ML20106G172
| ML20106G172 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/01/1983 |
| From: | Brandt C EBASCO SERVICES, INC. |
| To: | |
| References | |
| NUDOCS 8410310075 | |
| Download: ML20106G172 (100) | |
Text
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I U.*ITED STATES
-)
A:SRICA hdCLEAR REGULATORY COMMISSION 3
INTERVIEA 5
6 OF CHARLES THOMAS BRANDT 8
9 Conference Room No. 2 10 Visitors Information Center Texas Utility Generating Company P.
O.
Box 2300 Glen Rose, Texas 76043 12 Thursday December 1, 1983 13 The interview commenced, pursuant to notice, g
at 1:25 p.m.
15 PARTIES PRES Et4T:
I On Behalf of the NRC Office of Investications:
18 H. BROOKS GRIFFIN, Investigator DONALD D.
DRISKILL, Investicator
)
19 U.
S. Nuclear Regulatory Commission Realon IV 20 611 Ryan Plaza Drive I
Suite 1000 21 Arlington, Texas 76001 nn On behalf of Texas Utility Generating Comcany:
U McNEILL w'ATKINS, II, ESO.
Debevoise & Lieber. nan 24 1200 Seventeenth Street, N.
W.
nasnington, D.
C.
20036 6
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EXHIBIT (11)
I
'P M O C E E D.I NGS n
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MR. GRIFFIN:
For the record, this is an 3
interview of Thomas Brandt, B-r-a-n-d-t, wno is employed 4
by Ebasco Services. Corporation.
The location of this interview is the Comanche 6
Peak Steam Electric Station near Glen Rose, Texas.
Present at this interview are Thomas Brandt 8
for Ebasco, McNeill Watkins, attorney for Debevoise and 9
Lieberman, Donald'D. Driskill and myself H.
Brooks 10 Griffih.
II The suoject of my questions to you, Tom, will 12 be regarding coati,ngs records and instances of I3 intimication that have been alleged.
I4 Tom, if you would please rise.
I am going to 15 swear you to the contents of your testimony.
16 knereupon,.
I CHARLES THOMAS BRANDT l
18 having been first duly sworn by Investigator Griffin, was 19 examined and testified as follows:
a0 MR. WATKINS:
Mr. Brandt, do you have anything 1
to say for the record before we start?
22 THE WITNESS: Yes. No.
1, I think that tne mode 23 of this investigation or interview or whatever you want to 24 call it is a little bit out of the ordinary in the fact 25 that it has never been done in this fashion before.to my i
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xnowlecge i n c.,
nree and a half ye&rs nere and ne fact tnat it is a sworn statement and there is a court reporter 3
present, anc on tnis very same investigation "X"
numoer of 4
interviewed in a fasnien unline nis.
inspectors were MR. GRI.FFIN:
Would you lixe an explanation, 6
Tom?
THE WITNESS:
Yes.
8 MR. GRIFFIN:
The NRC Office of Investigations 9
has not made an official policy, but is operating under a 10 celief that in instances where employees of companies 11 retain. attorneys or request attorneys or in instances 12 where incividuals that we interview request attorneys, or 13 if say in the case of as an example, an alleger wants to 14 make a statement to the NRC with an intervenor present, we 15 have decided within the Office of Investigations to use 16 court reporting services so that the flavor as well as the U
content of tne interviews will be captured and tnose I8 parties interested within tne NRC anc witnout and in the 19 case of you being interviewed, you would be supplied a a0 copy of the transcript, will have an opportunity to 21 recount the exact questions and answers and tnis will not 22 be lost and it will not be subject to interpretation.
23 We are trying to make it as exact and as 23 accurate as we possibly can and it allows us as the 23 investigators the freedom to pose our questions and TAYLOE ASSOCIATES 1625 1 STREET, N.W. - SUITE 1004 WASHtHGTON, D.C.
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I prepare cur questior.s witnout having to take notes ano preparing a written statement afterwards.
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3 So it makes it easier for us.
We capture tne 4
exact flavor of what we saic and there can be no doubt. It 5
removes all doubt or almost all doubt, and for these 6
potentially adversarial or conflicting situations where somebody might object or have objections to a 8
proceeding, we have'just used this as a tool to expedite 9
our investigations, our interviews.and to get a more 10 accurate picture of what was said and what the testimony 11 1
of tne person is.
I THE WlTNESS:
Whicn of the circumstances you l
13 have outlined is present here?
I4 MR. GRIFFIN:
Tne presence of an attorney.
15 THE WITNESS: No one here requested an attorney 16 until you showed up with a court reporter.
MR. GRIFFIN:
I have a further explanation for 18 that.
Tom has been interviewed by the NRC before and he I9 has given a statement to the NRC before, a signed sworn a0 statement, which from our point of view is pretty much the
'l same-as having a sworn testimony before a court reporter.
no l
The last time Tom was interviewed, he declined I believe
- 3 to give a statement.
Is that correct, Tom?
24
(
THE WITNESS:
That is right.
25 MR. GRIFFIN:
So we chose to have a court TAYLOE ASSOCIATES 1625 i STREET, N.W. - SUITE 1004 WA3HINGTON, D.C.
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5 reporter in tnis instance cecause tnere was going to be an attorney present and we knew that that was going to tage 3
place.
4 Ooviously Tom doesn't have to give us a 5
statement if ne doesn't want to and he doesn't. nave to be 6
interviewed here tocay, out it is more to our liking and I
it' satisfies our purposes if we have every reason to 8
believe that the testimony received is understood clearly 9
between all parties involved and that the interviewee is IO obligated and bound to the truth through the swearing u
process.
So we use this tool to expedite our interviews.
I2 THE WITNESS:
That has never ceen an issue, I3 Brooks.
I explainec to you last time exactly what my I4 hesitancy with tne sworn statement was.
MR. GRIFFIN:
Right. I understand.
16 THE WITNESS:
The only -- I won't go any I
further. To give it to you just in a nutshell, I was asked 18 last week I tnink if I wished to have an attorney present 19 and I said no, but wnen you showed up in the fashion tnat a0 you have, I have no intentions of talking to you without
'l an attorney present.
22 MR. GRIFFIN:
Kell, when did you map.e that 23 decision, Tom, tnis morning?
24 THE WITNESS:
No.
25 MR. GRIFFIN:
When we arrived?
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THE WITNESS:
Wnen you arr: 7sd.
MR. GRIFFIN:
nhen we arrived to talk to 3
Curley?
4 THE WITNESS:
V. hen you arrivec to tal4 to 5
Curley and he explained briefly the process that he.went 6
through.
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MR. GRIFFIN:
Well, see, if it was just me 8
talking to you or Don talxing to you or even botn of us 9
talking to you over in your office, there would be no 10 court reporter or lawyer present.
That is the way we II normally do it and that is the-way we lixe to do it, but l'
if we are getting.other parties involved and if tnere is a 13 question as to what was said or how it was understood, we I4 find tnat a court reporting service el'iminates that 15 problem.
16 THE WITNESS:
That is fine.
MR. DRISKILL: Just let me interject one thing.
18 The topic came up during the course of tne investigation, 19 gosh, it has been September I believe, the topic came up oo of interviewing Gordon Purdy, yourself and Ron Tolson, and "I
we were told at that time that we may have to wait a couple of days for some attorneys to come in, giving us
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23 the. clear indication at that particular point in time with 24 respect to the Dunham issue tnat the three of you would J
prefer to have attorneys present.
l i
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'f-he didn't ask each one of you, anc I don't o
even believe you were on the site on tnat occasion.
3 THE WITNESS:
Is that when you interviewed tne inspectors' with Rice?
MR. DRISKILL:
Yes.
6 THE WITNESS:
Okay.
MR. DRISKILL:
he were given that indication.
8 So we let Rice come bacx and do his thing and I don't know 9
whetner he had attorneys.
I don ' t really know anything 10 aoout what nappened.
II THE WITNESS:
Let me explain my bottom line 12 concern.
We are nere trying to do a job, as you guys are.
13 You know, everybody has got a 3ob to do.
There are U
400-plus QC inspectors out there that see the NRC come in with the Department of Labor and concuct a joint 16 investigation of the Dennam thing as Kind of a causual.
17 type investigation going. You asked for certain. people'and 18 we went cut anc found them and brought them in.
19 Now tne inspectors know, due to word of mouth, O
if nothing else, about this investigation. They know for a al fact that when the Department of Labor came back to tals U
to management, it was the Department of Labor alone and "I
they proceeded oh, with skepticism I guess is the best 24 word to use, the fact that you interviewed all the 3
inspection persona 11 as a joint investigation in a casual TAYLOE ASSOCIATES 1625 i STREET. H.W. - $UITE 1004 WASHINGTON. D.C.
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I environment, out yet w :.t : you come back to talx to tne supervisory personnel and management personnel, it is a 3
f separate investigation and it.is a much cigger deal.
You 4
come in with court reporters, swearing in and the wncle bit.
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6 MR.. GRIFFIN:
Tne swearing goes with our 1
statement taking, whether it is sworn that way or the i
8 i
other way, and the court reporting service, if tnat is l
9 intimidating or if that disturbs anybody, that is not our I
10 purpose at all.
It is not supposed to make this a more 11 formal proceeding.
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THE WITNESS:
I understand that, Brooks. All I 13 am saying is the perception tnat it gives 400 people out 14 tnere tnat we are trying to manage and head in a straight 15 diretion.
16 MR. GRIFFIN:
Well, I personally do not see it II tne same way.
I understand now ---
I THE WITNESS:
I am not saying I see it tham I9 way.
I am just telling you the way they see it.
O MR. GRIFFIN:
Okay.
'l THE WITNESS: They perceive it as a much bigger en deal, like, oh God, they are after Brandt, Tolson, Purdy n3 and,Krisher,
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at MR. GRIFFIN:
We are never after anybody. We
.n5 investigate and try to reconstruct the facts as tney J
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cccurred, and this is just sic. ply a tool tnat we use.
If n
somebocy reads something as this being more critical or j
3 as tnis being damning to QC representives, then I think 4
Oney just misreprsent what we intend.
5 THE WITNESS:
I can hear you caying that, 6
Brooks, but there is no ---
MR. GRIFFIN:
We can't back up because we are 8
liable to of f end these 400 OC inspectors.
9 THE WITNESS:
no, it is not offending tnem. I 10 tninx it would make, you know, I am not saying my jon, but 11 anybody, put yourself in my position or Ron Tolson's 12 position or Purdy's position. You know, by the hoopla, for 13 lack of a better term, that is being snown or demonstrated 14 over management interviews as opposed to line inspector interviews ---
16 MR. GRIFFIN:
Well, tne distinction is that in l~
line inspector interviews they don't have their attorneys 18 present, and in tnis instance ---
19 THE WITNESS:
The line inspectors were offered
- 0 attorneys wnen they were interviewed, and in thie l
4 21 instance ---
22 MR. GRIFFIN:
Well, I am not familiar with the 23 particular situation that you are talking about, but when 24 I interview inspectors on site, when I just casually call 3
tnem in and solicit whatever information tney nave in the i
l TAYLOE A550CliTE5 1625 i STREET. N.W. - SulTE 1004 WASHINGTON, D.C.
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9 10 area tnat I am investigating, I don't t. a '. e a 7F for the utility over in Dallas calling us and saying we are going 3
1 to have attorneys down enere. 'Now when you mention 4
attorneys and we know attorneys are going tc ce there, 5
expect to see court reporters oecause that is the way the 6
Office ~of Investigations is going to do it so that there can be no doubt as to"what was said.
6 THE WITNESS: I understand that, Brooks. I nave
-i i
9 no personal problem witn it. Don't get me wrong. I will be 10 glad to have the interview done on national television.
I 11 i
don't care.
j jo (Laughter.)
I3 All I am saying is you are you are casting a j
shadow of' doubt I tnink without warrant over the situation.
16 MR. GRIFFIN:
Well, that is not our intent at all, and I frankly do not believe that that is the case.
i 18 Now you have your own opinion on that.
We have not 19 announced our coming down nere. The people that know about 90 this are the people you work for anc the client managers I
al in Dallas.
Now we haven't made an announcement and nobody no Rnows we are here.
23 6
THE WITNESS:
Well, let me tell you how the 23 troops know.
25 MR. GRIFFIN:
Okay.
h*
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THE WITNESS:
Ine other cay Curley Krisher was 2
gone from his office and was unreachable for four hours 3
and people ask where he is.
Well, he is with the,NRC.
4 MR. GRIFFIh:
And is there anything unusual 5
about that?
All of you are subject to be interviewed by 6
the NRC on a repeated basis.
THE WITNESS:
I am getting quite use to it.
8 MR. GRIFFIN:
We are remote from your office 9
an'd we don't have you nailed down to a chair or nandcuffed 10 and you are not hanging from the wall'.
II (Laughter.)
12 We are up here in wnat I consider a fairly 13 b
remote place.
I4 THE, WITNESS:
I agree.
15 MR. GRIFFIN: We originally wanted to have this 16 done at TUDC0_ corporate headquarters in Dallas, ano that II would have c' een fine, too, or any other place. You all are la tne ones tnat deciued wnere and to a certain degree when.
19 If we can go ofr the record a moment, I have a0 got to take a phone call.
91 (Short recess.)
U KR. GRIFFIN:
Back on the record.
U You said you have some more statements.
24 THE WITNESS:
Yes, I have two requests. No.-1, 3
I.co formally request confidentiality of the transcript in TAYLOE ASSOCIATES 1625 I STREET, N.W. - $UITE 1004 WA$HINGTON, D.C.
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light of wnat nas already nappened in anotner similar investigation.
3 MR. GRIFFIN:
.You request conficentiality?
4 ThE WITNESS:
Yes, of the transcript.
MR. GRIFFIN: Okay. Now let me tell you what we 6
do with the t'anscript.
We mail you a copy' Now are you r
referring to.how we use it or the dissemination within the 8
NRC?
9 THE WITNESS:
No. I am talking about external 10 to the NRC.
MR. GRIFFIN:
Only you get a copy. We mail you l'
to your nome address a copy.-
13 THE WITNESS:
That is all I am requesting, I4 because if it can't be tnat way I am going to have I
proolems talking about individuals in light of the 16 potential civil action that can occur as a result of the labor suit.
I have been down this road once.
I8 MR. GAIFFIN:
Okay. Well, you are not talxing 19 about conricentiality in the same way that if we would go a0 out and we would talk to an alleger or a witness who wants 21 to give information because I presume you plan to discuss on your testimony with other members, not only your attorney, 23 cut yith other members of the community.
24 MR. WATKINS:
Pernaps I can help. By 25 confidentiality in terms of your treatment of the TAYLOE ASSOCIATES 16251 STREET, N.W. - $UITE 1004 WASHINGTON, D.C.
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i transcript, we woulo request, and I am spean..g.:cr you, Tom, that it not be discloseo to tne Department or Labor 3
or any representative of the Department of Laccr, that i not ce oisclosed to any member of tne puolic under tne Freedom of Information Act in response to a Freedom of 6
Information Act request, not that the substance of Mr.
I Brandt's testimony be disclosed whether via the transcript 8
or questions from you to any member of the OC inspection 9
program nere, and there is a reason for that, a management 10 reason for that'.
II It is difficult enough to supervise tne troops 12 as it i's without having tne.NRC, yourselves or somebocy 13 else within the NRC go to an inspector and say Mr. Erandt N
told us tnis about you and would you care to comment.
15 MR. GRIFFIN: There is another of putting that.
16 You could say on such and such a date did you attend a U
meeting'in which you said this, and if Mr. Branct was the 18 one that told us 19 THE WITNESS:
I have no proolem with that. But
'O particularly, as I said when we were off tne record, I 21 believe, in light of the pending DOL investigation, which 22 you chose, at least with my interview with the DOL not to 23 protect it, in the event that tne same event happens witn-28 this investigation as opposed to a section 210 complaint 3
that happened in the Atchison 210 complaint in that it was i
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inrreduced in a public hearing unsanitized, and the complainant's attorney had copies of my privileged 3
statement to the touclear Regulatory Commission and I 4
ocject to tnat.
MR. DRISKILL:
Okay. For the record, let me 6
respond by stating that we can accept your request for confidentiality.
However, there are certain provisions 8
wnich relate to -that, one of which is if we receive a 9
court subpoena for your testimony, we will nave to provide 10 it.
11 I am not sure that either Brooks or I have the 12 rignt to commit NRC to not providing investigative I3 information, even to include conficential information, to I4 another government agency conducting an investigation into 15 an area.
16 MR. GAIFFIN:
Under the parameters that you I
nave set.
In some areas confidentiality is quite clear. I 18 will tell you what we can co. he can go off the record anc I9 we can explore it a little further and make sure we have a "O
clear understancing of exactly what limitations you want 21 on your testimony and then we can research whether we can 22 abide by that.
If we can, then we can proceed.
23 He will go off the record.
23 (Shcrt recess.)
3 MR. GRIFFIN:
he will go back on tne recoi-d.
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15 Do you nave anything else ---
THE WITNESS: I have one other request. I would 3
like a copy of the transcript.
MR. GRIFFIN:
Okay. I don't recall wnether it 5
was on the record or of f, Tom, out you indicated earlier 6
that until you learned that a court reporter was to be used here you had not specifically er you had not planned 8
to retain an attorney or have an attorney present; is that 9
true?
10 THE WITNESS:
That is true.
II MR. GRIFFla: Okay. And you say your-reason for 12 wanting an attorney was the fact that it was to be I3 reported under oatn?
I4 THE WITNESS:
Right.
15 MR. GRIFFIN:
Coula you tell me when you made 16 the decision to have an attorney present?
17 ThE WITNESS:
Can I asx a question?
18 MR. GRIFE16:
Sure.
19 THE WITNESS:
When was Kirsher interviewed?
'O MR. DRISKILL:
Monday afternoon.
21 THE WITNESS:
It was that evening.
22 MR. GRIFFIN:
That evening?
23 THE WITNESS:
That evening, about 6 o' clock 28 that evening.
25 MR. GRIFFIN:
Had anybody spoken to you prior TAYLOE ASSOCIATES 1625 i STREET, N.W. - SUITE 1004 WASHINGTON, D.C.
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16 c that time about having an attorney witn you?
THE WITNESS:
In tne NRC investigation?
MR. GRIFFIS:
No, in tnis instance for tnis interview.
THE WITNESS:
I had been asked if I was going to use an attorney by Ron Tolson sometime last week, if I was going to request that an attorney be present and my 8
answer was no.
9 MR. GRIFFIN:
Oxay. So nobody instructed you 10 that you would have an attorney and that that attorney II would be a TOGCO attorney?
12 ThE WITNESS:f Absolutely not.
13 MR. GRIFFIN:
Or a Brown and Root attorney?
I4 THE WITNESS:
Absolutely not.
MR. GRIFFIN:
Ebasco, I presume, does not nave 16 any policy that requires you to have an attorney?
I THE WITNESS:
That is correct. Ebasco's policy l
18 l
1s that an attorney will ce made available if requested.
I9 MR. GRIFFIN:
Okay. Last week when the NRC "O
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contacted with Clements at TUGCO, he indicated to us that al all three of you would nava an attorney.
Now did you
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22 discuss this with Clements or any of his representatives 23 and thereby state that you didn't want an attorney?
24 THE WITNESS:
I have not discussed Enis 3
investigation with Mr. Clements at all. I was asked by, as TAYLOE ASSOCIATES 1625 I STREET, N.W. - $UITE 1004 WASHINGTON, D.C.
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7 17 I saio, Ron Teiso:.
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reports to Mr. Clements one level removed, if I wisned to have an attorney present during 3
tne investigation, and I stated at tnat point no.
4 MR. GRIFFIK:
Oxay. Tnen when you founo out on 5
Monday evening of the form in wh'ich Krisher was 6
interviewed, you decided you wanted an attorney?
THE WITNESS:
That is right.
8 MR. GRIFF lN: How did you decide wnich attorney 9
you wantec?
10 THE WITNESS:
It h'as been customary, if 11 requested, that the utility provide an attorney.
That was I2 discussed botp in NRC investigations'and Department of I3 La'bor investigations in a three-way discussion between I4 Texas Utility, Ebasco's legal department and myself.
15 MR. GRIFFIN:
So when did you realize Mr.
16 Watkins was going to be your personal representative?
II THE WITNESS:
Tuesday sometime.
18 MR. GRIFFIK:
Did you choose Mr. Watkins for 19 expediency in that he was going to be representing Gordon a0 Purdy anu I presume Mr. Tolson?
21 THE WITNESS:
Mr. Watkins meets with my approval is that is the question.
23 MR. GRIFFIN:
Have you ever met Mr. Watkins 24 before or tal.<ed to him?
D ThE WITNESS:
Yes, I have.
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MR. G'e I: I l h :
On other inquiries?
THE WITNESS:
On other inquiries, yes.
3 MR. GRIFFIN:
Okay.
4 Mr. Watkins, is it correct to say tr.at you are 5
nere tocay representing Tom Brandt as his personal 6
representative?
MR. WATKINs:
For purposes of this interview e 8
- ye3, 9
MR. GRIFFIN:
Altnough it nas oeen stated 10 betore, would you restate who else you represent or who II else your firm represents in enis matter?
12 MR. WATKINS:,
In tnis investigation?
13 MR. GRIFFIN:
In relation to Comanche Peak. I 16 mean be more specific.
j Ib 4
MR. WATKINS: Debevoise and Liberman represents 16 TOGCO in tne NRC licensing proceedings. It also represents I
Erown ana Root in the Department of Labor Dunham case.
'I8 MR. GRIFFIN:
All right. Anc you say that your 19 firm coes not formally represent Ebasco in any manner?
20 MR. WATKINS:
Not to my knowledge, s
21 MR. GRIFFIN: In this instance you are employed no by TUGCO then and you are representing Mr. Brand
- as his o3 personal representative?
24 MR. WATKINS:
I am not employed by TOGCO.
25 MR. GRIFFIN:
You are employed by Brown and TAYLOE ASSOCIATES 1625 i STREET, N.W. - $UITE 1004 WASHlHGTON, D.t.
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MR. WATKINS:
I am employed oy Decevolse and 3
Licerman, a partnership, and I am here for Mr. Brandt for 4
purposes of this interview.
5 MR. GRIFFIK:
Your law firm then,' wno is their 6'
client in this matter?
MR. WATKINS:
The firm has many clients.
8 MR. GRIFFIN:
Okay. In this matter tnough, do 9
taey have many clients in tnis matter?
10 MR. WATKINS:
At tnis moment as I sit here in U
this room speaking to you, Mr. Brandt is my client.
12 MR. GRIFFIN:
Is Mr. Brandt paying you?
13 MR. WATKINS:
That is information to which you I4 are not entitled.
MR. GRIFFIN:
Oxay. Well, let me restate that 16 tnen. I am trying to rind out if you have been retained as U
it appears on tne surface by TUGCO to represent employees 18 wno wors for various contractors and subcor. tractors in 19 benalf of TUGCO.
"O MR. WATKINS:
Mr. Griffin, I personally have al done very little, if any, work for TUGCO in my entire career, and my firm, as I say, several lawyers in my firm U
represent TUGCO in the NRC licensing proceeding.
I 24 personally am working for Brown and Root in the Dunham 23 Department of Labor case, anc rignt now I am representing TAYLOE ASSOCIATES 1625 i $TREET, N.W. - $UITE 1004 WASHINGTON, D.C.
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I Tom'Branct in this interview for purp._e3 of tnis interview.
3 MR. GRIFFIN: Okay. Well, tne reason I put tnis 4
question to you is tnat last weer. I was in telepnone contact with Nick Reynolds who is also a member of your 6
firm'I belive.
MR. WATKINS:
Yes, he is one of my law 8
partners.
9 MR. GRIFFIN: And Mr. Reynolds indicated tnat a TUGCO attorney would be down here or an attorney from the i
11 firm. I am just trying to snow for the record the relation l'
of wno at Comanche Peak, employs your firm.
13 MR. WATKINS:
Well, as I have stated, TOGCO is I4 a cl'ient of the firm and Brown and Root is a client of the 15 firm.
I have saic that twice and I don't think it can be 16 any more clear.
Fm. GRIFFIN: In this case, for the purposes of 18 today, you are also a client of Mr. Brandt's?
I9 MR. WATKINS:
No.
Mr. Brandt is a client of 20 ourS.
- 1 MR. GRIFFIN:
Okay. Again, Mr. Watkins, if a.
nn potential conflict of interest should arise between Brown e3 i
anc Root and the interests of Mr. Brandt, how would you 26 acdress tnat?
25 MR. WATKINS:
If by'your questions or any of l
l TAYLOE ASSOCIATES I
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Mr. Brandt's answers a potential or a natural conflic: of 2
interest emerges, I will asx for a recess and I will 3
discuss tne matter with Mr. Brandt.
MR. GRIFFIN:
Mr. Brandt,_then Mr. Watkins represe'nts you freeiy and voluntarily of your own 6
choosing?
THE WITNESS:
Rignt.
8 MR. GHIFFIN: Well, let's proceed then with the 9
questioning, if tnat is agreeable to both of you all.
10 MR. WATKINS:
Fine.
THE WITNESS:
Okay.
I2 MR. GRIFFIN:
Tom, I am going to be going into 13 a variety of areas.
Some of them are ones that you have U
adcressed on numerous occasions before.
So for the I
purpoces of the ongoing investigations, I am going to be 16 covering some old ground for you.
BY MR. GRIFFIN:
18 Q
Do you recall an incident in March of 1962 in 19 wnich Charles Atenison wrote an NCR on vendor welds in the 20 pressurizer tank in Unit l?
Do you recall that NCR?
21 A
At that time in March of 1962 I was unaware 22 tnat Mr. Atchison had ever written an NCR on the welds in U
the 822 pressurizer tank room.
24 C
When did you become aware of this NCR?
25 A
I had seen a sketch in March of 1962 which TAYLOE ASSOCIATES 1625 i STREET, H.W. - SUITI 1004 WASHINGTON, D.C.
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i is
.r.
A:ca son naa preparec indicating wna ne perceivec.;
2 be welaing defects anc a-CB&I supplied pipe wipe restra.r.:
3 assemcly. I haa only one sneet of paper whien was a s.<eten 4
of an area of this wnip restraint.
It was scmetime later 5
during tne summer or fall of 1982, I don't remember off 6
tne top of my head, when the non-conformance report 5crm emerged either ln' the licensing proceedings itself or 4
8 attached to one of tne intervenor's pleadings with the Board to wnere Atchison's nandwritten and unnumbered draft 10 of the non-conforma ~nce report was brought to my attention.
II Q
Was this NCR that came to lignt later on, it 12 was not then an actual NOR that had put in the program, 13 made part of th.e system, documented, and then tracked on M
site here?
15 A
I was unaware at tne time that Mr. Atenison 16 hao anything other tnan a concern over these welds.
II Q
das anybocy ever told you that this NCR had 18 been cnaracterized as having been lost on site?
Have you 19 ever heard that before?
20 A
I have heard that explanation.
I have also 21 heard explanations as to how it was purported to oe found.
22 Q
would you mind telling me what you had heard?
23 A
The story that was told was that a Mrs.
I 24 Darlene Stiner found the draft non-conformance report in a 25 Tuperware package she had at her house.
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23 I
celieve that.
2 Q
Was this NCR ever issued?
3 A
Yes, sir, it was.
4 Q
When was that?
5 A
sometime during the summer of 1982.
It is a
~
6 matter of record in the ASLB proceedings.
It was not,
~
however, issued as Mr. Atchison had reported it.
Mr.
8 Atchison's evaluations of the welds were in error.
Both 9
ar. Atchison's craft and tne correct reflection of wnat 10 was potentially def ective in those welds is a matter of Il record in the pe'rmanent plant recoro system at Comanche 12 Peax.
13 Q
hho issued this NCR?
14 A
I did.
15 0
was your name written on it as tne issuing 16 party?
17 A
I believe tne name on tne issuing party is C.
18 T.
urandt and C.
C.
Rancall.If not, it is one or the 19 other.
We conductec a joint investigation or Mr.
20 Atchison's concern.
21 Q
I m well aware that some of these issues have 22 been more than thoroughly examined by the Board and other a3 parties, but nevertheless we need to go over them one more
'4
~
time for a separate investigation.
25 A
It aculd be nice if we could get everycody TAYLOE ASSOCIATES 1625 i STRIET, N.W. - SUITE 1004 WASHINGTON, D.C.
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l 24 together.
2 (Laughter.)
3 Q
At the time that you first became aware of a
tnis drawing, I presume the drawing was made by Atenison?
5 A
I was told tne drawing was made by Atchison.
6
~
O Did he show you the drawing himself?
?
A No.
8 0
How did you come into possession of this?
9 A
It was brougnt to me by either Randy Smitn or 10 Mixe Foote.
11 Q
Did they represent it as having been John or tnis issue identified by Atchison?
13 A
Yes, tnat is correct.
14 Q
And did you ever have any communication witn 15 Atenison about this?
16 A
Directly?
~
1; Q
Yes.
18 A
No.
19 Q
Did you have any tnrough your subordinates?
20 A
Yes.
- 21 Q
Who?
nn A
I don't know that my subordinates ever y~
discussed it,witn Atchison.
I know they toic me they did.
at I have no reason to doubt them.
When I received tne 25 drawing, I wen't'with Randy Smith and Mike Focte to the TAYLOE ASSOCIATES 1625 i STREET N.W. - $Ulff 1004 WASHINGTON, D.C.
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q H
1 pressurizer tanx roca., the 822'or 832, wnatever it is, 2
reactor' building, Unit No. 1, to loox at the descriced
.3 welding anomalies,.for lack of a better term.
4
^N Due to the way that Mr.,Atenison,.cr wnoever 5
hac prepared the sketch, it looked like Mr. Atchison's handwriting quite frankly, I was looking for a piece about y
13 or 14-foot long.
The way he had drawn the sketch was 8
very confusing as it turned out even to the Chairman of 9
o tne.ASLB.
lo he located a foreman, a general foreman who l'
11 was familiar with Mr. Atchison's concerns.and he pointed me to the area of nis concerns. At'the time there was only 13 one safety belt amongst the tiiree of us. -I.went up and 14 looked at the concerns, whien were largely porosity, and, 15 as I recall, one linear ind,ication.
I went up and looked 16 at the area, came back down and told Randy Smitn and Mi.te 17 Foote.that the porosity that; Atchison nad noted was 18 acceptable.
The linear indication that he had identified 19 on this one page sketch that I had I celieved was a cracx 20 in the paint and not any linear indication on the weld and 91
~
also made an observation that a weld some distance away, wnich was a Brown and Root weld, and by some distance I
,3
~
will say three feet, had--just been PT'd. The craft foreman 4
4 or general foreman, whoever it was that was with us had complained about the amount of s0rface preparation 1
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-requirec. It.cas readily apparent, as the weld:1coe.ed li<e it nad been polished to a mirror finish, and I mentioned
'g3
' 4 also to-!.r. Foote and Mr. Smith at that time that it 4
. appeared Mr. Atchison'was requiring an excessive amount of i
I 5
surface preparation prior'to performing the liquid 6
7 MR. GRIFFIN:
Okay. Could we go off the record 8
just for a moment.
9 f
(Discussion off the recoro.)
10 (short recess.)
11 MR. GRIFFIN:
Let's go back on.the record.
,. 12 BY MR. GRIFFIN:,
13 Q
I~may have already asked you this,. Tom, but 14
.was it your understanding or did you hear from third 15 parties that Darlene Stiner had found this NCR that 16 l-related to tnis pressurizer tanks in Unit l?
17 A
That was the story that I heard.
18 Q
-Do you nave any personal knowledge of tnat?
19 A
I don't have any idea where Darlene Stiner 20 lives and sne purportedly found it at her house.
The 21 answer to the question is no.
22 Q
It was not found on site or it was not located
- x. \\
2.3 on ---
24 A
The story I heard was she found it at home. As 33 a matter of fact, she even told me that, that Mrs. Ellis i
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., ~, -
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3 nac come to her house and said tnat, and I nave zorgotten now it was explained now Mrs. Ellis even knew she had it, 3
but Mrs. Ellis came and claimed that :nat was Mr.
4 Atenison's property and came to retrieve it from Darlene.
5 0
You indicated that one of your subordinates 6
back to Atchison and gave him was it your reply to -
went the conditions you found as relates to these vendor welds?
8 A
What I was told was, anc xeep in mind we are 9
talking a year and a half ago, by either Mike Foote or 10 Randy Smitn, that they hao'gone cac4 and told Atchison 11 essentially that I didn't have a problem with the porosity.
12 and if ne still concern over tne linear indication, to 13 have tne paint' removed. Mr. IJ.chison cnose not to have the 14 paint removed, as was evidenced by me personally wnen I 15 went to reinspect the welds.
When I became aware of the 16 draft NCR later during the summer of 1962, the paint was 17 still intact.
18 O
Did you give Foote or Smith, whichever one of 19 these two supervisors who went back to Atenison, did you 1
give them any instructions beyond just your opinion on tne 21 state of tnese welds?
no
~~
a When I came down off the scaffolding or wall,
~3 or comoination thereof,. they were both standing or leaning 94 against the vertical leg of the scaffolding, and keep in 20 mind this is a very small room we are talking about, l'
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26 prcoably nt_I tne size of the room we are in witn a tank 2
in~it, quite close quarters, so we were in close proximity 3
to one another, and I just looked at them, and to tne best e
of my recollection my statement was you guys nave got a.
5 problem with Atchison. In my cpinion, he doesn't Know what 6
ne is doing.
He o'oviously coes not understand the reject 7
criteria.
I also mentioned the polishing of the welos.
8 Possibly in retrospect Ranoy Smith didn'.t understand what 9
I was saying at the time as far as my statement that I cid 10 4
have a problem with Atchison.
Mike Foote knew me well 11 enough by that time to know that I was telling him ney, we 12 needed to look at it.
I didn't say go yee therefore and 13 speak to Charles.
I just said to tell him ta-da, ta -d a,
14 ta-63 15 Q
Did you later learn of what Atchison was tolc?
16 Dic you get any feedback as what hc had been in told and 17 in what manner?
18 A
It is a matter of record, to the best of my 19 recollection in the Department of Labor nearing and the 20 ASLB hearing tnat Atchison was told tnat if ne had further 21 concerns with that weld on that whip restraint to nave the en craft remove the paint.
23 Q
D,o you have any personal knowleoge of anybocy
, z intimidating or attempting to intimidate Atenison to be 25 not so thorougn in his inspections as a result of this l
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m..
.,--,.e~-
4 l
29 I
- nctaent?
2 A
That question implies that Atchison was 3
thorougn.
I coulcn't disagree with the statement more.
4 Atchison was never thorougn in is inspections.
Atchisen 5
could not realize-that a weld could have anomalies in,it 6
and still be acceptable in accordance with the code.
7 So if your question, and I will attempt to 8
rephrase what you are trying to get at, was that did 9
anybody ever tell Atchison to slack off and cut the craft 10 some slacx, no.
Il Q
Okay.
Let's move on to another instance. Do I
you recall an incident in Unit 1 in which an NCR,was 13 written on hilty bolt failure during hydrotorqueing?
Do 14 you recall that NCR?
15 A
Yes, I do.
16 Q
Did you review that NCR?
17 A
1 ceg your pardon.
No, I don't. I recall an 18 incident on -- hilty bolts, to the best of my knowledge, I9 were never torqued with a hydrotorque.
The issue that was 20 raised by Mr. Atchison was the A-480 colts failing during 21 torqueing with a hydrotorque, not nilti bolts.
22 Q
Did you review this NCR?
'3
~
A Prior to issuance?
94
~
Q No, after it was issued.
25 A
Yes.
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30 Q
D d ycu give Atcr. sen any instructions as 2
.related to his NCR?
3
-A 1 don't ever rememoer discussing the NCR witn 4
- Atenison, i
5 Q
Did you discuss it with some.of your 6
subordinates who then. discussed it with Atchison?
7 A
The answer to tne first part of the question 8
is yes, I did discuss it with my subordinates because at 9
i tne time we didn't xnow what the problem was.
The rirst-10 two people that I remember discussing it witn were Bill 11 hartshorn and Mike Foote. Mixe Foote I know discussed this
. witn Atchison.
Mixe was irrtimately involved in tne 13 establishment of torque values for A-490 bolts subsequent 14 to the problem and was also responsible for making tne 15 observation that Atchison didn't know how to read the
^
16 nydrotorque which was in our best estimation today the
-17 reason the bolts were failing.
18 There are four individual scales on the nead 19 of the nydrotorque corresponding to a series of mechanican 20 advantages and hydraulic advantages, depending on size of 21 the head.
Excuse me, there is a scale on the meter of the 9,
hydrotorque, and depending on what size head you use, 23 there are four scales.
It is called T-1 througn T-4.
- ~4 Atchison was unaware of the fact that eaca particular 25 scale corresponded to a particular size head, so it is TAYLOE ASSOCIATES 1625 i STREIT. N.W. - SUITE 1004 WASHINGTON. D.C.
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unx:,osn cy me or anyecdy, other
- t. tan possioly Atctu sen, what-scale ne was really using on tne hydrotorque when tne 3
bolts failed.
4 Q
Do you know what instructions Foote may nave 5
given Atchison related to this?
6
~
A.
Foote instructed Mr. Atchison~on 'the proper use of the hycrotorque.
8 Q
Do you know if Mr. Foote tnreatenec or 9
intimidated or attempted to get Mr. Atchison to be less 10 thorough?
11 A
Certainly, I do know, and the answer is I
certainly not, because at the time we went through an 13 extensive -- we tested the bolts that' failed. We ran tests 14 to establisn torque values for the A-490 colts, which at 15 the time took, I won't say a consideraole amount of 16 effort, but took some effort. We were interested in really 17 wny the bolts failed and not in the fact that Atchison or 18 anybody else had identified the proolem.
19 Q
Were these tests conducted by representatives 20 from Chicago Eridge and Iron?
21 A
No.
22 O
Do you know of any testing on these bolts by Chicago Bridge and Iron that resulted in bolt failure?
24 A
No.
25 Q
Has tne issue of tnese bolts been resolved?
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A Yes, it has, botn on sate anc occh. : the 2
satisfaction of your resident inspector.
3 Q
Let's move on to another issue.
Lc yce recall 4
an incident in February 1962 wnen Atchison refused to sign 5
off on design changes on bestinghouse whip restraints.
6 without-olueprints which did'not contain Westinghouse 7
headquarters approval?
8 A
I am aware of the charge by Atchison.
We were 9
not, the best of my recollection, ever able to come to 10 grips with exactly what he was talking about.
The people 11 he alleged made the changes, we went back and reviewed 12 many instances and the changes nad all occurred with 13 Westingnouse concurrence.
It was possicly not formal on 14 anything that was issued to Mr. Atchison indication that 15 1
Kestinghouse Pictsourgh had reviewed it, but in all cases 16 tne nestingnouse site representative had approved the 17 cnange, who is responsible for maintaining continuity with 18 the westingnouse design process in Pittsburgh.
O Are you aware of any threats of narm or bodily I
20 injury made to Atchison,made by a millwright lead over 21 this incident?
22 A
No, absolutely not.
Q You never neard of any such incident at all?
a4 A
No.
i 5
Q Did you yourself tell Atchison during your TAYLOE ASSOCIATES 1625 i STREET, N.W. - $UITI 1004 WASHINGTON, D.C.
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l 33 discussion witn nlm on tnis incicent cack cif cr I will
~
fire you?
3 A
Mr. Atchison and I never discussed tnat 4
l incicent by Mr. Atchison's own admission.
In the August a
1982, Department of Labor hearings Mr. Atchison and I,
6 other than casual conversation passing in the hall and in tne field only had two occasions to ever speak to one 8
another.
I don't remember off tne top of my nead what
[
9 tnose two occasions were.
Excuse me, only had two 10 occasions to speak to one another while he worked for me.
Il Q
Do you know if anybody tolo Atchison to back off on this issue or that he would be fired?
13 A
No, I don't.
I have no reason to believe that 14 even occurreo, It 15 Q
Okay.
Let's move on to another subject. 'Anat 16 was your involvement in tne termination or Robert 17 Hamilton, Joe Krolak anc a fellow by the'name of Sheldon?
18 A
Sherman Sheldon.
I was the decision-maker 19 together witn Gordon Puray wno was their administrative 20 supervlsor.
21 Q
So the facts were presented to you and you
~
decioed on the termination?
"3
~
A Yes, sir.
at O
As relates to that incident, during the incident had you heard of statements tnat were. allegedly TAYLOE ASSOCIATES 1625 15TRIET, N.W. - SUITE 1004 WASHINGTON, D.C.
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'made oy a supervir or cy the name of Hawkins in wnien i
2 Hawkins indicateo or related to otner parties that tnis 3
particular inspection, and I believe it is on a ring in n
--tne dome, was unsafe?
5 A
I am not firsthand fam.iliar with what 6
~
happened.
I am familiar with-the facts surrounding the inciaent, but it is not really a similar incident.
The indhent that you are referring to occurred in Unit 1 as I
b 9
opposed to Unit 2, which was the incident whien I was 10 familiar with and was involved with. -The incicent in Unit 11 i involved some unsafe practices, for lack of a better 12 term, involved swinging essentially on a rope from place 13 to place 106 feet above the ground floor, and I would have 14 to concur witn Mr. Hawkins that.that is unsafe.
15 Q
So are you saying that if this is tne same 16 incident, it is not the same' inspection that these men 17 were required to perform?
18 A
Absolutely not.
As a matter of fact, Mr.
19 Krolak, which is one of the two men, had been on the 20 rotating access platform rail as early as I believe two 21 days, but I will specify within a week prior and made no n,
~
mention of any unsafe practices.
Before I made any n3
~
decision, I gent Mr. Harry Williams and Mr. Mixe Foote uo
.~4 a
to the area.
Harry Williams was definitely afraid of i
neights ano Harry had no problem with walxing completely 1
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as
(
arouno the circumference of tac containment.
I called
-f b
^
~
Safety.
Sam Hogart, who is the senior safety 3
representative, innicated that ne had inspected tne area 4
i and it was safe, and Neil Britton, who at the time saa One
,a 6
protective coatings supervisor, had indica'ed to me that t
he felt the area.was safe.
Prior to dismissal the gentlemen were tolc to 8
perform the inspection and not once, I might add, dio any 9
of tnem claim that tney were afraid of heights. Had anyone 10 come and said, Tom, I am just absolutely scared to death 11 to go up there, I would have evaluated the situation much differently than I did.
13 Q
What did they give as their reasoning?
A They just said it was unsa8e and we ain't i
I 33 going.
As recently, or as late I guess is a better way to-l 16 put it, as Mr. Britton going out and getting the three 17 indiviouals and coming into my office at my direction 18 early the afternoon that they left, Mr. Britton said, 19 guys, you are making a mistake.
Brandt is serious.
20 Hamilton laughea and said Brandt is bluffing.
I did not 21 know tnat at the time, but in retrospect it even confirms my decision of what really was the motive.
,3 Q
well, what was the motive?
ot A
In my opinion, it was an effort to call it. It 25 was a power play and an ef fort at mutiny, and the f act TAYLOE A550Cl4TES 1625 I $TRIET, N.W.
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nat they tried to implicate houston Gunn in the issue.
2 houston Gunn has worked in the fab snop on a concrete
~
3 tacor as long as I have been here and he is still working 4
in tne f ab.snop on a concrete floor and nas never been 5
, assigned to the area. They also attempted to implica.te, Joe 6
Fazi in the issue who at the time was assigned to night 7
shift ana who on the very night that Mr. Hamilton was 8
dismissed went up ano performed inspections on ene 9
rotating access platform rail.
10 Q
But to what end?
11 A
Bob Hamilton called Houston Gunn ano said come 12 on, we have got to go to Brandt's office.
We are getting 13 fired for not walking the rail.
I had never requestec 14 2
Houston Gunn to walk the rail.
15 Q
I am asking you, Tom, wnat is your 16 uncerstancing of the reason they dicn't want to do it?
l 17 A
I think,it was an effort at mutiny.
la Q
To what end?
19 A
To what end?
20 Q
Yes.
21 A
To show me that they were going to do what n,
~
I they wanted to do, that they would decide what was safe i
4 en and unsafe..I mean it is hard for me to believe that i
21 someone probably in his early 40's, as Mr. Krolak was, 25 coula nave routinely performed the inspection en the rail I
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37 and-for nc ci.uations to have enanged, ano all of the sudden one day decice that walking the rail was unsafe.
3 Q
Do you know of any etner factors or concerns 4
tnat tne tnree gentimen had tha-woulc nave brougnt an 5
inciuent like t'his to a head, or that would, add support to 6
why this occurred.at this time?
'T A
I don't understano the question.
3 Q
Well, let me approach it from a different way.
9 Do you believe that tnese three people legitimately
]()
believed that-this was an unsafe inspection?
11 A
I think I just answered that. It is incredicle l'~
for me to believe that a guy had been up there routinely, 13 in exactly the same condition, and just one day woke up in 14 a new world and deciced it was unsafe.
15 O
okay.
Well, tnen let me go back to tne 16 question I asked before. Are there any other circumstances 17 or events or tnings that were going on ---
13 A
- Jot to my Knowledge.
19 Q
They just hit you witn this cold?
20 A
One morning they decided they weren't 21 performing the inspection.
22 Q
And you don't know why ---
23 A
I have no idea.
48 Q
other tnan just you feel li<e it may have been a mutiny?
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3E A
1 have no loea.
As a matter of f act, I even
.2 looked into any extenuating circumstances and was unable 3-to discern any.
I specifically asxeo the question did the 4
conditions on the rail itself change ano, you know, for 5
some reason had the craft. spilled some grease on the rail i
6 to make it slicx where tney would feel unsafe.
I have a 7
memo in file from Mr. Britton saying that tne rail was 4
8 j
clean, no debris, no obstructions, a safety line within 9
hand's reach and no grease.
Q During the process of their termination did 11 they offer you any other explanation other tnan it was 12 unsare?
13 A
Absolutely not.
14 Q
Prior to the time these men were terminated, 15 would you characterize their performance as inspectors as 16 adequate?
17 A
Sherman Sheldon nac not been employed long 18 enougn for me to make a decision one way or the other. Joe 19 Krolak was no ball of fire and had trouble properly 20 preparing documentation and seemed to have a little 21 problem understanding the changes we had made in the e,
program in November of 1981 as a result of a notice of violation received from Region IV in order to properly 4
og document the inspections whicn they were performing.
Bob
, hamilton had been the coatings lead inspector for probably TAYLOE ASSOCIATES 16251 STREET, N.W. - SUITE 1004 WASHINGTON, D.C.
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19 years and was directly responsicle fer non-imple.nentation
~
of the program wnich resulted in a notice of violation. So 3
I had a hard time oelieving that I would reco.nmend hic 4
very highly.
er 5
Q Are you familar witn who tney were rated by 6
the performance appra,isals prior to their termination?
~.
A No.
It was never any concern of mine.
8 O
Did you ever find out throogn this incident if 9
they had nac satisfactory appraisals?
10 A
I never looked.
To me.it was a clear-cut case 4
11 of insuboraination.
)I 12 1
C Did anybody g.ve you any instructions or 13 influence you in your decision to terminate these people?
14
,l A
To be quite honest about it, I don't even l
15 remember asning anybody.
I remember calling Gordon Purdy, 16 as they were all three Brown and Root employees, to my j
17 office and I said, Gordon, I have a problem with tnree of 18 your people.
He assed me what it was and I explained the 19 situation fully to nim.
We sat all three of them down in 20 the presence of Neil Britton and Harry Williams, Gordon 21 Purdy and myself discussed the situation with them and i
22 asked them if they had anything further to add.
They had 23 none, and I said well, guys, this is the last chance.
You 64 either neea to go and perform the inspections or I don't
~5 need you.
They all three chose to go to the gate.
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4C 1
l We : 1 ied out,.I won't call it a co.:nseling 8
form because it really wasn't counseling, but a 3
description of tne incident indicating the recomended 4
course of action was to be termination whicn Gordon Purdy 5
anc myself co-signed.
6 Q
Prior to your terminating these fellows, was 7
Tolson involved in or aware of wnat was going on?
8 A
As I-just stated, I con't remember asking 9
anyone or ir.volvir.g anyone else. I'mignt have told Tolson, 10 but I can't really speculate on whether I did or not.
Il Q
How about Mr. Chapman or Mr.
'Clements, where la tney aware of this incident'at all as it developed?
13 A
Definitely.not, not from me anyway.
14 Q
Okay.
I want to switen subjects again. Do you i
15 recall an incident involving Darlene Stiner anc a QC 16 trainee in wnich the trainee was using large amounts of l-liquid penetrant during a training exercise? Do you recall 18 this incide'nt?
19 A
No, not from that description anyway.
20 Q
Large amounts of liquid penetrant on a wall 21 4
apparently applied without knowledge of the normal means 4
of performing that.
23 A
No.
ng Q
Did you ever instruct Darlene Stiner to 25 perform plug welds?
i TAYLOE ASSOCIATES 1625 i STRitT, N.W. - $UITE 1004 WASHINGTON, D.C.
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i A
Darlene Stiner never welded while I supervised 2
her.
The answer to your question is no.
[
3 0
Did you ever instruct her to accept plug welds 4
performec oy other people?
A I don't ever remember instructing'her to.
6 However, such is a said practice, not to accept, but to l
7 inspect plug welds would have part of ner normal course of 8
outies.
9 O
Are plug welds, and I am asking because I 10 don't know, are plug welds an acceptable means of welding 11 according to site procedures?
1 A
The't'erm plug wela is misleading, as I. nave 13 testitied at some length on at tne ASLB proceedings.
Tne term plug we.1, if I can draw a picture for you, as 15 defined by both ASME and AWS, would be performed by 16 drilling a hole through this piece of material, 17 essentially welding to tnis piece of material at tnat 18 location and only tnat location.
By doing such you woulc I9 be transmitting any kind of shear force applied there to 20 that member.
'1 What Darlene Stiner has historically been
~
concerned with in her plug weld story, for lack of a
~1 better term, has been the repair of a misdrilled bolt hole
' 4 in a single piece of material which AWS clearly defines as
,3
~
fillet welding a hole.
l TAYLOE ASSOCIATES 1625 i STREET, N.W. - $UITE 1004 WASHINGTON, D4 20006 (202) 293 3950 l
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Q so in your opinion a plug welc is not tne 2
proper term?
3 A
That is right.
My testimony in.the ASLB-4 proceeding uses tne term plug weld, 5
~
out it'is italics.
o Tom, you were called on another instance.
6 involving Darlene Stiner-regarding vendor welds on some 7
large doors tnat she had written an NCR on.
8 A
No, not any involvement that Darlene Stiner 9
nao with any large doors.
There have been NCR's on large 10 doors, but not that Darlene Stiner and I ever had any 11 discussion or anytning on.
As a matter of fact, I was 12 unaware that sne was even Involved with the missile doors.
13 0
Could you tell me what the NRC's that you are 14 familiar with, wnat they involve?
15 A
Tnere are some NCR's involving vendor welding 16 made by Overly Manufacturing Company which were 17 suosequently repaired.
18 0
Because the welds were found to be 19 unsatisfactory?
20 A
Right, when they wera received on site.
21 Q
And NCR's were written and they were n,
dispositionded?
21 A
The vendor told Overly to come in and repair "4
the welds.
25 O
And all these NRC's, have they been TAYLOE ASSOCIATES 1625 i STRitT, N.W. - SUITE 1004 i
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dispositioned and closed?
2 A
I won't say they have been closed.
They have 3
all been dispositioned, to tne best of my xnowledge.
4 o
And you have already stated that you did not 5
. recall Darlene Stiner's. involvement regarding these, vendor 6
Do you recall ever instructing Darlene Stiner to buy off on large coors in spite of her concerns of vendor 8
9 A
ho, I definitely dia not do that.
10-Q Dio you yourself inspect these welds once'tnis 11 1-ssue was brought to your attention, not necessarily as l'
~
relates to Darlene Stiner, but just to ---
A Provided that we can make that clarification 14 that your question appears to make the assumption anyway 15 that we are talking about the same doors or same welds, I 16 have reason to believe tnat is not tne case because I 17 think the particular issue that I am talking about was 18 identifiec ana resolved after Darlene Stiner left the I9 site.
20 Maybe I can make a generic statement.
I have 21 never instructed anybody to accept anything they were uncomfortable with accepting. I have on occasion disagreed n3
~
with inspectors, in which case as a Level III certified in 94 accoraance with ANSI N-45 2.6, I signed off approval on 25 the IR as the Level III examiner.
It nas happened on two TAYLOE ASSOCIATES 1625 i STREET, N.W. - $UITE 1004 WASHINGTON, D.C.
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,4 i
cases that I.can remember, one with an inspector namec 2
Mike Rhodes on a piece of structural steel that was in the 3
warehouse, and the other incident that I distinctly 4
remember was with Dan Hanke in an incident in tne paint 5
laycown yard on some whip restraints, and by inference 1 6
essentially did the same with Mr. Atchison's concerns on 7
porosity that he identified in this 822 pressurizer tank 8
room incident.
I have never asked any inspector to sign 9
something tney were uncomfortable with.
10 Q
Do you recall ever having a conversation with 11 Darlene Stiner in which you toic her to confine ner 1
inspect 1.ons to those that,she nad been assigned and not to 13 report deficiencies or to examine areas otner'than those 14 she had been assigned?
15 A
There was a period of time that we had 16 problems with inspectors just wandering acout looking at 17 what they per.ceived were rancon issues. I can't say beyona 18 a snadow of doubt in my mind that I didn't tell Darlene 19 that she was assigned to, for example, classified pipe 20 supports and sne didn't need to be looking at ASME class 21 one, two and three piping.
That is possinle that I might ad have told her that, in which case if I had told her that, m
as I said, I.never told anybody if they had a genuine at
~
concern about something to not bring it to light.
I have 25 encouraged it in several issues.
)
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45 1
Q Did you ever hear Mr. Tolson tell Darlene 4
~
Stiner to confine ner inspections to nose sne was 3
assigned?
4 A
.Not tnat I recall.
1 only recaAl Mr. Tolson and I ever talAing 3cintly witn Darlene 5 er
$l5E5 l$$?2QQ.f95[hWE 5 5f(k.;,
h' $j im i
O Oxay.
hell, tnat orings us to cur next 8
Suoject. You were present for, would it be fair tc term it 9
a counseling session?
A It Wasn't really a counseliag session
(
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i Q
- Yes,
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ria;te;;;;i)que..=agg Ron and I callec her in ana talxed to 18 ner I celieve in tne presence of -- excuse me.
Tne first t
i 19 l
dir,cussion I celieve was just Ron and I, and I am talking j
20 i
oft tne top ot.ny h ea c.
I don't reme:noer time secuence i
"I
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tnat well cecause it was never any big deal as far as I i
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was concerned.
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20006 (202) 293 3950
46 1
clon't tnink that it was in her best nealtn interests to j
2 i
continue working as an inspector anc we just wanted ner tc I
3 be aware or -nat ner options were as far as leave or ac=ence.
5 It might have ceen in the same saeeting or it 6
i migot have been la a suosequent.neering that we brought
[
?
Mr. any Yockey, wnc is brown ana Root's personnel manager j
on site into the discussion to implicitly descrine to her 9
i what her options were as far aa a leave of absence,
(
10 l
Q Do you know how many sucn meetings nat sne 11 had with Tolson over the course of ---
e l'
I A
I ca n ' t speak for Tolson.
I can speak fcc j
13 meetings that I was involved witn.%r. Tolson and Carlene and, as I said, it might have been the same meeting or it 15 mignt have been two meetings.
I don't really Know.
16 Q
Are you aware of ner attencing otner meetings f
17 9
on tnia same sub]ect, more spectrically being calleu to 0
18 Tolson's oftice?
g 19 i
A The meeting = cna: I am describing toon place l
20
[
in Tolson's oftice.
nl 0
Q 1 am tal<ing about otoer meetings.
Are you
)
n, t
aware or onner meetings?
]
f al A
I believe, ano once again I would have to al check toe recoras to be sure, I believe Darlene was a f
25 h
person that we were concernec witn due to our commitment h
I TAYLOE ASSOCIATES
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20006 (202) 293 3950
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to Reg Guide 1.56 as of Feoraary 21st or 26tn, 1982.
It endorsea and required tne adoption of ANSI N-45 2.6 as far 3
as certification.of inspection personnel and acded enat in 4
acoition to all tnose requirements tne Commission was 5
requiring that any inspector be a nign school graouate or 6
a recipient of a_GED.
7 To tne best of my recollection, Darlene was 8
one of tne personnel who had been here prior to February 9
'ez ana nau been certifiec when that requireinent dio not 10 l
apply, ano I celieve acn and I sat cown and explainec to l
11 i
ner that in order to continue worg sne woulo nave to go l
g,-
i octain 4 GED tc co.aply witn the reg guide.
13 Q
Dic tnese meetings tnat you attended in 14 I
Toisen's oftice alta Darlene Stiner that related to ner i.
not naving a nign 16 schoci ecucaticn come about following ner appearance before that ASLB boars?
18 A
I am not sure of cates, and I want to say in 19 botn cases no.
Definitely in the education case the ander l
20 i
is rio. It was significantly prior to that. In either case, i
nj ner appearance nau no effect on our discussion.
,,o Q
During these meetings, tne one or two that you s
attended in Tolson's office did
' 4 you or Tolson ma<e any recommencations to Darlene Stiner regarding her einploy men t ?
TAYLOE ASSOCIATES 16251 $TRitT, N.W. ~ $UITI 1004 WASHINGTON, D.C.
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A It apoears to be a leacing question.
I can't 2
really know wnat you are after.
I have explaine6 to you 3
tnat we even went to tne extreme of calling in tne Brown 4
and Root personnel manager to explain to her what Srown 5
ana aoot's corporate policy was as far as leave of s
aosence.
l Q
well, I mean do you call everyocdy in and 8
i econsel them er ---
9 j
A Sne nao mace statements to ner peers that sne j
10 really couldn't do her 3oc any longer due to tne pnysical i
limitations et I
he 13 j
movec ner out of the field to the fao shop and noused ner l:
in a building right outsice the faa snog maybe, on, ten i
15 l
yarus away from the fac shop whien, as far as I aa 16 i
concerned looicing in retrospect, we proca'ly treated her o
f 17 j
witn cia gicve.s. I don't know :nat I woulc co tne same for 1
18 l
every:>ody that got pregnant. To me it you are an inspector 19 4
y:>u are expectec to oe able to climo and go up and oown p
00 i
stairs anc ov her owr acmission she couldn't uo sucn.
i e xept her
.c the extent of even providing j
~
transportation for ner to and from the guard gate because y
l she coin;.lained of physica). tnreats and was concerned about 25 4
her well oeing.
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l 49 1
Q was t.li s f rilowing tne A3* 8 hearings ?
2 A
This was following the hearings.
I won't say 3
pnysical threat.
Please strixe that. It was harassment I 4
think was the actual complaint in the event tnat from tne 5
guard gate where she would nave to have entered to her 6
place of work which was probably 3/8tns of a mile.
We 7
arranged to have her park in the 2-C parking lot and the 8
Brown anu Root administrative assistant was sen t everv
~
9 morning in a car and picked her up in the 2-C parking lot to and delivered her to her door of her office and returned 11 in the afternoon, picked her up at her office and I
delivered her to the 2-C parking lot.
I don't xnow what 13 more we could have done for her.
14 Q
I am just trying to explore what 15 A
I understand wnat you are trying.
Tne only 16 thing I could nave done any more was to sit and hold ner l'
hand for eight hours a day.
18 C
All I want to do is recount the facts as they 19 occurred, including the ones that you just said.
20 A
I understand.
21 Q
During the two counseling sessions, the one or
~
two that you were involved in witn Tolson and Darlene
'3
~
stiner, did eitner one of you, you or Tolson, recommend at tnat she end her employment as a QC inspector?
A Keep in mind that we are talxing a year and a TAYLOE ASSOCIATES N
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'l ns;; ago.
I want to say a year and a half ago. It seems 2'
that way.
It seems like it was the first part of last 3
summer, the summer of
'e2.
It is poscible that we s
encouraged her to taxe a leave of absence because that is 5
really what I felt she shoulo'do.
It is hard for me to.
6 justify even to myself in fairness 1to other inspectors to have one inspector that is being treated the way sne was 8
to the extent of rather than having to walk' what we call 9
tne cattle shoot here whien leacs from the crart parking 10 lot whien OC parks on, which is a mass of humanity moving 11 down to the gate on an 18-foot wide sidewalk essentially, i
12 walxing probably oh, a quarter'to three-eignths of a mile i
4 13 even to get in the site and tnen walking to your office on 14 the site. When you have got 400-plus people doing tnat and 15 one person being escorted from a privileged parking area 16 8
to her door and bacx working in an area that is roughly i
i ten yarcs from her work area doing no climbing, doing no L
18 stair climbing, and doing a minimal number of inspections, 19 it is in my opinion not really fair to the people that are 1
20 working in 100-plus degree heat climbing up and down out 21 scaffolding in the daily construction activities.
22 Q
Was the decision made to do all these things
,3
~
i for her based on her appearance before the Board?
"4 A
Absolutely not.
The original confrontation ns
~
with Darlene Stiner'was before she ever appeared.
I 4
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---m.
3
I 51 1
Q I am asxing you did you do all these nice unings for ner because she appeared before toe Boars?
What was tne thinking behind 4
all tnis?
5 A
As ridiculous as it may seem, it cercainly dic 6
to me, the intervenor fileo for a protective action, flied a request witn tne Chairman of tne ASL8 for a protective 8
order on Darlene Stiner.
Based on tne fact tnat I nad 9
moved her twice in three days, tne intervenor alleged tnat to thia was narassment wnen in fact I had movea ner from an 11 area in WniCh Sae was noused with 17 or 13 other s-l '~
inspectors probably close to a half a mile from ner work i
13 area to an area which was less than 10 yards from ner wcrs n
area.
15 at tnis point it was the considered opinion of l.
i 16 cctn myself and tne applicant's management tnat in cruer not to mar.e more of an issue out of it than it nau already 18 become, we would provice any and all metnods of masing her l
19 3o0 as easy as possible for Ms. Stiner as could possibly be done.
O
~
c ':l < =.
~
.KI N Q
.h
' :.. a
~
A I don't know.
't Q
As a supervisor, have you hac to oeal witn I
- b f
~
tais proclem before with pregnant women in these demanding l
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52 1
Joos?
2 A
I have never seen concessions made on seven 3
nuclear power facilities similar to the concessions made to Ms. Stiner. I have never seen concessions even close to 5
ene concessions we maae for
.v.s.
Stiner.
6 O
Do you Know what site policy is -or what Brown anc Root policy is A
I nave no ioea.
Site policy is you taay only 9
pertoria you jco as long as you are pnysically capable of 10 300.
i per:orming your 11 0
so all tnis attention paid to v.s. Stiner was 12 special and unusual?
13 A
I woula say highly, If cy attention you mean 14 ene fact that we were virtually catering to her every whlar.
15 and fancy, yes, I'woula say that is unusual.
I would say 16 tnat is extremely unusual in tne constraction industry.
17 0
In ger.eral. sere the concerns that.sts. Stiner 18 raised betore the ASLe valid, in your opinion?
19 A
Tha;. seems to be a Snerraan Williams type of 20 question.
21 C
well, 1 am asking for your opinion.
A It is nard for me to even rememoer wnat n3
~
concerns belon.;ed to wno in the ASLB hearing.
nt Q
How about tne ones tnat I have recounted to 25 you here tooay, tne ones that you recalled?
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ine only One that I Delieve we even talked aoout that I was familiar with was the large coors which I 3
don't recall Ms. Stiner ever having any dealings with.
I
'1 4
honestly don't remember what Ms. Stiner's concerns in the 5
x proc'eding were.
e 6
I might. add something just in retrospect.
If g
It is my personal opinion representing only myself that
]
8 there_ had been no significant safety issues raised by 9
anyone in the ASLB proceedings.
10 Q
On a different subject, were you involved in 11 ll Henry Stiner's termination?
l!
l' I
~
A Absolutely not.
13 Q
Do you have any personal knowledge of the 14 incicent leading u.p to his termination?
I 15 1
A Negatory.
l 16 i
C to change subjects again, in the area of I.
1 coatines documentation, prior to Revision 4 of tne quality 18
[
instructions related to coatings, whien Rev. 4 wa s l
I October of
'dl, NCR's were part of $he quality 20 t
instrdctions; i's that right' 21 l
A NRC's were part of the quality instructions after October of
'61, and I don't know where you are o3
~
headed.
"4 O
You con't know where I am headed?
1 A
No.
The answer to your question is yes, 'cu t I TAYLOE ASSOCIATES N
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I 54 1
might ano taat they were part of tne ir.t rsction after 2
Rev. 4 in 1981, if by tnc NCR you mean non-conformance
{
3 report.
It is a paper-that says ---
4 Q
16.0 anc the OI's?
S A
Yes.
6
~
Q When a decision was made'on site nere to got tc tne IR program, were not NCR's dropped from the 8
instructions, the quality instructions?
9 MR. WATxIN3:
Can you be a little more 10 cpecific?
11 MR. GRIFFIN:
I think he unoerstands tne 12 question.
?
13 ThE WITNESS:
I understand the question and I 14 am going to cla'rlfy it for him, if that is permissible.
15 Mk. GRIFFItJ:
Sure.
16 THE WITNESS:
Let's go all the way back to 17 Appendix B. 10 CFR 50 Appendix E does not ever mention the 18 terza non-conf ormance report.
It says in one of its 16 19 criteria tnat non-conforming conditions must be properly 20 identified and controlled.
Whether you identify suen on a 21
. piece of paper called a non-conformance report, a piece of
- 2 paper called a deficiency report ---
t3 BY MR. GRIFFIN:
'4 Q
Okay, Tom, if you will let me break in on you a minute.
What you are going to tell me I already know. I TAYLOE ASSOCIATES 1625 i STREET, N.W. - SUITE 1004 WASHlHGTON, D.C.
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55 I
nave had tne aavantage of going bacx and looking at the
~
nistorical file for the revisions and the QI's related to 3
coatings for vurious things lixe steel. In my reviea I was 1
able to determine tnat Rev.
4, wnich was October of 1981 5
you all went to an IR program.
6 A
Rev. 4 of the coatings procedure went to an IR as opposed to probably nine to ten other little sheets 8
of paper they called enecx lists and mixing forms, 9
batehing forms, final inspection forms, which our 10 inspection force fro ~m 1979 to 1981 handled to marvelously 11 we got a severity level 4 I believe notice of violation over the subject.
13 All of the coatings procedures were rewritten 14 to put them in the inspection report format as opposed to 15 check lists.
16 Q
Okay. According to my review of the historical 17 file, wnen you all went to tne IR program, 16. 0 wa s 18 oropped from the QI's for a period of time.
19 A
It might have been dropped from the QI's, but 20 I can show you literally hundreds of NCR's that have been
'l
~
written on coatings post-1981.
J' Q
But they were not contained in the procedure.
93
~
I am telling you that.
Is that consistent with your 24 memory?
g h
No.
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Q
- oxay, so as far as ycu know, 15. 0 wa s
?
still ---
3 A
i am not arguing the point, Mr. Griffin.
I 4
don't remember.
O Okay.
Well, that is what I am asking you.
6 A
I only see hundreds of procedures every week and I don't remember.
8 Q
I unde ~rstand.
9 A
If you want to talk phil'osophy of NCR or IR, I 10 will oe glac to talk about it.
Il Q
No, that is not the' gist of my question.
I 1
just want to xnow what you' knew and you say you do not 13 know ---
14 A
If it was not included -- I sas the author 15 probably without looking of Revision 4 to the coatings 16 instruction. If not, I was the approver and the author was 17 a g'entleman by the name of either Dick Cummings or Mike 18 Foote.
19 We were working kind of jointly and I had the 20 responsibility for approving them.
If_at that time the 21 non-conformance reporting procedure, CP/QP 16.0, was omitted, it was essentially an oversight.
It was used by 23 inspectors at that time to identify wnat they perceived to "4
~
be non-conforming conditions.
Unsat IR's were typically 25
~
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s seneme as part of a routine inspection.
I don't know if n
~
that muddied tne issue, but that is essentially the way I 3
recall it.
4 Q
So as to wny 16.0 was dropped, it would nave 5
been an oversight?
.6 A
It was just no.t. included.
The program was, I mean it wasn't simple.
I mean if you look at the scope of 8
the revision between Rev. 3 and Rev.
4, and taking your 9
word for the fact tnat Rev. 4.was written in October
'ol, 10
- is about the time that it was cha'nged, and because that l
11 assuming that Rev. 4 is tne rewrite of the program which li occurred at that' time, which I am not sure of, it wasn't.
13 intentional at that time to leave it out.
It was the 14 complete rewrite of the program and the fact that it 15 didn't say hey, if you encounter non-conforming conditions l
16 icentify'it on a form we call an NCR in accordance witn 17 16.0,.it wasn't intentional.
.There was no philosophy 18 behind tnat event.
19 Q
And you say inspectors continued to write 20 NCR's following tnat date?
21 A
Yes, sir.
.an
~~
Q And did you continue to assign numbers to "3
them?
a4 A
Whenever asked, we have always given an NCR number to anybody.
I know of no incident when anybody was i
l TAYLOE ASSOCIATES 1625 i STREET. N.W. - $UITE 1004 WASHINGTON, D.C.
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I sa refusec an NCR numoer.
2 O
And you were the reviewer of all NCR's that 3
came througn?
4 A
No.
5 0
who was?
wno would nave been for: coatings?
6 A
In 1981?
7
.O Yes.
8 A
Probably Harry Williams.
9 Q
Did Harry hilliams have tne authority to void 10 NCR's?
11 A
Yes, he did.
O Did this continue to be tne case?
13 A
Yes, it cid.
14 Q
As long as Mr. Williams was'employec nere, he 15 hao tne authority to voic?
16 A
Yes.
17 Q
I am going to drop back in time prior to 18 October
'61.
During the perico in 1980 and
'ol, tne early 19 part of 'ol tnere appears to nave been about a 14-month 20 gap in the writing of NCR's.
I am telling you this. Are 21 you aware of this?
Are you familiar with this?
22 A
Only multihanded.
I mean not even 23 secondnanded.
24 Q
You have heard that?
25 A
I have heard that.
4 TAYLOE ASSOCIATES 1625 i STREET, N.W. - SUITE 1004 WASHINGTON, D.C.
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b is I
Q Do you know or any explanation for a 14-montn 2
i
_ gap?
)
3 A
No.
I never even looked at a possible 4
3 explanation ror it.
5 Q
And you never heard anybody voice an 6
explanation?
T A
I have never heard anybody really ask the 8
ouestion until Just recently.
9 O
Do you know of anycody during 1980 or the 10 early part of 'bl tnat told the inspectors they coulc not 11 write NCR's?
12 A
No./
13 You indicated earlier that following Rev. 4 in Q
14 October of 'bl there were many NCR's written.
15 A
That is my personal ooservation.
I might say i!
16 for tne recora.tnat prior to September 1980 I was not even 17 at Comanene Peak.
I had very limited exposure to the 18 coatings program prior to Octocer or November 1981.
So 19 wnat went on was more Job talk or hearsay rather than kind 20 of personal involvement.
21 Q
Prior to Rev.
4, the QI's referred to final
'2 acceptance, but the in process concept as relates to IR's e3
~
does not relate to final acceptance; is that right?
"4
.4 I don't understand tnat.
Q Prior to Rev. 4 inspections were considered l
l TAYLOE ASSOCIATES l
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60 iinals.
2 A
No.
5 Q
Tney were not?
4 A
No.
5 Q
They.were in process?
6 A
At least the philosophy and possibly the procedure stated at tnat time that final acceptance of the 8
coating would come'at tne time of final walkdown.
9 t
Consequently, many of tne records that were really in l
10 l
process applicz. tion type records were neter properly
)
11 filled out, some were never signed and many were not 12 traceable to any area.
Some say, for example, pressurizer 13 room, Unit 1.
The pressurizer room is probably 60 feet to hign and 20 feet square and all the surfaces are coated l
l 15 and not traceable to anything, whicn was ultimately the 16 reason we were served with a notice of violation.
17 Q
oxay.
Well, let me again tell you I in 18 reviewing tne historical file it referenced final 19 acceptance up to Rev.
4, and final acceptance was not 20 referred to from Rev. 4 on, out you have no knowlecge or 21 recollection that and I don't suppose you can answer my on
'~
question.
A I don't even understand your observation. I am
'~l more conf useo now than I was.
25 Q
Well, one of the paragraphs in the CI's tnat TAYLOE ASSOCIATES 1625 i STREET, N.W. - $UITE 1004 WASHINGTOH, D.C.
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l El I
relate to coating inspections referenced the final 2
acceptance.
3 A
Rignt, wnich is wnat I just answe' red stating 4
the the inspectors were waiting for this day to come with 5
all these records still what they considered in process waiting to do this final inspection, which is how we got the records as screwed up as they were.
8 Q
So tae fact that prior Rev. 4 it stated that 9
it 8
was final acceptance, the in process concept was 10 already in place and in use?
11 A
Yes.
12 Q
Oxay.
Once the inspection report was put in 13 use, how were IR's used for deficiencias identified whicn were not part of assigned inspections?
15 A
I don't understand the question.
{
16 Q
If an inspector indentified a deficiency that 17 was not part of tneir assigned inspection, now did they report tnose deficiencies?
19 A
At what point in time?
20 Q
when they identified them.
21 A
No, the time frame.
O This would have been from Rev. 4 tnrough Rev, a3
~
15, which I believe is October of tnis year.
" 4 A
There is more than one answer to the question, i
if I can explain just briefly.
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1 Q
sure.
2 A
As I started on the dissertation a minute ago 3
and I cut off that it makes no difference, to meet both 4
regulatory ano federal law requirements wnat you icentify 5
discrepant or deficient conditions on, what you call t'nat 6
piece of paper, or not even a piece of paper.
We coulo we 7
could, if we wanted, etch it in stone.
You have got me at 8
a certain disadvantage because I don't nave the procedures 9
in front of me at this time.
10 Q
Now I am just asking you, Tom.
This is really 11 pretty straigntforward.
19 A
I understand. 'If you will let me finisn, I 13 think I will answer your question, Brooks. For a long time 14 they were writing NCR's in answer to your question.
For 15 some reason, procaoly more on this site than many I have 16 been on, the NCR cycle seems to get Dogged cown in paper 17 and just doesn't move as quickly.
Given the same problem, 18 you can reach tne same ends more quickly with other 19 documents than tne document we call a non-conformance 20 report achieving essentially exactly the same degree of 21 quality and essentially the same involvement from the same o,
people.
a3
~
Somewhere between the period of a4 October / November '81 and present, we decided we could do
,it much more efficiently on an inspection report.
I TAYLOE ASSOCIATES 1625 I STREET, N.W. - SUITE 1004 WASHINGTON. D.C.
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63 procaoly am responsiole as anyoody fer initiating that 2
philosophy having received my supervisor, Mr. Tolson's 3
olessing on it before I ever did it.
I. started it in the 4
classified pipe support area and it proved to be very 5
successful as far as expediting the resolution of the 6
problem, not in expediting the work necessarily, but as far as identif'ying the problem and getting properly just a 8
corrective action described, implemented anc closed in a 9
mucn more expeditious fasnion than what we were doing with 10 a.non-conformance report.
I 11 We expanded from the classified pipe supports 1
into other areas and ultimately ending up in coatings, anu 13 exactly what time that took I can't tell you.
But the 14 process for identifying a discrepant condition is exactly 15 the same on the inspectors oehalf, I mean looking through 16 tne eyes of an inspector if he puts it down on an 17 inspection report or on a non-conformance report.
18 0
Okay. Now back to my question. If an inspector 19 identifies a deficiency tnat is not part of his assigned inspection, wnat method under the IR progr.am ---
21 A
He marks it un-sat and describes the problem.
22 Q
Does he just get a blank IR?
'3
~
A Right.
94 Q
And he puts the location and then puts ---
25 A
He puts the item description, the location ---
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t 54 1
1 i
(Pause due to te.er.r.one call interrupticr..)
2
)
i MR. GRIFFIN:
Let's go off the record.
3 (Short recess.)
4
(.The pending question and partial answer were b
read by the reporter after tue recess.)
6 ThE WITNESS:
In addition to the item 7
description and the location, he describes what the i
8 particular problem'is ne has observed, makes the IR 9
un-sat, obtains an IR number for the IR and enters it into 10 ene system.
Il BY MR. GRIFFIN:
12 Q
How are un-sat.>s on IR's trackeo?
13 A
By a log, a manual log similar to an NCR log.
14 Q
Is this log a formal record?
A Yes.
16 Q
Is it a permanent record or does it beccme a 17 permanent record?
18 A
The term permanent record as defined by NCN-45 19 2.9, I will have to say in my interpretation neither a 20 non-conformance report log or an inspection report log are 21 permanent records.
n,o o
Kho maintains this log?
23 A
QC themselves.
24 o
QC who?
25 A
Tnemselves.
The clerk in each particular area TAYLOE ASSOCIATES 1625 i STREET, N.W. - SUITE 1004 WASHINGTON, D.C.
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65 1
- s responsiole.
for example, the protective coatings log 2
begins witn the numbers PC.
The backfit that we have been 3
unuergoing for a couple of years now is PCR.
hilti colts 4
are IRMd.
5 0
Well, the gist of my question is you nave a 6
formal system for tracking un-sat's on IR's?
A Right, procedurally described in CP/QP 16.0.
l 8
Q I nad not read that, but it says now the log
(
9
(
will De set up, how they will be tracked and how it will l
10 oe reported when they are dispositioned.
Does it acdress f
11 that?
12 A
It tells how an inspection report may be 13 closed.
In essence it provides disposition to the problem 14 that tne inspector reported.
15 Q
Since the inception of IR's in the coatings 16 procedures, did writing an NCR guarantee an inspector trip 17 to your office?
18 A
No, in no way.
19 Q
In other words, you continued to accept NCR's.
20 MR. WATKINS:
Excuse me, cou'ld you read the 21 question bacK.
I just didn't hear it.
~
(The pending question was read by the 23 reporter.)
' 1 THE WITNESS:
I might add that Appenaix E requires you to have a QA program establisned that clearly TAYLOE ASSOCIATES 1625 i STREET, N.W. - SUITE 1004 WASHINGTON, D.C.
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66 i
defined now you operate.
When an inspectior, prr_cecure 2
describes tnat any defiencies you find snall be reported 3
on an IR and not on a non-conformance report and 4
inspectors insist on using non-conformance reports, 5
technically they are in violation of the procedure.
To 6
~
streten a point, a non-conformance report could be written on that inspector's behavior for failure to follow the 8
written procecure. Of course, that has never happened, but 9
hCR's are still written.
10 BY MR. GRIFFIN:
11 Q
Okay.
As an extension thougn, since the 12 inception of the In prog, ram in that NCR's
'ere dropped 13 from the quality instruction, cid you ever have occasion 14 to counsel inspectors who wrote NCR's since they were not 15 part of the procedure as to why they weren't using IR's in 16 accoraance with the procedure?
l 17 A
Tne sucject has come up several times to me 18 personally-I was not there, and the only reason I 19 remember the date is I remember when I was in.New York 20 City, on August leth or 19th my supervisor, Mr. Tolson, nac a meeting witn some paint inspectors explaining philsophically how the program was structured and why we
,3
~
wanted them,to use an IR.
94
.Let me again emphasize this is secondhand 25 information.
I was not there. After that one particular TAYLOE ASSOCIATES 1625 i STREET, N.W. - SUITE 1004 WASHINGTON, D.C.
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67 I
inspector tnat was involved in the meeting went out the 2
very next day and wrote a non-conformance report on the 3
same subject we had discussed in the meeting.
Yet, he was not counseled for it, which in retrospect mignt have been 5
a mistake.
6 Then a period of time later, and I don't remember which day of the week, the same inspector wrote 8
anotner non-conformance report.
His supervisor wno was 9
Everett Mouser orought the non-conformance report to me 10 and said, Tom, I can't make Elliott understand wnat the 11 program is and wnat should I do? I said explain again that the procedure specifically dictates tne use of an 13 inspection report, get Mr. Elliott to issue an inspection 14 report, reference tne inspection report on the 15 non-contormance report and bring the non-conformance 16 report back to me and I will void it.
17 Q
Is this October of this year that this 18 occurrea?
1 19 A
It was August or September of this year.
I 20 subsequent to tnat got in a discussion with another 21 inspector by the name of Tom Miller who one day came to my office to find out wno was responsible for bringi.ng him n3
~
back to day shift.
He was quite aggitated over it and he a t says I can't get anybody to admit oringing me back to day shift,, and I said well, you have come to the rignt place, TAYLOE ASSOCIATES 1625 i STREET, N.W. - SUITE 1004 WASHINGTON, D.C.
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66 i
because it was my decision to bring you cack to day shif t, 2
wnicn he dicn't lixe any more.
He said he had to respect 3
to tne fact that I woulc at least admit it was my decision 4
and we got into a lengthy discussion about the use of IR's 5
versus NCR's.
6 Mr. Miller was going to explain wnat Appendix B said to me so ne perceived. After discusssing it at some 8
great length witn three procedure books in front of me 9
snowing me how I was in violation of 10 CFx 50 Appendix B 10 and my cemonstrating how I wasn't, Mr. Miller said ne 11 finally understood.
If you will give me Just a second, I 12 can tell you wnen tnat occurred.
It was tne last part of 13 September, to the best of my recollection.
It was on 14 September 28th as a matter of. fact.
15
- le said he uncerstood. He said a lot of people 16 were confused over the pnilosopny of the issue and asxed 17 me to describe or present the same presentation casically 18 that I had given him to the group, whien I did at 5 19 o' clock the next evening on tne 29tn of September.
I had 20 about a 3u to 45-minute philosophical discussion witn both 21 day shift and night shift coatings inspectors. I asked for
~~
any question and any further concerns on the NCR/IR issue 23 and tnere were none.
24 Q
So tne answer is no, that you didn't nave
~
25 reason since the inception of our program up until these TAYLOE ASSOCIATES 1625 i STREET, N.W. - SUITE 1004 WASHINGTON, D.C.
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69 events tnat you related to counsel?
2 i
A Well, tne only reason I explained tnat is I 3
don't know what you mean by tne word " counsel."
4 Q
Well, I am just saying if there had been 50 5
instances where people had come in who had written NCR's 6
and you had said we use an IR program and NCR's are no 7
longer included in reporting coatings deficiences ---
8 A
To me it was more of a training sessicn than a 9
i~
counseling session.
10 Q
But I am just saying if there had been 50 11 I
instances, that you woula probably have remembered these, I
would you not?
13 A
Oh, yes.
14 Q
And there were no such instances?
15 A
Counseling sessions, no.
16 Q
Well, not formal counseling, but wnere you nad 17 to instruct your inspectors we have an IR program anc 18 NCH's are not i
19 A
To my recollection, I aodressed it once 20 previously prior to August / September of '83 as a group
'l o
which I tnought I provided an adequate philosophical
~
discussion to the group, but due to the number of
'3
~
inspectors that claimed they still misunderstood it or 94 didn't understand.and thought we were in violation of
'5 Appendix B ---
TAYLOE ASSOCIATES 1625 i STREET, N.W. - SU TE 1004 WASHINGTON, DA 20006 (202) 293 3950
70 i
C But since tne inception cf tne inspection ~
i 2
reports ---
3 A.
No,-other-tnan the incidents I descrioed ---
4 Q
But these inspectors have continued to write 5
NCR's; is that right?
6 A
Not any more I hope. To me it is crystal clear r
what we want non-conformance reports for and what we 8
con't.
9 0
It is also my understanding that Rev. 15 10 placed NCR's oack into the inspection. instructions as
-11 related to failed; is tnat right?
12 A
Due to unacceptable coatings uue to loss of 13 adnesion.
That was a result of the Decemoer 29th group 16 meeting wnich Fred Dunham, who was the night shift QC 15 coatings lead inspector, had expressed a concern on how we 16 were going to handle it because it wa s n ' t procedurally 17 described how to isolate the area.
18 Q
What date was that again?
19 A
September 29th.
20 Q
In the IR program you use reject tags as 21 opposed to nold tags; is that correct?
2 A
For coatings, yes.
23 Q
Maybe you were going to tell me this.
Why was l
na l
the NCR reinstated?
25 A
I thins I did just describe that, the concern TAYLOE ASSOCIATES 16251 STREET, N.W. - $UITE 1004 WASHINGTON, D.C.
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72 tnat Fred Dunham nau on la ci: of a procedural de:inition on now to isolate tne area on which the failed adnesion 3
occurred.
4 Q
All right. Do you currently have a pclicy with 5
our inspectors that relates to inspections of items 6
outsice those that they are assigned?
7 A
1 con't know that there is a policy.
8 t
Q Well, presently today are inspectors allowed 9
(
to conduct inspections outside those that they are 10 assigned?
11 A
Not on a routine basis.
If they have a 1
concern, in all, cases their concern has been evaluated. If 13 we had 400 people out there doing wnat they wanted, I 14 think even a causual observer woulo have to admit it was 15 an unmanageable situation.
16 o
You indicated that over the period of tne last 17 few years inspectors had continued to write NCR's even 18 thougn you had an IR program.
When these NCR's were 19 written, did these inspectors place hold tags on the items 20 they had icentified?
21 A
Procedurally they were required to.
I didn't
~~
follow any inspector around to see that he did.
23 Q
Well, I am just asking you.
They wrote NCR 's,
91 but 25 A
They used hold tags it tney used an NCR.
Tha.t TAYLOE ASSOCIATES 1625 i STREET, N.W. - SUITE 1004 WASHINGTON, D4 20006 (202) 293 3950
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72
\\
is what they were supposed to have used.
g J
O Do you review IR's, unsat's on TR's, or it is 3
done by the first-line supervisor?
4 A
Yes.
5 Q
Tom, are you familiar with sno within the URC 6
and if the NRC was approached to give its blessing on this I
IR program?
You had indicated earlier that you nad
\\,
8
~
presentec in to To1 son, has the NRC approacned tc
\\
determine whether there was an agreement tnat this met 10 reporting necessi~ ties?
~
11 t
A Before the IR concept as far as reporting
' discrepant conditions, and'as I said I was respons"iole for 13 the idea essentially, was ever proceduralized or ever 14 used, it was discussed pnilosophically with the resicent.
15 he told me agreed that I was within the bounds of Appendix 16 B any regulatory requirement.
We had a philosopnical disagreement, which I believe if questioned at this date, 18 he would have to acmit ne was wrong on the ef f ectiveness 19 of what I was trying to achieve.
20 0
But the NRC representative concurred tnat it i
21 was an acceptable procedure?
22 A
Yes, sir.
23 Q
And then it was instituted?
24 A
Yes, sir.
It has also been evaluated oy the 25 construction appraisal team, by the ASLB and both have TAYLOE ASSOCIATES 1625 i STREET, N.W. - $UITE 1004 WASHINGTON, D.C.
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i 9
73 h
0 1
apprevc
-:is s e.
2 Q
Was there recently or in the last three months 3
consideration given to having craft supervision perforr. in I
4 process inspections of coatings as opposed to QC
[
5 inspectors?
6 A
Yes.
~
Q was a decision made as to wnether to 8
incorporate this?
9 A
Yes, a decision was made.
10 Q
What was that decision?
11 A
Not to do it.
I 12 Q
Was this a decision made by you?
I 13 A
I nad input on it, but the final decision was 14 not mine.
15 Q
Whose was it?
16 A
I do not know.
It was made by a superict of 17 mine.
At exactly what level I do not know.
18 Q
Do you know if craft conducts their own 19 inspections in any other areas?
20 A
Yes, they do.
Craft conducts an inspection of 21 varying magnitude in just abou: any area of safety related n
construction.
You mean prior to submitting to QC?
23 Q
coes craft conduct its own inspectio.ns in 2;
place of QC?
25 A
In any safety related area?
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Q C.ncr
- u. u n anat was consicersa nere.
2 A
You are implying if they ever did tnat.
-3 Q
No, no, I am not.
4 A
The craft has never made an inspection to 5
satisfy-Appendix B requirements in any safety related area 6
at Comanche Peak.
7 Q
My question is y this method used in the 8
other area?
9 A
No.
10 Q
It is my understanding that recent procedure t
11 changes dropped dry spray, overspray and emoeddec 12 particles from inspection criteria; is enat correct?
Are
-I
?
13 you familiar with that in' coatings?
14 A
I con't think they are approved yet.
15 0
Also, I think there is a provision tnat 16 incicateo inspections are to be done at arm's length witn 17 a flashlignt tilted at a 90 degree angle.
Is that an 18 incorporated procedure no'?
w 19 A
Yes, it is.
20 Q
Were you the one tnat implemented this?
21 A
Yes, I did.
It is still quite conservative.
22 Q
Why were these changes made?
How did you 23 arrive at these?
24 A
The safety issue on protective coatings is to 25 assure that the coating stays on the wall in the event of Y
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l 75 1
a design cacis accident as opposed to falling off tne wall 2
in large sheets and theoretically, and only theoretically, 3
clogging tne containment sumps.
4 I know of an arenitect/ engineering firm, wno 5
will remain nameless for purposes of this discussion, who
- {
6 has shown analytically that that physically
- impossible.
I l
l 7
However, in today's regulatory environment it is not worth 8
the time and effort to try to it through the NRR.
Several 9
A/E firms have defined much incre 11oeral inspection 10 guidelines than at arm's length with a two-cell 11 flasnlight.
12 Ke were having problems at the time with 13 inspectors asking well, how much light do I have to have 14 to make tnis inspection, how close,do I have to get, I 15 can't get my head in there close enough to see that.
It 16 became a constant question of accessicility or 17 non-accessioility, and I ceciced to procedurally define.
18 O
So you were more specific than mayne you woulo 19 normally have intended to be to answer tnese questions?
20 A
Correct.
21 Q
Have a number of new QC inspectors in the 22 coatings arena been recently brought in from the paint 23 department?
24 A
Yes, sir.
25 Q
And are they being certified or qualified at TAYLOE ASSOCIATES 16251 STREET, N.W. - SUITE 1004 WASHINGTON, D.C.
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I tnis time?
2 A
Yes, sir, by the same process that anyone is 3
qualified and certifieo.
4 Q
Are these postions that they are going to 5
occupy, is this a long-term job for'these people?
I mean 6
is there a need for a large influx of coatings QC inspectors for an indefinite period of time?
6 A
There was at the time, yes, to support 9
construction.
10 Q.
Will tais demand continue to exist 11 indefinitely into the future?
12 A
It depends-on production schedules.
It seems e
13 rather elementary that if we are working on two units at 14 one time obviously it is g.oing to take us twice as many 15 people than if we were only Oorking on one unit.
And if j
16 you nave 400 painters, you need proportionately more QC inspectors tnan if you only nave 200 painters.
18 Q
Okay.
Did you nave 400 painters a month ago?
i 19 A
I believe in the last two months, and I am not 20 intimately involved with the construction details, there 21 have been eight crews of painters added to days.
22 Q
so prior to bringing these people into QC you 23 didn't nave enough people to support the craft?
24 A
Right.
25
-Q Tom, do you know when final coatings TAYLOE ASSOCIATES 1625 i STREET, N.W. - SUITE 1004 l
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77 1
inspections will oegin?
2 A
They already have.
3 Q
How long have finals been in process?
4 A
I give up.
I dor. ' t remember. It depenas a lot 5
on wnat area you are talking about. For example, the final 6
coatings inspection on the containment ~lindi in the dome 7
occurred as we were coming down out of the dome.
We have 8
no reason to go back up in the dome at this point.
9 Q
So all tnose are considered fir.als?
10 A
Right.
11 Q
Is the rework or repainting of damaged paint 12 in process now?
13 A
Right, if you are talxing aDout mechanical 14 damage.
15 Q
Yes.
16 A
Yes.
1; Q
In the concept of final walkdown for room 18 turnover, does that allow for inspection of all damageo 19 paint?
20 A
Yes, that is exactly what it involves if the 21 scope of your question is restricted to the protective 22 coatings walkdown.
23 Q
It is.
2; A
Yes, that is exactly what it is for.
25 Q
I am interested in the coatings backfit TAYLOE ASSOCIATES 1623 i STREET, RW. - SUITE 1004 WASHINGTON, D.C.
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i i
program.
It-sas 1961 tnat.NRC released tnat notice ci.
2 violation on old documents, originally wasn't intended 3
that there would be a total backfit?
4 A
t.o.
5 Q
What was the original intention?
6 A
The original intention was to backfit areas 7
.where adequate documentation.did not exist.
8 Q
what steps were taken to identify what 9
documentation was acequate?
10 A
We reviewed tne olo documents.
Il Q
Kho is we?
12 A
QA.
13 Q
was there any. body in particular that nandled 14 the review?
15 A
For me to list everybody would oe a long list.
16 The initial shot at it was myself, Dick Cummings and Mixe 17 Foote.
Since tnat time Neil Britton has become involved 18 and several other people.
19 Q
During the review done by you, Foote and 20 Cummings, did you all also map areas as you went?
21 A
That is what we were working on at that time.
22 Q
Did you map them according to adequate or 23 inadequate or sat or un-sat?
24 A
We only mapped adequate documentation. That is 25 all we were interested in. If I can basically oescribe it, TAYLOE ASSOCIATES 1625 i STREET, N.W. - SUITE 1004 WASHINGTON, D.C.
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I we woulc picx up an inspection report and it it meant 2
anything or if it was able to stana on its own, we would 3
map the. location of that IR saying, yes, we have got 4
documentation'en this area.
If we picked up a recore tnat 5
wouldn't stand on its own, it just went over nere.
6 Q
I have looked at some of_the old records and 7
many of the packages that I reviewed had surface 8
preparation primer, mixed sheets and seal coat. Did all of 9
these togetner constitute an inspection package?
'10 A
No.
What we were coing at that time was i
11 making, anu I am talking of f the top of my head once 12 again, I believe we made three maps, one for surface 13 preparation, one for primer application and one for 14 finished coat application.
We took each individual record 15 on its own and exa' mined it and said will this stand on its 16 own as a quality assurance document, and if it would, we 17 mapped it.
If it wouldn't, we disregarded it. We did not 18 throw anything away.
19 We assigned numbers to absolutely everything 20 so that they coula be entered into the permanent plant 21 record system.
We had had no intentions to ever take 22 credit for it.
23 Q
Did you yourself ever nave occasion during the 24 review to attach say a mix sheet to a seal coat sheet if 3
they were related? I am using that as an example. It could TAYLOE ASSOCIATES 1625 I, STREET, N.W. - $UITE 1004 WASHINGTON, D.C.
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l 80 1
nave teen surface preparation to a primer coat.
2 A
I honestly don't remember. I can't see that it.
3
.would make any possible dif ference one way or the other, 4
but I honestly can't remember whether we did or not.
5 Q
Did you make any Xerox copies of any the ---
6 A-Did I personally?
No.
7 Q
Do you know if anybody else did?
8 A
No. I do know that of the people I was working 9
with tnat we didn't make any.
Whetner somebody nas mace 10 copies of them, I have no idea.
Il Q
How long did this review last with you, Foote 12 anc Cummings?
13 A
Dick Cummings left Comanche Pean in January or 14 February of 1982.
Mike Foote is still here. Mike Foote 15 has been involved on and off with review of coatings 16 records since tnat time.
My original involvement, as of 17 January of 1982 I was deeply involved in getting Brown and 18 Root through the ASME survey anc in February of 'd2 I 19 assumed supervisory responsibility for basically all of 20 the non-ASME QC activities.
Tne amount of time that I 21 spent reviewing coatings records was extremely limited, c
22 Q
When was Neil Britton brought into the review 23 process?
24 A
Sometime later..
25 Q
Did he in effect take over from Foote and TAYLOE ASSOCIATES 1625 i STREET, N.W. - SUITE 1004 WASHINGTON, D.C.
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1; bl 1
Cu.rn.ings?
2 A
You are asking a sequence type question, 3
. Brooks, and I really don't remember.
4 Q
Are you familiar at all witn Britton 's review?
5 A
I don't understand the question.
I know Neil, n
6 Britton reviewed ' records, but what he did, I' don't know.
3 7
Q Do you kno-if he mapped areas?
i 8
A
't eA'.
9 Q
Did he map them for adequacy?
10 A
Neil did the same thing that we did.
If, the T
11 record would stand on its own, he mapped it.
If it we'nt in a separate pile.
At least that is
\\
12 wouldn't, it r
4 N,
13 wnat he was instructed to do.
{
i 14
' O, Okay.
As relater. to the backfit program, how l
L 15 were these maps used?
16 "A
They were used by the inspectors to determine 17 whethdr or not, for example, whetner the area had been 18 seal coated.
They verified tnat they had a surface prep 19 IR, cley verified that they nad a primer IR and a seal 20 coat IR prior to letting them put any more finish coat on 21 the item.
If tne documentation was lacking for the n
particular area that the ongoing work was in, the area was I
t3 backfit.
24 C
Okay.
But in the backfitting'did the 25
. inspectors conducting the backfit'make,use of tnese olc r
(
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records?'
2
.A Make use of the records tnemselves?
n3 0
Yes.
1 4
'A
'Not to my Knowledge.
They mignt nave.
'5' Q
- In the backfit did tne inspectors reinspect 6
areas'that had been mapped as having adequate
~
. 7 documentation?
8 A
I am sure that happened.
9 Q
Well, are you saying that tney did not take 10 into account the adequacy of the old records?
11 A
In some cases it was probably that craft was 12 screaming at tnem to release the area as far as is it good 13 to paint or not, and this is strictly supposition on my 14 part and I have no reason to believe it is true other than' l'5 tne fact that given tne choice of going and loosing to see 16 the map to figure out whether you had adequate records for
~
17 the area or going ahead with the backfit inspection for 18 tne crea, I.am sure there are cases out tnere wnere they
}9 did the bacKfit inspection rather than looking for the 20 records.
21 Q
okay.
But are you saying there is no formal 22 decision made whether areas mapped as having adequate 23 documentation were cluded in backfit or not?
24 A
I don't see what difference it could,cossioly 25 mane.
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Q hell, :t.; me where I am wrong, cut 11 say I
2 this were a room on tne site out there and the. paint on l
3 tne, let's say it was concrete, if it was - mapped as naving 4
adequate documentation, I am asxing you, woulc tne room 5
nave been involved in the backfit?
f 6
A As a matter of course?
7 Q
Yes.
8 A
tJo.
There was no reason to backfit an area 9
you nad adequate documentation on.
10 Q
So the, records that were found to be adequate 11 were used and were excluded from backfit?
12 A
The only point I was trying to maxe, Brooks,
?
13 and maybe I misunderstood where you were headed, was if~
14 this room, for example, had adequate documentation, did it 15 ever happen that an inspector backfit part of the room in 16 addition to having adequate original records, and tne G
1; answer to that'was ycs, probably that happened.
Tha t 18 wasn't the intent, but you just did more wor 4 than was 19 necessary.
i 20 0
What I am trying to get to, Tom, is in that 21 you all did these document review and in tnat you mapped r
areas and certain areas were found to have adequate 3
documentation, does that mean as of this date today are a
24 tnese old records that are represented as being used to 5
attest to ---
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Ss-1 The quality of.that paint?
2 Q
Yes.
3 A
Yes, sir.
4 Q
So tnese records are still in use?
5 A
Yes.
They are in the vault.
6 Q
In your review of the records that you T
conducted with Foote and Cummings, were these, in your 8
opinion, cid these old records meet ANSI standards'and are 9
they acequate documentation?
10 A
When I said that the record was adequate, tnat 11 is what I was referring to.
12 Q
So tnat if you marked adequate, it met all
?
13 criteria?
14 A
All criteria for which we are committed to at 15 Comanche Peak in our professional opinion.
16 Q
I am aware that Mr. Britton created a log in 17 nis document' review as well as maps and in the log you 18 recorded particular inspections as sat or un-sat.
These i
19 that were marked sat, it is my understanding, were mapped 20 as satisfactory.
21 A
Yes, having satisfactory documentation.
22 O
If I understand you correctly, those maps were Il used to determine whicn areas did not require oackfitting?
24 A
Yes.
25 Q
I understand that for liner plate anc concrete TAYLOE ASSOCIATES 1625 i STREET, N.W. - SUITE 1004 WASHINGTON, D.C.
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65 r
- r e was total cacxf i t, complete bacxfit; is that right?
2 A
Yes.
3 Q
But for miscellaneous steel, wnica includes.
4
-conduit and cable tray supports and stuff like that that 5
there:was representative sampling taxen; is that right?
We started under the concept of'doing a 6
A hundred percent of them.
After doing tens of thousands of 8
destructive tests, we did a statistical analysis on the 9
results of our sampling and determined that a 90 percent 10 confi~dence interval could be achieved if'at~1 east 95 11 percent of the coating was acceptable and discontinued the 12 destructive tes. ting.
f 13 0
were those areas that were tr;apped as having 14 adequate documentation excluded from the sampling?
f-15 A
I don't understand your question.
l l'
16 Q
Were not maps drawn for what is included as l'
17 miscellaneous steel?
18 A
No.
19 Q
Just liner plate and concrete?
20 A
Yes.
I 21 O
Oxay, that answered my question.
22 A
Just to make a point, Brooks. If we had mapped 23 miscellaneous steel we-would have 45,000 maps.
24 (Laughter.)
25 That ought to be self-explanatory.
(
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MR. GRIFFIh:
.c.
me tell you this, I :,.. In
~2 that'I reviewed Britton's log, he went into areas other 3
tnan concrete and steel and he marked them sat or un-sat, 4
too.
5 THE WITNESS:
By piece number possibly, yes, 6
but no mapping.
~
~
BY MR. GRIFFIN:
8 Q
Well,,let me restate the question. Do you know 9
-if nis log was used to determine ---
10 A
Whether or not an area required a bac,cfit?
11 Q
Yes, and whetner it was included in the 12 sampling for backfit.
1 13 A
Are you separating those two?
14 Q
Well, no.
I guess they are the same, are tney 15 not?
16 A
Yes.
Our sample was only what was backfit.
17 Q
'Okay.
18 A
The answer to the question is yes, it was 19 used.
Now the procedure stated, if you say October on, 20 tnat if an area has adequate documentation, just carry on 21 your ongoing inspection.
.If it doesn't have adequate 22 documentation, perform a backfit in accordance witn 1.3-23 23 or 24.
26 0
In the old records those that reference an NCR 25 are considered inadequate; is that correct?
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A It depends on wnat One hCR 15.
There was line
(
2 six origianal NCR's that were broken down to 12 tnat were I
3 broken down to pro'aoly 50 now, depending on what c
4 elevation and whetner it is concrete or miscellaneous j
.5 steel or_ liner.
If that is the NCR number referenced on 6
the olc check list, yes, those were considered inadequate.
~
7 Q
so tnose that do not reference an NCR are 8
considered adequate conversely?
9 A
I guess.
I don't know wnere you are headed.
10 Q
Well, I am not headed anywhere. I have gone to 11 tne vault and I have looked at the documents and many have 12 NCR's.
It just so happens wnen you look in the log book, 13 Britton's log book you find that those are un-sat.
14 A
The ones that had NCR's.
OKay
{
15 Q
I am j'ust trying to find out if'that is your 16 understancing also.
17 A
Yes, that is my general understanding.
That 18 was tne intent.
19 Q
1s Britton's log book going to be tne I
20 permanent record for tne oackfit 21 A
ho.
Absolutely not.
22 O
What will be used?
23 A
The IR's.
The original inspection reports. It 23 is rather bulky to have inspectors having to look through l
I 23 file cabinet af ter file cabinet to find support No. AYX to
/
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find out wnether the original cocumentatic:.
..;c adequate 2
or not.
,3 Q
so you use a log book in place of tnat?
o A
Right.
We would be sitting nere and talxing 5
about lost records if that was the case.
6 Q
During the backfit program these maps were
~
7 used to determine which areas would be backfitted?
)
8 A
Right..
9 MR. GRIFFIN:.That is all I nave.
l l
10 Do you have any-questions?
11 MR. DRISKILL:
Yes, just a couple.
l l
12 BY MR. DRISKILL:
1 13 Q
Going back for a few minutes to the discussion le that was had earlier, I have got a couple of things I 15 wanted to ask you about.
16 One of the topics was tne generation of 1;
inspection reports spontaneously oy inspectors.
In other 18 words, if they are walking down past something and they 19 see a bad spot, as I understand it, your instructions to 20 tnem were to go get 4 blank IR and write this up as an 21 unsatisfactory condition and identify where it is and wnat 22 it is and turn that in. Is that correct in what Brooks has 23 called or represented as the IR program?
24 A
Rignt.
25 Q'
That is correct?
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89 j
i-1 A
Tne concept wasn't necessarily though, Don, i
2 you know, if I was neaded to tne reactor building and 4
3 walking through the safeguard building and if I found
- 4 something wrong to use an IR.
Although that could have 5
been the case,.that wasn't really the philosoph~y behind 6
it.
The philosophy behind it was anything that was 7
discovered wrong with the coatings system in service level 8
one areas, wnien are tne only areas tnat a QA program 9
applies to'at Comanche Peak, that-anyf discrepant
[-
10 condition being identified on an IR. If it was not covered 11 as an attricute on the IR that is included in one of the 12 coatings inspection procedures, just use the blank IR and 13 describe wnat was wrong with the area and mark the IR 14 unsatisfactory.
j-15 O
So you are saying then, so that I un6erstand, 16 you are saying if they do not possess an inspection report 17 for that area when they find this, or if there is not an 18 existing inspection report for tnat area, they are to l
19 generate an inspection report?
l 20 A
If I could use an example, I think I might 21 clarify it.
If this is a room in the reactor builaing, I walk by and see that we have haa severe mechanical damage 22 23 in there to the coating system which has been previously-g 24 accepted.
There will be an inspection report saying that s
that had been inspected, but now is mechanically damageo.
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90 Ine concept was to tage an'IR out of tne coatings 2
inspection procecure where it says final visual 3
acceptance, mark that unsatisf actory and describe the 1
mechanical damage tnat exists in there.
5 Only in cases where tnere was no IR. covering
~
6 it, you know, if it was such an odd-ball case, which I 7
can't imagine in coatings, because coatings is a pretty 8
clear-cut, not clear-cut from the scientific aspects of it 9
certainly, it is more of an art, out if tnere was no 10 pre-identified inspection attribute for what was wrong er 11 what was discrepant about the condition, to just take a 12 blank IR and mark it unsatisfactory and just describe what 13 Was wrong with it.
u Q
Let me ask a ques' tion just for the sake of tne 15 recora.
How does a coatings inspector generally come into 16 possession of an Ia?
Who is it generally speaking i
4 17 originally generated by?
18 A
The Ix?
The coatings inspector. They are in 19 possession of literally hundreds of them.
20 Q
Based on a request though from tne craft to 21 conduct that inspection?
r A
The craft does not have IR's.
What generally 4
23 causes an inspection is that your question?
24 0
Yes.
3 A
A request from tne c' raft to inspect the area.
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Q So based on wna t you nave saic, wnc: ;
2 unaerstand has apparently been a controversial topic here, 3
at least witn some people, has been this generation of an 4
inspection report without a request for an inspection.
5 A
That has never been a controversy to my 6
knowledge.
7 Q
Well, as I understand it, some people believe 8
that that was a non-conforming condition that they saw on 9
a wall and they should write an NCR.
l 10 A
That leads me back to my soap box.
I will not 11 get back on it, however.
It is clearly described now in 12 tne coatings instruction that wnen non-conforming 13 conditions other than coating failure due to loss of 14 adhesion are encountered, tney shall be identified on an-15 inspection report in accordance with CP/QP 16.0.
16 Tne terms discrepant, unacceptacle, 17 non-conforming and aeficient all essentially mean the same 18 thing, and I think the controversy was the fact tnat it is 19 non-conforming means that it nas to go in a 20 non-conformance report.
The fact that we weren't asked to 21 do tne inspection means tnat we use an NCR rather than an 22 IR.
If that is the point you are trying to make, I agree, 23 that was the controversy.
24 Q
I am trying for the recoro to determine anc 23 for myself wnat in your mind has resulted in this TAYLOE ASSOCIATES 1625 1 STREET. N.W. - $UITE 1004 WASHINGTON, D.C.
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- .isuncerstancing of tne enange in programs.
2 A
I think it is straight now. You are making the 3
assuming'that tnere is still a controversy.
I feel tnat inspectors currently understand philsopnically wny
't the 5
what we are doing is acceptable.
If they do not, they are 6
either too shy to tell me so or they are just flat 7
disnonest because I have asked them as a group if they 8
understood and they all have indicated they understood.
i 9
I tnins the original controversy was over a 10 God-given rignt to use a piece of paper that-is identified 11 as a non-conformance report, which I cannot endorse wnen 12 it is procedurally defined,to identify deficiencies on an 13 inspection report.
14 Q
Thank you. You made a comment a few minutes on 15 anotner topic here about Tom Miller being transferred back 16 to tne cay shift.
17 A
That is'right.
18 Q
And I understand tnat you said you met with 19 him on I celieve September the 28th, 1963 anc that tne two 20 of you were able to resolve your differences.
21 A
I am not sure we resolved our differences, but 22 at least he understood wno made the decision and why the n
accision was made.
24 Q
And why was the cecision made?
23 A
The decision was made by me due to tne fact i
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93 1
tnat I was receiving so many r: e.alaints on Tom Miller 's d
b 2
performance, that both Tom Miller and others claime6 that 3
he was not responsible for and tnat he hadn't really done 4
it this way or tnat way or whatever tney were complaining n
5
'about,~but I -wanted to personally evaluate Mr. Miller, ano
[
?
6 that is exactly what I' told Mr. Miller on'the 28th of j
7 September. He complained that the craft was after him, and a
l 8
I tolo him he was paranoid.
He agreed with me, and to a 9
certain extent he says I am very paranoid.
,10 I explained tnat the oniy way I could get-11 around that apparent discrepancy in what he thought of 12 liimself anc wnat other people tnought of him anc what tne 13 craft tnought of him was to bring him in a situation to u-wnere I could more closely evaluate his capabilities.
15 O
Have there been any complaints about nis 16 perfcrmance since he has been on days?
17 A
Yes, tnere has.
18 0
You stated that as a result of Fred Dunnam's 19 concern, NCR's were reinstated in tne program; is that 20 Correct?
21 A
I think you took it a little bit out of 22 context.
In this meeting that I held with the day and n
nignt shift coatings inspectors on September 29th of 1983 24 I asked for comments or questions, one of which was Fred 23 Dunham's asking, Tom, in the event that coating fails due TAYLOE ASSOCl TES 1625 i STREET, N.W. - SUITE 1004 WASHINGTON, D.C.
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94 to loss'of adnesien, it is r.ct procedurally cescribed now 2
we isolate the area and how is tnat possiole to resclve 3
with an IR?
4 I oiscussed at some length witn him af ter the 5
general meeting in a personal. meeting several things, one 6
of which was that in particular, and I described to him 7
that there were essentially two ways that we could go.
8 One, I could procedurally identify wnen you had coatings 9
failure due to loss of aonesion on how you isolate tne 10 unacceptable area or we could go-with use of an NCR in 11 that case and get an engineering evaluation on now to 12 isolate the area.
13 I told him I would get back with him in tne 14 next day or two.
I opted to go with the non-conformance
^
15 report anc tne procedure was changed to reflect that 16 report.
1; O
Another topic.
A few minutes ago Brooks 18 brought up.the proposal tnat coatings craft supervisors 19 conduct inspections; is that correct?
20 A
That is correct.
21 O
I wanted to ask you, was this proposed 22 intended to satisfy any requirements of Appendix B?
23 A
I don't know where you are headed, Don.
j 2
O If the preposal had oeen accepted to allow 3
craft supervisors to conduct inspections, would any of 1
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tnoce inspec__cns have ever oeen acceptec an; used tc 2
satisy NRC requirements?
'1 3
A Aren't we talxing about a hypothetical 4
situation that didn't nappen?
I just don't see tne merits l
5 of even talking about it.
I 6
Q Well, the matter was discussed 'and you pointed j
7 out tnat i
i f
8 A
he asked me if it was ever discussed ana I l
i 9
said yes.
I coula nave objected to answering tne question 10 there cecause we were talking about a hypothetical 11 discussion that took place that was.never implemented and l
l 12 tnat will probably never be implemented.
I can't possibly I
13 see now that affects anytning.
14 MR. GRIFFIN:
I will be glad to give you my l
15 reaconing for that.
I 16 THE WITNESS:
Okay.
17 MR. GRIFFIN:
Starting back with these old j
18 recoras in
'77,
'78 and '79 I am trying to establisn a 19 chronology and bring us up to date as to wnere tne 20 revisions have gone and things that nave been deleted and 21 added into the revisions of OI's.
A couple of months ago I
i 22 tnat was under consideration, and I am just putting it 23 togetner for historical purposes as developing the i
24 reasoning as to why things ---
25 THE WITNESS:
But it was never implemented. It TAYLOE ASSOCIATES 1625 l $TREET, N.W. - $UITE 1004 WASHINGTON, D.C.
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I was never eno:
and it was never introduced as part of 2
tne Oh program at Comanche Peax.
I can't possicly see how 3
tnat has any impact.
4 MR. GRIFFIN:
Well, tne NRC was approached to 5
see if this idea would fly.
So it was formal enough to 6
approach the NRC with it.
You are right, it was not 7
accepted by the NRC, among others.
8 THE KITNESS:
I don't know that it was ever 9
formally reiused oy tne NRC, at least tc my own personal 10 information.
i 11 I really don't see where it is headed, Don.
I 12 could taix for hours and tell you the pros and cons of the 13 issue.
I could a case that it does meet Appendix B 14 requirements and turn around and five minutes argue that 15 it doesn't meet Appendix B requirements.
As it never 16 aappened, it was never procedurally identified and it 17 never came to pass, I just can't see where it is worth 18 discussing.
19 BY MR. DRISKILL:
20 0
0xay.
One last question. You made the 21 statement I believe that you nave got coa. tings inspectors 22 working in two units.
21 A
t40 I was using a hypothetical example to 24 describe wny we needed extra inspectors.
You know, if we 25 had three units, I would have said it takes three times as TAYLOE ASSOCIATES 1625 i STRitT, N.W.. $UITE 1004 WASHINGTON, D.C.
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57 many inspectors'tc cover tnree units as it does one.
2 At the time prior to bringing tne craft i n, ~ w'e 3
were desperately looxing from one, two, tnree, at least 4
four different sources that I know of, for coatings 5
inspectors because we were literally burning the people 6
up. They were working 60 and 70 hours8.101852e-4 days <br />0.0194 hours <br />1.157407e-4 weeks <br />2.6635e-5 months <br />'a week. Some of them 7
nadn't nad a ~ day of f in a month which is inhumane and I 8
realize-that as much as any of them do.
We couldn't find 9
them quite frankly.
10 My job is to. try to support construction, not t
11 at the cost of quality, but if construction wants to nave 12 a thousana painters and I am only geared to inspect the 13 work of ten of them, I feel it is my obligation to try to 14 scarf up and properly train and certify people to support 15 the construction effort.
16 We were desperately short of people at that 17 time.
Construction was talking about essentially doubling 18 their work force and we neeced some inspection people.
}9 Interviews were conducted witn about, to the best of my 20 recollection, 50 -- excuse me. Resumes were examined first 21 from potential QC candicates out of the craft.
.I tnink 22 there were about 50 resumes submitted. A certain number of 23 tnose were interviewed and out.of those 16 were selected 24 as QC inspectors.
It was only an effort to oeef up the 3
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g l
a 95 l
'l inspections to support the ongoing acnstruction effort and i
2 to give people time.off tnat most of them desperately ~
~3 neeced.
4 The oiscussion on Unit 2 cr two units, I :.unk 5
~I~u, sed 10 crews and 20 crews as an example or 400 painters
'6 anci 800 painters.
It was' strictly a hypothetical example.
7 MR. DRISKILL:
I have no other questions.
8 MR. GRIFFIN:
Tom, have I or any other.4RC 1
9 representative here tnreatened you in any manner or s
10 cifered you any reward in return for.this statement?
11 THE WITNESS:
No.
- 12 MR. GRIFFIN
Have you given this statement
- 13 freely and voluntarily?
4 14 ThE WITNESS:
I have given tnis statement 15 freely and voluntarily.
I am not here freely and 16 voluntarily.
17 MR. GRIFFIN:
Is there anything further you 4
l 18 woulo care to add for the record?
19 THE WITNESS:
No.
00 MR. GRIFFIN:
Okay. Thank you.
l' 21 (Whereupon, at 5:23 p.m.,
the INTERVIEd OF 22 CHARLES THOMAS BRANDT concluded.)
{3 i
] 21 125 i
1 a
TAYLOE ASSOCIATES
(
1625 i STRifT, N.W. - SulTE 1004 WASHINGTON, D.C.
20006 (202) 293 3950 l
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t CERTIFICATE OF PROCEEDIllGS 2
3 Tnis is to certify that the attacned prcceedin.js of tae I
Interview of CHARLES THOMAS BRASDT before the Office of e
Investigations at Texas Utility Generating Corapany,-
6 Comanche Peak Steam Electric Station, Glen Rose, Texas 76043, on Thursday, December 1, 1983, commencing at 1:25 8
p.m.,
was neld as herein appears, and that this is ene 9
original transcript for the files of the Office of 10 Investigations, Region IV.
11 12 13 Mary C.
Simons 14 Official Reporter - Typed 16 G
& Y1_ k ____
18 Official Reporter - Signature 19 20 21 22 23 24 25 TAY1.OE ASSOCIATES
' a-1625 i STREET, N.W. _ $UITE 1004 WASHtNGTON, D.C.
20006 (202) 293 3950