ML20149E530
| ML20149E530 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/15/1987 |
| From: | Beck J TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| Shared Package | |
| ML20149A806 | List: |
| References | |
| FOIA-88-37 OL, NUDOCS 8802110118 | |
| Download: ML20149E530 (58) | |
Text
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- 1
- 1 DNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 2 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 3
4 IN THE MATTER OF: )
)
5 TEXAS UTILITIES GENERATING )
COMPANY, ET AL. ) DOCFET NOS. 50-445-OL 6 ) 50-446-OL (COMANCHE PEAK STEAM )
7 ELECTRIC STATION, UNITS 1 )
AND 2) )
10 **************************
ORAL DEPOSITION OF 11 JOHN W. BECK OCTOBER 15, 1987 12 **************************
13 14 15 16 ORAL DEPOSITION OF JOHN W. BECK, 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 4:00 p.m., before James M. Shaw, RPR, 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 23 Tower, Suite 3200, in the City of Dallas, County of f 24 Dallas, State of Texas, pursuant to the Federal Rules 25 of Civil Procedure.
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PDR FOIA WILLIAMGBO-37 PDR UNITsu nMERICAN 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 Nuclear Regulatory Commi ssion 6 Washington, D.C. 20555 7
FOR THE CITIZENS ASSOCIATION '
8 FOR SOUND ENERGY:
9 JUANITA ELLIS, PRESIDENT i JERRY ELLIS [
10 1426 South Polk l, Dallas, Texas 75224 ;
11 i
12 BILLIE P. GARDE 'l Trial Lawyers For Public Justice ,
13 3424 North Marcos Lane Appleton, Wisconsin 54911 1 14 '
l' 15 FOR TEXAS UTILITIES GENERATING COMPANY:
16 ROPES E GRAY !
225 Franklin Street I 17 Boston, MA 02110 BY: WILLIAd S. EGGELING 18 ROPES & GRAY 19 1001 Twenty-Second Street, N.W.
Washington, D.C. 20037 20 BY: ROBERT J. STILLMAN DAVID MA RTLAND !
21-22 WORSHAM, FORSYTHE. SAMPELS & WOOLDRIDGE 2001 Bryan Tower, Suite 2500 23 Dallas, Texas 75201-2168 BY: ROBERT A. WOOLDRIDGE
. 24 '
25 ;
UNITED AMERI CAN REPORTING SERVICES. INC.
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3
, 1 JOHN _W._ BECK, !
2 the witness hereinbefore named, being first duly F 3 cautioned and sworn to tell the truth, the whole i t
4 truth, and nothing but the truth, testified under 5 oath as follows:
6 EXAMINATION 7
_B_ Y __M_S _. __G A__R _D_E _:
8 Q. Mr. Beck, will you state your full name 1
9: for the record?
10l: A. John W. Beck.
11' (Beck Exhibits 1 and 2 l
12 (marked for i den t i f i ca t i on .
13 l Q. I'm going to show you what has been marked I !
14 l.
Beck Deposition Exhibits 1 and 2, which is a copy of 15 a subpoena and a notice of deposition i s s. ue d to you 16l in this case. I would like you to review them and d
17 tell me if you have ever seen them before? l
-I 18' (Witness perusing document.
19 A. Yes, I have seen it.
[
20 Q. Okay. Did you bring any documents with 21 you?
22 A. No, I didn't. !
23 Q. All right. Did your counsel ask you to :
24 bri ng any documents with you?
25 A. No. '
t 6
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1 Q. What is your current position at Texas 2 Utilities? ,
3 A. Vice-president, nuclear en gi nee r i ng .
4 Q. What are your duties?
5 A. -I ' m responsible for quality assurance, 6 reactor engineering, fuel, nuclear fuel, and i
7 licensing.
8 0. What are your duties in regard to the !
l 9 Comanche Peak response team program plant? j 10 A.
Chairman of the senior review team. i il Q. Prior to beginning employment at Texas 12 Utili ti es , what did you do?
13 A. I was a vi ce-pr e si dent with Terra !
14 Cor po:: a t i on . t 1
I 15' O. How long did you hold that job? f I
16 A. Four years. ,
1 17' O. During that time period that you were r
18 vi ce-pr e si de nt at Terra, did you have occasion to d
19 work on any re-inspecti on programs at nuclear power 20 plants? i
. t 21 A. I was associated with a Terra contract 22 with Consumers Power on the Midland plant. ;
23 0.
Did Terra have a contract with Diablo t l
24 l
Canyon? '
25 A. Yes.
i UNITED AMERICAN REPORTING SFWVTerc tue i
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1 Q.
Did you do any work on that 1 2
contract?
A. No. ;
3 Q.
Prior to your working at the Terra 4
Corporation, what did you do?
5 A.
I was executive vi ce -pr e s i de nt of Vermont 6 Yankee Nuclear power Corporation.
7; Q. How long did you have that title?
8 A.
i Slightly less than four years.
9; Q.
i Has your entire professional career been 10!
in the nuclear power field?
11!
A. Yes.
i 12' O.
When were you offered employment at Texas 13l Utili ti es?
! I' 14l A. April 1984.
15; Q.
. When was the first meeting that you had 16' l with Te xas Utiliti es ' officials regarding potential 17 employment at Texas Utilities?
18 A.
I believe it was in March of '84.
19 Q.
Did you come to Texas?
'20 MR. EGGELING: Is he here now?
21 A. The state?
22 Q.
t (BY MS. GARDE) Did you come to Texas for 23 the meeting in March of '847 !
24
- A.
25 I lived in Texas at that time. !
Q. Who did you meet with? '
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6 i 1 A. Mr. Spence. ;
2 Q. When was the first time that you vi si ted [
r 3 the Comanche Peak site? -
'i 4 A. To the best of my recollection, in 1981. l 5 -Q. In what connection?
6 A. I was a member of the operations review 7 committee for Comanche Peak.
8 Q. What was that committee?
9 A. What was that committee? t 10 Q. Yeah. What was the purpose of that ;
i 11 committee?
12 A. It was a committee that served in an l il 13 overview capacity for the operations department at 14 Comanche Peak. It is mandated by federal regulations i f 15 that such a committee exist.
16 Q. When did you begin your employment with 17 Texas Utilities? '
18 A. In May of 1984.
i 19 Q. Prior --
i 20 A. Excuse me. April 24th, 1984.
21 Q. Prior to your accepting employment after 22 you had been of f ered employment, did you r evi ew any !
, 23 documents sbout the Comanche Peak si t e?
l
.24 A. No.
- I
! 25 Q. After you accept ed employment --
i i
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7 1 strike that.
2 When you first went to work for Texas 3 Utilities, what was your title?
4 A. Assistant to the president or executive 5 assistant. I can't recall exactly.
6 Q. And that was to Michael Spence?
7i A. Yes. '
8 Q. When did you become a vice-president?
i ?
9- A. In May of 1985.
i 10' O. During the first several months of your 11' employment, from April 24th, 1984 through the summer 12 of 1984, did you have an occasion to review various I
13; documents about the Comanche Peak plant? i i
14! i A. Yes.
15 5 Q. Did you review the MAC report of 19787 16 A. No.
17 Q. Did you review the Lobbin report?
18 A. No.
19, Q. Did you read the Atomic Safety and 20 Licensing Board opinion of December 1983 regarding 21 the quality assurance for design?
22 A. I read it. I don't recall if I read it 23 during that time period or not.
. 24
- Q. Did you read the proposed findings of 25 CASE on the Walsh Doyle allegations?
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1 A. I have read tham. 1. d o n !. t remember 2 whether it was in that specific time period.
3 Q. Did you review the NRC's report that is 4 referred ~to as the SIT report, the special inspection 5 team report?
6 A. Yes, I have, but I don't remember whether i
7 '
it was in those months or not.
8 Q. Did you review the CAT report, the NRC's l
. 9 CAT report?
10 A. Yes.
11 Q. But you don't remember if it was in those 12 months?
13 A. Thank you. ,
14 Q. I have a few more I have to --
15 A. Okay.
16 Q. Did you review the Region IV inspection 17 reports up to the time period that we are discussing,I 18 which is the summer of '847
! 19 A. I have reviewed a lot of Region IV l ,
j 20 inspection reports, but I don't recall whether it was 21 in that time per;od or not or they were the ones that[
l 22 preceded that time period.
l 23 Q. Did you review the NRC's systematic 24 assessment of licensing performance reports?
1 25 A. I have, but --
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9 1 Q. Did you during that time period?
2 A. I don't recall.
3 Q. Did you review the ASME audits of Brown &
4 Root during this time period?
5 A. Not that I recall.
6 Q. Have you ever reviewed the ASME audits?
7 A. I don't think so.
8 Q. Did you review any of the ANI, the 9 a ut ho r i ze d nuclear inspector's, reports?
10 A. I have, 'o u t I doa't think in that time 11l period.
i 12' O. Did you review the audits of the Texas 13 Utilities' quality assurance audit office?
14 A. I'm not sure what you are referring to by 15 that.
16 Q. Texas Utilities has a corporate quality 17 assurance audit department. Did you resiew their 18l audit reports?
- 19) A. I don't think so. Certainly not in that l 20 time period.
l 21 Q. At the time that the NRC wrote to 22 Texas Utilities regarding its findings of the 23 electrical group of the technical review team, did 24 you receive a copy of that letter immediately?
25 A. Yes.
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l Q. And in response to that letter, was it 2 your idea to form a Comanche Peak review team? '
1 3 A. I don't think it was my idea to form a 4 Comanche Peak review team, no.
5 Q. Do you recall'the history of the beginning 6 of the CP RT program? !
7 A. Some of it.
8 Q. All right. What is the first meeting that i
, 9 you recall in which the idea of a CPRT program by i
10 that or any other name was discussed?
11 A. I don't remember the specific date, but it 12 was certainly shortly after we received the first T RT 13 letter that we began discussing response mechanisms, 14 what we would do about it.
15 O. Who were those discussions with?
16 A. Certainly Mr. Spence was involved, ,
17 Mr. Fikar, Mr. George, probably John Merritt.
18 Q. Mr. Clements?
19 A. Mr. Clements. Mr. Schmidt, myself, 20 perhaps others.
21 Q. During those initial meetings --
Let me 22 ask: Was there more than one meeting?
23 A. Yes.
. 24 Q. During those meetings, were you questioned 25 about the r e-i ns pe c ti on program experience that you UNITED AMERI CAN RE P ORT I N G SERVICES, INC.
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1 i had at.the Midland plant?
l 2 A. I don't specifically recall, but I'm sure 3 the subject came up.
4 Q. Do you recall whether the idea of a S
re-inspection program was generated by someone within 6 these meetings or suggested by the NRC? '
7! A. Certainly in the case of the electrical 8;
i
' TRT findings, there was a specific suggestion to go 9;
I -
back and look at terminations, for example, and I 10-believe that was included in the first letter that we 11: received from the staff.
12, Q. At the time that we are discussing --
For i
13! the time period that we are discussing, do you recall l
14i whether there were any memos created out of the 15; meetings that you have referred to that memorialized 16} these di s cus si ons ?
I 17! t A. Not that I remember, no.
i 18' O. Okay. Do you recall whether there were 19 discussions during these meetings regarding the 20 involvement of individuals who had previously been 21 involved in the areas where problems had been 22 identified?
23 A. Yes.
24 Q. What was the subject of those discussions?
25 A. The initial response was predicated on the UNITED AMERICAN REPORTING SERVTrPC Tur
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,7 12 1 assumption, among others, that the people who were involved were those most knowledgeable and capable of 2
3 dealing with the issues.
4 Q. Did you have an opinion on whether it 5
should be the same individuals involved with the 6 problem areas?
t 7 A. -l I did not disagree that they were the most !
l 8 knowledgeable and qualified to deal with the issues.
i
. 9 Q. Did you have an opi ni on on whether, >
t 10 regardless of their knowledge, it would be ,
11 appropriate to have them be the review team leaders 12 in charge of the area that the problems had occurred 13 in?
14 A. I concluded, and I can't remember exactly i 15 when, that it was necessary to put third party people 16 into that role, not because of lack of qualifications, 17 but simply because of the realities that we were 18 dealing with at the time. But exactly when --
when 19 that became clear, I'm not sure.
20 Q. Do you recall having an opinion about the 21 appropriateness of having the same individuals be in 22 charge of the areas that the problems were identified 23 in, before Revision 0 of the program plan was issued?
24 A. I don't.
25 Q. Do you remember voicing that opinion to UNITED AMERICAN REPORTING SERVICES. TNC.
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13 1 anyone?
2 A. I don't recall that.
3 Q. You don't recall if you voiced that 4 opinion to anyone?
5 A.
or whether I had one at that time.
6 Q. All right. Do you recall whether 7
Mr. Spence was asked to make a speci fic deci sion on 8 the individuals who were going to be the review team i
9' leaders?
. I 10 A. The best of my recollection, it was a 11! ,
collective decision making process which Mr. Spence, i
12' in his position, certainly had to approve before it 13, went forward.
14] Q. Do you recall if Mr. Chapman was one of 15 the individuals involved in these discussions?
s 16! A. Specifically, no.
I I should imagine that i
17 he was involved, though.
18 MR. EGGELING: Don't guess.
19' A. That was a guess.
20 MR. EGGELING: Which he regrets.
l 21 THE WITNESS: Thanks.
! 22 Q. (BY MS. GARDE) i After Revi si on 0 was l 23 issued, did there come a time when the program was l
!. 24 changed?
25 A. Yes.
l l
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14 1 Q. Do you remember why that program was i
2 changed?
f 3 A. We were seeking to establish a basis to 4 understand the issues and to do it in a way that was 5
acceptable not only to us, but to the regulatory body 6 as well. And one of the driving forces in our quest !
7 to reach that basis was to make it an objective '
8 process, and that was the primary thrust of the first i
9 r evi si on, to establish more obj ect i vi ty.
10 Q. Was one of the purposes of the issuance of 11 the original plan to convince the Nuclear Regulatory 12, Commission that it was acceptable to grant a fuel 13 load license in the fall of '847 14 A. I don't recall that that was the primary ;
15 thrust.
16 Q. Do you recall whether Texas Utilities was t
i
, 17 attempting to get permission to load fuel in the fall 18 of '84?
19 A. Certainly were.
20 Q. Was Revision 1 issued publicly?
! 21 A. It was sent to the NRC.
l 22 Q. Do you have a recollection of when?
23 A. I believe it was November of '84.
l 24
' Q. Was the - Strike that.
25 To the best of your recollection, what was UNITED AMERICAN REPORTING S E RV I C E S . INC.
15 1 the primary changes between Rev. O and Rev. 17
' 2 A. Composition of the SRT that I recall. I 3 would have to review the document, look at the 4 differences.
5 O. Were you on-the senior review team at the !,
6 time it was initially created? j 7 A. Yes. \
i 8 Q. Have you always remained a member of the i i
, 9j senior review team? -
i 10 A. Yes. i lli O. Is there anyone else on the senior review ,
I '
12: team now that was on it at the time it was created? ;
13 A. John Guibert.
- i. l' 14! Q. Is Mr. Guibert a Texas Utilities employee?i i
15; A. No. i '
i O. Who does he work for?
16 l' 17i A. Terra. !
I i
18 Q. At the time that Revision 1 was issued, 1 91 had the NRC issued any more of its preliminary l
20; letters of their findings? !
l 21' A. I believe so. l 22 Q. Did there come a time when the CPRT 23 changed again?
24 A. Yes.
25 Q. When was that?
, UN ITE D A!4E RI CAN REP ORTING SERV ICES. INC.
16 1 A. Could you be more specific by what you
. 2 mean by "changed again"?
I
, 3 Q. Was there another r evi si on issued?
4 A. There was a Revision 2.
5 O. Okay. When was Revision 2 created?
6 A. I don't know.
7 Q. You have no idea? i 1
8 A. We can go to the record and look it up, 9 Billie. .
10 Q. Well, we don't have all the records with 11 us, so I -- At this point, I just want your memory.
12 This isn't a guessing game. I'm not trying to 13 impeach-you on it. I'm just trying to figure out 14 what it is. '
15 A. I don't rem embe r .
16 Q. . Okay. Do you know if Revision 2 was 17 issued publicly?
18 A. It was.
19' O. By sending it to the NRC?
20 A. Correct.
21 Q. Was Revision 2 issued after the January 22 8th, 1985 letter from the NRC to Texas Utilities l
23 regarding the TRT's quality assurance, quality
. 24 control group's preliminary findings?
25 A. Yes.
UNITED AMERICAN REPORTING SERVTORR. TMr.
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17 1 Q. What was the primary changes between 2 Revision 1 and Revision 2?
3 A. I would have to review the document before 4 I can specifically answer that question.
5 MS. GARDE: Off the record.
6 (Off-the-record discussion.
7 Q. All right. Mr. Beck, I'm going to hand i
8 you a document that is entitled Re vi sion 2, it is a
, 9 cover letter, and ask if this refreshes your i
10' recollection of when Revision 2 was issued, first of 11! all?
i 12 t (Witness perusing document.
13 MS. GARDE: Mr. Eggeling, I object to 14l you pointing out things to the witness.
t 15! MR. EGGELING: That is fine.
16' (Witness perusing document.
17 A. This cover letter is dated April 23, 1985, 18 and it transmits draft sections of a revised CPRT 19; program plan.
20 Q. (BY MS. GARDE) Do you recall any other 21 letters sending any other document to the NRC other 22 than that one?
23 A. I'm sure there were.
24 0. You are sure there was a final revision?
' ~
25 A. I'm sure there were other letters.
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18 1 Q. Was there a final Revi si on 2 sent to the 2 NRC that you rerecall?
3 A. I will have to spend some time looking at 4 that.
5 Q. Isn't it true, Mr. Beck, that there was no 6 final Revision 2 issued; that, in fact, what followed i
7 was Revi si on 3 of the CPRT?
r l
8 THE WITNESS: Have you got the i
, 9 document? !
10 MR. EGGELING: This is Revi si on 4.
11 THE WITNESS: That is okay. Do you 12 have the chronology?
13 MR. EGGELING: Part of it is there.
14 Part of it is somewhere else. I l
15 (Witness perusing document.
i 16 A. Revision 2 was formally transmitted to thel 17; NRC on June 28th, 1985.
18 MR. EGGELING: Why don't we let the 19 record reflect that the witness has been referring to 20 the description of the history of the program plan as 21 contained in Revision 4, which you have, Counsel.
22 Q. (BY MS. GARDE) And that statement that 23 you jus'. referred to indicates to you that there was l 24 a formal transmittal of Revision 2 to the NRC?
25 A. That's correct.
UNITED AMERI CAN REPORTING SERVICES. TNr.
m . s _- g. - y 19 1 Q. By cover letter?
2 A. No, not this cover letter.
3 Q. No, not --
I understand not by that cover 4 letter. Did you ever provide documents to Mr. Noonan 5 directly without sending them to the NRC?
6 A. No.
7, Q. After Revi si on 2 was issued, did it --
8: Strike that.
9l Did there come a time when the CPRT was 10 revised again?
11; A. Yes.
I, 12 Q. Do you r eca ll when that r evi si on was?
i 13! A. Refer to the same chronology.
14 MR. EGGELING: Lost the page it was 1 i 15, on.
1 16- THE WITNESS: In Revi si on 4.
17 (Witness perusing document.
18 A. January 25th, '86, Revision 3 was sent to 19 the staff.
20 Q. (BY MS. GARDE) All right. Going back to 21 Revision 0 of the CPRT program plan, was the work 22 done under Revision 0 accomplished in accordance with 23 the plan?
i , 24 A. Any work that was done was accomplished in l 2S accordance with the plan in existence at the time, i
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20 1 yes.
1 2 Q. Was there any other governing documents 3 besides the plan that covered the work that was done?
4 A. If you mean the plan to include all the 5 issue specific action plans --
6 Q. Yes.
7 A. --
yes.
8 Q. Was the work done during the time period 9 that Revision 0 was the governing document done 10 according to checklists prepared by CPRT officials?
11 A. I don't remember, Billie.
12 Q. Do you recall whether it was done to any 13 written procedures?
14 A. I don't recall precisely how much work was 15 accomplished during the time period Revision 0 was in 16 existence.
17 Q. All right. Mr. Beck, if I expand my 18 question to include the time period of Revision 0 and 19 Revi si on 1, does it change your previous answer 20 regarding checklists? Do you want me to repeat the 21 question?
22 A. Would you?
23 Q. If you include the time period from the 24 issuance of Revisica O through the time period 25 covered by Revi si on 1, was the work done during that UNITED AMERICAN REPORTING S E RVI C ES . INC.
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3 A. I don't remember.
4 Q. Who would know?
5 A. I'm thinking of any number of people, 6 including myself, if I go back and do the research.
7 Q. Okay. Who besides yourself?
8l A. Other SRT members, the review team leaders 9 ;i who were there at the time.
10 Q. Was the work done during the time period 11 of Revision 0 and Revision 1 in accordance with i
12' 10CFR50, Appendix B requirements?
13 A. All the work that has been done under the 14; CP RT plan was either done specifically in accordance i
- 15. with applicable pr ovi si ons of 10CFR50, Appendix B, or 16 it was subsequently reviewed and appropriate steps 17 were taken to make sure that those a ppl i ca bl e 18 provisions were honored. i 19 Q. Okay. That doesn't complet ely answer my 20 question. At the time period --
Strike that. l 21 At the time Revi si on 0 was issued, did it 22 contemplate the identification of d e f i ci en ci e s or 23 nonconf ormi ng condi ti ons ?
24 A. Yes.
25 Q. And at the time that Revi si on 0 was issued, UNITED AMERICAN REPORTING S E RV I C E S . INC.
- -- an 22 1 was there an intention by the senior review team that
.2 those deficiencies or nonconforming conditions be 3 recorded on some type of control documentation?
4 THE WITNESS: Can I ask you a S question?
6 MR. EGGELING: Sure, you can, if you 7 can't answer the question.
8 THE WITNESS: Well, I need to go back 9 and review Revision 0 in order to answer that 10 question.
11 MR. EGGELING: She is asking for your 12 memory, for reasons --
for reasons I don't understand.
13 You can answer from your memory, unless she refers 14 you to a document.
15 THE WITNESS: Ok a y .
16 MR. EGGELING: If you don't know what 17I the answer is without the document, then that is what '
18 you tell her, all right?
19 A. My r ecollecti on is that we have always 20 required any findings of deficiencies to be 21 transmitted across from the C P RT to the project where t
22 each one of those deviations becomes an NCR. If it i
23 involves an inspection result and it is dealt with
. 24 accordingly, which means that a record is established 25 and it is properly processed.
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y 23 1 Q. (BY MS. GARDE) According to the 2 project's --
1 3 A. According to the project's regulations.
4 Q. --
QA/QC program?
5 A. That's correct.
6 Q. I would like to ask you to look at 7, Revision 0 and identify where in Revi si on 0 it states l
8' that. I believe zero is the first one.
t
- 9) (Witness perusing document.
l 10- MS. GARDE: Off the record.
11- (Witness perusing document.
12 I
(Off-the-record discussion.
1 31 A. Let me give you two examples on page 2 of 14 15 of Rovision 0 under the program plan principals, 15 Roman Numeral III, B, expanded reviews. The 16 statement is made that any deficiencies identified in 17 the larger sample will be dispositioned by 18, appropriate corrective action.
l 19 And action plan I.a.4, page 3 of 4, 20 Re vi si on 0, letter D, if changes are not reconcilable 21 and thus nonconforming, make appropriate changes 22 using existing procedures. The changes that are 23 referred to are di scr epanci es between the inspection 24 documents and the drawings.
25 Q. (BY MS. G A RDE) Those two examples are l
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24 1 !
offered in response to my query about where the 2 program plan requires that all deficiencies are 3 identified on controlled deficiency paper?
4 A. Yes. Action plan I . a . 5, page 1 of 2. The 5 NRC identifies as a requirement to reevaluate and 6 redisposition NCR related to vendor installed loads 7 in GE motor control centers. Page 2 of 2, same 8 action plan, the NCR redispositioning was scheduled i
9 to be completed by November 16th. I'm finished.
10 Q. Isn't it true, Mr. Beck, that in regards 11 to 184, that the out of scope deficiencies were i
12 identified on memorandums not transferred to any j 13 control paper and nonconformance reports?
14 A. I don't remember.
15 MS. GARDE: Let me show you and ask 16 to mark as an exhibit two documents.
17 (Beck Exh i bi t s 3 and 4 18 (marked for identification.
19 Q. (BY MS. GARDE) Okay. I'm showing you two 20 documents which have been marked Beck 3 and Beck 4.
21 They ha ve identifications on them from the wor ki ng 22 files of the results reports. I would like to ask if 23 you can identify the documents as documents coming 24 from the working file of the results reports?
25 A. I can't personally vouch for that, no.
UNITED AMERICAN REPORTING S E RV I C E S , INC.
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25 1 Q. Can you find identification numbers on 2 them that will tell you that they were processed in 3 accordance with the working file program of the 4 results reports?
I 5 A. Would you repeat the question? I'm sorry. ;
6 Can I find --
7l Q. I asked --
I just asked you if you could l
8j identify numbers --
numbering system that would tell
- ; i
, 9: you it came from the working file of I.a.47 l
10 A. The document you handed me labeled 3 is an i
1 1 '. office memorandum to M. B. Jones that references f '
12! I .a . 4.
I 13 Q. But you don't know if it came from the l
l 14{ working file?
15 }: A. I do not know whether it came from the 16 f working file.
l 17 Q. All right. Let me ask --
Let me ask this 18 question again. If the answer is you don't know, you 19' don't know. Isn't it true that the out of scope 20 deficiencies identified in I .a . 4 were not put on 21 project --
NCR's or any other deficiency paper, but 22 were recorded only on memorandum?
23 A. I don't know.
- l. 24
- Q. All right. What else besides the l
25 l references that you have just given me regarding l
t UNITED AMERICAN REPORTTNG SERVTerc Tue
26 1 Revi si on 0 do you base your belief on that the work i
2 done under Revision 0 and Revision 1 was done 3 according to Appenix B's criteria?
4 MR. EGGELING: Do you understand that 5 was your belief?
6 THE WITNESS: No, I didn't.
7 MR. EGGELING: Why don't you tell us 8 where you got the assumption that that was his belief?
9 MS. GARDE: That is what my notes say 10 he testified to. If my notes are wrong, I will stand 11 corrected. Start this all over again.
12 Q. (BY MS. GARDE) Do you believe the work 13 done under Revision 0 and Revision 1 was done 14 according to the quality assurance requirements of 15 10CFR50, Appendix B?
16 A. I stated earlier that the work done under 17 the CP RT program was either done specifically in 18 accordance with the applicable criteria or reviewed 19 to see that it was in accordance with the criteria.
20 Q. All right. Was Revi si on 0 done in 21 accordance with Appendix B criteria or re vi ewed to 22 determine if it was done in Appendix B criteria?
23 A. That is my belief, yes.
l 24 Q. That it was reviewed?
25 A. Probably reviewed, rather than i
UNITED AMERICAN REPORTING S E R V T C F. A . TNr.
27 i I specifically done, in recognition that Appendix B 2 criteria would always apply.
3 Q. Who would have probably done the review?
4 A. Third party personnel and the OQT.
5 O. What third party personnel?
6 A. Specifically who did that, I don't know.
7 Q. Would it have been done under 8 Mr. Hansel's direction and control?
9 A. Either Mr. Hansel or the OQT.
10f Q. If it had been done by the OQT, would it 11 have been listed on the audits that the OQT had 12 performed that was publicly made available to the 13 Nucicar Regulatory Commi ssion?
14 A. Say that again, please.
15 O. Okay. If the OQT had done it, the review, 16 how would I know that?
17 A. It would be in their reports and records.
18 Q. It would not be in the results reports 19 working file of the individual ISAP7 20 A. I'm not sure, Billie.
21 Q. If it had been done by Mr. Hansel, where 22 would it be recorded?
23 A. In the cent ral file records which would be i
24 the results report or supporting documentation.
25 Q. Do you know if the work done according to UNITED AMERICAN REPORTING SERVICES, INC.
28 1 Revision 1 was done to 10CFR50, Appendix B criteria 2 or reviewed to determine its acceptability under that 3 criteria?
4 A. My previous answer is the same.
5 Q. Review, probably reviewed?
t I
6 A. Probably.
7 Q.
What about the work done under Re vi si on 27 A. Let me see some dates.
8l 9 Q. You have the draft of Revi si on 2 in front 10 of you.
11 A. I'm looking at some dates.
12 Q. Okay.
13 (Witness per using document .
14l A. I believe that the work done under ,
15 Revi si on 2 was done when the OQT program was in 16 effect, and their audit with respect to Appendix B i i
17 applicable criteria were constantly ongoing. So it 18 would probably be more the latter, rather than a 19 backfit proposition.
20 Q. What about the work done on Revision 3?
21 A. It was clearly under the OQT perview.
22 Q. When the decision was made to change the 23 review team leaders, which I believe you testified
. 24 was between Revi si on 0 and Revi si on 1, was there a 25 discussion about the appropriateness of involving UNITED AMERICAN REPORTTNG AERVTrPC ter
_n..~ - . - . ~ - . . _ _ . , , , , - . . . , . . - . . a_
29 1 those individuals in any of the CPRT work?
2 A. I don't remember.
l 3 Q. Do you know Mr. Ron Tolson?
4 A. Yes.
5 O. What was Mr. Tolson's role in regard to 6 Revision 0 of the CPRT?
7 A. My recollection is that he was review team 8; leader for coatings.
9 Q. Did he cont i nue to have that position into 10 Rev. 1? I don't have Rev. I with me.
11l A. I don't remember.
12' O. Does he have it now?
13 A. No.
I 14' O. Did you make the deci si on to have 15l Mr. Tolson taken off as the r e vi e w team leader on 16 paint coatings?
17 A. No.
18 Q. Who made that de ci si on?
19 A. I don't --
can't recall.
20 Q. Do you know Mr. Vega, Antonio Vega ?
21 A. Yes.
22 Q. What was Mr. Vega's role in Rev. 07 If 23 you are looking for the old chart --
24 A. The old chart.
25 O. --
that has been marked as an exhibit in UNITED AMERICAN REPORTING SF9VTerc vue
._, - -_.-....m .
30 1 Mr. Hansel's de po s i ti on . I'm showing you Hansel 2 Exhibit 4, which is an old chart. It says "Rev. 0" 3 on the bottom.
4 A. This Exhibit 4 Hansel shows A. Vega as a
- 5. QA/QC review team leader.
6 Q. Has he continued in that role?
7 A. He did until we made the change. ,
.' 8 Q. All right. Does he continue in that role 9 now? -
r
- e 10 A. No.
f 11 Q. Did you make the deci si on having Mr. Vega 12 taken out of the review team leader position?
13 A. I did not.
14 Q. Do you know who did?
j 15 A. I don't recall.
16 Q. Did you attend any meetings in which there 17 was discussions about removing Mr. Tolson or Mr. Vega?
18 A. Yes.
19 Q. Who was present at those meetings?
20 A. The SRT.
21 Q. Only the SRT?
22 A. I don't remember.
23 Q. What was the subject of those discussions?
24 A. The context that I'm thinking about were
~
25 meetings to discuss revisions to the program plan.
UNITED AMERICAN REPORTING SERVICES. INC.
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31 1 And as I indicated earlier, one of the factors 2 involved was to put third party people in the review 3 team leader r o l e,, and that would involve Mr. Tolson, 4 Mr. Vega, and the other review team leaders.
5 O. Did the de ci si on that was reached 6 regarding Mr. Tolson, Mr. Vega, and the others carry 7 forward to any involvement those individuals had in 8 the CPRT?
9{ A. I don't remember. ;
1 i
10! Q. You don't remember discussing it? l l
11- A. No. l 1
i 12j Q. Do you recall what was the basis of the [
t 13 concern about Mr. Vega and Mr. Tolson in their role !
! i
-14i as review team leaders?
f i
15 A. As I said, the consideration was to put l 16! third party people in that review team leader role, 17 and it was not an individual-oriented decision.
18 Q. Does that apply to Mr. Merritt as well?
19 A. It did.
20 Q. Does it apply to Mr. Fenner?
21 A. Yes.
22 Q. Did it also --
23 A. Mr. Penner, I don't believe, was a review
. 24 t e'a m leader.
25 O. Okay. He is not on this chart. I UNITED AMERICAN REPORTING SERVICES, INC.
32 1 withdraw the question as to Mr. Fenner.
2 What about Mr. Vogelsang?
3 A. He was not a review team leader, and he 4 continued to be a resource responsible to the review 5 team leader in electrical.
6 Q. What about Mr. Popplewell?
7 A. He was replaced.
8 Q. What about Mr. Mc Bay ?
9 A. He was not a review team leader, but I 10 think he continued to be a resource available to the 11 third party.
12 Q. What about Mr. Camp?
13 A. He was replaced by a third party person.
14 Q. Does Mr. Camp have duties in regard to the 15 CPBT today?
16 A. No.
17 Q. Now, as to er.ch of the named individuals 18 that we have discussed, do you know what involvemett 19 they conti nued to have with the CPRT --
I will go 20 over them individually --
after they were removed as 2! review team leader? Do you understand the question?
2m A. You are going to start with i ndi vid ual s ;
23 right? I 24 Q. Again, okay. After Mr. Tolson was removed 25 as review team leader, what role did he play in the !
UNITED AMERICAN REPORTING SERVICES. TNc.
- ~ -- ~~ .
33 1 C P RT 7 2 A. I don't specifically recall what role he
, 3 played.
4 Q. Did he have any role?
5 A. I don't remember.
6l Q. What about Mr. Vega?
i 7l A. I don't remember.
8! Q. What about Mr. Vogelsang?
9; A. I definitely recall that he continued to 1
10 be a resource to the electrical review team leader, ll! Q. Mr. Popplewell?
12 A. I don't remember.
1 31 Q. Mr. Mc Ba y ?
14l A. I remember Mr. McBa y 's cont i nue d 15 involvement as a resource.
16 Q. Mr. Camp?
17 A. He continued to be involved.
18 Q. Do you know Mr. C. T. Brandt?
19 A. No.
20 Q. Have you ever met Tom Brandt?
21 A. Yes. I thought you said "Grant," excuse 22 me. You said "Brandt." I know Tom Brandt.
23 Q. And Mr. Brandt isn't listed as a review 24 team loader on Revision 0 to CPRT on the Hansel 4 25 Exhibit. Do you know what, if any, role Mr. Brandt UNITED AMERICAN REPORTING grouvere vue
34 1
played in the CPRT at the beginning of the program?
2 (Witness perusing document.
3 A. I don't remember specifically what he did, 4
but I'm sure that he served as a resource.
S Q. What about Mr. Finneran?
6 A. He certainly was involved as a project 7 resource.
8 Q. What about Mr. Iodi?
{
l 9 A. Same.
10 Q.
Now, did there come a time period when thef 11 involvement of Mr. Tolson stopped with the CPRT?
12 A. Yes.
13 Q. When was that? l 14 A. I don't remember exactly. He resigned I i
15 from the company and his involvement certainly l 16 stopped at that point. '
17 Q. He didn't continue in the role of a 18 consultant?
19 A. No.
20 Q. What about Mr. Vega, what about Mr. Vega?
21 A. Mr. Vega was reassigned, I don't remember 22 exactly when, and his involvement with CPRT ceased at 23 that point as well. It may have been earlier. I
. 24 don't r eca ll exactly when.
25 Q. All right. Mr. Vogelsang?
UNITED AMERI CAN REPORTTnn crou vece tun
l l
35 1 A. He was given another assignment, and 2 certainly any involvement would have stopped at that 3 point.
4 O. Mr. Popplewell?
5 A. My recollection is that Mr. Popplewell's 6 involvement stopped before he was reassigned in the 1
7 company, but I don't remember exactly when. 4 8; Q. Mr. McBay?
l '
i 9, A.- Same answer.
10: Q. Mr. Camp? i i
i 11 A. I think Mr. Camp b's continued to be a 12 resource to CPRT and continues to this day, so far as l I
13 I know.
14 O. Mr. Finneran and Mr. Iodi?
15' A. They're both still with the project, and f '
16 l to the e xt en t that their project acti vi ti es int er f ace '
- '1 7 with CPRT action plans or e val ua tions , we still have 18 contact with them from time to time.
- 19- Q. And Mr. Brandt?
I i 20- A. I hesitate to say zero i n vol vem en t , but it i
21 is awfully close to none.
l 22 Q. With the CPRT?
23 A. Yea +
l l
24 Q. Do you know when Mr. Brandt's involvement 25 got to the point of being almost zero?
r i UNITED AMERICAN REpnRTIkh groutchc ton
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36 1 A. I don't remember.
2 MS. GARDE: I want to mark this.
3 (Beck Exhibit N unebe r 5 4 (marked for identification.
5 Q. Mr. Eeck, I'm going to show you 3xhibi t 5, 6 which is a TUGCO procedure CP-QP-16.3, Revision 3.
7 MS. GARDEt Is there something wrong 8 with it?
9 MR. EGGELING: Yeah. The next page 10 is something entiraly different, unless I 11 misunderstand.
12 MS. GARDE: Let ms look at it.
13 MR. EGGELINGt (Indi cating ) .
14 MS. GARDE: Well, you are right, it 15 is.
MR. EGGELING: That is why I like to 16l '
17 look at them first. !
18 MS. GARDE: Oh, I k r.o w what it is.
19 Q. (BY MS. GARDE) Let me Icdefine what I l
}
20 have just handed you. It is the first page of l
t 21 nunerous different procedures, TUGCO CP-QP procedures, 22 all of which have one thing in common, which is 23 Mr. Brandt's signature in the approval line regarding 24 the procedure.
25 I want to ask you --
I want to ask you UNITED AMERICAN REPORTTNG A P. R V T O P C TMF
37 1 what those duties are generally that is, what is-the 2 duties that Mr. Brandt was performing when he signed 3 these procedures?
4 MR. EGGELING: Okay. I understand 5 you want t' -m 'hrough this stack of documents one at 6i a time?
7 MS. GARDE: 1:o , that is not the i question.
8!
9 MR. EGGELING: What is the question, 10 please?
11 MS. GARDE: I want Mr. Beck to 1
12, describe to me what his understanding of Mr. Brandt's t
13! role was in appr o vi n g those procedures. It is a 14 generic question.
15 MR. EGGELING: Are you representing 16, that this is Mr. Brandt's signature?
17 MS. GARDE: Yes. ;
18 MR. EGGELING: Are you familiar with 1 9 ', Mr. Brandt's signature?
l 20 I MS. GARDE: Intimately.
21 MR. EGGELING: Are you familiar with 22 Mr. Brandt's signature, Mr. Beck? >
23 THE WITNESS: No.
3
. 24
- MR. E G G'i .f G : Well, then, if you 251 don't know that is his signature, just assume for the UNITED AMERICAN REPORTING S E RVI C E S . INC.
38 1 moment that it is. Maybe some time Ms. Garde can 2 prove that.
3 (Witness perusing document.
4 MR. EGGELING: Do you understand the 5 question? Is the question capable of being answered?
6 Are there things sufficiently similar and whatever so 7 the answer would make sense?
I 8 A. I can't answer that from firsthand l
9 knowledge.
10 Q. (BY MS. GARDE) In your role as a 11 vice-president in charge of quality assurance, you ,
i 12 can't tell me what Mr. Brandt's role is in approving :
13 those procedures?
14 A. No.
15 Q. All right.
16 MS. GARDE: Counsel, I want to put 17 you on notice that I'm going to have to call 18 Mr. Brandt up here. I don't want to call Mr. Brandt 19 up here. I assumed that in his position, he would be 20 able to answer that question. I will ask both 21 Mr. Tyler and Mr. Streeter if they know what 22 Mr. Brandt was doi ng wi th approvi ng those procedures.
23 If they can't answer the question, then l'm going to 24 move to produce Mr. Brandt, at least as to that 25 narrow question. Hopefully, Mr. Streeter will be UNITED AME RI CA N RE P O RT 1 N G AERVirPC. TNr.
39 1
able to answer it because he is Mr. Brandt's direct
.' 2 boss.
, 3 MR. EGGELING: Ms. Garde, since at 4 this moment I still have no idea what the question 5 has to do with with regard to the scope of the 6 depositions, since I have no idea why it is relevant l 71 to anything, because I have no idea why you think it i 8! would be necessary to ask this witness the question t
! l 9 or Mr. Brandt the question, I'm not going to take any 1
I i
10: position to your ability to get any other witnesses. i i
11 You have indicated the witnesses that you ;
12' have included to conduct whatever it is you are .
13l trying to conduct, and I have yet to see any reason )
14: why they are sufficient. Perhaps I will learn. !-
15; MS. GARDE: All right. How late do 16, you want to go tonight because I'm going to start i ,
i 17 another line of questions? i 1
18' MR. EGGELING: 6:00.
19' MRS. ELLIS: What time did you say?
20 MR. EGGELING: 6:00, as we agreed ,
21 yesterday. t i 22 Q. (BY MS. GARDE) Mr. Beck, is it your !'
l .
23 understanding that the CPRT is going to identify all l i
24 undetected deficiencies of the site? I 25 A. The mission of the CPRT is to reach a l
UNITED AMERICAN REPORTING RF.RVTOPA Tuc
40 e
1 position of reasonable assurance that we have i
2 identified all deficiencies that would preclude the 3 plant from being operated in accordance with NRC 4 regulations.
5 Q. Are you familiar with the statement that 6 the CPRT will not perform i nspe ctions , calculations, 7 or designs of record for Comanche Peak?
8 A. Yes.
i 9 Q. What does that statement mean?
10 A. I'm familiar with this statement. ,
11 Q. What does that statement mean?
12 A. That means that the CPRT does not perform 13 inspections of record.
14 Q. What does "of record" mean?
15 A. That means that any official inspections l 16 that fall under the TUGCO QA program are done under 17 that program by personnel responsible to that 18 organization and not by third party people. !
19 Q. Does the phrase "of record" I
-- or 20 "i ns pe cti ons , calculations, or designs of record" ,
r 21 refer to the record that you will attempt to get -
22 Comanche Peak licensed on?
23 A. I don't unde r s t an d your question.
24 MR. WOOLDRIDGE:
You mean the hearing 25 record?
UNITED AMERI CAN REPORTTNG RERVTPFC TMc
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41 1 MS. GARDE: No, I don't mean the 2 hearing record, but "record" has often a legalistic 3 term. And for sake of clarification, I am thinking 4 about Mr. Eggeling --
Mr. Gad's long dissertation-on 5 what this phrase means, and I want the witness to 6 explain it. His answer is, at least to me, 7 inconsistent with Mr. Gad's explanation. I'm going 8 to ask this question again.
i
, 9 O. (BY MS. GARDE) Does the phrase loi i
"inspections, calculations, or designs of record" 11l refer to the record that you are --
you, Texas l
12{ Utilities, are going to rely upon regarding the $
i
- 13) ,
licensing of the plant?
14 MR. EGGELING: I have no idea what 15; the question now is. I object to the question. If I
16 you would ask him to somehow make a comparison with 17 legalistic conclusions --
18 MS. GARDE: I'm not --
19 MR. EGGELING: Please, I did not 20 interrupt you. i 21 --
addressed by one of the lawyers for TU !
1 22 Electric with regard to the legal obligations that 23 may be imposed upon it which presumably will be the 24 only thing that Mr. Gad was addressing, but I'm not 25 familiar with what you are de s cr i bi ng . The witness UNITED AME RI CAN REPORTTNG ARRUTrPC Tur
42 1
has described the best to you, as far as I know he 2 can, of what it means to him. If you are looking for 3
a different answer, I don't understand the purpose of 4 your question.
5 MS. GARDE: Okay. Will you read back l
6 his answer?
7 (Record read back.
8 Q. (BY MS. GARDE) Are the documents that are f
9-created under the CPRT going into the permanent plant 10 records va ul t for each of the systems or components 11 that the documents pertain to?
12 MR. EGGELING: Do you understand that 13 que s ti on?
14 THE WITNESS: No.
15 MR. EGGELING: Can I help him? I 16 think I understand that ques ti on . I think all she is 17 asking is are the inspection records the CPRT has 18 going to be kept permanently in places where they 19 could be found if someone wanted to look up the 20 particular component.
21 MS. GARDE: That is a good 22 preliminary, but that is not the question.
23 Q. (BY MS. GARDE) Let's start with that 24 question.
25 A. We are maintaining all the CPRT records.
UNITED AME RI CAN REPORTTNn A F DV T PF C . TMF
a
<i.
43 1 yes.
2 Q. Where the CPRT does an inspection on a
! 3 particular component, identifies a de vi a tion , is the 4 ERC deviation report going to be kept in the 5 permanent plant record regarding that component?
6 A. Are you asking me is it going to be 7 physically located in the permanent plant record 8 vault?
9,I Q. For that component?
10 A. For that, that doesn't make any sense to 11! me, I'm sorry.
l 12' O. Let's take it hypothetically, a fuel pool
, 13 winder --
There is a package regarding each fuel pool 14 winder, is there not?
15 A. I don't know.
16 Q. All right. Let's take a weld. If it is a 17 safety significant weld on a bellow, is there a 18 package of documents that goes to that weld on that 19 bellow?
20 A. If it is required that that weld be 21 inspected and that that record be maintained, there 22 is a record, yes.
23 Q. All right. If ERC conducts an inspection
. 24 on*that same weld under the CPRT program plan and 25 they identified a deviation, will the ERC deviation UNITED AMERICAN RRDoDTTMn CPD"T"ec '""
y.
44 1 report be found in the package on that weld?
2 A. I don't know.
3 Q. Who would know?
4 A. I suspect Mr. Streeter may know.
5 O. Is the site required to keep quality 6 assurance packages on each quality control 7 inspector's certifications?
8 A. Yes. !
, 9 Q. Hypothetically, if the CPRT efforts by 10 Mr. Hansel identif y deficient conditions regarding an '
11 inspector's qualifications, are those discoveries by i
12 ERC as recorded by ERC contained in the record '
13 regarding that inspector? '
i 14 A. All the ERC records are maintained, i 15 regardless of which action plan they were done in l
16 accordance with. Specifically, physically how they ;
i 17 are stored, I don't know. !
i 18 (Beck Exhibit Number 6 19 (marked for identification.
20 Q. Mr. Beck, I'm going to show you what has 21 been marked as Exhibit 6. Do you recognize that type 22 of document?
23 MR. EGGELING: Has he ever seen such 24 a document before, i*s that the question?
! 25 MS. G A RDE : Yes.
I UNITED AMERT CAN REPonT TNn er NUT rec . Tur
45 1 Q. -(BY MS. G A RDE ) Yes. Have you ever seen a 2 document like that before?
3 A. Yes.
4 Q. What is it?
5 A. The document is Comanche Peak response 6 team QA/QC program deviation report.
7 Q. Who prepares those documents?
8 A. This one was originated by J. E. Young, it
, 9I says here.
10 Q. Does Mr. Young work for ERC or TU?
11! A. To my knowledge, ERC.
I 12 Q. All right. To your knowledge, will that 13 document appear in the files regarding the Bahnson 14 1 QA/QC program maintained by Texas Utilities in the 15! vault?
16 A. I don't know.
17 Q. Who would know? i 18 A. I would suggest you ask Mr. Streeter.
I 19, MR. EGGELING: If you don't know, 20 don't suggest anything.
21 THE WITNESS: Okay.
22 Q. (BY MS. GARDE) Mr. Beck, is it possible i 23 for you to reach a conclusion on the adequacy of the 24 QA/QC program of the Comanche Peak plant by reviewing i 25 only the results of the CPRT?
UNTTen auroteau econn-vua aaa"- ~~- ---
46 1 A. What do you mean by "the results of the 2 C P RT " ?
, 3 Q. The collective e va l ua t i on report, the 4 release of all the results reports, and the 5 collective significance report?
6 A. Repeat the question again for me so I can 7 get all of them.
8 Q. Is it pos si bl e for you to reach a 9 conclusion on the adequacy of the QA/QC program of l 10, the Comanche Peak plant by reviewing only the results 11 of the CPRT7 12 '
MR. EGGELING: The question, though I 13 think this is --
Ms. Garde has made clear in the ,
1 41 past. She means would it be possible for you to do 15' so, regardless of what those results were. It is a l 16 l theoretical possibility, the full range of the '
17 possible results that might be.
18 A. It is possible, yes.
19 Q. (BY MS. GARDE) Is it necessary or would 20 it be necessary to wait until the results of the 21 corrective action programs were completed and 22 released before reaching a conclusion about the 23 adequacy of the QA/QC program of the plant?
. 24 A. Repeat it, please.
25 Q. Would it be necessary to wait until the UNITED AMERicAN Dronomvue a eeou'_oce _ _ _ ' " _ _ _ _ _ _ _ _ _ _
.-,..-_-.n....,, -,,,~._~...,,n.v...,
47 1
release of the results of the corrective action '
2 program or programs to reach a conclusion on the 3
adequacy of the QA/QC program of the plant?
4 A. Are you referring to me as an individual 5 when you ask that question?
6 Q. Yes.
7 A. No.
8li : Q. Why not?
9 A. Because of the responsibilities I have for 10, the QA/QC program at Comanche Peak, I reached the 11! conclusion that that program is adequate some time 12 ago.
13)
I Q. Does the conclusion that you just voiced i
14l go to the program as it exists today, or to the i
15, program as it has existed during the life of the 16 project?
17 A. Today.
18 Q. Do you have an opinion on the historical 19: QA/QC program's adequacy?
20 MR. EGGELING: Hold it.
21 MS. GARDE: I withdraw the question.
22 I couldn't help myself. You can't blame me for 23 trying.
24 Q. (BY MS. GARDE) Were you involved in the 25 selection of ERC as the third party re viewer?
UNITP.B LMroichu Den ^""'"a " " - " - - -
48 1 A. Yes.
2 Q. Had you had professional experience with ,
3 Mr. Hansel before?
4 A. No.
5 Q. Do you know whether or not the CPRT 6 -program has reviewed the allegations raised by two 7 l Department of Labor complainants, Mr. Hasan and '
8 Mr. Macktal in the CPRT's work?
9 A. Repeat it, please.
10 Q. Okay. Are you familiar with Mr. Hasan?
11 A. Yes.
12 Q. Are you familiar with Mr. Joe Macktal?
13 A. Yes. '
14 !
Q. Are you familiar with the fact that they ,
15 raised allegations?
o 16 A. Yes.
17 Q. Do you know whether those allegations 18 that they raised have been reviewed by the CPRT?
19 MR. EGGELING: Define "reviewed ;
20 by."
21 MS. GARDE: It is a broad question 22 because I don't know where they would have fit in.
23 MR. EGGELING:
L But that is what you {
24 mean, anywhere filtered in? :
25 MS. GARDE: Anywhere in the CPRT, i
Itu T Tr n a ve ov ea u neaa---"- - - - " - - - -
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49 [
l does he know.
2 A. Being familiar with Mr. Hasan's 3 allegations, I know t'n e CPRT has --
in the broad 4 sense of the word --
reviewed them, not necessarily 5 be ca us e of the source, but because many of the issues 6 were similar to alle ga t i ons from other sources. I t, 7,
the case of Mr. Macktal, I don't recall.
81 Q. (BY MS. GARDE) Were the --
Strike that.
I 9; Do you know if the CPRT has reviewed the 10 allegations or findings of NRC inspection reports lit l
r el eased since the beginning of the CPRT program plan 12, I
in the fall of 1984, other than the SSERs?
1 31 A. Yes.
i 14i Q. Who in the CPRT program plan would be l
15 responsible for that?
16' , A. The primary responsibility lies wi th the 17 review team leaders. How they delegate thst 18 s pe ci f i ca ll y , I'm not aware of.
19 .
Q. Do you know if the CPRT has reviewed the 20 allegations or concerns raised in the report of the 21 office of inspector and auditor regarding 22 Comanche Peak?
23 A. Can you be more spe ci fi :?
. 24
- Q. Yeah, I'm sorry. Are you familiar with 25 the report of the office of inspecto'r and auditor, UNITED AMRRTchu oro^n*'"" e"""'""" '""
50 1
8610, that was prepared by George Malley and released 2 publicly in December of 19867
.' 3 A. Yeah, I know.
4 Q. Are you aware of whether the CPRT has 5
reviewed that report and the attachments for !
6 allegations or concerns that should be processed in i 7
accordance with the CPRT program plan?
8 A. I don't remember. i 9 Q. Who would know?
10 A. Mr. Ferguson.
11 Q. Who is he?
12 A. He is a CPRT program director.
13 Q. Did he replace Terry Tyler?
14 A. Yes.
15 O. Are you familiar with the site safe team I 16 program? !
l 17 A. Yes.
18 Q. Do you know if the CPRT has reviewed all 19 of the safe team files to determine whether there are 20 any issues in those files that should be considered ,
21 under the safe team --
or the CPRT program?
t 22 A. No.
23 Q. No, you don't know?
24 A. No, I don't know.
25 Q. Who would know that?
UNITED AMEDTrau ovnnn=voa ---"----
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y 51 1 A. The question as you posed it is a broad ;
2 one. Certainly the CRPT would not be reviewing all 3 of the safe team records because many of them have ,
4 nothing to do with safety.
5 O. If I designate the class of safe team i 1
6 files that contain safety-related allegations, does '
7 your answer change?
A. We have established the necessity to be 8l i
9- aware of all external source issues including those 10 in safe team. Mr. Ferguson can probably be more 11! direct as to precisely how that is done.
I 12 Q. Do you know why Mr. Monty Wise is no i
13 longer the electrical review team leader?
14, A. He was replaced by Mr. Rushwick. '
i 15{ o. Why was that?
16 A.
1 One of the issues that has faced a number 17 of CRPT third party people is the length of the :
18; engagement, and in Mr. Wise's case, he has a company 19' that made substantial demands on his time. The ,
20 length of the engagement was longer, frankly, than he '
21 could properly allow for, and we needed to get 22 somebody who could devote full-time to that 23 particular review team leader's r esponsi bili ti es .
24 l 0. Is the company that you are referring to S 25 & W Technical Services?
I
, , u , ,,. c n . . . . . . . . . . . - - .
- y. ,, -c. yn - ~. - , _ . c v. - . .w ,
52 1 A. That is the company that he has today.
2 Q. Is it the company that he had at the time ;
3 that he left?
4 A. I can't remember exactly when he bought 5 into that particular firm. He had a firm of his own 6 at the time he signed on with CPRT.
7 Q. It had nothing to do --
8' A. Not by that name.
9 Q. Mr. Wise's leaving had nothing to do with 10 di s agr eem en t s between Mr. Wise and CRPT management 11 over how the electrical area had been handled?
12: A. He had nothing to do with electrical.
l 13l Q. Testing, I'm sorry.
I 14 j A. No.
l l
15' O. It has nothing to do with the need for i
1 more independence in Mr. Wise's review? '
17 A. Independence in his review in what sense? >
18, MS. GARDE: Well, I withdraw the :
i 19 question.
20 I think I'm just about done. I would likel 21 to talk to Juanita for a minute, and I will be right 22 back.
23 MR. EGGELING: Fine.
24 (Off-the-record discussion 25 (between Ms. Garde and nutmen a uc os m o n o n - - . .. - - - - . . . --- . . . -
.n _ ,- = , a n gw . . ,n n , a .vv ww, ,,,g . wn n . n. ev ,w - w. v. wgnwn . mn-,
53 1
(Mrs. Ellis.
2 MS. GARDE: I have no more questions.
3 MR. gGGELING: Thank you, Mr. Beck.
4 (Deposition concluded at 5:45 p.m.
5 6
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54 1 CORRECTIONS A TID SI,G_j]ATURE
/, 2 PAGE LIllE CORRECTION REASON FOR CHANGE 3
(SEE ATTACHED) 4 5
6 7
8 9
10 11 12 1, JOllN W. BECK, have road the foregoing I
13 deposition and hereby affix my signature that same is 14 true and correct, except as noted herein.
15 16 'l
- JO%~W. SECK 17 18 l 19 SUBSCRIBED AllD SHORN to before me by the said 20 witness on this theJ5_4_ _ day of_@ , 1987.
21 23 ,
NOTAp PUDLIC IN AND FOR T112 5
STATE OF TEXAS 24 25 !!y commisuton expires: _?_ _fg/99'/_
UNITED AMERICAN RE P O RTIllG SERVICES, IIIC .
n w , _ anu v, ~ ~v..~.-.v: n.v.- u.a.e.,n n o n n w.r.v,m n wa n owu m m g.n,vw-I ERRATA SHEET John W. Beck (October 15, 1987)
Page (line) Correction 4(9) Correct "Comanche Peak response team program plant" to "Comanche Peak Response Team Program Plan" 4(13), (18), (21) Correct "Terra" to "Tera" and (23) 5(3), 15(17) 12(23), 18(20), 19(21), Correct "program plan" 23(14), 24(2), 30(25), to "Program Plan" 49(11) and (14), 50(7) 19(23) and (25), Correct "plan" to "Plan" 20(3) and (4) 24(6) Correct "NCR" to "NCRs" 24(11) Correct "184" to "I.a.4" -
( 28(21) Correct "perview" to "purview" :
31(20), (23), 32(1) Correct "Fenner" to "Finneran" 34(8), 35(14) Correct "Iodi" to "Iotti" 39(14) Correct "are sufficient" to "are not sufficient" 43(13-14) Correct "winder" to ' liner" 45(5-6) Correct "Comanche Peak response team QA/QC program deviation report" to "Comanche Peak Response Team QA/QC Program Deviation Report" 48(24) Correct "filtered" to "fitted" 50(12) Correct "is a CPRT program director" to "is the CPRT program director" 50(15), (19), (21) and Correct "safe team" to l
/ 51(3), (E), (10) "Safeteam" 51(2), (17) and Correct "CRPT" to "CPRT"' '
52(10) i
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CORRECTIONS AND SIGNATURE 2 PAGE LINE CORRE
CTION ---- REASON FOR CHANGE 3
4 5
6 l l
7 8 I 9
10 11 12 1, JOHN W. BECK, have read the foregoing 13 deposition and hereby affix ny signature that same is 14 true and correct, except as noted herein. :
15 16 i l
JOHN W. BECK ;
17 !
18 i 19 SUBSCRIBED AND SWORN to before me by the said !
1 20 witness on this the______ i day of____________, 1987. '
21 22 23 NOTARY PUBLIC IN AND FOR THE STATE OF TEXAS 24
- 25 My commission expires:
UNITED AMERICAN REPORTING SERV 1cEs. TNr.
ny,awven gwn ~ ~ . ,,e , . . . .- , , +.w v .e - ,
A 55 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 4:00 o' clock p.m., at the 8 offices of Worsham, Forsythe, Sampels & Wooldridge, 9j 2001 Bryan Tower, Suite 3200, Dallas, Texas, the i
10 following named person, to-wit: JOHN W. BECK, who 11' was by me duly sworn to testify the truth and nothing k
12j but the truth of his knowledge touching and 13 concerning the matters in controversy in this cause; i
14; and that he was thereupon examined upon his oath and i
15; i his exanination reduced to writing under my -
16l supervision; that the deposition is a true record of i i
1 7 .' the testimony given by the witness, same to be sworn 18 and subscribed to before any notary public, pursuant 19 to the agreement of all parties.
20 l
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 a ct i on in which this deposition is ,
24 taken, and further that I am n'o t a relative or 25 employee of any attorney or counsel employed by the ,
i f
, UNITED AMERICAN REPORTING SERVICES. INC.
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A 56 1
parties hereto, or financially interested in the 2 action.
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 ,
9
_ _ _ _ _ IAG- ______________
JAMES (M. SHAW, RPR, CSR IN AND FOR THE STATE OF TEXAS 10 2414 North Akard, suite 600 Dallas, Texas 75201 11 (214) 855-5300 12 l.
My commission expires: :
13 December 31, 1988 l
CSR No. 1694 i 14 '
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25 UNITED AMERICAN REPORTING SERVICES, INC.