ML20149E506
| ML20149E506 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/15/1987 |
| From: | Hansel J TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| Shared Package | |
| ML20149A806 | List: |
| References | |
| FOIA-88-37 OL, NUDOCS 8802110083 | |
| Download: ML20149E506 (55) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATOR?? COMMISSION I
2 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 3
4 IN THE MATTER OF:
)
)
5 TEXAS UTILITIES GENERATING
)
) DOCKET NOS. 50-445-OL 6
)
50-446-OL (COMANCHE PEAK STEAM
)
7 ELECTRIC STATION, UNITS 1
)
AND 2)
)
F074-08-T7 4)2_
10 ORAL DEPOSITION OF JOHN HANSEL 11 OCTOBER 15, 1987 VOLUME II 12 13
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14 15 16 ORAL DEPOSITION OF JOHN HANSEL, produced as a 17 witness at the instance of the Intervenor CASE, taken 18 in the above-styled and numbered cause on October 15, 19 1987, at 9:15 a.m., before James M.
Shaw, RPR, 1
1 20 Certified Shorthand Reporter and Notary Public in and 21 for the State of Texas, at the Law Offices of 22 Worsham, Forsythe, sampels & Wooldridge, 2001 Bryan l
23 Tower, Suite 3200, in the City of Dallas, County of I
24 Dallas, State of Texas, pursuant to the Federal Rules
! l
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j 25 of Civil Procedure.
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PDR FOIA WILLIAMSBO-37 PDR UNITED AMERICAN REPORTING SERVICES, INC.
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3 FOR THE NUCLEAR REGULATORY COMMISSION:
4 JANICE E.
MOORE Office of the Executive Legal Director 5
United States i
Nuclear Regulatory Commission l
6 Washington, D.C.
20555 7
FOR THE CITIZENS ASSOCIATION 8
FOR SOUND ENERGY:
9 BILLIE P.
GARDE Trial Lawyers For Public Justice 10 3424 North Marcos Lane Appleton, Wisconsin 54911 11 12 FOR TEXAS UTILITIES GENERATING COMPANY:
4 13 ROPES & GRAY 225 Franklin Street 14 Boston, MA 02110 BY: WILLIAM S.
EGGELING 15 ROPES & GRAY 16 1001 Twenty-Second Street, N.W.
Washington, D.C.
20037 17 BY: ROBERT J.
STILLMAN DAVID MARTLAND 18 i
i 19 WORSHAM, FORSYTHE, SAMPELS & WOOLDRIDGE l
2001 Bryan Tower, Suite 2500 20 Dallas, Texas 75201-2168 BY: ROBERT A.
WOOLDRIDGE 21 22 23 24 25 UNITED AMERICAN REPORTING SERVICES, INC.
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_J _OH _N __H A _N S E L,
2 the witness hereinbefore named, beinn first duly 3
cautioned and sworn to tell the truth, the whole 4
truth, and nothing but the truth, testified under 5
oath as follows:
6 FURTHER_ EXAMINATION 7
BY_MS._ GARDE:
8!
O.
Mr. Hansel, we are starting the second day 9l1 of your deposition.
I will try to.get you out of 10l, here as quickly as possible.
I have a couple of 11' areas of questions which touch on things that we 12 started yesterday, but didn't complete.
13' Let me first draw your attention to the 14 external source issues that we both were discussing 15 but not in detail.
The external source issues that 16' provide the source, if you will, of the allegations 17' that you investigated, you referred to a list in 18:
Rev.
4, I believe it was page 15, that gave a general 19 description of some of those and listed specifically 20 like the MAC report and the Lobbin report that.we 21 talked about yesterday.
In regard to the issues 22 raised by or through the Nuclear Regulatory 23 Commission, I have a couple of questions.
24 Do you understand what I mean when I say, 25 "by or through the Nuclear Regulatory Commission"?
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1 A.
Yes.
I 2
Q.
Okay.
As to the issues raised in SSER 7 3
through 11, when the CPRT looked at those documents, 4
did it accept the NRC's definition of the issue and 5
goal from that point in terms of writing an issue 6
specific action plan?
I 7
A.
We took the report as written from the j
i 8
NRC and accepted it.
In a number of cases where they I
i 9
had substantiated an issue as no problem, we still, 10 in the drafting of our ISAPs, pu rs ued and evaluated l
11 some of those issues.
l 12 Q.
Do you know where in the program plan it 13 identifies those it. sues that the NRC said were no 14 problem that you pursued anyway?
15 A.
It would not be in the program plan.
16 Q.
Okay.
How would I find that out?
17 A.
The I believe the program plan requires 18 us to develop a matrix of all our external source l
19 issues, and where they are being investigated.
I 20 Q.
Did you develop that matrix?
j i
21 A.
Yes.
22 Q.
Do you recall whether that matrix was 23 provided to the board as Appendix B in response to a 24 board order?
25 A.
That' matrix has I don't believe been UNITED AMERICAN REPORTING SERVICES.
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Q.
Did the CPRT review the transcripts of 2
interviews between employees and former employees of 3
the site and the TRT in which allegations were raised 4
to TRT members?
5 A.
Not in their totality.
I reviewed a few 6
of those.
7 Q.
Of the ones that you reviewed personally, 8
do you recall if they were transcripts that were 9
taken during the summer of 1984, or had they been 10 taken earlier than the summer of 1984 by the NRC?
i 11 A.
I don't recall.
12 Q.
Is it a correct understanding of your 13 testimony that, by and large, the CPRT took the 14 NRC's work and used that as a base in terms of those 15 source issues that come from the TRT?
16 MR. EGGELING:
Can I have that back?
[
17 (Record read back.
18 Q.
(BY MS. GARDE)
Do you want me to repeat 19 the question?
20 MR. EGGELING:
Yes, and let me list i
21 the four ambiguities that bother me.
The first, 22 "by and large," and "used that as a base" produce a 23 level of generality that I'm not sure helps much, 24 particularly when the question starts out with:
25 "Is it a correct understanding," which is necessarily l
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subjective.
2 And the last point, you have let this slip 3
into a couple of questions, but I think the witness 4
and you have been understanding one another.
You 5
phrased them, "Did the CPRT," "Did the CPRT" where, 6
in fact, of course, this witness can answer what he 7l knows and particularly what he knows about those 8
ISAPs in which he was in charge of, not necessarily 9
what the CPRT as a collective effort did.
10 MS. GARDE:
All right.
I understand i
11 his testimony to mean that.
12 MR. EGGELING:
That is what I figured, 13 but I just thought if you are going to rephrase the 14 question, you ought to try to get all of those out.
15 Q.
(BY MS. GARDE)
Yesterday I thought I 16 understood your testimony on some things.
When I 17 went back, it was obvious that I did not, so I want 18' to make sure that I understand your testimony 19 correctly.
20 What I am trying to determine is if the 21 testimony you have just given regarding what extent 22 you looked at the T RT ' s reports as the SSER's and to 23 what extent you went back and looked at the raw data.
24 My understanding !. s that you, except in a few 25 instances that you have described, you used the SSERs UNITED AMERTPAN OPDoomT"o cen"'"""
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as the source documents; is that correct?
2 A.
Yes.
I would say in all instances.
3 Q.
Okay.
In all instances, you used the TRT.
4
- okay, on what occasions, then, did you go back and 5
look at the raw data?
6 A.
In those cases where the ISAP requirements 7
or instructions led us to go back and look at those, 8
and it va r i es from ISAP to ISAP.
9 Q.
All right.
So I will be able to tell in 10 the ISAPs or the results reports if you went back and 11 looked at the raw data?
12 A.
And the working file, yes.
13 Q.
Now, following the issuance of the SSERs, 14 the NRC has continued to write inspection reports 15 based on their own work and based on allegations that 16 they have received.
For the NRC reports, inspection 17 reports subsequent to the TRT, has the CPRT reviewed I
18 those and looked for new issues?
19 A.
Yes.
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20 Q.
Have they found any new issues?
21 A.
Yes.
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22 Q.
Are the new issues identified through NRC 23 inspection reports subsequent to the SSERs, included 24 in the work of the CPRT7 25 A.
Yes.
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Q.
Okay.
When the collective evaluation 2
reports and the collective significance reports come 3
out, will they also address those issues?
4 A.
You will find those addressed in 5
individual ISAP results reports.
And in VII.c.,
I 6
don't know that you will see them flagged out again 7
in the collective evaluation report.
8 Q.
Are you familiar with the issues raised by 9
a Department of Labor complainant, Joe Macktal?
j 10 A.
No.
11' O.
Do you have any knowledge of allegations 12 raised by that individual being factored into the 13 CPRT?
14 A.
No.
1 ISI Q.
Are you familiar with a Department of 16 Labor complainant, Mr. Hasan?
17 A.
No.
18 Q.
Are you aware of whether or not the 19 allegations raised by Mr. Hasan were factored into 20 the CPRT?
21 A.
No.
22 Q.
Are you familiar with the NRC's report of 23 the offico of inspector and auditor 86107 24 A.
Not by just that number.
25 Q.
Okay.
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the office of inspector and auditor prepared by 2
George Halley and released publicly in December of 3
19867 4
A-No.
5 Q.
Was any review done by the CPRT into any 6
OIA report released by the NRC since December of 1986?
7 A.
I don't know.
8 Q.
You didn't do any?
9 A.
No.
Well, let me clarify that.
I'm 10 not I don't recall any right now.
Unless I had a 11 specific reference to it, I couldn't give you a i
12 "yes" or a "no."
13 Q.
Are you personally faniliar with the i
14 allegations raised by Shannon Phillips regarding 15 incomplete inspection reports?
16 A.
Only in general terms.
17 Q.
Okay.
To the extent that you are familiar 18 with them, have you included those concerns in any of 19 the work of the CPRT?
20 A.
No.
21 Q.
Are you familiar with the site's safe team 22 program?
23 A.
Yes.
24 Q.
Have you, in the work that you have done 25 with the CPRT, reviewed the safe team files UNITED AMERICAN REPORTING SERVICES, INC.
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and Well, let me stop at that point.
2 Have you reviewed the safe team files?
3
-A.
Personally?
4 Q.
Yes.
5 A.
No.
6 Q.
Has the CPRT effort that you are involved 7
with reviewed the safe team files?
Bl A.
Yes.
9 O.
And have the safe team files produced 10!
other issues other than originally included in the 11!
CPRT?
12' A.
I believe so, but I'm not positive.
13l Q.
Mr. Hansel, are you familiar with the term i
14!
"inaccessible" or "hidden" attribute?
15 A.
Familiar with the term "inaccessible."
16 Q.
And what does that term mean in terms of 17 the CPRT program plan?
18 A.
It is defined in ISAP VII.c.
19 I Q.
As what?
Did you bring the ISAP with you 20 today?
21 A.
No, but I think it is also in the program j
t 22 plan.
23 (Witness perusing document.
24 MS. GARDE:
Off the record.
25 (Off-the-record discussion.
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A.
It is not defined specifically in the 2
program plan.
3 O.
C o r ', d you define what you understand it to 4
mean?
5 A.
I would prefer not to.
I would again 6
refer you to ISAP VII.c.
7 O.
Okay.
Is the reason that you would prefer!
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8 not to because it is a very specific definition and i
9 you are afraid you can't recite it?
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10 A.
Yes.
I ll i O..
With that clarification, I would like to 12 understand how the hidden hidden, inaccessible 13 attribute fits into your work.
And I will stipulate I
14 that the definition of the CPRT is what the program 15 plan says it is.
Am I correct in assuming that is 16 the working definition that you have followed?
l 17 A.
Yes.
18 O.
All right.
In regards to inaccessible 19 attributes, is the collective evaluation process 20 discussing implications of your findings on hidden 21 attributes, inaccessible attributes?
22 A.
I don't know.
23 O.
Okay.
Why, why don't you know?
24 A.
It is discussed in ISAP's VII series 25 results report, but I'm not certain if it is repeated UNITED AMERICAN REPORTING SERVICES, INC.
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if it will be repeated in the collective evaluation 2
report.
3 Q.
But V11.c.'s result report will include 4
that?
5 A.
Yes.
61 Q.
For each of the populations?
7, A.
I believe so.
I 8l Q.
We spent some time yesterday talking about 9;
the safety significance evaluation group's work.
Do l
10, you recall that testimony?
11' A.
Yes.
12; Q.
Okay.
I would like to ask you some 13'j questions regarding how the SSEG group does its work.
14, And I have with me and we can mark, but it is my only 1
15-copy at this time, Revision 6 of CPP-016, which is 16!
safety significance evaluations of deviation reports.
17 And I believe the change sheet the only change 18l sheet that is subsequent to that on CPP-016.
If I'm i
If this is wrong, that hasn't come yet.
I 19, wrong 20 will stand corrected, but let me mark them.
21 (Hansel Exhibits 10 and 11 22 (marked for identification.
23 Q.
Mr. Hansel, I'm going to show you what has 24 been marked as 10 and 11, and draw your attention to 25 pages 5 and 6.
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MR. EGGELING:
Thank you.
2 (Witness perusing document.
3 Q.
(BY HS. GARDE)
Is that your signature on 4
the first page of Hansel 107 5
A.
Yes.
I 6
Q.
What does your signature mean on that page?;
I 7
A.
As indicated, that I approved it.
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i 8
Q.
All right.
Your counsel has handed you l
9 Exhibit 11.
Is that your signature on Exhibit 117 10 A.
Yes.
11 0.
Okay.
Is that a subsequent change to 12 Exhibit 10?
13 A.
Yes.
14 Q.
Are there any other changes to CPP-016 i
15 that you are aware of?
{
16 (Witness perusing document, j
17 A.
Not that I'm aware of.
18 Q.
All right.
I draw your attention to page 19 5 of Revision 6,
Section 5.2, safety significance 20 evaluation.
Do you see that?
21 A.
Yes.
22 Q.
Okay.
Because it is my only copy, I'm 23 going to have to stand up to ask you my questions.
24 If that bothers you, let me know.
25 Drawing your attention t'o 5.2.2 regarding UNITED AMERICAN REPORTING SERVICES, INC.
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what the discipline engineers do in their evaluation 2
of the performed conditions, there are six lettered 3
paragraphs that follow 5.2.2.
Do you see that?
4 A.
Yes.
5 Q.
Okay.
Is that process described in those 6
numbered I'm sorry, lettered paragraphs the 7
process that is followed in conducting the safety 8
significance evaluation?
I 9
(Witness perusing document.
10 A.
Yes.
I 11 I Q.
okay.
In small lettered paragraph (a), it l
12i refers to a discipline engineer becoming familiar 13i with the physical arrangement of the referenced item.
14 Do you see that paragraph?
15, A.
Yes.
16' O.
Okay.
How does he do that?
i 17' A.
Well, that very paragraph says, "This may 18 be accomplished by reviewing the Verification Package, 19 project documents, and/or performing a plant 20 inspection."
i 21 Q.
Is that an informal nonproceduralized 22 action; does the engineer himself decide what area to 23 become familiar with?
24 A.
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physical arrangement of where that component is 2
installed.
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okay.
4 A.
Whatever it may be.
5 Q.
Okay.
What I'm asking you:
-Is there 6
another procedure that the discipline engineer 7
follows when he puts together those things that he is 8
going to becoma familiar with?
Is there a numbered 9
procedure?
10 A.
No.
11 Q.
okay.
So each discipline engineer is 12 using his own judgment in terms of what things-to do 13 or things to look at to become familiar.with physical 14 arrangement; is that correct?
15 A.
That is correct.
16 Q.
All right.
Ilow many different discipline 17 engineers are there?
18 A.
I don't know how many there are on board 19 today.
20 Q.
Okay.
At the height of the work that you 21 were doing, how many were there?
22 A.
Approximately 30.
t 23 Q.
Now, are there any written instructions to 24 the di sci pli ne engineer regard'ing how he is to become 25 familiar with a physical arrangement?
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Just this procedure, plus instructions 2
from his lead engineer.
3 Q.
Okay.
And those are oral instructions?
4 A.
Yes.
5 O.
How many lead engineers are there that 6
were giving those instructions?
7!
A.
Four.
8j Q.
Okay.
Who were they?
I 9j A.
I would have to go back and check.
They 10l varied from time to time, and I would have to know i
- lit, upon what date, who you were -- you know, who you 12 wanted to know.
I 13!
Q.
Was there one lead engineer for each of l
14: the four areast civil, mechanical, electrical 15 A.
Yes.
16 l' and structural?
O.
17.
All right.
In item (b), it talks about 18 the intended safety function of the referenced item 1 96 is determined.
How was that done?
20 A.
By reviewing drawings and specifications.
21 Q.
All right.
Was there a procedure which 22 set forth what documents that conclusion should have 23 been drawn from?
24 A.
No.
25 Q.
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that information from the lead engineer?
2 A.
The discipline en gi n tr e r did the job, and 3
then reviewed it with the lead engineer.
4 Q.
Okay.
And there was no procedure setting 5
forth how to do that?
6 A.
No.
7 Q.
Just oral instructions?
8 A.
Yes.
9 Q.
Okay.
1 10 A.
It is not a very complicated process.
t i
11 Q.
All right.
In determining the safety 12 function for each of the physical arrangements or 13 components that were being reviewed, did that go 14 through Texas Utilities' design engineers?
15 A.
No.
16 Q.
So thi s was within ERC?
17 A.
Yes.
18 Q.
Okay.
Was it checked against the current 19 design of the plant?
20 A.
No.
21 Q.
The then current design of the plant?
j 22 MS. GARDE:
He already answered l
i 23 "no."
l 24 MR. EGGELING:
Do you understand what 25 she means?
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(Witness perusing document.
2 Q.
(BY MS. GARDE)
Have you reviewed that 3
section?
4 A.
Yes.
5 Q.
Making reference to the sentence with the 6
change bar, whi ch says, "No conclusion shall be made 7
on the ability of the a2fected item to performance i
8 its intended safety-related function without taking 9
into account the referenced corrective acti on. "
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10 Is that referring to corrective action 11 that has been Strike that.
i 12 Let me just ask yout What corrective 13 action does that refer to?
I think I understand, but 14 I don't want to say that.
15 A.
It we are aware of corrective actions that 16 the project is already taking that would correct that 17 type of deviation, then we would do not hi ng further
-18 on it in terms of -- of doing an evaluation.
The 19 majority of those kinds of corrective actions have 20 been as a result of CPRT efforts.
21 Q.
All right.
That answer doesn't completely 22 answer my question to my ability to understand it.
23 not because it wasn't a complete answer.
24 The corrective acti'on process, in which we 25 discussed yesterday that the project engages in, is UNITED AMERICAN REPORTING SERVICES, INC.
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not something that you have oversight ont is that 2
correct?
3 A.
Let me straighten it out.
For eve r y 4
deviation that we write, there is an NCR written by 5
the project.
They can go fix that i ndi vi dua l piece 6
of equipment or item.
Coming out of our program, we 7
-also have findings that result in corrective 8l larger, more comprehensive corrective action programs.
9!
Some of those require reinspections, some require 10 rework.
They will all be identified in the records 11 that you would receive.
This paragraph is referring I
12 to the latter.
I 13I Q.
To the findings?
I 14l A.
Where it may have corrective action 15 programs in response to our findings, for those kinds 16 of conditions identified in Appendix E.
17 Q.
All right.
But the corrective actions i
18.
that this refers to are current actions?
i 19 A.
Correct.
20 Q.
All right.
The safety significance 21' evaluation group reached historical snapshot in time 22 conclusions; correct?
23 A.
Yes.
24 Q.
Okay.
Between And you used a 1984 25 hypothetical.
Between 1984 and the corrective UNITED AMERICAN REPORTING SERVICES.
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actions that resulted from your findings, a lot has 2
happened on the site, hasn't it?
3 A.
Yes.
4 Q.
Okay.
In writing up your reports on the 5
safety significance evaluation of each de viation, do 6
you jump from the past conclusion into the present 7
corrective action?
8 A.
The present corrective action in most 9
cases was a result of our findings based on earlier 10 inspections, and those corrective actions are both 11; retrospective and prospective.
1 i
12 Q.
When the safety significance evaluation 13 group does its work, it goes through the screen set I
l 14 up in Appendix E, and it reaches a conclusion on a 15 specific deviation that is ca ps uli ze d in time by and 16 bounded by what were the procedures and the 17 requirements and licensing commitments at that timer 18 is that correct?
19 A.
Correct.
20 Q.
All right.
In sose cases, those 21 conclusions that using those documents vindicate r
4 22 the action done in 1984; isn't that correct?
23 A.
What do you mean?
You don't understand 24 what I'm saying.
What do you mean by "vi ndi ca t e"?
i 25 Q.
In 1984, certain procedures were written s
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that were supposed to have been followed?
2 A.
Yes.
3 Q.
Okay.
You do the safety significance 4
evaluation 5
A.
Yes.
6 Q.
using those documents?
7 A.
Yes.
8 Q.
And you reached the conclusion that it was 9
all done by the numbers in 19847 l
10.
MR. EGGELING:
What was?
11 MS. GARDE:
Whatever he is reviewing, 12' whatever deviation he is looking at.
13 MR. EGGELING:
How can he have gotten 14 there?
You don't attribute the safety significance 15 evaluation until you find something wrong.
You have 16 lost me.
17 MS. GARDE:
I'm starting with 18 deviations.
19 MR. EGGELING:
Then I don't Do you 20 understand it?
21 THE WITNESS:
Well, it is a bit 22 confusing.
She started with the premise that we had 23 deviation, and then we are evaluati ng that deviation 24 against the procedures, the drawings, the 25 specifications UNITED AMERICAN REPORTING SERVICES. INC.
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MS. GARDE:
Right.
'l 2
THE WITNESS:
in effect at that 3
date.
4 MS. GARDE:
Right.
5 MR. EGGELING:
For its safety 6
signifance?
7 THE WITNESS:
For its safety i
8 significance.
i I
9 MR. EGGELING:
That is where I have ai 4
l 10 disconnection with how it has something to do with 11 whether or not all the procedures were followed, 12 because then you go back into another loop.
You are 13 testing it for its safety significance, or for 14 whether the procedures are followed.
15 MS. GARDE:
Okay.
Let me take that 16 out that loop out.
17 Q.
(BY MS. GARDE)
You are in the safety 18 significance evaluation?
19 A.
Yes.
20 Q.
All right.
You are using the then current 21 criteria to reach your conclusions 22 A.
Yes.
23 Q.
on whether it was saf ety si gni ficant?
24 A.
Yes.
25 O.
All right.
In order to be classified I
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1 using the Appendix E criteria, is there any look at 2
the current efforts of the site regarding that 3
component or function?
Is it all historical?
4 MR. EGGELING:
Do you understand what 5
she means by "classified"?
Make sure you include it 6
in your answer.
7 A.
I think we got two cases again.
If we 8,
were evaluating that condition under the earlier 9'
paragraphs referenced, which were 5.2.2, we would use 10 the information in effect at the time that the lli hardware was accepted by TU Electric and using the l
12' documents that were in effect on that date.
13 Pa r a g r a ph 5.5.2 says that if we 14 have if we have knowledge of corrective action 15 programs that the project already has in place that I
16 would detect and fix that same type of deviating 17 condition, then we can merely stop, not perform the 18 safety significance evaluation, but reference that TU 19 corrective action program.
20 Q.
(BY MS. GARDE)
All right.
I understand 21 that to mean that there is a way to avoid safety 22 significance evaluations, even kicking in, if there 23 is already cor r ect i ve action going ont is that 24 correct?
'25 A.
If you mean by "ki cki ng in,"
that we would
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not do it, we would not go through the process of 2
performing the evaluation, but it would still be 3
counted as a as a deficiency in accordance with 4
Appendix E.
5 Q.
All right.
How does that happen?
6 A.
In the documentation on that particular 7
deviation, as we do the evaluation.
i 8
Q.
So the documentation exists, but its 9
resciution references the corrective action?
l t
10 A.
Yes.
That is in the second paragraph l
11 under 5.5.2.
12 Q.
So when the final report that you prepare 13 on the collective evaluation of all of the deviations ;
i 14 and deficiencies and findings is prepared, it is 15 going to incorporate those things that did not go 16 through the safety significance evaluation group?
17 A.
It will incorporate all findings, and 18 these still go through the safety significance 19 evaluation group.
The data will be included in the 20 VII.c. results report and possibly repeated again in 21 collective evaluation, but I'm not sure.
This 22 procedure requires the safety significance evaluation 23 group to make those determinations in accordance with 24 the second paragraph of 5. 2. 5.'2, and it is documented 25 and in the files.
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Q.
All right.
And so those files will be 2
made available and those items that you have just 3
discussed that 5.2.5.2 apply to are going to be 4
identified?
5 A.
Yes.
l 6
0.
All right.
Now, the change to this
?
Exhibit 10 goes to Section 5.2.4.
The change is 8
recorded in Hansel 11.
As I read it, it essentially 9
is the addition of some words regarding constructions 1 0 '. is that correct?
11 MR. EGGELING:
Do you want him to 12 read what the words are?
I don't understand the 13] point.
14 MS. GARDE:
I want to know what the 15' significance of the change is and what change it 16l resulted in.
i 17 !
MR. EGGELING:
I still don't I
i 18; understand.
We have a document in front of us for i
~
19' the record. Exhibit 11, which consists of the 20 insertion of a series of between five and seven 21 common English words in the sentences.
I don't 22 understand what you want the witness to do with that 1
23 fact.
24 MS. GARDE:
I want him to become 25 familiar with what the change is that was made to the l
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program as a result of that change to CPP-016.
[
2 MR. EGGELING:
You want him to read 3
the sentence with the amendment; correct?
4 MS. GARDE:
That is what he is doing.
5 MR. EGGELING:
I don't know what he 6
is doing.
I'm asking you what you want him to do.
7 MS. GARDE:
He is doing what I want 8
him to do.
He is reading the' changes.
9 THE WITNESS:
Shall I proceed?
10 MR. EGGELING:
Read the steps with 11 the change in it and then stop.
Wait and find out
! t 12 what she wants you to do.
13 (Witness per usi ng document.
14 A.
All right.
I have finished reading it.
t 4
15 Q.
(BY MS. GARDE)
All right.
What effect 16 did the changes as contained in Exhibit 11 have on 17 the safety significance e va l ua t i on program itself?
18 A.
- None, j
j 19 Q.
It just clarified the words about and 20 said -- Strike that.
4 21 It just described more accurately what you 22 were already doing?
4 23 A.
Yes.
4 i
i 24 Q.
Gkay.
Thank you.
25 Where in the CPRT program is there a i
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I determination made on whether a QA/QC commitment was 2
not met in the historical implementation of the 3
QA/QC program?
4 A.
What do you mean by "commitment"?
5 Q.
If there was a QA/QC requirement for an 6
inspection, hypothetically, an inspection was 7
supposed to be conducted which had certain hold 8
points.
Those hold points were not followed.
At 9
where in the program plan do you identify where 10 original commitments were not met?
11!
MR. EGGELING:
Program plan?
e I
i 12li MS. GARDE:
In the whole CPRT program l 13! plan, wherever it may exist.
14 MR. EGGELING:
But you are asking thej i
15, question about a result, aren't you?
16 MS. GARDE:
Well, it may be in the i
17 results report, I don't know.
That is what I want to f 18 know.
19 MR. EGGELING:
What is it that you 20 are asking about the program plan as opposed to the 21 output the results report?
22 MS. GARDE:
No, I think he 23 understands what my question is, but I will restate 24 it.
25 Q.
(BY'MS. GARDE)
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program plan provides for that determination to take 2
place.
Do you understand my question?
3 As-Not really.
4 Q.
Okay.
There was original commitments, 5
FSAR commitments, licensing commitments, QA/QC 6
requirements, procedures, specific quality control 1
i 7
checklist procedures that should have been followed i
8 that the project was committed to following; is that i
9 correct?
I 10l A.
Yes.
l 11 Q.
Okay.
Does the CPRT intend to reach a 12 conclusion on whether those commitments were followed '
13 in each and every actual inspection that you 14 performed?
It is a "yes" or "no" question.
15 A.
I can answer it.
Any time that we found a l
16 deviation from a procedure requirement in any of our 17 inspections or reviews, it is documented on a 18 deviation report.
19 Q.
And then we start the path that we have 20 been discussing regarding what happens to deviations?
21 A.
Yes.
22 Q.
The review that produced the deviation 23 report is done in the context of the 32 populations:
24 is.that correct?
4 25 A.
Also all the other ISAPs.
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Q.
Okay.
For purposes of these questions, 2
let me just limit it to the quality of construction 3
program and the 32 populations.
Okay.
Does that 4
change your previous answer?
5 A.
Would you restate it?
6 Q.
Just looking at the quality construction 7
in the VII.c. program and reviewing the 32 8
populations, is your answer the same as to -- that 9
all identified deviations from comaitments will be 10j recorded on deviation forms?
11 A.
Yes, but I would like to work on the l
12; semantics.
13_
Q.
- Okay, t
14I A.
I wobid prefer to call it requirements, I
15' procedural requirements or i nspection requirements,
16 rather than commitments.
17 Q.
That is okay.
I understand what you are 18 saying.
Those are still recorded on deviations?
19 A.
Yes.
20 Q.
Okay.
And within those 32 populations, 21 which you are approaching through a sampling basis, 22 are the deviations from the original procedural 23 requirements the trigger to expand the population?
24 A.
No.
25 O.
Okay.
Is the trigger after another UNITED AMERICAN REPORTING SERVICES. INC.
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evaluation is done of the failure to meet the 2
procedural requirements?
3 A.
Yes.
4 Q.
Okay.
What is'that e va l ua t i on ?
5 A.
It is the evaluation in accordance with 6
Appendix E.
7 Q.
Okay.
That is the safety significance 8
evaluation?
9 A.
Yes, and trend analysis.
10 Q.
Okay.
The trend analysis that you just i
11 referred to, is it population specific?
j 12 A.
Yes.
13 Q.
Does the trend analysis go beyond any of I
i 14 the populations at any point?
15 A.
Yes.
16 Q.
Is that at the end of the process?
}
17 A.
I don't know about what you saan by "at 18 the end of the process."
19 Q.
Okay.
Triggering an expansion of the 20 population si te is based on a trend analysis within 21 each population of the identified deviations from 22 procedural requirements; is that correct?
23 A.
Yes.
l 24 Q.
All right.
And whe're there is a root 25 cause or potential root cause identified as a result i
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of a trend in another population, at what point in 2
the process is that evaluated for each i
3 population?
4 A.
When we tour the generic implication.
5 Q.
When is that in the process?
6 A.
At the point in time we think we have the 7i root cause identified.
8 Q.
Has that been completed or is it largely 9
completed?
10l A.
Largely completed.
lif Q.
Is there any evaluation done between the 1
12 identification of the initial deviation to meet a 13!
procedural requirement and the safety significance 14' e va l ua t i on regarding individual deviations 15 identified?
16' MR. EGGELING:
Could I hear that back?
17 I
( Re cord cead back.
18 MR. EGGELING:
Do you understand that?;
j 19 THE WITNESS:
Yes.
20 A.
Yes.
21 Q.
(BY MS. GARDE)
What is that?
22 A.
To assure ourselves that the deviating 23 condition as identified by the inspector is a valid 24 condition.
25 Q.
Who performs that validation?
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A.
The engineer. responsible for the 2
population.
3 Q.
Is that an ERC employee or a site employee?-
4 A.
ERC or a subcontractor.
5 Q.
On what form is that evaluation recorded?
i 6
A.
It is done on the deviation report.
I 7
Q.
Is that the blank that is for a reviewer?
i 8
A.
Yes.
It is at the very bottom of the f orm.i 9
Q.
Okay.
If a failure to meet a procedural l
10 requirement is not con si d ered safety significant 11 using the Appendix B criteria, is it considered in 12 terms of expanding the scope in that population?
13 A.
First off, it is Appendix E.
I 14 Q.
What did I say?
15 A.
"B".
16 Q.
Oh, I'm sorry.
l' A.
And as we discussed yesterday, they are 18 all considered for trending analysis and then to 19 determine if they fit the screen in Appendix E.
20 Q.
Were any potential root causes considered 21 other than those that came up through the inspection 22 process?
23 A.
I guess I don't understand your question.
24 Q.
Okay.
Let me Let me ask it another way.
25 You said yesterday that you reviewed the UNITED AMERICAN REPORTING SERVICES. INC.
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information provided to you by the attorneys 2
regarding the harassment and intimidation issue.
Do 3
you recall that testimony?
4 A.
Yes.
5 Q.
Okay.
Did you consider the harassment and 6
intimidation allegations as a potential root cause 7,
without regard to deviations identified?
8 A.
No.
i 9;
Q.
Okay.
There was an allegation in the TRT 10I report that dealt with quality control inspector 11l ce r t i f i ca t i ons.
We talked about that a little 12 yesterday'.
Do you recall that?
13!
A.
Yes.
I 14 !
Q.
Did you look at that issue as potentially 15 affecting all areas of quality control inspections at 16 the plant?
17 A.
Only in the context of the requirements of 18 ISAP I. d.1.
19 Q.
Does the CPRT program plan have any I
20 definition of a root cause that would describe the 21 types of root ca u s es that you are looking for?
22 A.
No.
i 23 Q.
Does the CPRT progran plan intend to make L
24 a conclusion about whether harassment and 25 intimidati on of quali ty cont rol inspectors was a root j
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cause?
i 2
MR. EGGELING:
Of?
3 MS. GARDE:
Of deviations?
4 A.
It will be the subject of harassment, and 5
intimidation will be addressed.
6 Q.
(BY MS. GARDE)
Where?
7 A.
In the VII.c. results report.
8 Q.
There is no ISAP that I'm familiar with I
i 9
that sets forth the work that the CPRT is doing to j
10 evaluate the harassment and the intimidation issue.
11 Did I miss something?
12 A.
No.
13 Q.
Okay.
Would you please explain what the 14 CPRT is going to do or is doing about the harassment 15; and i nt i mi da t i on issue?
I 16 A.
I believe that that is addressed in the 17 program plan.
18 Q.
Okay.
I would like to take just a short l
19 break and let you find where that is.
20 MR. EGGELING:
How much longer are i
21 you going to go with him?
22 MS. GARDE:
I'm just about done.
23 MR. EGGELING:
Ten minutes?
l 24 MS. GARDE:
Well, I don't know what 25 his answer is going to be.
I have ibout three more t
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little areas of qdis t i ons ; 10, 15 minutes.
2 ttR..EGGELING:
,o'k a y.
~
/
3 (R,ecess.
4 O.
(BY MS. GARDE)
Mr. Hansel, we had a short 5
break, and yod were going to loon where in the CPRT 6
it talks about the consideration of the harassment 7
and intimidation issues.
.Did you find that?
8 A.
Yes.
9l O.
Okay.
Where is that?
i 10I A.
Page 8 of 17 of Appendix B,
top paragraph.
i 11 O.
This is the Revision 4 you are looking at?
i 12, A.
Yes.
It is also addressed in the ISAP i
13' VII.c.
14 O.
Do you mind if I look at your copy?
I see 15, it is yellow lined.
Save me some time.
Okay.
I i
16 Under B,
subpart B,
potential occurrence 17 of harassment or intimidation of OC inspectors, do y
18l you have a specific CPP or QI that is providing you l
19' guidance as to how to make those evaluations?
20 A.
No.
l l
21 O.
Okay.
How are you doing it then?
22 A.
Through root cause analysis.
l 23 O.
So you are not doing any independent look 24 at the evidence of harassment and intimidation, you
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1 regarding independent incidents of harassments and i
2 intimidation of inspectors?
3 MR. EGGELING:
What do you mean by 4
"independent"?
5 MS. GARDE:
Separate incidents would 6
be a better word.
He is not looking at the 1
7 evidence Off the record.
8 (Off-the-record discussion.
9 Q.
(BY MS. GARDE)
I apologize.
Let me redo 10 the question.
Do your efforts regarding the I.
11 harassment and intimidation as a potential cause i
12 include reviewing all of the testimony i
I 13 apologize.
i I
14 (Off-the-record discussion.
i l
15 (Recess.
16 l' O.
(BY MS. GARDE)
Back on the record.
I 17 apologize for the interruption, Mr. Hansel.
We are 18 talking about the harassment and i nt i mi da t i on issue 19 you are looking at in the CPRT.
Is the CPRT going to 20 reach a determination on whether or not specific i
21 incidents of harassments and intimidation occurred?
22 A.
No.
23 Q.
What type of work 24 A.
I'm answering that'in the context of your 4
25 use of the word "specific."
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1 Q.
All right.
Are you going to reach a 2
determination on whether or not there was an 3
atmosphere of harassment and i nt i mi da t i on at the site?
4 A.
Only if we are led to that through root 5
cause analysis.
6 Q.
Is the root cause analysis that you are 7
performing the same as the process you have described i
8 through all your deposition and that is contained in 9
the CPRT?
It is not a different root cause analysis 10; you are talking about?
11j A.
No.
12 Q.
How would that root cause analysis that 13 you are performing lead you to conclusions regarding i
14i harassment and intimidation of inspectors?
15, A.
I cannot answer that specifically.
16 Q.
Oka y.
I want to understand in the process 17 how the process would lead to harassment and 18 intimidation.
19 (Off-the-record discussion 20l (between Mr. Eggeling and 21 (Mr. Hansel.
22 MS. GARDE:
I heard you saying words 23 to implementation.
This isn't an implementation 24 problem.
25 MR.
EGGELING:
I appreciate that.
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MS. GARDE:
It is a process question.
2 MR. EGGELING:
I think what she is 3
trying to get to is for you to redescribe the root 4
cause analysis.
And as far as I know, you have to 5
give the accurate answers.
If the root cause appears 6
to be harassment and intimidation, that is what you 7
are going to declare.
8 But I'm not sure I I know what you are 9
trying to do, and I think I know the answer, but 10 obviously I'm not the witness.
But I'm not sure 11 there is anyone to answer any more than what I just 12 said.
13 She only wants you to stay at the 14 conceptual intention through the analysis set forth 15 in the program.
16 Q.
(BY MS. GARDE)
Do you want me to phrase 17 it as a hypothetical?
18 A.
No.
Let me go ahead and address your r
19 question.
20 We take all the information that we can 21 gather concerning a particular deviating condition.
22 And then through an analysis, we determine what, if 23 anything, in the process was flawed that led to the 24 deviating condition, such as An example might be 25 an ambiguous procedure or an improper tool used or UNITED AMERI CAN REPORTING SERVICES.
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unqualified inspector or whatever.
2 And we will continue that process down 3
until we feel that we have identified all of the 4
primary causes and even contributing causes to where, 5
if those causes are corrected, then the problem would 6
be bounded.
If in that process we see anything at 7
all that leads us to harassment or i nt i mi da t i on, then B
we would try to pursue that to determine if we in 9
fact felt that it was a root cause.
10, Q.
When you say "if we see anything at all,"
i 11 are you looking at the testimony given in the 12 harassment and intimidation docket by witnesses who 13 were also the source of an external source issue 14 which is the subject of an ISAP?
15 A.
We are looking at the external source 16 issue.
17 Q.
All right.
That isn't the answer to my 18 question.
19 A.
We are not going to go beyond the external 20 source issue, unless we're led there in our 21 evaluation.
22 Q.
Okay.
How would you be led back to the 23 harassment and intimidation testimony of a source of 24 an external source issue, by what process?
25 A.
I doubt if we would be.
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Q.
All right.
Then how does the process that 2
you have described enable to you to reach conclusions 3
about whether or not harassment and i nt i mi da t i on was 4
a root cause?
5 A.
If we cannot find any other root causes, 6
it may have to be through interviews and reviewing j
7 other records.
Maybe reviewing other work done by I
8 the individuals involved, possibly by r e vi ewi n g other 9
work accomplished by the same draft in the same time 10 period.
i 11 Q.
But that would be only after you had 12 eliminated all other reasons?
13 A.
Yes.
J 14 O.
I want to give you a hypothetical.
If 15 there was an inspector who testified in the 16 harassment and intimidation proceedings about an 17 incident which he refused to sign off a document 18 because he believed it was wrong and was ordered to 19-do so, and in your work you conclude that the 20 procedure which dictated what was actually supposed i
21 to have been signed off was flawed, the procedure was 22 flawed, do you go beyond that conclusion to determine 23 or reach any determinations about harassment and 24 i nt i mi da t i on of the inspector?
25 A.
N o ". if we think that tho' flawed procedure l
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bounds the issue.
t 2
Q.
Would you even know that the testimony 3
hypothetically that I just gave you existed, based on 4
the documents that you are reviewing?
5 A.
Probably not.
6 Q.
Are all of your personal notes regarding 7
the work you have done on the CPRT going to be made i
8 j' available when your work is finished?
9l A.
I don't know what you mean by "personal i
10:
notes."
11:
O.
Are you keeping written records above and
'n 12; beyond the documentation that is contained in the l
13 CPRT working files?
5 14 A.
No.
15}
Q.
Do you have any personal logs, calendars?
I 16' A.
I have a calendar that keeps track of l
17 where I was on a certain day and how many hours I l
18 L worked, and that is about the extent of it.
19 Q.
Okay.
You don't have any other log that 20 discusses meetings or notes of meetings, handwritten 21 notes of discussions with Texas Utilities' officials?
22 A.
No.
23 Q.
Everything is on some document?
24 A.
Yes.
25 O.
Okay.
So when we review the working files i
UNITED AMERICAN REPORTING SERVICES.
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1 on any individual ISAP, i ncludi ng VII. c., we will 1
2 have access to all of the written materials that you 3
personally prepared regarding implementation; is that 4
correct?
5 A.
Yes.
6 Q.
Do you do any work on DSAPs?
i 7
A.
No.
8 0.
Do the quality control and quality 9
assurance implications of DSAP findings get factored 10 into your work?
I 11 A.
I don't understand your question.
12 O.
Okay.
When the design review is done 13 under the DSAPs are completed, will those reports 14 produce information which is then considered by you 15 in VII.c.?
16 A.
There is a requirement in the program plan 17 for the DSAP personnel.
As they find anything that 18 might have an impact on our inspections in the field, j
19 they are obligated to provide that information to us.
20 In terms of their end product, the answer is no.
i 21 Q.
Okay.
Is VII.c. going to reach l
22 conclusions on the adequacy of the quality assurance, 1
23 quality control program as to the design aspects of 24 the plant?
l 25 A.
No.
I probably need to cla'rify that.
1 9
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47 1
Q.
All right.
2 A.
Only where we found a root ca u s e that 3
indicated that the engineering requirements were 4
confucing or ambiguous.
5 Q.
And then you identified that as a root 6
cause?
7l A.
Yes.
8l!
Q.
But where on the design side a deviation 9l from an original procedural requirement is identified, 10 you don't process that; is that true?
11 A.
I'm not sure I understand your question.
I 1 21 MS. GARDE:
I will withdraw the I
13l question.
I 14 I didn't want to invade implementation, 15; but the latest date I heard, Counsel, on the release 16' of the collective evaluation report was October 1st, 17 1987.
Is this a new date?
18-MR. EGGELING:
I know of no specific 19 date.
20 MS. GARDE:
Okay.
I think I'm 21:
finished, Mr. Hansel.
I just want to review my notes.
22
( Pa u s e.
23 Q.
(BY MS. GARDE)
I have one other question.
24 In the spring of 1987, is it true that some of the 25 work being done by the CPRT was stopped by your UNITED AMERICAN REPORTING SERVTcPc Tuc
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organization as a result of the PCHVP program?
2 A.
Would you restate your question or read it 3
back, either one?
Y 4
Q.
Let me restate it.
In the spring of 1987, 5
I don't have a date specific, did some of the work by 6
the CPRT stop as a result of a memorandum or 7
agreement to the review team leaders -- Strike that.
8 Let me start again.
9 Were the review team leaders instructed in 10 the spring of '87 to stop any of the w or k that they 11 were doing by Texas Utilities?
f 12 A.
No.
13 Q.
You have no recollection of a document l
14 directing work to be stopped because of a superseding 15 program?
And I identified the PCHVP.
16 A.
No.
17 Q.
If a memorandum was sent to the review 18 team leaders asking them to stop work or shut down 19 some of their operations, would you know about that?
20 A.
Yes.
21 Q.
Do you review the progress reports that 22 the a ppli ca nt sends in to the licensing board on a 23 regular basis?
24 A.
Can you be more specific?
25 Q.
Do you read them after they are sent to UNITED AMERICAN REDoDTTun ecouvan-
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the licensing board?
2 A.
You said "progress reports"?
3 Q.
Progress reports sent by the applicant's 4
attorneys to the licensing board.
5 A.
I read most of that material.
If you are 6
talking about the periodic status reports, I don't 7
know if that is what they are ca ll e d, but status of 8
various ISAPs and Yes, I do, if that is what you 9,
are referring to.
l 10 Q.
Do you read them after they are sont to 11l the board or before?
12-A.
After.
13 Q.
One other question.
We went into the 14 history of your involvement with the CPRT, and my 15 notes say that your expansion effort came in February 16 of '85 beyond the first two ISAPs who were contacted 17 to work on; is that correct?
18 A.
Yes.
19 Q.
Prior to 1985, February 1985, there was 20 work done by the CPRT effort, wasn't there?
21 A.
Yes.
22 Q.
Is your program to some extent 23 relying -- your quality construction program relying 24 to any extent on work done prior to your involvement 25 with the quality of construction program?
l l
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50 1
A.
No.
2 Q.
So VII.c. is going to be completely based 3
on your work?
4 A.
Yes.
5 Q.
Where ISAPs are based on work that was 6
done prior to your expanded involvement, have you 7
retained that work?
8 A.
What do you mean, "retained"?
9 Q.
Do you rely 7n that work?
10 A.
No.
11 Q.
What do you rely on where you didn't i
12 conduct the original inspection?
13 A.
There were no inspections conducted prior l
14 to that time.
We basically started all over again on 1
15 ISAP I.d.1, I.d.2.
16 Q.
Okay.
You are familiar with the CASE 17 preliminary analysis of ISAP I.a.4?
18 A.
No.
19 Q.
Have you ever read the ISAP preliminary 20 analysis of ISAP I.a.4?
21 A.
I don't recall.
It is not an ISAP under 4
22 my control, so 23 Q.
All right.
I'm going to show you a 24 document.
I'm not going to mark it as an exhibit.
25 It is the pr elimi nar y analysi s of I*a.4 prepared by i
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CASE in May of last. year.
Have you ever seen that 2
document?
3 (Witness per usi ng document.
4 A.
No.
5 MS. GARDE:
I don't have any other 6
questions.
Thank you, Mr. Hansel, for your patience.
7 MR. EGGELING:
Thank you, Mr. Hansel.
8 (Deposition concluded at 11 :15 a.m.
9' 10 11 12 13 1 44 15.
16 17 18 19 20 21 22 23 24
. 25 i
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CORRECTIONS AND. SIGNATURE 2
P_AG_g__hlEg__ CORRECTION REASON F O R _ C_ H A,N_ G E_
3 SEE ATTACHED.
4 5
6 7
8 9
10 11 12 I, JOHN HANSEL, have read the foregoing
~
13 deposition and hereby affix my signature that same is 14 true and correct, except as noted herein.
15 16 Su44 l'
OHN HANSEL 17 v
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18 19 SUBSCRIBED AND SWORN to before me by the said 20 witness on this the d __
day of _dA c- @ 1987.
21 22
~
23 N TARE ~PUBd2C IN AND FOR THE STATE OF TEXAS 24 25 My commission expires: [ _ _ [_ d
[ O UNITED AMERICAN REPORTING SERVICES, INC.
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ERRATA SHEET
(
John Hansel volume II (October 15, 1987 Page (line)
Correction 4(5)
Correct "goal" to "go" 4(12), (15) and (17),
Amend "program plan" to 11(17) and (21-22), 12(2)
"Program Plan" and (14-15), 31(9), (11),
(12-13) and (20), 32(1),
37(19) and (23), 38(17) 4(21)
Clarify by changing "yes" to "ERC personnel" 12(24)
Correct to read "It is discussed in the ISAP VII.c Results Report"....
18(20)-22(5) and The questioning beginning 23(20)-26(24) at 18(18) was ambiguous
(
as to the meaning of r
"current." The consequent ambiguity in succeeding answers may be removed by replacing "No" on 18(20) with "ERC conducted physical inspections in accordrace with inspection packages / checklists that ERC prepared between mid-1985 and early 1986.
Inspection attributes were based on Codes, Standards, FSAR and engineering criteria applicable to CPSES at the time of release of the ERC inspection package, regardless of whether those criteria differed from those applicable to CPSES when the hardware originally was constructed and/or inspected."
Similarly, answers to the line of l
questioning at 20(18)-21(11) and 23(20)-26(24) should indicate W
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Page (line)
Correction
~
that in conducting the safety significance evaluation ERC referred to the inspection criteria contained in the ERC inspection packages, and those' inspection criteria in some cases differ from the criteria applicable to CPSES when the hardware originally was constructed and/or inspected.
20(22-23) should be amended from "at the' time that the hardware was accepted" to "at the time that the ERC inspection package was released."
Subsequent answers in this line of questioning are correct if it is understood that any time period referred to is the time at which the relevant ERC inspection package was released.
35(4) l Change to read "When we evaluate the root cause t
for generic implications" 36(4)
Clarify by changing to read "ERC or one of our subcontractors."
38(4)
Change to read "yes the subject of harassment and intimidation will be addressed" 44(9)
Change "draft" to "craft" ll l
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53 1
C E RT I F I CAT E 2
3 I,
James M. Shaw, RPR, Certified Shorthand 4
Reporter in and for the State of Texas, do hereby 5
certify that, pursuant to the agreement hereinbefore 6
set forth, there came before me on the 15th day of 7
- October, A.
D., 1987, at 9:15 o' clock a.m.,
at the 8j offices of Worsham, Forsythe, Sampels & Wooldridge, 9!
2001 Bryan Tower, Suite 3200, Dallas, Texas, the 10 following named person, to-wit:
JOHN HANSEL, who was 11 by me duly sworn to testify the truth and nothing but 12:
the truth of his knowledge touching and concerning 13 the matters in controversy in this ca u s e r and that he 14 was thereupon examined upon his oath and his 15l' examination reduced to writing under my s uper vi s i on :
16 that the deposition is a true record of the testimony 17 given by the w i t n e s s,, same to be sworn and subscribed 18 to before any notary public, pursuant to the 19 agreement of all parties.
20 21 I further certify that I am neither attorney or 22 counsel for, nor related to or employed by, any of 23 the parties to the action in which this deposition is 24 taken, and further that I am not a relative or 25 employee of an attorney or counsel employed by the UNITED AMERICAN REPORTING SERVic"'
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y, 54-1 parties hereto, or financially interested in the 2
action.
l i
3 4
In witness whereof, I have hereunto set my hand 5
and affixed my seal this 26th day of October, A.D.,
6 1987 7
8 h
9
_ ___1 om kJ_ _ _ _ _ _ _ _ _ _ _ _ __ _ _
JAMES M.
13 Decea 2: 31, 1988 i
CSR Nv.
1694 14' i
I 15i 16 17
+
18 19 20 21 22 23 24 25 UNITED AMERICAN REPORTING S F.R V 1 e r c '""
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