ML20106G210
| ML20106G210 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/07/1983 |
| From: | Williams H DRAVO CORP. |
| To: | |
| References | |
| NUDOCS 8410310091 | |
| Download: ML20106G210 (47) | |
Text
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-i il UNITED STATES CF' AMERICA NUCLEAR REGULATORY COMMISSION t
I-l, INTERVIEW OF HARRY WILLIAMS Pittsburgh, Pennsylvania November 7, 1983 J
Appearances:
H. BROOKS GRIFFIN',
NRC Investigator DONALD D. DRISKILL, NRC Investigator ,
LeBOEUF, LAMB, LEIBY & MacRAE By: JOHN S. KINZEY, JR., ESQUIRE
Counsel for Dravo Constructors, Inc.
and Harry Williams TAYLOE ASSOCIATES Registered Professional Reporters Telephone (804) 461-1984 Norfolk, Virginia 8410310091 831107 PDR ADOCK 05000445 T- PDR Esbiro)
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WI T!J E F 5 E x a r. i n 3 - i o r. b/: Page Harry Williams Mr. Griffin 5 i
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(; ' 'r 1 Sworn statement of HARRY WILLIAMS, taken before
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i 2 Marcia B. Itall, a Registered Professional Reporter, ',
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3 commencing at 2:30 p.m., on the 7th day of November 1983, at !
i
- 4 the office of Dravo Constructors, Inc., 32nd Floor , One
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l . .
5 Oliver Plaza, Pittehurgh, Pennsylvania.
6 -------
7 8 MR. GRIFFIN: For the record, this is an*
9 interview by H. Brooks Griffin of Harry Williams who is 10 employed by Dravo, Constructors, Inc.
11 MR. WILLIAMS: 'Jh-h uh .
32 MR. GRIF' FIN: And you are presently located in -
13 El Centro, California.
(m 1
?
14 The location of this interview is the 32nd floor 15 of One Oliver Plaza, Pittsburgh, Pennsylvania.
16 Present at this interview are, for the NRC, H.
17 Brooks Griffin and Don D. Driskill. We are interviewing Mr.
18 Harry Williams.
19 And for Dravo, what is your first name?
20 MR. KINZEY: John Kinzey. -
21 I am also representing Mr. Williams in 22 connection with this interview.
23 MR. GRIFFIN: Dravo and Mr. Williams?
24 MR. KINZEY: Yes.
[\_/ .
25 MR. GRIFFIN: This interview is being TAYLOE ASSOCIATES
, . . . .. . -- . . . - - - - - - . ~
~
transcribed by a court reporter. !
I i .
2 i There are a variety of subjects that are going T ,
to be coverec in this interview. One of them being some QC 4 records, and intimidation, are the basic is 2es I want to
- 5. talk to you about. "
l 6 Mr. Williams, i f you will please stand, I want 7 l
, to swear you to the contents of this ststement.
.1 8 Would you stand and raise /our right hand? !l
-l 9 l l
l 10 (The witness was first duly sworn.)
11 12 l l MR. KINZEY: Before we begin, I understand there l
l 13 are certain agreements that have been reached prior to going i
14 on the record with the interview.
, 15 Some weeks ago, Mr. Williams gave an interview ,
16 and a statement to Mr. Driskill, who is present here today, 17 at a time when Mr. Williams was not represented by counsel.
18 As I understand, he was promised a copy of that 19 signed statement which he has not yet received.
20 It was my position at the outset today that we 21 were not prepared to go forward with that inte.rview on the 22 record until Mr. Williams has been provided a copy of that 23 statement.
24 So I will allow the in'terview to go forward. I A
25 believe.it is the agreement of those of us present thtt the TAYLOE ASSOCIATES
4 I
I 1 subject matter as to which Mr. Williams was interviewed in '
I i :
l 2 the prior interview, and which was the subject of that I, I
'3 statement, will not be covered during the course of today's 4 interview; and that statement which he signed previously wi,11 5 not be used in any way to impeach him.- .
6 MR. GRIFFIN: That's correct.
7 MR. KINZEY: I further understand that we will l
o 8 be provided a' copy of that signed statement b,y mail after Mr.
9 Griffin an( Mr. Driskill have had a chance to go back to 10 their office.
11 MR. GRIFFIN: Tha t 's co r r.ec t , also.
12 MR. KINZEY: Let's go ahead, I j
13 MR. GRIFFIN: Harry, before I start talking to 14 you I want to go into, for a moment --
15 MR. KINZEY: Do you want this on the record?
16 MR. GRIFFIN: Yes, I do.
17 MR. KINZEY: I didn't mean to interrupt. Go on.
18 MR. GRIFFIN: Before I start the interview, I 19 want to go into the relationship that exists between Mr.
20 Kinzey and you for the record.
21 Mr. Kinzey, I pose some of the questions to you.
22 Do you presently represent Dravo Constructors, 23 Inc.?
24 MR. KINZEY: Yes.
4 N .. ,
25 MR. GRIFFIN: In this instance, you say you also TAYLOE ASSOCIATES v__
.; , r r y S. ' ' ' : r n e.
t
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I represent Mr. Williams; is that correct?
2 MR. KIN 2EY: Yes.
3 t MR.-GRIFFIN: Do'you represent any of the other-4 parties involved,- like Tugco, Brown & Root?
5 MR. KINZEY: I.do'not represent any other party,-
6 including those two.
7 8 HARRY WILLIAMS, being previously duly sworn, was 9 examined and testified as'follows:
'10 11 EXAMINATION 12 BY MR. GRIFFIN:
13 0 Mr. Williams, the NRC allows an interviewee,_an 14 employee of a contractor, or representative in the nuclear 15 industry that is being interviewed by the NRC, an opportunity ,
10 to have with him or present with him in the interview a 17 representative.
18 That doesn't necessarily mean counsel. It just 19 means maybe that you want -- the intent was I believe to make 20 you feel more comfortable in the interview and not to direct 21 his testimony or to tell him what to say or what not to say 22 or where to start and stop.
23 When I interviewed or when I called you on the 24 , phone earlier, you indicated that'you could not be 25 interviewed by the NRC until you had a Dravo attorney present,
. l TAYLOE ASSOCIATES
. . h -
silliams s l l
1 and I believe you indicated this was company policy; .is that {
i 2 , true? I l !
3 A. Uh-huh. That's true.
4 MR. KINZEY: Harry?
5 THE WITNESS: Yes. Excuse me.
6 BY MR. GRIFFIN:
7 Q. In this instance, are you adhering .to company 8- policy, or is it your personal preference that your i
9 representative be Mr. Kinzey?
10 In other words,-are you doing it because Dravo s
11 says you will, or are you doing it because'he is your 12- personal representative?
13 A. He is my representative'.
14 Q. So he speaks not for you because that's not our 15 intent here today, but he is your representative under the 16 term; representative, as put forward by the NRC; is that your 17 understanding?
18 A. Yes.
19 MR. GRIFFIN: Mr. Kinzey, I do not know how 20- involved you will become in these proceedings, but when you 21 sp.ok, will you be speaking for Mr. Williams, or for Dravo?
22 MR. KINZEY: I will be speaking for Mr. Williams.
23 MR. GRIFFIN: Mr. Kinzey, you said that, I 24 believe,-you indicated that when the NRC interviews Dravo 25 employees, it is their company policy that they be TAYLOE ASSOCIATES
!!a r r y .. i l l i a:-s -
1 represented by Dravo counsel; is that correct?
j 2 ;
MR. KINZEY: That is not their stated policy, no.
3 MR. GRIFFIN: Would you explain it to me 4 briefly?
5 MR. KINZEY: My understanding of the policy is 6 that prior to speaking to any attorney for another party or 7 any enforcement agency, it is Dravo Company policy that the 8 potential witness or interviewee is to contact corporate 9 legal department here in Pittsburgh who will advise the 10 witness at that point as to whether he needs a lawyer, to 11 give him a choice of lawyer, if he wants one, or to represent 12 him if that is what seems appropriate in the circumstances.
13 MR. GRIFFIN: You say if that is what seems 14 appropriate.
15 Tell me this, did Mr. Williams before the outset ~
16 or before today have a choice as to whether he could have a 17 Dravo attorney or not? Does he have'a choice?
18 MR. KINZEY: He most certainly does. We spoke 19 with Mr. Williams last night and told him what his options 20 were, and under Dravo bylaws, he had the right to retain any-21 counsel he chose, and the company would reimburse him for 22 that expense.
23 MR. GRIFFIN: It is your understanding that Mr.
24 Williams -- it is his choice that you be present here today?
25 MR. KINZEY: Yes.
TAYLOE ASSOCIATES
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- , . tia r r y *..'i l l i ams '
i l, !
1 MR. GRIFFIN: I think you told me earlier., Mr.
-2 Kinzey, who implemented this policy. Do you know?
MR. KINZEY:
3 . I don't personally know, no.
4 It is my understanding Mr. Glen Burns, who is 5 Dravo's Corporate attorney, initiated this policy some period 6 of time back. !
7 MR. GRIFFIN: And it is your understanding that 8 this policy will be uniformly applied?
9 MR. KINZEY: Yes.
10 M R .' G,R I FF I N : To other employ es as these issues 11 come up as they relate to the nuclear industry and contact 12 with the NRC and others? , . .
t 13 MR. KINZEY: Yes. It is not limited to the NRC.
14 MR. GRIFFIN: Okay.
15 Mr. Kinzey, have you been given any instructions 16 that relate to a potential conflict between what Mr. Williams 17 might be saying in his testinony and what Dravo Company's 18 policy might be? Do you understand my question?
19 MR. KINZEY: No.
20 MR. GRIFFIN: Has anybody instructed you as to 21 how to represent Mr. Williams in this matter?
22 MR. KINZEY: No.
23 MR. GRIFFIN: No?
24 MR. KINZEY: No. I am not quite sure what your
{ ~
25 point is, but I would simply observe as a lawyer if a TAYLOE ASSOCIATES
1
? . . ~
ilar ry hiil iams I
1 conflict arises and there is an attorney,t.e nas an ethig 2
obligation to deal with that.
3 I am here today because we don ' t perceive a .,
4 conflict between Mr. Williams and th,e company.
5 MR. GRIFFIN:
The NRC does not have an offic 6
policy on this that I am aware of. We have already discu 7 this.
But the NRC does see a potential conflict between 8
company attorney representing an interviewee, and the com; 9
has its own interests in mind during the interview.
10 We are proceeding with this interview in spi <
11 of my concerns in 'tha t area ,
12 MR. KINZEY:
If we are going to go into this, 13 which I think is burdening the record unnecessarily, I jos 14 i observe that, as I understand it, Mr. Williams has the rig 15 in any informal administrative procedure to have counsel o 16 his choice.
17 If there is a potential conflict between the 18 witness and another entity that the lawyer may represent, 19 really, it isn't necessarily something of the NRC's concer!
20 MR. GRIFFIN: '
The NRC is concerned about whetl 21 the testimony received is an accurate recreation or portra) 22 of the events and knowledge of the witne'ss, rather than a 23 reflection of the company's perceived or desired portrayal 24 recreation of the events, and that's where the concern lies 25 MR. KIN 2EY:
I can understand that is a conces i
TAYLOE ASSOCIATES
i j Harry hilliams ,,
1 A.- Supervisor. ll s:
2 Q. The term, supervisor, is that the same as, like, '
6:
3 superintendent? I:
r!
1:
4 Were you a superintendent part of that time?
5 A. I don't feel like --'I was a supervisor most of-6 the time.
7 Q. You were a Dravo supervisor. Did you supervise 8 Brown & Root employees?
9 A. Yes.
l 10 Q. Were. you employed in other than coatings, e
.C Q
l 11 inspections? Did you have other jobs also?
12 A. Well, supervisor with another group, yes.
13 Q. What other group was that?
14 A. Concrete. QC.
15 Q. Did you hold th'at position at the same time you
. 16 held the position as coatings QC supervisor?
17 A. Yes.
18 Q. Did you hold that same position during the 19 entire time you were employed there?
20 A. . With the concrete, yes.
21 Q. And coatings is just a portion of the title?
22 A. Yes.
23 Q. When did you start or when did you become a 24 supervisor over coatings?
25 A. I believe it was June '81.
TAYLOE ASSOCIATES
S -
l Harry Williams , ,
1 Q. And did you hold that position until you left? '
2 A. Yes.
l 3- Q. And when did you leave Comanche Peak?
4 A. September, let me think, the first of September.
, 5 Q. 1983?
6 A. '83.
7 Q.- .What-is your present position?
8 A. QA at.the Heber site.
9 Q. H-e-b-e-r?
- 10 A. H-e-b-e-r.
I 11
- Q. What type facility is that?
12 A. That's a geothermal system.
t 't 13 Q. All right. ' ~
14 In the fall of 1982, among the other groups that 15 you supervised, did you supervise the QC coatings group at 16 Comanche Peak in which Robert Hamilton was the supervisor or 17 the foreman?
18 A. Yes.
19 Q. Do you recall an instance which occorred in 20 March of 1982, in which I believe Mr. Hamilton, Mr. Krolack, ,
21 Mr.'Shelton, were asked by you, I believe, to perform an 22 inspection at, I believe they described it as high on the 23 ring in the containment, Unit I? Do you recall that incident?
24 A. Yes, sir. ,
(
25 Q. Were you the supervisor of Mr. Hamilton at that '"
TAYLOE ASSOCIATES '
- _ lia ..;iams' ,,
13
- I time? .
I 2 A. Yes. .'
3 Q. And Mr. Shelton and Krolack, were they on Mr. '
i 4 Itamilton's crew?
5 A. Yes.
6 Q. Were Krolack, Hamilton and Shelton subsequently 7 terminated as a result of their unwillingness to perform an-8 inspection on that ring?
9 A. Yes.
1 10 Q. Whose decision was it to terminate them?
11 A. My supervisor.
12 Q. Who was Liat? ,
e 13 A. Tom'Brandt. I 14 i Q. Were you the one that instruct >d Hamilton to i, i
15 perform the inspection? '
i 16 A. I gave word that he needed to go up there, him i 17 or he and his people.
a 18 Q. Who originated this inspection?
t Who decided 19 this inspection had to be made? Was it routine?
20 A. Construction.
21 Q. Construction. So they were at a point where l 22 that needed to be inspected? i-23 A. Needed to be inspected.
I t
24 Q. Do you remember which-one you asked to go up 25 first?
l TAYLOE ASSOCIATES
,, .. , . - _ . . - . _ , , . - , , - - ~ . . -
I Harry hilliams 11 1 A. I didn't ask,any of them personally. I told the 2 supervisor to send somebody up there.
3 Q. You told Hamilton?
4 A. I told Neil Britton and he relayed a message to 5 Hamilton.
6 Q. I see. There were a couple other paint 7 inspectors whose names I am familiar with. Fa z i and Gunn, 8 are you familiar with those two gentlemen?
9 A. Yes.
10 Q. Were they also asked to make this inspection?
11 A. Gunn wasn't.
12 Q. Wa s Fa z i?
13 A. I don't know. t 14 Q. Do you recall, or is it your personal knowledge 15 that Krolack and Shelton were asked to make this inspection?
16 A. I don't know if they --
17 Q. Is your knowledge of this instance based on 18 having been there yourself or just related to you through l
19 some third-party?
20 A. They were told to go up there to inspect. And .
21 they refused to go.
22 Q. But the instructions came -- originated with you,
~ 23 went through Britton to these guys?
24 A. Uh-huh.
(
25 Q. Did Hamilton ever have.any personal conversation TAYLOE ASSOCIATES
lia r ry v. a . . i ans 15 1
with you about refusing to perform this inspection?
2 A. Hamilton came to me and said it was unsafe, or 3 he said it was unfair.
4 Q. Hamilton did?
5 A. Uh-huh.
6 Q. Do you recall what your comments were or what 7 your response was?
8 A. Yes.
9 Q. What d id you tell him?
10 A. I said, "I will go up to the Safety Department 11 and have a look at it."
L 12 Q. Did the Sa fety Depar tment look at it?
13 A. Yes.
14 Q. And what was their --
15 A. They said it was safe. No problem with it.
16 Q. Do you know if Hamilton was the first one that 17 was asked to perform his inspection? Or did Krolack and 18 Shelton precede him; do you know?
19 A. I don't know.
20 Q. Af ter Safety decided that it was a safe 21 inspection, did you make any further - give Hamilton further 22 instructions?
23 A. I informed Neil that the Safety Department said 24 it was safe; that they were to go up and do their job.
t 25 Q. I presume Mr. Hamilton continued to refuse, is TAYLOE ASSOCIATES
L Harry Williams 16 l 1 that right?
2 A. Yes.
- 3 Q. Did he tell you this personally, or written, as 4 related to you?
5 A. He told Britton, and he related it to me.
, 6 Q. What happened next?
7 A. I went to my supervisor.
8 .Q. Brandt?
9 A. Yes.
10 Q. And what did Brandt say?
11 A. He said that they are to perform that inspection 12 And if not, be wanted to see them in his office.
1 13 l
4 Q. Did Brandt subrequently see them in the office?
l 14 A. Yes.
15 Q. Was it Shelton, Hamilton and Krolack?
16 A. Yes.
17 Q. What did Brandt do, now?
18 A. He had also Gordon Purdy there, and they had 19 prior discussed this to them getting there. And he gave them 20 one more chance to go up and inspect it. .
21 O. And they refused?
I 22 A. Yes. -
9
' 23 Q. Then what happened?
24 A. They were terminated. ,
(
25 By Brandt? *~
Q.
TAYLOC ASSOCIATES
'* :r e W!::i ms ,-
1 A. _(Witness nodding head) 2 Q. During that time, were you present for that
-3 conversation?
4 A. I was in the area, yes. . ,
5 Q. Do you recall' Hamilton, Krolack or Shelton-6 recalling or relating any prior histo y on this particular
- 7 inspection? Do you recall him saying that a previous 8 supervisor by the name of Hawkins had already made a 9 statement that this was an unsafe inspection?
l 10 Do 'you recall that statement?
11 A. Yes, sir.
t l
12 Q. Do you recall any comments by yourself, Brandt, 13 or Purdy as it relates to that?
! 14 A. No. I don't.
15 Q. Did the statement that Hawkins, the previous
, 16 supervisor, had said that this was an unsafe inspection, did i
17 it carry any weight, or did it influence anybody to your i 18 knowledge to believe that this was an unsafe inspection?
l 19 A. I don't remember. I don't know.
20 Q. Did it cause you to question whether this was a' 21 safe inspection? .
22 A. No.
23 Q. In other words --
24 A. I walked it.
25 Q. You did?
TAYLOE ASSOCIATES
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Harry Will: 13 ;i s
'l A. Yes.
2 Q. At that time?
3 A.- At a time before they went to the office.
4 Q. Did anybody else walk it?
5 A. Yes.
6 Q. Who?
.i 7 A. Mike Foo te and Neil Britton and I all went up 8 there. , ,
9 Q. Do you have an opinion beyond these facts as to 10 why these men were,not performing inspections?
11 or do you feel like they were being honest in 4
12 that they thought-it was an unsafe inspection?
- +
13 A. I don't know.
14 Q. Do you recall if anybody else voiced an opinion 1.5 as to why these men were not to perform this inspection?
16 A. No. The reason they gave was unsa fe.
37 Q. You said Brandt actually terminated Hamilton, 18 Krolack and Shelton. Was anybody else involved in the 19 decision to terminate them?
i 20 A. Gordon Purdy was there. **
j 21 Q. But Brandt was the one that made the decision?
22 A. I am assuming. I can't put words in their mouth.
23 Q. All I want to know is what you personally know.
24 I am not asking for hearsay or speculation in this instance.
25 A. I don' t know. You would have to talk to them on TAYLOE ASSOCIATES
Marry hi!!iams ..
i i that.
l 1
i 2 Q. But you were present if, for instance, if Purdy l 3 had said " Tom, fire him"? That's why I am asking the 1
4 question. '
5 A. Tom and I discussed it. And I an assuming that 6 he discussed it with Gordon, you know.
7 Q. But it was Brandt's decision?
8 A. Yes. It might have been both of their 9 deciuions, I don' t know.
10 0. Do you ever recall anybody in your presence 11 telling Mr. Hamilton, or had you ever told to Mr. Hamilton 12 that he was conducting his inspections too well? Quote, 13 "too well," unquote?
14 A. No.
15 Q. You never made that statement?
16 A. (Witness shaking head neg a tively) .
17 0 Harry, I want to move onto a different subject:
18 Ron Tolson.
19 Ha r ry, do you recall an .ncident while you were 20 I believe the QC superintendent of HP in which Darlene Stine.r 21 refused to sign off on a hanger? A. .d she voiced this to you, 22 injicated she refused to sign off on it? Do you recall that 23 incident?
24 A. No, I don't.
25 0 Do you ever recall telling Mrs. Stiner when she TAYLOE ASSOCIATES
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j Harry Williams !
1 23 t
l I
refused to perform an inspection to buy off the hanger, you 2 would find somebody else who would? Do you ever recall 3 making that statement to Mrs. Stiner? i 4 A. No, I don't.
5 Q. Do you ever recall. substituting' Randy Smith to G perform an inspection that Darlene Stiner had indicated she 1
7 would not perform?
8 A. No.
- 9 Q. Have you' ever heard of this incident that I am 10 trying to --
s 11 A. No, I haven't.
12 Q. Has anybody ever told you that this incident was 13 testified to before the ASLB hearing board?
14 A. No.
15 Q. Do you recall another instance in which a 16 foreman by the name of James Sturbridge instructed Mrs.
1,7 Stiner to weld a leg on a hanger that did not contain a F
l 18 drawing with the dimensions in the traveler? Do you recall t
I 19 that incident?
t l
l 20 A. No, I don't. ,,
21 O. Do you recall that instance yourself?
l l 22 A. I don't. -
! '23 Q. Do you. recall that?
i 24 A. No, I don't recall that.
\
25 Q ., would it be in violation of proc? dure? '-
TAYLOE I.SSOCIATES
r- r r-Harry Williama . ::
- j 1 A. Pardon? !-
1 I
2 Q. Would it be in violatien of. Brown & Root's 3 procedure to add a leg? You understand what-I mean by leg?
4' A. .Yes. I know what you mean.
1 5 Q. A hanger without proper documentation?
6 A. Yes, it would be.
7 Q. If such thing had occurred, do you think you 8 would recall it? The incident?
9 A. I think I would'.
, 10 Q. You do not recall it?
11 A. I don't' recall it right now, no.
12 Q. Do you rec.all any incident in which a leg was l 13 welded on a hanger without proper documentation, in which QC l
! 14 discovered the welding in process, and brought a halt to it, 15 involving Mrs. Stiner?
16 A. Not to my knowledge.
17 Q. A separate issue now, do you recall in 1982, 18 when Mrs. Stiner was instructed to perform inspections 19 relating to torqueing of Hilti bolts? Do you recall her 20 inspections in that area? ,
21 A. Well, she inspected the bolts as she inspected a 22 hanger. -
23 Q, Do you recall an instant in which Mrs. Stiner 24 was instructed to accept the torque on Hilti bolts without a 25 sign-off on the traveler?
I
, TAYLOE ASSOCIATES l
L- ___
1 l
1
!!a r ry Williams 22 1 A. Sign off on the traveler?
2 Q. Yes.
3 A. No. She accepted them. She signed off on the 4 traveler fo'r them.
5 Q. So it would have 'been her responsibility?
6 A. It would have been her responsibility to sign' 7 that, yes.
8 Q. Is it possible that her -- let me rephrase my 9 question. In her inspection of Hilti bolts, they had already 10 been installed, which only her inspections involved the
?
11 torqueing. -
12 Did you ever recall an incident in which there .
i 13 had not been a sign-o f f of the installation of the Hilti 14 bolts in the traveler?
15 I am just trying to jog your memory as to an 16 incident.
17 A. If the traveler is present when you go up to 18 inspect the hanger, if the torqueing is not signed off at 19 .thot time, they are to do it with the inspection of the 20 hanger at that precise time. ,,
21 Q. In other words, let me see if I understand this.
22 You are saying if the traveler does not show the
' 23 installation of the Hilti bolt, then the fact that they are 24 just inspecting torqueing at that point, that the QC .
s 25 inspector can go back and sign off on the installation that TAYLOE ASSOCIATES
!!a r ry Will iact- 23 f .l 1 has previously occurred?-
2 A. Well, now you are saying two.differen: things.
'3 Q. Am I? !
1-4 A. Yes. Installation is installing the bolt. '
5 Q. Right.
6 A. Okay. That is done on a random basis by QC 7 . people.
8 . Q. Okay.
9 A. They have separate IR's for those Hilti bolts as 10 being installed in the-wall.
11 'he T bolts *are preset by construction.
12 Q. But if you are-inspecting just the torqueing on
. 13 them and you find that they have not been bought off.by QC on 14 the installation, did you proceed with the torqueing 15 inspection?
16 A. Yes. Because they may not have inspected those 17 certain bolts on installation.
18 Q. Because it is a random?
19 A. Yes. A random-type sampling, yes.
20 Q. This was a part of the procedure at Comanche ,
21 Peak for Brown & Root?.
22 A. Yes, at that time.
'So it is not unusual to see a traveler package, 23 O.
24 cay, during an inspection of Hilti' bolts for torqueing in 25 which QC has not bought off the installation of that Hilti TAYLOE ASSOCIATES
- Harry Williams 24 I
1 bolt?
2 A. Well, now, yes. '
3 Q. Do you recall an i ncident in which Mrs. Stiner I l
declined to perform inspections of torqueing on Hilti bolts, 4
5 and made this declination or declined to do it to you, 6 indicated to you that she would not do this?
7 A. No, I don't.
S Q. Do you-recall Mrs. Stiner at all?
9 A. Sure.
10 Q. Darlene Stiner?
a 11 A. Yes, I know her.
12 Q. Do you recall an argument with Mrs. Stiner over 13 this issue, at all?
- i 14 A. No.
15 Q. Do you recall ever indicating to Mrs.-Stiner 16 that if she did not trust you, that you would replace her?
17 A. No.
18 Q. Do you recall ever making such a statement to 19 her?
20 A. No.
21 Q. Harry, in 1982, do you recall asking Mrs. Stiner 22 to work on inspections of vendor welds on diesel generators 23 with Randy Smith?
24 A. Yes. ,
I '
25 '- '
Q. Do you remember any statements or any position TAYLCE ASSOCIATES
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---w - , , _,.rw. . - - . --
Arry Will'iams 25 l' j that Mrs. Stiner related to you as to her feelings about l
2- conducting these inspections?
3 A. Yes. She said she wasn't familiar with the 4 drawings of,the diesel generator.
5 Q. Did she indicate she would rather'not perform 6 these inspections?
7 A. Yes.
8 Q. What were your instructions to her?
9 A. At the time, I told her to help out Randy as 10 much as she could until we could get caught up, and then 11 Randy Smith took over and just run it by himself.*
12 Q. Do you recall instructing Mrs. Stiner to go i'
13 forward with the inspections even though she indicated she 14 did not want to?
15 A. No. She preferred that she'd help; do what she 16 could.
17 Q. Did she conduct inspect.ons?
18 A. Yes.
19 Q. During your conversation in which she indicated 20 that she didn't know about them, was not familiar with them,-
21 did you make any statements to her to the point that she 22 could conduct the inspections, or go home?
23 A. No.
24 Q. So you did_not threaten her with that?
25 A. No.
TANLOE ASSCCIATES
p
= harry Williams 26 1 Q. In any manner?
i 2 A. (Witness shaking head) 3 Q. You did not indicate that her employment hinged 4 on her conducting these. inspections?'
5 A. No.
G Q. Do you recall'an incident in which Mrs. Stiner 7 wrote an NCI on some large doors in the containment plates, 8 and put hold tags on welds on these doors. Do you remember
- 9 that incident?
10 A. I don't know. On some welds on a door?
11 I am in the dark here.
12 0 . .. Okay. I think they may have been vendor welds 13 on some preconstructed doors.
14 I am just trying to jog your memory.
15 A. There is -- well, I know there was some doors 16 out there that we had to redo. But I am not, I am not saying 17 these are those. I am not sure.
18 Q. Do you recall Mrs. Stiner putting tags on those 19 doors, hold tags?
20 A. No.
21 Q. Were you present when Mr. Brandt told Randy 22 Smith to tell Darlene Stiner that she would perform the 23 inspections and buy of f on the doors, or she would be gone?
24 A. Who made that statement?-
25 Q. Were you present when Mr. Brandt indicated that TAYLOE ASSOCIATES
m j l' . r r y *.. i l l i ac: ;- ,
?
1 Mrs. Stiner -- indicated to Mr. Smith -- that Mrs. Stiner :
2 would perform the inspections, or be gone?
f 3 A. No. 6 1
i 4 Q. Were you present when Mr. Smith related to Mrs. '
5 Stiner that she would perform the inspections or-be gone?
6 A. No. Because at that time, Smith didn't work 7 :
with Stiner.
8 Q. Since you do not recall .the incident, how do you i
9 know what time we are talking about?
-10 A. Because when you said Brandt, the names changed 11 when he took over.
12 Q. Did your position change?
13 A. Yes, sir.
14 Q. What did your job title become when Brandt moved 15 in?
4 16 A. My job title stayed the same. Just had less 17 people to worry about.
18 Q. You didn't have --
19 A. I didn't have Stiner, Smith and Britton.
20 Q. Were you present for any of the interviews or ..
21 ' counseling sessions? I don't know exactly how to term it,
]U 22 which, while Mrs. Stiner was pregnant, and still working she 23 was called into Mr. Tolson's office, the QA manager, and 24 -conducted discussions with him on her health and her i
i
- b; 25 pregnancy?
TAYLOE ASSOCIATES
+
y Williams ~ -
28-
+ . .
'. 1
~
h 1- A. No. -
-2 Q. You.were not present for any of these? '
1 3 A. _-No.
.4 Q. Were you aware'of these interviews by third
. 5 parties or talk around? -
9 1
6 A. Just talk.
, 7 Q. Do you know how many times Mrs. Stiner was s
8 called into Mr. Tolson's office?
9 A. No, I don' t.
j 10 Q. Do you have any idea? One or more times? .
l -
11 A. No, I' d o n ' t .
$ 12 Q. Did Mr. Tolson.or Mr. Brandt ever convey to you 13 or tell you about these sessions?
14 A. No?
15 Q. Different subject now: Do you recall the woman J
j 16 who I believe is now Robert Hamilton's wife, Corde11a '
j 17 Hamilton; do you recall her?
/ s j 18 A. Yes.
19 Q. I believe her job was document clerk QA, QC j 20 coating, is that correct?
l'-
21 A. Clerk.
t .
! 22 Q. For coatings; is that correct?
23 A. Yes.
1 24 Q. And in this position, was she also'under your -
( -
25 - supervision? 's- i o
I TAYLOE ASSOCIATES 9 ,- - * . , ,.,7, ,-w-.v.,c.-,,,-,,my,- ,-,,c-.v,.+-,,,,m_. ,,-,m.-,,,,,,,.,,.,.ry- e,- py.. n,,w,--w.wy,.,,,,,.y,v,.w,,,%,,,,-ny-- ,,, .r.,,c-,,v,-,,,n-~----,,-
l Harry Williams 29 p
1 I 'A. Yes.
2 O'. But there was a' foreman'over her?
3 A.. Which was Hamilton.
,- 4 Q.- Robert Hamilton?
I 5 A. (Witness no'dding head) 6 Q. Did you ever give direct instructions to 7 Cordella . Hamilton as rela tes to her performing her duties?
8 A. That time is when he came in with the IR' system.
! 9 She needed help with that. I sent another clerk down there 10 .to help set up a logbook.
11 Q. Do you ever recall giving Mrs. Hamilton any
] 12 instruction in performing her duty?
13 A. As a clerk?
4
, 14 Q. Yes.
i 15 A. No.
.16 Q. Do you recall ever telling Mrs. Hamilton that i
17 she needed to perform her -document review, which I believe is l,
18 what she was involved in? Well, let me start over. Let me
[ 19 ~ start: did her duties involve document review o'f coating 4
20 inspection records for adequacy? ,,
21 A. Records?
22 Q. Yes. -
1
- 23 A. No.
i 24 Q. What was her job as you knew it to be?
25 A. As a clerk, just to log them in.
TAYLOE ASSOCIATES
Harry Willians 30 1 Q. Log what in? i
.2 A. The IR's at the time we started them.
3 Q. The inspection check list?
4 'A . Yes. At that time when Brandt went there, then 5 we went into the CR system. ,
6 Q. Did she work there prior to the time Brandt was 7 there?
8 A. Yes.
9 Q.* Were you her supervisor prior to the time Brandt 10 came?
11 A. As far as that goes, Hamilton fell under me from 12 the simplicity of just people to hire or to fire.
s 13 Technically, problems went to Hawkins.
14 Q. Did you ever tell Mrs. Hamilton prior to Mr.
15 Brandt's arrival on site' anr4 changing to IR's, did you ever 16 instruct Mrs. Hamilton to conduct her clerking duties in a 17 more timely manner?
18 A. No.
19 0 Did you ever counsel her or give her 20 instructions as relates to speeding up her documer.t clerking 21 activities?
f 22 A. No. -
23 You are saying prior to Brandt now?
24 Q. Right.
25 A. No.
TAYLOE ASSOCIATES
p 1
i
-l ilarry Will i ams- 31-
'l' O. Do you recall giving her ~instructions after I.
2 Brandt came to hurry up or speed up her clerking duties? '
3 A. No.
~4 Q. Now, just in a kind of small r.eview here, we 15 'have talked about an instance involving Robert-Hamilton, 6 Darlene Stiner, and Cordella Hamilton.
7 LIf I am remembering correctly, other than.the 8 Hilti bolt, torqueing of Hilt.i bolts incident, which I 9 related to you and possibly the .large d' oo.rs, you don' t have 10 any recollection of-the incidents that I'have questioned you 11 about, is that right?
12 A. That's correct.
13 Q. Based on my questions -- do you believe that e
14 these incidents that I am - telling you as they have been 15 related to me, which is the foundation for these questions, 16 have these people truthfully related these instances to me, 17 or are these pure fabrications?
18 MR. KINZEY: That's an unfair question to ask 19 this witness.
20 THE WITNESS: I don't know.
21 MR. GRIFFIN: I am trying, Mr. Kinzey, I am 22 tr,ying to -- we have quite a few incidents here of 23 confrontations that have been related to us. And Mr.
24 Williams indicates he has little or no memory of them.
25 And he may have an opinion that I am trying to TAYLOE ASSOCIATES
m;w r-( Ha r r y; Wi l'l i ams 3_
1 elicit-as to whether the NRC has~been provided with false t
2 information. .He may have a clear recollection that these- !
l-3 instances have never occurred, or I am trying find out if -
4 -they'ever did occur, or he just has no memory of them. ~
I 5 would appreciate an answer on that.
G' MR. KINZEY: Do you understand the question?
.7 THE WITNESS: I understand the question.
8 BY MR. GRIFFIN:
9 Q. Do these represent real events that occurred?
10 A. I don't have recall of them. Put it that way.
11 Q. You don't recall them?
.12 A. No.
13 Q. Let me elicit your opinion then for a moment:
14 Do you believe that these events may have been real, or are 15 they fabrication? Do you have an opinion?
16 A. No. I don't have an opinion.
17 Q. Switch to a different subject now: In that you 18 were the supervisor over coatings records, when did you first 19 start as superintendent over coatings, or as the supervisor 20 over coatings? Do you remember what year?
21 A. When did we determine -- to the best of my 22 recollection, I would say 1982. -
23 Q. You started handling --
24 A. I would say '82.
i- 25 Q. Okay.
TAYLOE ASSOCIATES
m.
Harry Walliams 3:
1 Q.. -Harry, when were_you involved?
l l
2 A. June. !
i 3 Q.. -June '82?
4 A. Something'like that.
5 -MR. DRISKILL: .I believe you said earlier June '81 c 6 THE WITNESS: Did I.say 'Bl? No.
7 Jim Hawkins was still there.
8 MR. DRISKILL: Okay.
9 BY MR. GRIFFIN,:
10 Q. To the best of your recollection, it would be 11 like June of '82?
12 A. I am just sorting that out. I am not sure.
13 Q. Who was the supervisor at that time over 14 coatings, QC?
15 A. Hawkins was at that time.
16 Q. This is prior to their switching to the IR 17 system, is that right?
18 A. Yes. They just had a check list.
19 Q. Were you during 1983 --
20 A. (Witness shaking head) .
21 O. -- involved, or did you participa te in a 22 document review conducted by Mr. Britton of these old 23 coatings inspection check lists?
24 A. Did I personally review them?
25 Q. Yes.
TAYLOE ASSOCIATES
-. - . . ~ - ...
Harry Williams- t-1 A. No. ,
2 Q. Were you aware that Mr. Britton was conducting 3 such?-
4 A. Yes.
5 Q. But you did not actually look at'any of the 6 documents?
7 A. I looked at them, but that was it.
- 8 Q. I mean, did you look at them in relation to this 9 review process?
10 A. No.
, 11 Q. Did Mr. Britton ever bring these documents to 12 you to request a comme.it or explanation for any of them?
'. 13 A. These documents were all reviewed by Ebasco '
14 people first.
15 Q. Who was that, do you recall the names of those 16 people?
17 A. Mike Foote was one , and Dick Cummings.
18 Q. Do you know if they looked at all of them?
19 A. They looked at every one of them. Never 4
20 involved. I put them in the vault.
21 Q. Where did you acquire the records?
22 A. Out of the QC shack. -
l L
l 23 Q. Which one?
24 A. Hamilton's.
l 25 Q. That is on the hill? '"'
l TAYLOE ASSOCIATES
n ._. . -
Harry h.... ms 35 ll
- 1. (Witness shaking head)
A.
2- Q. -The other onefthat is dowr. there close to the 3 admin. building?'
. .4 A~. ' No . Those are'down at the intake structure.
5 Excuse me. 'The service.wat'er tank.
6 Q. Okay.
.- ~
7 Do you recall when you put those QC records in 8 the vault?
9 A. Right after I found out what shape they were in.
10 I am not -- it isn't ---shortly.after: Tom Brandt took over.
11' O. In the summer of '82? -
12 A. Gee, shortly a f ter.
13 Q. Do youchave any idea 'when Foote and Cummings 14 conducted their review of these records?
15 A. That same year, in the fall.
16 Q. Was it at your instruction that this review was 17 conducted?
18 A. No.
19 Q. Do you know what the purpose of their review was, 20 Cummings and Foote? ..
21 A. See what they could find that would amount to 22 anything. -
23 Q. Was this review that they conducted as a result l
24 of an NRC notice of violation? Do you know that?
25 A. I don't know that.
4 l- TAYLOE ASSOCIATES r
o -
f Harry 1WilliDms ~
36
- 11. Q. So you don't know what the origins ~of this I ; ,. l
' 1 2- document--review were?
3 A. (Witness shaking head) 4 Q. Do' you know what 'the findings were of Foote ' and' 5 Cummings' review?
6 A. Yes. One massive'back fit program.
7 -Q. Were NCIs issued as a result?
8 A. Yes.
9 Q. Were they this issued af ter Foote and Cummings-10 got the review or-prior-to this?
11 A. They ' issued it at the time.
12 Q. During then? ,
~
13 A. Well, shortly, I can't say it was right at that
- 14 time or you know. They were issued after their findings.
15 Q. After Cummings and Foote's findings?
16 A. (Witness nodding head) 17 Q. Do you know what the recommendation was?-
P 18 Or did they make one? Did Cummings and Foote 19 make a recommendation as relates to these records?
20 A. No.
21 Q. Who decided that there would be a massive back i
l '22 fit program? .
i 23 A. I think Tolson did.
- 24 Q. Is that your personal knottledge or just assuming -
! (
25 that? '
l l
TAYLOE ASSOCIATES l
Harry Williams 37 A. I am-just assuming. Went full scale into it.
2 Q. Do ycv2 know why Mr. Britton was then asked 1to do 3 _-- a review of.these_same documents?
4 A. Because he was doing a back fit. He was the 5 back fit person at that time. ,
l 6 Q. He was the supervisor' in charge of the back j 7 fitters?
8 A. Yes.
I 9 Q. Is it your understanding that the back fit was j 10 to be for all coatings inspections prior to a certain period?
11 A. Prior to --
t 12 Q. Is it April ' 81, do es that sound right?
13 A. March; April, somewhere in that time.
~.
14 Q. I have heard that before.
15 A. Yes, right.
J 16 Q. I think March, April?
17 A. Right, yes. _
18 Q. So while Mr. Britton was conducting his back fit, 19 he was also reviewing these old documents. Is that your 20 understanding? ..
21 A. When they started the back fit, Cummings and 22 Foote hadn't got through the initial documents yet. So I am 23 not familiar with when you are talking about written review-24 on these documents.
'*' ~
25 Q. Are you aware that Britton -- are you aware that TAYt0E ASSOCIATES
Harry Williams' 38-1 he reviewed the documents?
2 A. He reviewed some to draw up.a map.
'3- Q. He mapped the locations of it?
. 4 A. That's right. The ones-that we could map.- .
5 'Q. As a result of his mapping, were any of these 6 old inspections deemed --~or inspection records, I am talking 7, about records, were any of these old inspection records 8 deemed or found to be satisfactory and. excluded from a back 9 fit?
10 A. Some,were.
11 Q. Who made the determination as to which records
~12 were to be accepted as satisfactory?
13 A. I believe Foote and Cummings were.
i 14 Q. Based on?
15 A. Based on the review. That they could get back to 16 it.
17 Q. How was -- how did they transmit this 18 information to Britton or any other inspectors for the back 19 fit as to which inspections were adequate, and which were 20 inadequate?
21 A. By their maps.
22 Q. Did they make entries on the map that indicated 23 inspections in a certain area were adequate?
24 A. Yes. [N 25 Q. Therefore, it did not have to be included in the i
TAYLOE ASSOCIATES
Harr/ Wi11icm3
~
39 1
I back' fit?-
2 -- A . Yes.
3 Q. And did the inspectors conducting the back fit, 4 did they have access and did they refer directly to'these, 5 maps?
6 A. They referred to the maps on the back fit.
7 Q. Were the inspectors permitted to use or'were
-8 they permitted access to these old inspection records for the -
9 back fit?
10 A. Yes. In the meeting.
r 11 Q. On these maps, whole areas that were represented 12 as being adequate documentation, they were'not to be back 13 fitted; is that correct?
14 A. That's right.
15 Q. I am asking you for your best estimate now, what 16 percentage of the old records were found to be inadequate so 17 that they had to be back fitted? If you had to guess , just 18 asking for a rough guess?
19 A. 98.
20 Q. Most of it had to be back fitted? ..
21 A. Yes.
. 22 Q. Was Mr. Britton primarily responsible for making b} '23 the maps or was it Foote and Cummings?
24 A. Af te r Foo te , Cummings had done theirs, then we 25 started up our IR program. And we were doing the back fit at TAYLOE ASSOCIATES
m ,
~
Harry wi. !am: 40 1- the time.
2- And Neil was making up his maps for.the back
~
-3 fitting to show what he had covered.
Then we started the 4 same process with it ongoing, and he gets the maps.
5 Q. Did Mr. Britton himself make any representation 6 indicating which documents were adequate and which were 7 inadequate?
8 A.- Yes.
9 Q. Was this reflected on the maps?
10 A. Yes.
-11 Q. I presume those that were found to be 12 satisfactory were not to be back fitted?
13 A. Yes.
14 Q. I have seen those maps. And a large -- tell me 15 if I am wrong, a large area or a large percentage of the 16 spaces on those maps indicated documents were adequate. And 17 I find that in conflict with your saying 98 percent were 18 inadequate?
19 A. I am just guessing. You say it was high?
20 Q. Those that hadn't already been back fitted? I 21 just think I saw one of those maps.
22 A. You might have.seen the ongoing map 23 Q. That may be that is it.
- 24 A. The back fit map, we back -fitted that whole line .
25' of plates. ~
l TAYLOE ASSOCIATES
n -
Harry Williems I I
I li Q. Did you back fit any of the.other things? Like 2 cable tray supports?-
3 A. Yes.
4- Q. Was that completely back fitted?
5 A. Yes.
9 6 Q. How about miscellaneous steel?
7 A. Miscellaneous steel._ Hangers.-
8 'Q. But~in individual inspections, in those areas, 9 was there some division that'were acceptable based on the 10 earlier document review?
?
-11 A. Some.
12 Q. So it just was --
13 A. Spotty..
14 Q. It varied from inspection to inspection then?
15 A. Yes. .
16 Q. Do you still, as you recollect, you think the 98 17 percent is still an accurate figure?
18 A. About. I just threw that out.
19 Q. Did Foote or Cummings ever characterize to you 20 the state or the condition that they found those records in?..
21 As to whether they were adequate or quality 22 documents? Did they ever express an opinion to you?
23 A. Yes.
24 Q. What was that?
.25 A . Not good.
TAYLOE ASSOCIATES
e - - .
- Harry Williams. 42 1 Q. That the documents were not adequate as quality -
2 records? .
3 A. .Most of them. ,
\
~
4 Q. How about Mr. Britton, did-he ever indicate to 5 you his feelings as to whether these things were -- would 6 stand up a; quality documents, these same inspect. ion records?
7 A. Basically.
.8 . Q. Did he say .they would or would not, to you?
9 A. Wouldn't.
10 Q. Would not. Do you know if the QA Department, 11 the QA at Comanche Peak, if it was their intention to use the
~
12 inspection records, or those that they labeled as adequate? .
1 13 Do you know if it was their intention to do a complete back 14 fit or to accept as adequate documentation a portion of those 15 old inspection records?
16 A. I don't know.
17 Q. They never conveyed that to you?
18 A. No.
19 Q. While you indicated a massive back fit, was the 20 back fit intended to be a total back fit of all inspections
+
21 conducted to April '81, or was it going to be selectively
~
22 determined based on the adequacy of old documentation?
23 A. I think the intent of it was, it was going to be 24 a complete back fit with exception of what old documentation r 25 on the old check list that they could use.
TAYLOE ASSOCIATES
Hcrry Willicms . '47 E 1 Q. When you left-there, was that still the f
[
2 prevailing --
~
3- A. Still going on.
4 Q. --
the prevailing idea of what the intention was f
l 5 of the QA Department?
)
6 A. Yes.
7 Q. You say you were not involved in the document 8 review at all; is that correct? '
9 A. That's correct.
. 10 Q. Do you have any knowledge, any personal direct 11 knowledge that any additional entries were made on any of 12 these old records that any values or entries existing on the. t 13 records were changed? Or that xeroxed copies were made and 14 subs'ituted t into these records to up grade them or make them i i
15 adequate records?
l l
16 A. Not -- no. I 17 Q. Is it your understanding then that these people 18 like Cummings and Foote, Britton, were simply reviewing them 19 for adequacy, as opposed to upgrading them?
20 A. Yes, sir.
21 Q. I asked you a moment ago if you had any personal 22 knowledge. You said you didn't. -
23 llave you heard from any source at any time that 24 anybody had made additional entries on those records and used 25 white-out to change entries on them, or had xeroxed c.,opies of TAYLOE ASSOCIATES
w -
t Harry Williams 44 1 other records and made them a part of these individual 2- packages to make them adequate? !
l 3 A. No.
4 Q. Thereby falsifying the documents?
5 A .' No.
6 Q. You have no persor.al knowledge, nor any 7 secondhand knowledge, so to speak?
8 'A. No. . .
9 Q. Third-party comments? Never heard anything like 10 that?
11 A. No. Never heard anything about that.
12 Q. Do you believe that those records represent the t .
13 original inspections conducted by the inspectors during I 14 believe '77, '78, '79 and '80?
15 A. Yes.
16 Q. As far as you know?
17 A. As far a3 I know. Yes.
18 MR. GRIFFIN: Okay. I believe that's all for me, 19 Donald.
20 Go off the record. .
21 (Discussion off the record) 22 MR. GRIFFIN: Let me go back on.
~
23 BY MR. GRIFFIN:
24 Q. To conclude my portion of this interview, Mr.
25 Williams, have I or Mr. Driskill or anybody else involved in TAYLOE ASSOCIATES
.< _ lja ry WillitmaI -45 l .. this proceeding threatened you in any manner or offered you 2 any-rewards in return for this statement?
3 A. No.
'4' Q. Have you giv.en this statement freely and 5 ' voluntarily?
6 A. Yes.
7 Q. Is there anything further that you would care to 8 add to your testimony while we are on the record?
. 9 A. No.
10 MR. GRIFFIN: Okay.
11 (Whereupon, the proceedings were concluded at
- i-12 3:35 p.m.)
13 s.
14 15 16 17 18 19 20 21 22 -
I l 23 l
24
? 25 TAYLOE ASSOCIATES
_. . 2. _. . _ _ . _ __ .- . _ _ _ . . . _ . - . _ _ _ , _ _ _ _ _ . _ _ . _ _ _ - _ _ _ .
1 l COMMONSEALTH OF VIHGINIA AT LARGE, to wit:
I i ,
2 l I, Marcia 8. Hall, a Notary Public in and for .
I the Commonwealth of Virginia at Large, cf qualification in i 4 the C i r e.u i t Court of the City of Norfolk, Virginia, do 5 certify that the foregoing statement of HARRY hILLIAMS was 6 taken and sworn to before me at the time and place 7 aforementioned, f/
8 Given under my hand this // day of November 9 1983.
10 11 .
12 13 Notary Public' '
14 15 16 17 18 19 20 21
- 22 -
i
- 23 24 i.
25 TAYLOE ASSOCIATES
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