<t'o e l/',n r C's!:

V.".",

v

~ #

i

~

4 t.

1.

..w:

r v ~- -

post omce som toot, c:en aces. Taas 76043

...e.

QUAUTY ASSURANCE DEPARTMENT T*

  • VISUAL. EXAMINATION C){ECA.IST PncJECn ccMANcHEPEAK Jos NO. 35 1195

~ UNIT *

/

PAGE

/ OP /

==

A F-/- 5 6 4 d O 7 M M M 30 30 sd=

.si.an====

n F V ~ l/ O'C.

6'C Vd.f f S/"/

h ~?$,.

~

Enter NA. adjacent to attribute when not applicabTe..

Enter Sat./Unsat, or NA above q.,results in each section 1 through 4 as applicable.

~~-

  • ggcp//$ ff/

QI-QAP 11.1-26 Rev.. /4t-CHECK UST

1. FITUP (Priorand During) e-aan Jeesse Omm o

_= se===

c m aa ses.seG w

  • =="'s"*"'"

Res 1ts.

sammens sausaseen sieras aey Otl A G8" M a.

j UPlenEd Elan / Ul reCIlOn 07 cl0W A

N'/9N i

omweu u ri e, e.

..n i

2. AFTER WELDING OF RCOT

'0I-0AP 11.)'-26 nev.

Results

//AL.

e i-s-

i ns nect.o r seve:

..n

3. CCMPLETICN OF WELD (10)

QI-QAP 11.1-26 Rev.

ca o

MM i.

I o= %

u_

Results awa.m UftWerust

  • CT14 n8C Tf P

'LOV.t caTE l

4. COMPT.ETICN OF WELD (CD)

QI-QAP 11.1-26 Rev.

14 sw va j

i Mllet slas Aj d s[

3

. so, s== nw.e so e

7 Res u i 'J'

.v.._

,wt sesrooms aus #r.ra a,e serites

= se J/

~.

n D-l /7/W gnspector /

Level OME V'

f l

OC Suneriision Oate OI-0[P11.1-26 Rev.

~

'~

^ " "

'* m+ e

. m.n.

~

ggg g

QUALITY ASSURANCE DEPARTMENi

~--- - ~

MT/PT REPORT PROJECT: COMANCHE PEAK JOB NO. 35-1195 UNIT PAGE

/

OF [

MT C PT F 1

WDC/ Traveler #

O k, f, Dr: wing h-6 6-007 System Class 3

hidhtem #

F. t.d.

OC Location ae, eos2 3 76" f, G. J hT73 Mfg Stage

[lgg[

NDE Procedure Nog g) g,y, f Rev. ]

Equip /M:t'Is Mfg.

gq gQ(q Acceptance Std.

fggg g

,~ l / l,

PenetrantBatch # k((Q7 f Cleaner Batch # M k[O O Develooer Batch # MC_O 9 O ACYeks O DC Prods O NA Modei #

aj g M&TE 1RC #

/\\/ A Diameter y

Mat'l Type

'- (

Mat'l Thickness

/1O Length O

Ca Skitc.* & Com&ts ID O OD V ya ec hA {o[e

' Al

  • C A SYON $

NO s

SY 4

l i

f

%6

%b' D in 3

MlU

~

M tor [j g f

[

Certification Level I Date / -f 7-E2/

$'*e'o*YReiect O

[

~

)

w 0%ME'En UW:'

UNITED STATES OF AMERICA *

. OCT 23 P4:02 NUCLEAR REGULATORY COMMISSI BEFORE THE ATOMIC SAFETY AND LICENSING: BOARD me,

- ~,

U In the Matter of

)

)

TEXAS UTILITIES ELECTRIC

)

Docket Nos. 50-445-2 and

COMPANY,

.e_t_ _a l.

)

50-446-2 (Comanche Peak. Steam Electric

)

(Application for Station, Units.1 and 2)

)

Operating Licenses)

CERTIFICATE OF SERVICE I hereby certify'that copies of the foregoing document in the above-captioned matter was served upon the following persons by hand-delivery,* overnight delivery,** or by deposit in the United States mail,*** first class, postage prepaid, this 23rd day of October, 1984:

  • Peter B.

Bloch, Esq.

      • Chairman, Atomic Safety and Chairman, Atomic Safety and Licensing Appeal Panel Licensing Soard U.

S.

Nuclear Regulatory U.S.

Nuclear Regulatory Commission Commission Washington, D.C.

20555 Washington, D.C.

20555 -

  • Mr. William L. Clements
    • Dr.

Walter H. Jordan Docketing & Services Branch 881 West Outer Drive U.

S.

Nuclear Regulatory Oak Ridge, Tennessee 37830 Commission Washington, D.C.

20555

  • Herbert Grossman, Esq.

U.

S. Nuclear Regulatory

  • Stuart A.

Treby, Esq.

Commission Office of the Executive Washington, D.C.

20555 Legal Director U.

S.

Nuclear Regulatory

      • Mr. John Collins Commission Regional Administrator Washington, D.

C.

20555 i

Region IV U.S.

Nuclear Regulatory

      • Chairman, Atomic Safety and Commission Licensing Board Panel 611 Ryan Plaza Drive U.S.

Nuclear Regulatory Suite 1000 Commission Arlington, Texas 76011 Washington, D.C.

20555

g.

O f

      • Renea Hicks, Esq.
  • Anthony Z.

Roisman, Esq.

Assistant Attorney General Executive Director Environmental Protection Trial Lawyers for Public Justice Division 2000 P.

Street, N.W.

P.O.

Box 12548 Suite 600 Capitol Station

-Washington, D.

C.

20036 Austin, Texas 78711

  • Ellen Ginsberg, Esq.
      • Lanny A.

Sinkin Atomic Safety and Licensing 114 W.

7th Street Board Panel Suite 220 U.

S.

Nuclear-Regulatory Austin, Texas 78701 Commission Washington, D.

C.

20555 f

MM McNeill Watkins II cc:

Homer C. Schmidt John W.

Beck Robert Wooldridge, Esq.

L

..