ML20149E541
| ML20149E541 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/16/1987 |
| From: | Streeter J TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| Shared Package | |
| ML20149A806 | List: |
| References | |
| FOIA-88-37 OL, NUDOCS 8802110126 | |
| Download: ML20149E541 (98) | |
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1 1 UNITED 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. ) DOCKET NOS. 50-445-OL 6 ) 50-446-OL (COMANCHE PEAK STEAM )
7 ELECTRIC STATION, UNIPS 1 )
AND 2) )
9 10 **************************
ORAL DEPOSITION OF 11 JOHN FRANKLIN STREETER OCTOBER 16, 1987 12 ***********************'**
, ,r 13 14 15 ORAL DEPOSITION OF JOHN FRANKLIN STREETER, 16 produced as a witness at the instance of the 17 Intervenor CASE, taken in the above-styled and numbered cause on October 16, 1987, at 8:45 a.m.,
18 19 before James M. Shaw, RPR, certified Shorthand 20 Reporter and Notary Public in and for the State of 21 Texas, at the Law Offices of Worsham, Forsythe, 22 Sampels & Wooldridge, 2001 Bryan Tower, Suite 3200, 23 in the City of Dallas, County of Dallas, S t a *. e of 24 Texas, pursuant to the Federal Rules of Civil 25 Procedure. '
8002110126 800120 \ '~
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DALLAS, TEXAS (214) 855-5300 -
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2 1
3 FOR THE NUCLEAR REGULATORY COMMISSION:
4 JANICE E. MOORE Office of the Executive Legal Director 5 United States Nuclear Regulatory Commi ssion 6j Washington, D.C. 20555 7:
FOR THE CITIZENS ASSOCIATION 8' FOR SOUND ENERGY: .
9 JUANITA ELLIS, PRESIDENT JERRY ELLIS 10 1426 South Polk Dallas, Texas 75224
, 11 12 BILLIE P. GARDE Trial Lawyers For Public Justice 13- 3424 North Marcos Lane
- Appleton, Wisconsin 54911 14 ,
15' FOR TEXAS UTILITIES GE NE RA TIN G COMPANY: l 16- ROPES & GRAY 225 Franklin Street 17! Boston, MA 02110 BY: WILLIAM S. EGGELING 18 i
ROPES & GRAY 19' 1001 Twenty-Second Street, N.W.
Washington, D.C. 20037 20; BY: ROBERT J. STILLMAN l DAVID MARTLAND 211 22 WORSHAM, FOPSYTHE, SAMPELS & WOOLDRIDGE 2001 Bryan Tower, suite 2500 23 Dallas, Texas 75201-2168 BY: ROBERT A. WOOLDRIDGE
, 24 25 UNITED AMERICAN REPORTING SERVICES, INC.
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22HE_I!nNghlg_SI3((Ig3, 2 the witness hereinbefore named, being 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 EXAMINATION 7 By_MS._gARggs 8 Q. All right. Mr. Streeter, my name is 9 Billie Garde, and I'm an attorney and I represent thei 10 Citizens Association for Sound Energy. And your 11 deposition is being taken in the context of the 12 Comanche Peak licensing hearing. )
13 MS. GARDE: Before we start, I would i
14 like to go around the table and have the people who 15 are present for this deposition identity themselves. l l
16 Janice. '
17 MS. MOORE: Janice Moorv, counsel for .
6 I
18 NRC Staff.
19 MR. M A RTLAND: David Martland with 20 Ropes & Gray.
l 21 MR. EGGELING: William S. Eggeling. l 22 Ropes & Gray.
23 MR. STILLMAN: Robert Stillman, 24 Ropes & Gray.
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- 25 MS. GARDE: And, Mr. Stillman, you UNITED AMERICAN REPORTING S E RVI C E S , INC.
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will be the primary attorney representing ,
2 Mr. Streeter in this action?
3 MR. STILLMAN: At this deposition, 4 yes.
5 MS. GARDE: All right. I would like 6 to mark as Exhibits 1 and 2, the subpoena and notice 7j of deposition for Mr. Streeter.
8 (Streeter Exhibits 1 and 2 i
9; i
(marked for i den t i f i ca t i on . ' ,
10 Q. (BY MS. GARDE) Mr. Streeter, I'm going to 11 show you what has been marked as Exhibits 1 and 2, 12l and ask if you have seen these documents before?
- 13; (Witness perusing document. f l !'
14l A. Yes. Yes, I have.
15! Q. When did you see them?
16 A. I don't recall exactly. It was some 17 time ago, 18l Q. Did you bring any documents with you in 19 response to this deposition --
20 A. No.
21 Q. -- notice?
22 A. No.
23 Q. Were you asked by your attorney to bring 24 any documents? l
);
25 A. No. -
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5 1 MR. STILLMAN: Slow down.
2 Q. (BY MS. GARDE) Would you please state i 3 your full name for the record?
4 A. John Franklin Streeter.
5 Q. How long have you been employed by Texas 6 Utilities?
7 A. Approximately two years.
8 Q. Prior to working for Texas U t i i. i t i e s ,
9' where did you work?
10 A. With the Nuclear Regulatory Commission.
11 Q. Yhere were you stationed?
12 A. Approximately eight years in the t 13 Region III office in Glen Ellyn, Illinois. '
14 Approximately five years prior to that, in the Region l ;
i 15 I office in King of Prussia, Pennsylvania. !
16 Approximately two years prior to that, Bethesda, j 17 Maryland, headquarters. 4 18 Q. While you were at Region III, what were .[f L '
19 20 your duties?
f{ >
A. I held va r i ou s positions --
managerial ,
21 supervisory positions for the txecution of the NRC ' '
22 inspection program for the f acilities within 23 Region III. .
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. 24
- Q. All f aciliti es ?
25 A. Nuclear power plants.
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6 1 Q. Were you assigned to any special plants, 2 or were you a branch cheif or section chief of some 3 type?
4 A. Section chief, branch chief, technical 5
assistant to the director of division reactor safety, 6 Q. Did you have any special duties during 7
your eight years in Region III with regard to quality 8;'
W control or quality assurance. issues?
- 9. A. Yes,
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10; Q. What were those?
11 A. !
I managed and supervised personnel who '
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- 12. were in the quality assurance section.
13I Q. And in your managerial and supervision !
i I 14; functions, did you review their work products?
15! A. Yes.
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16: O. And briefly, what did you do at Region I?
I !
i 17 A. I was an inspector.
18l Q. Assigned to a specific plant or out of the 1
19 region office?
20 A. I was out of the region office, assigned
- 21. to specific p.1 ants most of the time I was there. ,
22 Q. All right. What plants?
23 A. Indian Point, Maine Yankee. Yankee Row.
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,24 Q. Prior to going to work for the NRC, you 25 have two other years previous there. In Bethesda, UNITED AME RI CA N RE P ORT ING. .S E RV I CE S , INC.
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7 1 did you work for the nuclear power industry?
2 A. The two years that'I explained that 3 1 --
When I worked in NRC headquarters, it was in the 4 division of reactor standards.
5 Q. Okay. prior to working for the NRC, did 6 you work for another company in the nuclear power 7 industry? I 8 A. Yes.
9 Q. What company was that?
i 10 A. Douglas United Nuclear. ;
11 MR. STILLMAN: Slow down.
12 Q. (BY MS. GARDE) Where is Douglas United 13 Nuclear located? l t
14' A. Richland, Washington. i i
15 Q. Do you have a prof essi onal degree in i
16 engineer;ng? l l
17 l A. No.
18 Q. What is your educational background?
19 A. I have a assoc. ate of arts degree in 20 mathematics, bachelor of arts degree in economics, 21 and I received my nuclear training in the U.S. Navy 22 nuclesr power program.
23 Q. Were you on a submarine?
24 A. Yes.
25 Q. When you wont to work for Texas Utilities, UNITED AME RI CAN REPORTING S E RV I C E S , I N C..
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8 1 did you go to work directly from the Nuclear 2 Regulatory Commission, or did you retire first, ha ve 3 a period of unemployment?
4 A. That's correct.
5 O. Who made you an offer of employment at 6 Texas Utilities?
7 A. Bill Counsil.
i 8l u. Had you met Mr. Counsil prior to his 9l, giving you an offer of employment for your current 10fposition?
I 11! A. Yes.
I 12 j Q. When was that?
13} A. I don't recall the e xa ct date, but it was 14! when Mr. Counsil was the plant manager at Millstone.
15 Q. Do you remember --
not maybe the specific
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16 ! date, but do you remember when you received an offer 17 of employment from Mr. Counsil?
18 A. Approximately October 1985.
19' O. The NRC has regulations regarding leaving 20 the industry -- leaving the agency and going to work l
21' for the industry, don't they, NRC regulations? It is 22 a question.
23 MR. STILLMAN: You are asking him his
. 24 awareness --
25 MS. GARDE: Of those regulations.
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MR. STILLMAN: --
that you are 2 representing in fact are the case?
3 If you can, answer them.
4 !
A. Yes.
5 Q. (BY MS. GARDE) And your acceptance of the 6 position at Texas Utilities was direct from the 7 agency to the industry, wasn't it?
8 A. Yes.
9 Q. Okay. Did you make a determination on 10 whether or not you were violating those regulations?
11 MR. STILLMAN: Hold on. Are you 12 asking Mr. Streeter whether he made a legal 13 determination on a certain point?
14 MS. GARDE: Well, I'm not asking him 15 about a legal determination. I'm asking him if he 16 made a determination.
17 MR. STILLMAN: Well, I'm trying to l 18 figure out what kind of determination, other than a 19 legal determination, you could be referring to. I'm 20 having difficulty. Perhaps you could help me. I 21 Q. (BY MS. GARDE) Mr. Streeter, does it 22 require an attorney to read the regulations and 23 understand them?
24 A. No.
25 Q. Did you understand the regulations that UNITED AMERICAN REPORTING SERVICES, INC.
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2 A. Yes.
3 Q. Did you read and understand the section of 4 the regulations regarding going to work directly for 5 the industry?
6 A. Yes.
7 Q. When Mr. Counsil offered you a job 8 directly from the NRC, did you make a determination 9 whether accepting that employment was not in 10 j accordance with the regulations, as you understood 11 ! them?
l 12 MR. STILLMAN: I still am confused as 13 to what kind of determination you are asking 14 Mr. Streeter about.
15 MS. GARDE: I just want to ask the 16- question. I'm asking him what he did in his mind at 17 the time that the job was offered. I'm not asking 18 him for a legal determination on whether or not that 19 was correct, or whether or not he vi ola t ed that. I 20 want to know if he made a determination at the time 21 the job was offered. It is a simple question, and 22 I'm sure the answer is --
I'm sure I know what the 23 answer is. I'm not asking him for a legal 24 determination.
l 25 MR. STILLMAN: Maybe we are just
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1 11 i 1 getting held up on semantics. Are you trying to ask 2 him whether he thought he was breaking the law at the 3 time he accepted the proposal?
4 MS. GARDE: No, that is not what I'm 5 asking.
6 MR. STILLMAN: Why don't you ask the t
7 question again. :
l 8 MS. GARDE: I have a pr el i mi nar y 9 question. I want to know if he thought about it.
10 A. Yes.
11 Q. (BY MS. G A RDE ) All right. Did you 12 personally, without the aid of an attorney, make a 13 conclusion regarding whether or not accepting 14 employment with Texas Utilities was acceptable under !
15 the regulations as you understood them?
16 A. I Yes, but I had questions. i 17 Q. Did you contact anyone for advice 18 regarding those questions?
19 A. Yes.
20 Q. Okay. Who did you contact for advice?
21 A. NRC legal staff.
22 Q. In Washington or in Region III?
23 A. Both.
. 24
- Q. Okay. Did they provide you a 25 determination?
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12 1 A. Yes.
2 Q. All ri ght . Was that determination 3 provided to you in writing?
4 A. Yes.
5 Q. When you accepted employment with 6 Texas Utilities, had you been to the Comanche Peak 7
site at the time you accepted the employment?
8 MR. STILLMAN: Could you read that tr 9 question back, please?
t 10' (Record read back.
11 A. No.
12;I THE WITNESS: May I get me a cup of 13; coffee, please?
14 MS. GARDE: Oh, yes. Off the record.
15' (Off-the-record discussion.
16' O. (BY MS. GARDE) Mr. Streeter, while you 17 were employed by the Nuclear Regulatory Commission, I,
18 did you testify in licensing proceedings?
19 A. No.
20 Q. Did you ever have your de pos i t i on taken?
21 A. Yes.
22 Q. So this is not the first de pos i ti on you 23 have ever had taken?
24- A. No.
25 O. When was your first trip to Texas UNITED AMERICAN REPORTING S E RV I C E S , INC.
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2 A. Approximately October 1985.
3 Q. 'During that trip, did you go to the-4 Comanche Peak site?
5 A. No.
6 Q. Did you meet with Mr. Counsil?
l 7 A. Yes.
f 8 Q. Oka y . Did you meet wi th other individuals i
9 besides Mr. Counsil? e 10 A. Yes.
I 11 Q. Okay. Who were those other individuals?
12 A. Roy McCann. I believe his title at that 13 time was director of personnel. ;
14 Q. Okay. I 4
i 15 A, John Beck, Mike Spence. I 16 Q. Prior to that meeting in October of 1985, 17 had you met Mr. John Beck?
18 A. Not that I remember.
19 Q. Had you met Mr. Spence?
20 A. No. i i
21 Q. Okay. How long a time period were you in l 22 Texas for that meeting?
23 A. I would like to clarify that there were 24 two interview trips.
25 Q. All right.
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2 Q. Both in October '85?
3 A. Approximately.
4 Q. All right.
5 A. They were separated about one month. !
l i
6 Q. Okay. '
7l A. The first trip was one day. The second 8 trip was, I believe, three days.
I 9' O. Okay. The meeting that you have just 10,1 described with Mr. McCann, Mr. Beck, and Mr. Spence, 11! was that on the first one-day trip?
I 12! MR. STILLMAN: I don't think that the 13 testimony is clear that he referred to a specific ;
14] meeting, but rather only to ha vi n g met those 15l; individuals. Whether it was in one or more meetings l 16 or in the hallway, I don't think it is clear on the 17 record. Pe r ha ps you want to clarify that.
18 Q. (BY MS. GARDE) Okay. During the one-day i
19 trip, did you meet with Mr. Counsil?
20 A. Yes.
21 Q. Did you also meet with Mr. Beck?
l 22 A. Not as I recall.
23 Q. Did you meet with Mr. Spence?
I .
24 A. No.
25 Q. Did you meet with Mr. McCann?
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~1 A. Not that I remember. ,
2 Q. So -- 'l Well, did you meet with anyone l besides Mr. Counsil on the one-day trip?
l 3
4 A. Not that I remember.
5 O. All right. During that trip in which you 6 visited with Mr. Counsil, did you review any 7
documents about Comanche Peak?
8 A. No.
9 Q. Did you know during that one-day trip what 10 position Mr. Counsil was interested in hiring you for?
11 A. Yes.
12 Q. Is that the position that you have today?
13 A. No.
14 Q. Okay. What position was that?
15 A. E xe c u t i ve assistant to the executive 16 vice-president, nuclear engineering operations.
17 Q. Was that e xecu ti ve vi ce-pr e si dent in !
18 operations under Mr. Counsil? !
19 A. Yes.
20 Q. Now, you testified that there was a second 21 trip approximately a month later; is that correct?
22 A. Yes.
23 Q. Okay. And that trip lasted for three days?
24 A. Yes.
l 25 O. Okay. During that trip, did you go to the UNITED AMERICAN REPORTING SERVICES, INC.
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16 1 Comanche Peak site?
2 A. No.
3 Q. Did that three-day trip take placa all in 4 Dallas?
5 A. No.
6 0. Okay. Where else did you go?
7 A. Kennefick, Oklahoma. i' 8 Q. I can't pacs this question up. Why did i
9l you go to Kennefick, Oklahoma? 6 1
10l A. My sister and her husband reside there, i
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l 1 11 Q. All right. Texas Utilities didn't pack 12 you into a helicopter and take you to their secret 13 nuclear plant in Kennefick, Oklahoma, did they?
14 Strike that.
15 Regarding the business aspect of your trip, 16 did you go anywhere besides Dallas?
17 A. The metroplex area.
18 Q. All right.
19 A. No.
s 20 Q. During those three days, did you ha ve a 21 separate meeting with Mr. Spence alone between you 22 and Mr. Spence?
23 A. No.
24 Q. Okay. Was there a series of meetings that 25 occurred during those three days?
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17 1 A. You might say that. I met with the 2 individual --
either in pairs or individually.
3 Q. Okay. During that time. period, were you 4 still being considered for the executive assistant to 5 the executive vice-president, is that still the 6 position that you were functioning under or in? 3 7 l A. Yes. ;
8 Q. Okay. Had you been actually hired by'the 9 time of the three-day trip?
l ') A. No.
11 Q. Okay. Did you review any documents about 12 Comanche Peak on that trip?
13 A.
Need to make a clarification on the first 14 and second trip. I reviewed the TU Electric annual 15 report. Within that annual report, there is one 16 section devoted to the status of the Comanche Peak '
17 project. I read that, and that is the extent of the 18 documents. 1 19 Q. And that goes to both trips?
20 A. Yes.
21 Q. Okay. '
Now, what is the date that you 22 actually were hired by Texas Utilities?
23 A. First date of employment was either 24 No'vember 30th, 1985 or December 1st, 1985.
i 25 Q. At the time that you were hired, what was i
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2 A.
Executive assistant to the executive 3 vice-president, nuclear engineering and operations.
4 Q. How long did you function in that position?
5 A. Approximately three and one-half months.
6 Q. During the time that you were in that 7 position, were you based in the Dallas area?
8; A. Yes.
I 9' O. Okay. During that time period, did you 10 work directly for Mr. Counsil?
lif !
A. Yes.
12 t O. Okay. During that three and a half month 13 time period, did you re vi ew documents regarding the 14 j comanche Peak plant?
l 15' A. Yes.
16 Q. What documents did you review?
17 A. I do not recall all of them. Some of them 18 were the CPRT program plan. And many others; I don't 19 recall the individual documents.
20 Q. All right. Do you recall --
Strike that.
21 Did you review the Lobbin report?
22 MR. STILLMAN: Do you want him to 23 restrict his answer to that particular time period 24 you are talki ng abodt ?
25 MS. GARDE: Yes. Thank you.
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19 1 Q. (BY MS. GARDE) During that three and a 2 half month time period?
3 A. No.
4 Q. Have you ever reviewed the Lobbin report?
5 A. I'm not certain.
6 Q. All right. Do you know what the CAT 7 report is for Comanche Peak?
8 A. Yes.
9 Q. Okay. During this three and a half month 10 period, did you review the CAT report?
11 A. Yes.
12 Q. Do you know what the SIT report is?
13 A. Yes.
14 Q. During this three and a half month time 15 period, did you review the SIT report? ;
16 A. No. i l
t 17I Q. Have you ever reviewed the SIT report? l 18 A. I am not certain.
19 Q. Did you --
Strike that.
20 Are you familiar with the ASME audits done 21 on Brown & Root's OA/QC program?
22 A. I am familiar that they were conducted.
23 l'm not familiar with each individual audit that was 24 conducted.
25 Q. During the three and a half months that
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I 20 1 you were the assistant to the executive 2 vice-president --
3 MR. STILLMAN: Executive assi stant .
4 Q. (BY MS. GARDE) Executive assistant to the 5 executive vice-president, did you review any of the 6 ASME reports on the Brown & Root QA/QC program?
7 A. No.
8f O. Have you ever?
9; A. Yes.
I 10 l! Q. Are you familiar with the INPO report i
11! regarding Comanche Peak?
I 12' A. Yes.
13 Q. During that three and a half months that 14 you were the executive assistant to the executive
- 15. vice-president, did you review the INPO report?
16' A. Yes.
17 Q. Are you familiar with the report of the 18 Management Analysis Corporation of 1978 regarding 19l Comanche Peak?
20 l: A. Yes.
I 21 O. During the three and a half months that we 22 have been discussing, did you review the MAC report?
23 A. No.
. 24 Q. Have you ever reviewed the MAC report?
25 A. Yes.
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21 1 Q. During the three and a hal f months that we 2 are discussing, did you re vi ew Region IV inspection 3
reports about Comanche Peak up to that time frame?
4 A. Would you clarify that, please?
5 Q. Okay. What part of the question don't you 6 understand?
7 A. Are you asking did I review all of the 8 inspection reports up to that time?
9 Q. Well, let me ask you if you reviewed all i i
10 of them? !
I 11 A. No.
4 12 Q. Did you review some of them? i 13 A. Yes.
l 14 Q. Do you remember which ones you reviewed?
15 A. One was the CAT report.
I 16 Q. Okay. My question goes to specifically l
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17 Region IV inspection reports, not just the CAT report, 18 but the SIT --
or the SIT report?
19 A. I don't recall.
20 Q. Are you familiar with annual prudency 21 audits?
l 22 A. No.
23 Q. Okay. Are you familiar with annual 24 retrospective audits?
25 A. No.
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22 1 Q. Did you review any annual or prudency 2
audits during the three and a half months that you i 3 were the executive vice-president?
4 A. No.
5 MR. STILLMAN: Sorry. Did you say 6 that he was the executive vice-president?
7 MS. GARDE: Oh, I might have said 8 that. I'm sorry. So many executives and assistants, 9l I'm getting mixed up.
i 10j MR. STILLMAN: Mr. Counsil perhaps I
11l might object to that.
12 MS. GARDE: I don't know. He might 13 or migh>c not.
14' O. (BY MS. G A RDE ) Are you familiar with the 15 proposed findings on the Walsh Doyle allegations 16 prepared by CASE?
17 A. No.
18 Q. You have never reviewed that document?
19 A. No.
20 Q. Are you familiar with the Atomic Safety 21 and Licensing Board's December 1983 order regarding 22 quality assurance for design?
23 A. I'm aware of its existence.
24 Q. Have you ever read it?
25 A. No.
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the harassment and intimidation issues in the Atomic 3 Safety and Licensing Board, Docket 27 4 A. Yes.
5 O. Have you read the proposed findings of 6 CASE 7 7 A. No.
8 Q. Have you read the proposed findings of the 9 company?
10 A. No.
11 Q. During the three and a half months that 12 you were the e xecu t i ve assistant to Mr. Counsil, did 13 you r e vi ew any of the transcripts or testimony from 14 the Atomic Safety and Licensing Board hearings?
15 A. Not that I recall.
16 Q. Did you r e vi ew the reports of the 17 technical review team?
18 A. To some extent.
19 Q. After leaving the position of executive 20 assistant, have you read in detail the SSERs 21 prepared by the technical review team?
22 MR. STILLMAN: Could you help me out 23 and explain what you mean by "read in detail" as 24 opposed t o "read" or "review" that you used in your 25 other questions?
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24 1 MS. GARDE: He said "to some extent" 2 in his other answer. I want to know if he compl et el y 3 read the technical review team reports in the SSERs.
4 MR. STILLMAN: From cover to cover?
5 MS. GARDE: From cover to cover.
6 A. No.
7 Q. (BY MS. GARDE) Have you reviewed the 8 summaries of those reports?
9 A. I believe so.
10 j Q. Okay. Have you reviewed summaries of the 11' SSERs prepared for you by someone else?
12, A. No.
I 13 Q. Okay. After spending three and a half 14 l months as the executive assistant, what position did i
15 you move into?
16 A. Director of quality assurance. ,
17 Q. During the time period that you were the 18 executive assistant, did you know that you were going 19 to be moving into the position of the director of QA?
20 A. Not until I was extended the offer.
21 Q. When was that?
22 A. Approximately January of 1986.
23 Q. Okay. Going back to the time period that 24 you were executive assistant to Mr. Counsil, what 25 were your duties in that position?
l UNITED AMERICAN REPORTING SERVICES, INC.
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25
, 1 A. Principally as a technical assistant.
2 Q. Okay. What did that -- What did you do as 3 a technical assistant?
4 A. Two tasks that I recall Mr. Counsil having 5 me involved with were the ca bl e tray hanger matter 6 that cane up in December of 1985 and the Bahnson 7 matter that came up also in December 1985. i 8 Q. And as a technical assistant to i 9 Mr. Couns, what were your tasks? What were you 10 supposed to do?
11 A. To go to the site and review those matters 12 and advise him on my recommendations.
13 Q. Did Mr. Counsil ask you to determine why 14 the CPRT program plan had not identified the ca ble i 15 tray hanger issue? i 16 MR. STILLMAN Objection. f 17 MS. GARDE: There is --
I withdraw
, 18 the question.
19 Q. (BY MS. GARDE) Is it your understanding 20 that the CPRT program identified the ca bl e tray 21 hanger issues?
22 MR. STILLMAN: Could you help out and 23 specify what cable tray hangers you are talking about,i 24 and then what time period? ;
25 MS. GARDE I think he understands.
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1 Q. (BY MS. GARDE) But will you please 2 briefly state what the cable tray hanger issue is 3
that arose in December of 19857 4 A. The issue basically related to the 5
creation of as-built documentation for the cable tray 6 hangers.
7; Q. What was problematic about that? Why was 8; that an issue?
i 9' A. The program that was established by TU to I l
10 develop that as-built documentation developed I*
11 problems on the accuracy of the inf ormati on it was 12 developing.
I 13 Q. Okay. Now, who brought those problems to 14; the attention of Mr. Counsil? 2 15' A.
I believe it was the NRC.
16j Q. Okay. Now, as to the Bahnson problem, 17 l what is the Bahnson problem that you referred to from i
18{ December of 1985?
i 19 A. Basically, that issue relates to the 20! as-built condition of the HVAC system, not being 21 correctly reflected in documentation.
22 Q. Who brought that attention to the issue of 23 Mr. Counsil?
24 MR. STILLMAN: I think you may have 25 reversed words in the sentence. Could you read back UNITED AMERI CAN REPORTING SERVICES, INC.
. ~ . . . s .m n . m o m.o.~ . mo n ~ s < . .e a.o a.v.c c . w 27 1
1 the question?
2 MS. GARDE: Well, J. e t me just ask it.
3 Q. (BY MS. GARDE) Who told Mr. Counsil about 4 the Bahnson problem?
5 A. I don't recall specifically who told 6 Mr. Counsil, but the information was initiated within i
7 the TU organization, engineering organization. i
& Q, All right. As to the cable tray hanger l 9 issue, set aside Bahnson for a minute, was 0
i 10 Mr. Counsil's instruction to you to determine why l 11 TU had not found the problem first?
12 A. I do not recall that specific instruction. ,
13 O. Is that one of the things that you looked i
14 at when you went to the site?
15 A. Yes.
16 O. Did you reach a conclusion as to why Texas i
17 Utilities did not find the problem first?
18 MR. STILLMAN: I realize that you are 19 in the stage of asking background questions, but it 20 does strike me that you are going fairly far afield i 21 from the concept of CPRT program plan adequacy. !
22 Could you tell me how this line of que s ti ons relates 23 to that topic?
24 MS. GARDE: No, I don't need to tell 25 you that. If you want to object and direct him not UNITED AMERI CAN REPORTING SERVICES, INC.
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to answer the question, I will take it up with the i
2 Court. I'm just not going to spend time on this 3 record arguing with you. If you know the history of 4 this program and the history of the plant, you will 5 know how this fits in. If you have a problem with 6 that, you will have to make a judgment call.
7 I'm not --
I'm just not going to take the time to 8l explain it to you.
9 MR. STILLMAN: Could you read back 10, the question, please?
11 (Record read back.
I 12' (Off-the-record discussion I
13l (between Mr. Stillman and 14, (Mr. Streeter.
15lj A. Yes.
1 i
16 j Q. (BY MS. GARDE) I forgot the question.
17 "Yes" what?
18 A. The question, as I understood it, was; Did 19 I develop a conclusion regarding why --
20 0 All right, thank you. I apologize.
21 What was that conclusion?
22 A. I do not remember all of the details, but 23 basically it amounted to both engineering and the QC 24 or gani zat i on not devoting sufficient oversight to the 25 conduct of the program.
l
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1 Q. When you say "conduct of the program," are 2 you referring to conduct of the CPRT program?
3 A. No. Cable tray hanger program.
4 Q. As a part of the regular Texas Utilities 5 project effort?
6 A. That's correct.
7 Q. Now, going to the Bahnson issue, what did j
8 you --
Strike that. '
9 What were your instructions regarding 10 looking at the Bahnson problem for Mr. Counsil?
11 A. Same instructions as with the cable tray 12 hanger.
13 Q. Did you reach conclusions about why Texas ,
i 14 Utilities had not caught the Bahnson problem earlier? !
15 MR. STILLMAN: I believe your 16 question reflects perhaps a forgetting of ,
17 Mr. Streeter's earlier testimony, I b e l l e '.' e , and the 18 record will reflect what the testimony is; that 19 Mr. Streeter testified that this was an issue that 20 was brought up through the Texas Utilities l
21 organiration. 1 22 MS. GARDE: My question assumes that.
23 I asked him why they didn't find it earlier.
. 24
- MR. STILLMAN: All right.
25 A. Could you repeat the question, please?
UNITED AMERICAN REPORTING SERVICES, INC.
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Let me bring you back up on Bahnson. What was 3 the problem wi th Bahnson that you are referring to 4 that was discovered in December 1985?
5 A. The as-built documentation did not agree 6 with field conditions or analyses.
7 Q. All right. And the as-built co nd i ti on of the HVAC system that you are referring to, how long 8l 9 had that !!VAC system been in place?
10, MR. STILLMAN: Prior to what?
11! MS. GARDE: Prior to December '85.
12 ! A. I don't recall exactly, but it was several .
13 years.
14! Q. (BY MS. GARDE) At the time that the
- 15. problems were discovered in December 1985, as you 16 testified earlier, they were discovered by Texas 17 Utilities theeselves; is that correct?
18 A. That is correct.
19 Q. All right. When you went to the site to 20 look at the Bahnson issue, is one of the thi ngs that 21 you were looking at to determine why it had taken co 22 long to discover the problems with Bahnson, HVAC 23 system?
24 A. That was'not one of the things I was 25 specifically looking at.
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31 1 Q. Okay. Did you reach a conclusion on that 2 issue?
3 A. Yes.
. 4 Q. What was that conclusion?
5 A. That the oversight of this particular 6 contractor by TU Electric was not as technically 7 oriented as it could have been.
8 i Q. Did you commit that conclusion to writing?l 9 A. I don't believe so.
10 Q. Did you communicate that conclusion to #
1 11 Mr. Counsil?
i 12 A. I do not recall. '
4 13 Q. Did you communicate that conclusion to the 14 CPRT?
15 A. No.
16 Q. Have you ever communicated that conclusioni l
17 ' to any member of the CPRT?
18 A. Not that I recall.
19 Q. Did you prepare 5055-E report?
20 A. Not personally.
21 Q. It is true that a 5055-E report was 22 prepared on the Bahnson issue, isn't it?
23 A. Yes.
24 Q. And you didn't prepare it?
- 25 A. No.
1
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32 1 Q. Did you. review it?
2 A. Yes.
3 Q. Prior to it being forwarded to the NRC?
4 A. I believe so.
5 Q. Okay. Did you --
Strike that.
6l Do you remember if the 5055-E report 7i included a statement to the effect that your i
8l conclusion --
your personal conclusion was 91 communicated to the NRC by someone else about the 10, potential cause of the problem?
I 11l MR. STILLMAN: Could you read back i
12' that question?
13 (Record read back. I I. !
14! Q. (BY MS. GARDE) That was confusing. Let i
15 ! me redo it. You read the 5055-E report; is that 16, I
correct?
17 A. That's correct.
18 Q. Okay. You read it before it w4nt to the 1 91 NRC?
20' A. I believe so.
t 21 !
Q. All right. Do you have a specific 22 recollection about what the 5055-E report contains?
23 A. No.
1 . 24 Q. All right. When you took the po s i ti on as 25 QA director, who did you replace?
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33 4
1 A. James Wells.
2 Q. Mr. Wells had been on loan from Duke Power 3 Company; is that correct?
4 A. That i s correct.
5 Q. Prior to meeting Mr. Wells in connection !
6 with your work with Texas Utilities, had you met !
t l
7 Mr. Wells at any other time?
I 8 A. No. I 9 Q. When you took over the position of QA ,
10 director, was Mr. Wells in an acting QA director f 11 position, or was he actually the di rect or ?
12 MR. STILLMAN: Are you asking 13 Mr. Streeter to recall what the title was?
14 MS. GARDE: Yes. !
i 15 Q. (BY MS. GARDE) What was his title?
1 l
16 A. Director of quality assurance. l 17 Q. So he wasn't acting in that role, he 18 wasn't acting in his title?
19 A. No.
20 Q. How long had he been the director of 21 quality assurance?
22 A. Approximately one year.
23 Q. Do you know why Mr. Wells was replaced 24 with you?
25 A. TU Electric wanted to have a permanent UNITED AMERICAN REPORTING SERVICES, INC.
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1 employeo in t ha t -po s i t'i on . That i's the, reason that 2 Mr. WeJ l9- w a s , r e pl a .c e d . '
3 'O. Mr. Wells was not a petmanent employee of 4 Texas Utilities?.
5 A. As you stated before, he was on loan from 6 Duke, always intended that he would be returning to 7 Duke at the completion of his assignment.
I ~
8j C'. Did M r. , Counsil ever inf orm you that you i
9l were replacing Mr. W111s'bec$c e of a concern about ' '
j . ,
10 Mr.' Wells' p e r f oim'a tt 'ce?
b 11! A. . s Mo . .. '
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12' O. ~ When you,' t ock 'ove r the poshtion 6f ,
m 13i director of quality a:k s u >r a n c e , did you meet with i - ,
1 4 ,' Mr. Ron Tolson? -
. - n i $
15: MR. STILLMAN:'1At any time while t
16 Mr. Streeter held that post?
17 MS. G A RbE Af ter whe took the 18 p o s i t.i o n --
19 Q (BY MS. GARDE) I guess my quest, ion is 20 going to immediately after that, you took --
you took 21 over the po s i t i on . '
22 -A. No.
23 ,
Q. Do you know whQ,Mr. Tolson is?
24 A. Yes.
25 O. Ckay. Did you review any of Mr. Tolson's
~
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performance evaluations for the time period that he 2 was the director of QA7 3 A. Mr. Tolson was never the director of QA.
4 Q. All right. What do you understand 5 Mr. Tolson's job was?
, 6 MR. STILLMAN: Sorry. What time 7 period? -
8 MS. GARDE: Up to 1985.
9 A. I recall Mr. Tolson's assignment to be 10 director of the site, QC or ga n i za t i on , or comething 11 close to that capacity. '
12 Q. (BY MS. GARDE) What is your understanding 13 of who was the director of quality assurance before 14 Mr. Wells?
I 15: A. Mr. Wells was the initial incumbent of 16 that position.
17 Q. Before that, there had been a different 18 organization; is that your understanding?
19 A. Yes.
20 Q. Oka y . What is your unde r s t an di ng of who 21 performed the duties that were part of your job 22 description pr i or to Mr. Well s ?
23 A. David Chapman. I i
, 24 -
Q. You are located at the site, are you not?
25 MR. STILLMAN: At present?
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2 A. My official job location is Dallas.
3 Q. (BY MS. GARDE) All right. How much time 4 of the time that you spend working do you' spend in 5 Dallas?
, 6 A. Less than 20 percent.
7 Q. Do you have an office at the Comanche Peak
- 8 site?
9, A. Yes.
I 10! Q. All right. What is your understanding of 11 who --
St rike that.
I 12 What individual prior to Mr. Wells 13 performed the director of quality assurance function, 14{ not the title, prior to Mr. Wells?
I 15! MR. STILLMAN: I'm sorry. Are you 16 asking a different question than the one that was 17 answered the name of Da vi d Cha pm o.. before?
)
18' MS. GARDE: I think I am, yeah.
19 MR. STILLMAN: Perhaps Mr. Streeter 20 understands the difference.
21 A. I would understand them to be the same 22 1
question, and --
23 Q. (BY MS. GARDE) You would?
24 A. Yes.
- 25 Q. All right. Do you know where Mr. Chapman UNITED AMERI CAN REPORTTNG ARRUTOPS- Tur
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37 1 spent most of his time?
2 A. No, I
I do not.
3 Q. All right.
Who briefed you on-the history i 4 I of quality assurance regarding the Comanche Peak '
5 plant?
, 6 A. Several people.
i 7: Q. Who were they?
8i A. Janes Wells, Dave McA f ee . At my request, 9-all of the supervisors in the reporting to Mr. McAfee.
10 Phillip Hal stead and some of his immediate 11 subordinates. This was not a special effort to where 12 I undertook to, say, to sit down with each of them in 13 a planned manner. It was just in the course of 14 f ul filling my duties, I periodically asked them, 15 became aware of information from facts.
16 Q. And how !
Do you know how long Mr. McAfee j 17 t had worked at the Comanche Peak facility?
18 A. Since approximately March 1985.
19 Q. How about Mr. Halstead?
20 A. Approximately the same date.
21 Q. And the subordinates that you referred to, 22 are those subordinates also new?
23 MR. STILLMAN: "New" meaning began --
24 MS. GARDE: Around the same time -
25 period, 1985.
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r 38 i A. No.
2 Q. (BY MS. GARDE) Okay. The subordinates 3
had been at the site for some timer is that your 4 understanding?
5 A.
Either at the site or in the Dallas office.
6; Q. Right. During I want to go back a l
7' minute to the time period that you were the executive 8 l' i assistant to Mr . Counsil. You testified that you I
9; reviewed the C P RT , that was one of the documents that 1 01 you reviewed. Do you recall that testimony?
i 11: A. Yes. i l
12 !
Q. Oka y . Were you asked by Mr. Counsil to 13 re vi ew that document?
14: A. No. '
l 15 Q. Okay. Why did you review the document?
i 16 A. I became aware of its existence, and I wasj 17 i nt er e s t ed .
18 Q. How did you become aware of its 19 A. I do not recall.
e x i s t en 20 Q. Did you have any duties regarding the CPRT 21 at that time?
22 A. No.
23 Q. Were you asked to give an opinion on any
. 24 aspect of the CPRT by Mr. Counsil?
25 MR. STILLMAN: At that time?
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MS. GARDE: At that time.
l 2 A. No.
3 Q. (BY MS. G A RDE ) Did you offer.Mr. Counsil 4 any opinions on the CPRT at that time?
5 A. No.
6 Q. okay. Did you form any opi ni ons or 7
conclusions about the program after r e vi ewing it t i
8 during that three and a half month time period?
9' MR. STILLMAN: Let's just make sure 10 we are clear. Are you talking now about the program ,
11 plan, as such, where the implementation of the plan ;
12 or the combination -- '
13 MS. GARDE: Well, he said he read the !
14 program plan. That is all I'm asking him about.
15 Q. (BY MS. GARDE) Did you form any opinions ;
i 16 or conclusions? i l
l 17 A. Yes.
18 Q. okay. What were those?
19 A. It is my view that it was a detailed 20 effort.
21 Q. Detailed effort to do what?
22 A. To address the problems as documented in 23 the individual action plans.
24 Q. Did you form an opi nion at that time 25 whether it was an adequate program to identify all nyymen aucercan n e n e - - . .. - - - - - - - - --
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40 1
deficiencies at the plant?
2.
i
! MR. STILLMAN: Are you using 3 "deficiencies" now in the technical sense which is 4 used in the program plan?
5 MS. GARDE: No. I'm using the term 6;
"deficiencies" to refer to all d e f i ci en ci es , failure 7!
to meet original commitments, nonconforming
. 8; conditions. Using the very broadest interpretation .
9 !,
of the word "deficiency," not connected in the 10 program plan.
11 i
MR. STILLMAN: Do you understand that 12' definition?
13i Q. (BY MS. G A RDE ) Usi ng that de f i .11 t i on , did 14 j i
you form an opinion as to whether or not the CPRT was 1 51 i
an adequate plan to identify all types of 16' d e f i ci en ci e s ?
17 A. No. '
18; Q. Okay. Have you ever formed an opinion as 19 to the adequacy of the CPRT to identify all forms of 20 deficiencies, nonconforming conditions, failure to 21 meet original commitments?
22 A. My opinion is yes.
23 Q. You have formed an opinion?
24 A. Yes.
25 Q. Okay. And that opi ni on is yes; is that t t y t er e n m u r n v a . .. = = = = - - - - - -
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3 41 1 your testimony?
2 A. Yes.
3 Q. During the time period that you worked for '
4 the NRC, were you ever involved in a major 5
re-inspection effort of a nuclear power plant under 6 construction?
7 MR. STILLMAN: As opposed to a minor 8 re-inspection effort?
9 I MS. GARDE: Yes.
10 MR. STILLMAN: Do you understand the 11 difference? '
12 Tile WITNESS: Yes. '
13 Q. (BY MS. GARDE) Okay. Yes, you understand. ,
1 14- the dif f erence? I I
I 15 A. Yes, I was involved --
i 16 Q. All right.
17 A. --
to answer your initial question.
18 Q. At which plant?
19 A. "Involved" meaning that I was --
In a 20 s uper vi sor y management capa ci ty, I was involved. Not 21 directly involved in making assessments for these 22 things. Byron and Bradewood.
23 Q. Okay. Only Byron and Bradewood?
24
- A. Zimmer.
25 O. .
What was your involvement with Zimmer?
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42 1 A. Zimmer, I was a branch chief, which was 2 responsible for that project in 19 --
I believe late 3 1981.
4 Q.. Did you maintain that position through the ,
5 rest of the Zimmer project?
. 6 A. No.
- 7 Q. When did you leave the work on the Zimmer
. 8 project?
9: A. As I recall, it was 1981, when the special 10 projects office was formed in Region III.
11 ~ 0. You were not part of the special projects 12, office?
I 13l A. No.
14i Q. In your work on Byron and Bradewood on the 15 re-inspection program, did you have an occasion to 1
i 16' meet with Mr. Hansel?
17 A. Not that I recall.
1 18' O. Did you overview any of the work by ERC at 19 either of those plants?
20 A. Not that I recall.
21 Q. Okay. Were you involved in writing any
. 22 inspection reports regarding ERC's compliance with 23 l those re-inspection programs at Byron and Bradewood? I 24 A. Not that*I recall.
25 Q. Did you supervise the inspectors who had UNITED AMERICAN REPORTING SERVICES, INC.
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2 A. Not that I recall.
3 Q. Did you supervise Ross Landsmant 4 MR. STILLMAN: At those particular 5 job sites?
6 Q. (BY MS. GARDE) Regarding those two job 7 sites?
t 8 A. No. !
9 (Recess.
10 MR. STILLMAN: Back on the record.
11 Before we resume questioning, Mr. Streeter wishes to 12 make a clarification at one point to his prior 13 testimony.
14 Q. (BY MS. GARDE) Where? !
I 15 A. It was the --
16 Q. Okay.
17 MR. STILLMAN: Go ahead.
18 Q. (BY MS. GARDE) Go ahead.
19 A. The question, as I recall, or as it was 20 asked me was: Had I formed an opinion as to whether 4
21 or not the CPRT program plan would lead to the 22 identification of all d e fi ci en ci es , broadly defined.
23 Q. Right.
24 A. My response was "Yes," as I recall.
25 Q. That was your response.
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44 1 A. Okay.
2 MR. STILLMAN: The response -- The 3 question and response exactly will be reflected in 4 the transcript, but go ahead.
5 A. My response was intended to mean that it 6 would achieve the CPRT program objective of 7 identifying any significant what you might call 8l deficiencies , meaning that any deficiency that would 9! draw any question to adequacy of design or 10 construction or the ability of the plant to be safely 11: operated; not every conceivable deficiency that might I
12; exist.
I 13! MR. STILLMAN: Broadly defined?
I I 14' THE WITNESS: Yes.
15, O. (BY MS. GARDE) During the break that we ,
i l 16- just took, did you look at the program plan objective?
17 A. No.
18! Q. Did you discuss this with your attorney?
l 19I A. Yes.
20 Q. Did you bring it to his attention, or did 21 he bring it to your attention?
22 MR. STILLMAN: Objection, direct the 23 witness not to answer that question.
. 24 MS. GARDE: Mark that question.
25 Q. (BY MS. GARD) What are your current UNITED AMERICAN REPORTING SERVTCES. TNr.
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45 1 duties at the site?
2 A. I am responsible for the quality assurance 3 organization which includes the quality control 4 organization.
5 Q. What do you do in that position?
6 A. Assure the effective execution of the 7 quality assurance program.
I 8 Q. Is it a managerial function?
9 A. Yes.
10 Q. Do you have a written job description?
{
11 A. Yes.
Q. Is one of the duti es that you are 12l 13 responsible for --
or people under your direction and 14 control are responsible for is preparing site 15 procedures?
16 MR. STILLMAN: Any kind of si te 17 procedures?
18 MS. GARDE: Any kind of site quality 1
19 control, quality assurance procedures. l i
20 A. Yes. '
21 Q. (BY MS. GARDE) Is there a specific 22 individual in your organization that writes all the 23 procedures?
Is there one individual that does that?
24 A. There is not one individual.
' t 25 Q. All right. Is there a process by which i
UNITED AMERICAN REPORTING SERV 1CE9. TNr.
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3 46 1 procedures are written?
2 A. Yes.
3 Q. Okay.
What is that process?
4 A. Process, as I recall it, for quality 5
cont.rol procedures are those procedures to be
. 6 developed within the quality control organization and i
I 7l l
reviewed by the supervisor of quality engineering and,-
8! I believe, the manager of quality control.
9 Q. Is there a procedure that covers the i
10f development of procedures?
11! A. Yes.
I I
12i O. Okay. Do you remember what that number is?
13 A. No.
14 Q. Do you remember what the title of the 15! procedure is?
16! A. No.
17 Q. Now, are there specific quality assurance 18' procedures that cover the communications between your 19 site quality assurance, quality control organization 20 and the CPRT?
21 A. I do not believe so.
22 Q. Okay. Is there a specific procedure that 23 covers transferring of information regarding 24 deviations, de f i ci enci es , and out of scope 25 obs er va t i ons , using those terms as they are used in UNITED AMERI CAN REPORTING SE RVI CES. TNr.
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47 1 the CPRT, to the project?
2 A. Yes.
3 Q. Okay. Did you prepare or review that 4 procedure personally?
5 A. Neither.
6 Q. Are you familiar with it? '
7 A. Vaguely.
8 Q. All right. When a procedure is reviewed 9 by someone in your department, what does that person 10 do?
11 MR. STILLMAN: You are talking about 12 procedures issued by his department now, I take it?
13 MS. GARDE: Issued by his department.
14 A. That individuals make sure the procedure o
15 is in the correct format as specified by the 16' procedure on how to write procedures. The individual ,
17 assures that the content complies with applicable 18 criteria. And then it will result in acceptable '
19 product.
20 Q. (BY MS. G A RDE ) Is that a different step 21 than when a procedure is approved, you said a review?
22 A. The preparer is the individual who is 23 developing the procedure and making sure all of these 24 t hi ng s are accomplished. The a pp r o va l is attesting 25 to the fact that someone has re vi ewe d that product UNITED AMERICAN REPORTING SERVICES. TNc.
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/
48 1
i and agrees that it is an acceptable procedure.
2 Q.
Is there a third step of approval by 3
someone in management in your or ga n i za t i on ?
4 A. I believe so.
5 Q. I'm going to show you a packet of 6
1 documents which was identified in a deposition 7
yesterday as Beck Deposition Exhibit 5. Is the first
- 8) page from a number of different documents?
9; i
MS. GARDE: Counsel, it is the same 10 ! document that you had yesterday.
11 i
(Witness perusing document.
12j Q. (BY MS. GARDE)
, I would like you, 13l Mr. Streeter, to look through the pages that are in i
l 4' front of you, and first identif y whether each is the 15 front page of a procedure generated in your office or 16- under your organization.
1 I'm not sure what is the 17 correct terminology.
18 (Witness perusing document.
19 A.
Yes, they were prepared within my 2 0 ;- organization.
21 Q. All right. Do you recognize the 22 signatures of the individuals on the page --
on the 23 first page of the deposition exhibit as --
24 MR.'STILLMAN: Do you want him to l
25 identify --
UNITE D AME R', CA N RFDooTT"" """"'"""
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49 1
MS. GARDE: The "prepared by," I want 2
to know if he recognizes that signature.
3 A. Not necessarily the signature. I 4 r e co gni z e the name --
5 Q. (BY MS. GARDE) Okay.
6 A. --
of the individual.
7 Q.
l So in this case, who is that individual? f' 8 1 n
MR. STILLMAN: Do you want the name? i 9! MS. GARDE: Yes. i 10 i MR. STILLMAN: Would you read the l
11 nane?
12 A. Doug Shelton.
13 Q. (BY MS. GARDE) All right. Mr. Shelton e
14 works in your office? :
l 15 A. Works in my organization. i i
, 16 Q. All right.
17 A. Yes.
18 Q.
And on the next line, the "approved by" 19 line, do you recognize the name of that in di vi d ua l ?
20 MR. STILLMAN: Just to clarify the 21 record, there are two "approved by" lines.
22 MS. GARDE: Okay. The second 23 "approved by" line or the middle "approved by" line.
24 '
MR. STILLMAN: No, there are two 25 "approved by" lines. l UNITED AMERTCAN Drono*'"a aa'"- ---
. . ... . . . ... ~ u . ......, . a n .o..u..a. u w a.>.s..,.
50 1 MS. GARDE: Right.
2 MR. STILLMAN: Do you want him to 3 identify the nane on the first or the second?
4 MS. GARDE: Yeah, the first.
5 MR. STILLMAN: The first.
6 A. It appears to be C. T. Brandt.
7: Q. (BY MS. G A RDE ) Does Mr. Brandt work in 8 your organization?
i 9l; A. Yes.
10' O. And the next line or the last "approved lli by" line, do you recognize the name of that 12 individual?
13 l A. Yes.
14i O. Okay. Who is that?
15 A. Phillip Halstead.
16 Q. All right. Now, you just describt ; t e ,
17 process of preparing and reviewing or approvin; 18 procedures. The document in front of you has three
, 19' lines. Is the process that you described in terms of 20; the preparer and the r evi ewer the same process that ;
i 21 I is i ndi cat ed by the signatures on that document in 22 front of you?
23 MR. STILLMAN: Could you read the
. 24 question back?
25 (Record read back.
UNITED AMERICAN REPORTING SERVICES, INC.
D A T.T.A R . Trvac ( 71 A \ o ^^
.......-.......ma-51 1 Q. (BY MS. GARDE) Well, let me clear it up.
( 2 You used the term "reviewed by," okay. This form has 3 the term "approved by." Is there a separate reviewed
?
4 function that is not indicated on the form with a 5 signature line?
6 A. I do not believe so.
7 Q. Okay. So when you were using the term 8 reviewed by first one person and then r e vi ewed by the, 9 head of the department, you were referring to the ,
10 term that is designated on this form as "approved 11 by," you were using them interchangeably; is that 12 correct?
13 MR. STILLMAN: I'm not sure that you 14 capt ured the right testimony completely accurately. !
15 Q. (BY MS. GARDE) What di d you testify about 16 that? What does "approved by" mean? j 17 A. "Approved by" means that individual has 18 read that procedure and concurs that it is acceptable.;
19 Q. Okay. There is no other reviewer function 20 regarding the procedures that you referred to in your ; ;
I 21 earlier testimony; is that true?
22 A. Not that I recall.
23 Q. Okay. On the last line of the signature
, 24 ,
lines, "approved by," in the case of Beck 5, it has
'25 Mr. H'a l s t e a d ' s name on it?
l l UNITED AMERICAN REPORTING SERVICES. INC. t DALLAS, TEXAS (214) 855-5300
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4 52 1
MR. STILLMAN: Referring to the first 2 page of Exhibit 5?
- e 3 MS. GARDE: Yes.
e 4 Q. (BY MS. GARDE) What does that signature 5 mean?
f
. 6 A. It means a second level r evi ew and i l 7l approval. When that is signed, it is acceptable for I ,
8' implementation.
9i Q. All right. Now, Mr. Brandt works in your 10;I organization; is that correct?
11! A. Yes.
12; Q. Okay. Do you know Mr. Brandt personally?
i 13! A. Yes.
I 14 l Q. Okay. What are Mr. Brandt's duties?
15! A. He is my assistant to the director for l
16j special projects. In that capacity, he responds to 17 my special requests for tasks as I assign them.
18;I Q. How long has he held that duty?
19 A. Since approximately January.
20 Q. Of what year?
21 A. '87.
22 Q. All right. Prior to January '87, did he 23 work in your department?
24 A. Yes.
25 Q. What were his duties prior to January '87 UNITED AMERI CAN REPORTING SERVICES, INC.
.,,,-....,.-nn,..n........-,.
53 1 during the time period that you were the director of 2 OA?
3 A. He was the supervisor quality engineering 4 reporting to Mr. Halstead in the quality control il l 5 organization.
6 Q. What were his duties while he was in that 7 position? l 8 A. Development of procedures, some 9 involvement in the training of quality control 10 personnel, and processing of unconformance documents-11 resolving technical issues.
12 Q. What qua l i f i ca t i on s does Mr. Brandt have 13 for the position of the supervisor of quality .
14 engineering, in your opinion?
15 A. In my opinion?
16 Q. Yes.
17 A. Mr. Brandt is an extremely technically 18 capable individual. He has very good leadership 19 skills. He has experience.
20 Q. Have you ever read Mr. Brandt's testimony 21 in any of the Atomic Safety and Licensing Board 22 proceedings?
23 A. I believe I have read portions of some of 24 his testimony.
I 25 Q. Do you recall what those portions were 1
UNITED AMERICAN REPORTING SERVICES, INC. '
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54 ,
i 1 about?
2 A. I believe it was fuel pool winder issues.
t 3 Q. Why.was Mr. Brandt moved from the position i
. 4 of supervisor quality engineering to the assistant to '
5 director for special requests?
6 A. Special projects. !
7, .Q. Thank you. Why was he moved to that 8 position?
9! A. I was aware that Mr. Brandt's past !
10 involvement in the licensing proceedings had been lli controversial. I decided that I had enough issues to I
12' deal with without dealing --
continue to deal with 13 that issue also. So at my request, Mr. Brandt 14} assumed his present position.
15 Q. Did anyone in your cha i n o f command above 16 you suggest that change? !
17 A. Not that specific change. !
18 Q. Did they request that you do something f
19 with Mr. Brandt that didn't specify what change you ,
20 should make?
21 A. They suggested limi t at i ons on his 22 assignments.
23 Q. Who was that?
24 MR.*STILLMAN: Who was what?
25 MS. GARDE: Who in hi s chai n of UNITED AMERICAN REPORTING S E RV I C E S , INC.
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55 1 command made that suggestion.
2 A. Mr. Spence, and others.
f 3 Q. (BY MS. GARDE) Was there a specific 4 meeting to deal with Mr. Brandt's continued 5
involvement in the quality assurance department?
6 A. There was a meeting or meetings, I can't
,' 7 l recall exa ctly whi ch , where I proposed changes to the l 82 quality assurance organization. During discussion of i
9, my propositions is when discussions were held
! l
)
10 regarding Mr. Brandt's position in the organization
{
11 and his assigned r esponsi bili ti es . '
12 Q. Had you proposed changing Mr. Brandt in '
13 those pr opos i t i ons ?
14 A. Yes.
15 Q. Is the reason that you proposed the change 16 because of the controversy surrounding his testimony 17 that you testified to earlier?
18 MR. STILLMAN: I don't think 19 Mr. Streeter testified to that earlier, but whatever 20 the prior testimony was.
21 MS. GARDE: Whatever the prior 22 testimony was, right.
23 Q. (BY MS. GARDE) Do you understand the 24 question?
25 A. Would you repeat it, please?
, UNITED AME RI CAN REPORTING SE RVI CES, INC~
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6 56 1 Q. -okay. Do you recall your testimony that 2 you stated that you were aware that Brandt's past 3 involvement in the licensing proceeding had been 4 controversial?
5 A. Yes, I did.
6 Q. All right. Did you propose to change
- l
- 7; Mr. Brandt prior to the meeting with Mr. Spence?
t '
8l A. Knowing the controversy that we have just 9j discussed, I proposed two options; one with 10l Mr. Brandt remaining in the capaci ty of quality 11' engineering supervisor, one with Mr. Brandt occupying f
12' the position that he is in now. Through discussions 13 with several individuals, I settled and proposed the 14 j organization which was accepted, which is the one i
i 15, that we have now.
16 Q. I asked you if you had read any of 17 Mr. Brandt's testimony. Do you recall your testimony 18 saying that you had read portions of it regarding the 19l fuel pool winder issues?
I 20; A. I recall saying that I thought I may have 21 read portions of it, and the portions that I recall I 22 thought related to ." pool sinders.
23 Q. You do 't n 'e a specific recollection of 24 reading the trans ' pt ,?
25 A. No, I do not.
1 UNITED AMERICAN REPORTING SERVICES, INC.
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57 1 Q. Didifou ever form any opinion on whether
+
2 Mr. Brandt's testimony on any issue was, in your 3 opinion, controversial?
4 A. No.
5 Q. Prior to January 1987, when Mr. Brandt l
6 became the assistant to director for special projects, 7, what involvement did he have with the CPRT program?
)
8' MR. STILLMAN: At any time prior to i
9, January 1987, or are you limiting your question to ;
10' when Mr. Streeter was employed by the company?
l 11 MS. GARDE: When Mr. Streeter was 12[ employed by the company.
13 A. I see. Mr. Brandt's role was to respond 14 i
to information requests from the CPRT as they were 15 conducting their acti vi ti es and through the normal >
16! role
' as a quality engineering supervisor of i i l ,
17l processing nonconformance documents which would have 18f been initiated because of findings from the CPRT.
19 Q. (BY MS. GARDE) Did you make any attempt 20 at the time you took over as QA manager to insure that Mr. Brandt did not review any CPRT issue that he L
21 "
22 had been previously involved with on the site?
23 MR. STILLMAN: Could you read that
, 24 back, please?
25 (Record read back. r UNITED AMERICAN REPORTING S E RVI C E S , INC. ,
DALLAS, TEXAS f214) 85% ;1nn
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t 58 1 Q. (BY MS. GARDE) Do you understand my 2 question?
3 A. I believe so. No.
4 Q. Do you know whether there was any i 5 programmatic cont rols of any type within your 6l department to insure that Mr. Brandt or anyone else 7 in your department was not involved in reviewing 8 issues that they previously had connection with?
9 You look confused. Do you not understand 10' my question?
11- A. The way the process worked was, as a CPRT 12- had need for information, they came to the project 13; organizations, in my case, the quality control, 14 quality assurance organization, and asked for 15! i nf ormation.
16 Q. Right.
17! A. We did not have any controls to -- that I i
- 18) recall, that it would have prohibited any individual 19' for de ve lopi ng that information for presentation to 2 0L the CPRT.
I 21 Q. Okay. The requests for information, are !
i 22 you ref er ring to formalized requests for information 23 on RFIC forms or oral requests for information?
24 A. They came in both fashions.
25 Q. All right. How many people were there in UNITED AMERICAN REPORTING SE RVI CES, INC.
DALLAS, TEXAS (214) 855 5100
m o. .m-uwese sewme wwm a-i 59.
1 your organization that would be in a position to 2 receive those requests for information, either oral 3 or written? How many people are we talking about 4 here that would receive those things?
5 MR. STILLMAN: Are you talking --
, 6 Please help me out. Are you asking how many people ,
7 had some assigned responsibility for processing i
8 certain requests, how many could concei vably be 9 contacted by someone on the CPRT side or what? I ; '
10 assume you are asking for just one number. ;
11 MS. GARDE: Well, I'm sorry, I didn't
- 12. mean it to be confusing.
13 Q. (BY MS. GARDE) Was there a separate 14 document within your organization that all requests '
15 for information were supposed to be directed to?
I I l
16 A. Yes.
17 Q. Okay. How many people were in that 18 department? -
19' A. Generally one. At times, there could have 20 been one more, and it was the CPRT coordinator 21 po s i ti on established by Mr. Halstead early in the 22 CPRT program.
23 Q. All right. When you assumed the position 24 of QA director, was Mr. Brandt that one person that 25 was receiving the requests for information, either UNITED AMERICAN REPORTING SERVICES, INC.
DALLAS. TEXAS f 214 ) As% sinn
,y,,,,,,_
60 1 oral or written?
' 2 A. I do not believe so.
3 Q. Okay. Do you remember who was?
4 A. Mr. Doug Snow.
5 Q. Okay. Are you aware of Mr. Doug Snow's 6 longevity with the project?
7j A. I'm aware that he has been at the project eeveral years, yes.
8{
l 9;
Q. .Now, at the time that you took over the i
10' position of QA director, what was the process in 11j place for referring identified deviations to the i :
12' project from the CPRT program?
I 13l MR. STILLMAN: Are you aski ng for a 14j CPRT procedure, or a project procedure, or are you 15 asking him about both? {
16 MS. GARDC: I'm asking his knowledge 17 is to both.
18! MR. STILbMANt '
Both.
I 19! A. At the time ti.at I assumed my 20 responsibilities, it happens that CP-QP-16.3 was in 21 effect which provided for the processing of deviations 22 reports and out of scope observations by my 23 organization. Apart from that, there were also
. 24 verbal and written requests for i n f or m at i on from the 25 CPRT that were directed generally either to l
r UNITED AMERI CAN REPORTING SERVICES, INC.
DALLAS. TEXAS (214) R55-5100
. . 4 .% . . . . m . . . ,, t.e.u .....ae%w s.g . ,
61 1 Mr. Phillip Halstead or me.
2 Q. (BY MS. GARDE) And as CPRT deviation 3 reports or out of scope observations were created and
, 4 referred to your organization, what was the process 5 that they went through wi thin the QA organization of 6 the plant?
7 A. They were converted from the i i
i
, 8 deficiency -- excuse me, deviation reports, out of 9 scope observation memos, I believe, to a deficiency 10 document in NCR to control it from the project's site.f 11- Q. Was that function of conve r s i on an
- 12. automatic function? Do you understand my question?
{
1 31 A. Yes. As I recall early in the process, we' i
14~ looked at the deviation reports, and in s ora e cases, I 15; voided them as being invalid. It did not translate i
16' them into NCRs. Subsequently, I believe we have 17l converted everyone, valid or not, conve r t ed them to l 18 NCRs and dispositioned those documents so that there 19 would not be a gap.
20 Q. Okay. During the time period -- Well, i 21 strike that.
22 At the time that you took over as director 23 of QA, were DRs being voided before being written 24 into NCRs? .
25 A. I do not believe so, and I believe by that UNITED AMERICAN REPORTING SERVICES, INC.
DALLAS. TEXAR ( 71 4) AEE 5166
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1 point in time, a11Y D R S l 'b v e r. t h'o s e previously voided,
- f. 2 had been convertbd [o'NCRs'an hrocessed. At this
. 3 point in time, I believe .there is a project 4 deficiency document for every DR that was from NRC 5 that was generated.
6 Q. What about out of scope observations?
7 A. Every out of scope observation, to my 8, knowledge, these are also the subject of a deficiency l
9; document on the project's site.
l 10.; Q. After a site -- Well, strike that.
11l Are all of the deficiency reports and out 12' of scope observations transferred on to an NCR form, 13 or are other forms used?
14 A. I am not certai , but it is possible that 15 l a deficiency report or a CAR, corrective action request, could have been the form of the deficiency 16l 17 document, as opposed to an NCR.
18 i 0 But everything would be on one of those l
19' three forms; is that correct?
l l 20 A. To my knowledge, it would have been on ur 21- of the three forms.
22 Q. Now, after the deviation report or the out
! 23 of scope memo is converted to one of the three types l
24 of site deficiency paper, if you will, what happens 1 .
l 25 to it?
1 i
UNITED AMERI CAN REPORTING SERVICES, INC.
1 DALLAS. TEXAS ( 214) A99-9100
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63 1 MR. STILLMAN: What happens to the 8
2 site deficiency paper?
3 MS. GARDE: Yes.
4 MR. STILLMAN: Physically what, where 5 is-it stored and kept?
6 Q. (BY MS. GARDE) What is the next step in
- 7. the process?
l 8! A. It goes through a validation process.
9 Q. All right. Who does the validation 10l' process?
11 A. In the past, until recently,-it has been '
i 12 the --
I believe the quality engineering organization.;
13 Q. Okay. When did it stop being the quality )
i 14, engineering organization?
1 l
15: A. I believe on October 5th at the issuance 16 of the revised NEO 3.05 on Don Foreman's report.
17 Q. October '877 18 A. October 5th, 1987.
19 Q. All right. What is the change that that 20 effectuated between the validation process?
21 A. It is the --
22 MR. STILLMAN: Please wait until the 23 question is finished before beginning your answer.
. 24 A. The originating or ganization validates the 25 NCR.
i UNITED AMERICAN REPORTING SERVICES, INC. !
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64 1 Q. (BY MS. GARDE) Okay. What do you mean, 2 the "originating or gani za tion"?
, 3 A. Anyone can write an NCR. If the --
Just 4 say that it happens to be the construction department.
5 That construction management super vi si on would 6: validate it as being a nonconforming condition. If
(
l i 7; .
it was engineering, engi neering management would do
, 8 it.
9l Q. Okay. That is the way it is now?
i 10 A. Yes.
11' O. Okay. Prior to that, who validated it?
12; A. I believe it was the quality engineering 13! organization.
14; MR. STILLMAN: Could you read the i
15; a ris w e r back?
16: (Record read back.
i 17 l' MR. STILLMAN: Thank you.
18 Q. (BY MS. GARDE) What does the validation 19l process entail?
l 20 A. Determining that the identified condition 21 is a -- meets the definition of either a 22 nonconformance or deficiency.
l 23 Q. Is the validation process governed by a l
24 procedure?
l 25 A. Yes. In what detail, I can't speak to.
\
1 I
UNITED AMERICAN REPORTING S E RVI CE S , INC.
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65 l 1 Q. Do you know the procedure name or number?
l
' 2 A. It is -- Generally, it would be our l l
3 . procedure on processing nonconformances.
4 Q. If the NCR DR or CAR is not validated, 5 what happens to it? Is my question more correct if I>
6 say the validation process does not validate the 7 issue, what happens to it?
8 A. I recall that the --
I don't recall the 9[ precise sequence of events, but the rationale for the 10 determination that it is invalid is documented and 11 a ppr ove d .
12 O. Okay. I didn't --
I didn't completely 13 understand your answer. If an NCR goes through the 14 validation process --
Let me start over.
15 Prior to October 5th, 1987, before the 16 change, but during the time period that you were the i
17 director of OA, okay, only from your own personal 18 knowledge of how those worked, if an NCR was not 19 validated and tha. process concluded that the 20 originally identi f ied item by the CPRT was not in 21 fact a deficiency, on what form or document is that 22 de ci si on recordad?
23 MR. STILLMAN: Are you asking him now !l
. i 24" to restrict his answer only to NCRs generated from '
25 findings coming over from the CPRT si de?
UNITED AMERICAN REPORTING SERVICES, INC.
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66 1 MS. GARDE: Yes.
2 MR. STILLMAN: Because I don't think 3 the earlier questions were so restricted.
4 Q. (BY MS. GARDE) I think he has been 5 answering my questions as t o C P RT generated
, 6i deficiencies, haven't you?
7 A. Yes.
t 8l Q. Okay.
I 9 A. On the NCR form?
- 10. Q. On the NCR form itself.
11 A. Yes.
- i 12 Q. So the block on the NCR form that has a 13! space for "disposition" will contain that i n f o rm a t i o n ?,
14: A. The NCR form will contain the information.
15 I can't tell you precisely which block, but that will 16f be the logical block for it to be contained in.
t i
17 j Q. Hypothetically, if an NCR is not validated, 18 l' does a copy of that NCR go back to the CPRT from your 19 organization?
20 A. I believe so. l 21 Q. But you don't know? i 22 A. l I do not know if it is programmatically ;
I i 23 required that that --
that that take place.
24
- Q.
Who would know the answer to that question?j i
25 A. The manager of quality c'o n t r ol .
l UNITED AMERICAN REPORTING SERVICES, INC.
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67 1 Q. Who is that?
2 A. Phillip Halstead.
3 Q. Would it be contained in any written 4 procedures, and would I be able to find the answer to {
5 that question by looking in some document available?
6 '
A. I believe so.
7 Q. But --
8 MR. STILLMAN: Let her finish the 9 question.
10 Q. (BY MS. GARDE) Do you know what that 11 would be?
12 A. It would be the procedure on processing 13 nonconformances.
14 MS. G A RDE : Okay. Let's take just a I
15 short break. Let me see if I have that procedure. ! ,
i 16 (Off-the-record discussion. '
i 17 (Recess. l 18 Q. (BY MS. GARDE) Okay. Back on the record.
19 You don't remember the number of that procedure for l
l 20 processing nonconformance reports?
I 21 A. CP-OP-16.0.
22 Q. Thank you. When you took over the l 23 position of director of quality assurance at the l 24 plant, did your duties include any type of audit l 25 function of the CPRT itself?
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1 A. Would you repeat the question, please?
l i
2 MS. GARDE: Could you read it back? ;
3 (Record read back.
4 A. Not in my capacity an director of quality' 5 assurance.
6 Q. (BY MS. GARDE) Did you --
Strike that.-
7 Were you a member of the OQT?
8 A. I later became a member of the OQT.
9! Q. When did you become a member of the i
i 10' overview quality team?
11 A. I believe it was May of 1986.
l 12 Q. In your capaci ty as a member of the OQT, 13 did you have a duty to review the quality aspects of 14 j the CPRT?
15; A. Yes.
16 Q. Okay. Did you in fact conduct audits of 17- the CPRT compliance with their own procedures?
18j A. Not personally.
I 19! Q. Are you aware that such audits were done?
20 A. I'm aware that the overview quality team 21, members conducted reviews in such areas.
22 Q. You used the term "review." I use the
, 23 term "audit." Would you please explain what the l
l 24 review is that the CQT performed?
l 25 A. OQT did exactly that; it reviewed l
l l
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69 1
documents and activities to determine implementation 2 of the quality assurance programs of the CPRT.
3 Q. Did they do so according to a procedure?
4 A. Yes.
5 O. Do you know what that procedure was?
6 A. It is --
It is --
I believe it is overview 7 quality team program document.
8 Q. Is this the same type of function as an i
9 audit? {
l 10 A. Ba s i ca ll y , yes.
f 11, O. Did the review performed by the OQT I
12' produce documented instances of noncompliance with 13 the CPRT's commitments?
14 MR. STILLMAN: Could you read back ,
15 that question, please?
16 (Record read back.
17,I MR. STILLMAN: Do you understand the 18 question?
19 A. If that question is intended to mean Did 20 it identify instances where activities were not ;
l 21 conducted in compliance with the program plan; I 22 understand it.
23 Q. (BY MS. GARDE) Yes.
. 24 A. Is that what you are saying?
25 O. Yes.
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70 1 A. Yes.
2 Q. What types of forms or documents were 3 their findings recorded on?
4 A. Within the periodic OQT status reports.
5 Q. Was --
Strike that.
6 The periodic OOT status reports were given 9
7 to who?
8l. A. Initially, they were sent to the executive 9l vice-president NEO. Later, they were directed to the 10 ! chairman of the SRT, with copies generally to all l 11, people affected by the subject matter of the i
12 documents.
13 Q. Are periodic OQT status reports the same 14 as NCRs?
15 A. No.
16! Q. Do they -- Do the periodic OOT status 17' reports themselves become control documents upon 18 which deficient conditions are identified a ccor di ng 19 to 10CFR50, Appendix B7 20l A. Could you read that question back?
21 (Record read back.
22 A. Items contained within the OOT of periodic 23 status reports as defined in the program document are 24 tracked closure satisfactory resolution.
25 Q. On what document?
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. ......_.. _ --. . .. . .. .,.2i,; ,...,.'. a ...o e,6 71 1 A. Within the attachment to the periodic 2 status reports, there is an open items list, which 3 identifies a condi ti on , who has responsibility for it, 4 whether it is open or closed, and the action that is 5 then taken to cl os e the item. In man y ca s es , the 6 . closure or addressing the i tems is expanded upon
- 7 within the body of the OQT periodic reports.
8 Q. How is the deficient condition that the 9- 00T audit --
or status --
Strike that. Sorry. .
10 In the case where the OQT identified a 11 deficient co nd i ti on within the CPRT's implementation, 12 is there any initial form filled out that accompanies 13 the identification of that cond i t i on ?
14 MR. STILLMAN: Just to clarify, you '
15 are asking Mr. Streeter to explain the procedures for i
16 handling this type of situation?
l 1
17 MS. GARDE: I want to know, Counsel, 18 Mr. Streeter is on the OQT and they go in there 19 looking at the CPRT's compliance, and that --
they 20 find a noncompliance. What piece of paper do they 21 generate at the time they find the noncompliance?
22 MR. STILLMAN: You are not asking for 23 the actual i mpl em en t a t i on of the OQT f un ct i ons , but 24 rather the structure of the a cti vity?
25 MS. GARDE: Right.
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72 '
1 MR. STILLMAN: Okay. Just wanted to 2 clarify that. Thank you.
3 A. The documentation of the finding in the
?
4 resolution thereof are contained only in the periodic 5 status reports.
6 Q. (BY MS. GARDE) Are periodic status I
, 7, reports filled out by each i n di vi d ual of the OOT? ,
I I 8:' A. It reflects --
No. It reflects a !
9! consensus of the OQT.
10: Q. Does the OQT itself conduct its overview ;
11; functions --
Strike that.
I 12 Do you become an inspector in your duties 13I with the OOT? Do you actually go out into the field 14 and look at the CPRT procedures and then an aspect of 15 implementation of those procedures, just as a QC 16l inspector or auditor would do?
i 17! A. Can you give me just a second?
18l Q. Yes.
I 19 (Off-the-record discussion i 20 (between Mr. Stillman and 21: (Mr. Streeter. .
22 MS. GARDE: If he doesn't understand i 23 the question, I want him to tell me he doesn't l
. 24 un'derstand the question. >
25 MR. STILLMAN: Oh, 'I agree i
UNITED AMERICAN REPORTING S E RV I C E S , INC.
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73 1 wholeheartedly, so I so instruct Mr. Streeter. If
' 2 you don't understand the question, please do tell 3 Ms. Garde, and she will ask you one that you can 4 understand. She will try to. ,
5 A. In the conduct of the OQT activities, 6 there may have been occasions where an OQT member did
, 7 an independent observation of a condition that was 1
8 inspected by an inspector. During the conduct of OQT 9 activities, the members, in reviewing the acti vi ti es ,
l 10 do much the same function as an auditor.
11 Q. (BY MS. GARDE) That is what I'm trying to !
I 12 find out. Is the OQT activities generally sitting in !
13 your office and reviewing documentation as opposed to ii 14 doing any kind of field inspections?
15 A. No. It involves a substantial amount of i l
16 overview of the audit activities of the QA 17 organizations of the CPRT.
18 Q. Okay. What are those overview activities?
19 A. It involves an 00T member accompanying the 20 audit team, reviewing the preparation, the 21 implementation, di sposition of matters reviewed 22 during the audit.
23 Q. Okay. Who makes up the audit team?
24 MR..STILLMAN: At any particular time 25 period, or are you asking for names of, individuals?
UNITED AME RI CAN REPORTING SERVICES, INC.
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74 1
MS. GARDE: Well, I wanted to know 2 during the time period that he was on the 00T, and P
3 the names of individuals would be fine, or some 4 designation of where these people come from.
5 A. The ERC, QA organization had a group of 6' individuals, auditors who conducted --
implemented
)
7' the audit program for ERC. These are for all of 8 the --
the activities under the ERC, and later it was 9 expanded to the electrical and t esting areas that are t
10 the program. For the Terra's efforts in the design 11 adequacy program, they likewise had a group of i
- 12) individuals, auditors who implemented the audit I
13! program for that acti vi ty.
i 14 ! MR. STILLMAN: I don't think the 15' witness has had a chance to finish his answer.
16! A. For that activity.
17{ Q. (BY MS. GARDE) Did Terra have their own l
18; auditors?
i 19! A. Yes.
20 Q. Okay. ERC auditocs didn't audit Terra?
21 A. No.
22 Q. All right. The OQT's act i vi ti es was an 23 overview function only of Terra and ERC's audit; is 24 that correct?
25 A. No.
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75 1 Q. All right. What am I mi ssing here? I
' 2 mean, that is not a question for you to answer. All 3 right. I don't understand something about the OQT in 4 terms of its function, and I understand what --
the 5 answers that you have given me, but there is a loop 6 in here I don't follow. So let me start where I
- 7. started this line of questions before.
i 8 What type of documents are prepared by the !
9, OQT which feed into or serve as a basis for their 1 i
10 periodic reports? j 11 MR. STILLMAN: Could you read back 12 just the question part of that?
13 (Record read back. ,
14 MR. STILLMAN: You are asking only l 15 about documents that OQT prepares now? '
16 MS. GARDE: Yes.
17; A. Okay. We prepare notes and develop their 18 portion or input to the periodic reports. Initially, 19 the OQT efforts, there were some occasions where some 20 checklists were developed by OQT members and used.
21 Q. (BY MS. GARDE) Were those checklists 22 individualized tools prepared by individual members?
23 A. Yes.
. 24 Q. Did they have procedure numbers?
25 A. Would you clarify that, please?
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76 1 Q. Did the checklists prepared by individuals i 2 for their own use ever receive a site document number 3 of any type?
I 4 A. No.
5 Q. Did you prepare a checklist for your use 6 in performing your OQT work?
7; A. No.
8l Q. Hcw many periodic reports have you 9 contributed to?
10! A. Approximately 13.
11 Q. When you were preparing the report, did 1 21 you prepare only a portion of the report or the whole l
1 31 thing?
14 A. Generally, my capacity was to take the i
15; inputs from the various individuals. Frequently, I l
16 would assign one of the OQT members then to take that 17 input and develop a consolidated report which would 18 come to me then for review. I then, through j 19 questioning of the OQT members, would finalize the l
20 report, sign it, and distribute it.
21 Q. Was the input that you received from the l 22 individual members oral input or in writing?
23 A. Both. Primarily, in writing.
l 24 Q. Did the information that you received 25 identify instances where either ERC or Terra had not i
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l 77 1 complied with their own programs?
8 2 MR. STILLMAN: Are you really 3 intending to get into the implementation --
4 MS. GARDE: No.
5 MR. STILLMAN: --
of the OOT effort?
6 MS. GARDE: I mean, I could ask that 7 question hypothetically and just say; Did you 8 anticipate that that would happen? I will do that, 9 if you want it. I don't want to get into 10 implementation.
1 11 MR. STILLHAN: All right. Maybe what .
I 12 you are trying to ask is a question like; Is that --
l t
13 MS. GARL4: Was that contemplated? ;
14 MR. STILLMAN: --
or was that the 15 kind of information that was designed?
16 MS. GARDE: Let me try again.
17 MR. STILLMAN: All right.
18 Q. (BY MS. GARDE) Was the OQT program or 19 group -- I don't know. I don't recall. If I just 20 call it the "OOT," you will know what I mean?
21 A. Yes.
22 Q. Was the OQT designed to identify specific 23 de fi ci en ci es of either Terra or ERC, using the term 24 "deficiency" to mean noncompliance with their 25 commitments?
UNITED AMERICAN REPORTING SERVICES, INC.
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l 78 1 A. OOT was designed as an added level of 2
1 assurance for the SRT, that the CPRT QA programs were 3 effectively implemented.
4 Q. Was it ever -- '
5 MR. STILLMAN: Why don't we take'a 6 pause?
The record will reflect Mr. and Mrs. Ellis 7j have arrived.
8! Q. (BY MS. G A RDE ) Okay. Was the OQT ever 9) i intended to prepare control documentation in the 10' event that it was di s co ve r ed there was no commitment 11 ~ met? Strike that.
12l I'm sorry.
- That que s ti on is so confusing.
13l I'm having a hard time doing this hypothetically.
14' Why don't wo take just a minute to break.
15,i Let me clear my head and try to refocus on this 16 question.
17l MR. STILLMAN: Fine.
I 18 j MS. GARDE: I'm nearing the end here.
I 19' I apologize.
20 (Recess.
21 Q. (BY MS. GARDE) Mr. Streeter, are you 22 familiar with 10CFR50, Appendix E -- B?
23 MR. STILLMAN: What?
24
- MS. GARDE: Appendix B.
25 MR. STILLMAN: "B" as in boy?
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79 1 MS. GARDE: I said "E" first.
2 A. Yes.
3 Q. (BY MS. GARDE) All right. Are you 4 familiar with criterion 18, audits?
5 A. Yes.
6 Q. Okay. Is the OOT or gan i ze d to comply with 7; 10CFR50, Appendix B, criterion 18? k i
8 MR. STILLMAN: Are you assuming in 9; your question that there was some requirement of such 10 compliance?
f 11 MS. GARDE: No. I'm asking him if it 12 was organized. No, I'm not assuming any compliance.
13 A. No. i i
14 Q. (BY MS. GARDE) Is one of the functions of 15 the OQT to review all NRC inspection reports? l l
16 MR. STILLMAN: All NRC inspection 17 reports of a whole plant?
18 MS. GARDE: Start with that, yeah.
19 Q. (BY MS. GARDE) Do you, as a member of the 20 OQT, review all NRC inspection reports?
I 21 A. No.
I 22 Q. Okay. Does the OQT itsel f have as a duty l-23 reviewing all NRC inspection reports?
24 A. No. .
l 25 Q. Does the OOT as a duty review all NRC UNITED AMERICAN REPORTING S E RV I C E S , INC.
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80 1 inspection reports that refer to or impact on the 2 CP RT program?
3 A. That refer to the CPRT program, yes.
4 Q. All right. Do you perform that review 5 personally?
6 A. No.
7 Q. Who does?
8! A. Larry Chockie, OQT member was assigned 9; primary responsibility for that activity.
10; Q. Does Mr. Chockie have in his duties 11l reviewing all NRC reports, even if they are not i i
12' inspection reports, to look for CPRT issues, for 1
13l example, reports from the office of investigations or ;
i 14 j the office of inspector and auditor?
i 4
15' A. No. '
i 16 Q. He only looks at inspection reports?
17 ! A. Looks at NRC reports related to CPRT l
l ,
18l t activities.
i 19 j Q. Okay. If there is a reference to CPRT 20 activity and a report from the office of !
l 21 investigations, would Mr. Chockie review that report?l 22 A. No, not unless it provided some kind of 23 assessment or comment on the conduct of the CPRT.
l l 24 Q. Okay. I think we a'r e talking --
I think i 1 .
25 your answer is "yes," although you say "no" to the l
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81 1 question. So maybe I'm not phrasing the question 2 correctly.
3 Does Mr. Chockie review all NRC documents 4 to see if there is a reference to the CPRT in those 5 documents?
6 A. No.
7 Q. Okay. Who makes the determination of what
- 8. NRC documents refer to the CPRT?
9 MR. STILLMAN: Let me see if I can i 10 help you out. I think perhaps part of the confusion 11 is that you keep asking him about --
refer to the 12-. CPRT, and I think that Mr. Streeter's answer is 13 somewhat different --
doesn't use quite that concept.
14 Maybe you are not'on the same wa v el en gt h in that i i
15; regard.
16 MS. GARDE: Well, we are not on the l 17; same wavelength, so your help is appreciated. l '
18' O. (BY MS. GARDE) Let me go backward. The !
19' NRC produces a multitude of material regarding 20: Comanche Peak, don't they? '
21 A. Yes. I I
22 Q. All right. They produce inspection 23 repor+s generally out of Region IV, don't they?
l l . 24 A. Yes.
25 Q. Okay. They al so produce reports out of UNITED AMERICAN REPORTING SERVICES, INC.
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the office of investigations, don't t he y ?
2 A. Yes.
3 0 And they also produce reports out of the 4 office of inspector and auditor, don't they?
5 A. Yes.
6l Q. Okay. As to only those three types of reports, 01, OIA, and inspection reports, who makes 7{
. 8! the initial de t ermi na t i on on whether any one of those
- 9. reports contains information such that the OQ? should 10 review it?
- 11. A. The way the process is set up is that the 12j NRC coordinator -- The CPRT effort was responsible 13, for assuring that any issues in NRC inspection 14; reports affecting the CPRT are addressed. We have an 15 interface set up with the CP --
wi th the OQT and that 16; individual to identify those documents. That is --
i 17 Those are the subjects of our review.
18! Q. And this is an NRC coordinator employed by 19' 1
the NRC7 20! A. No.
21i Q. Okay.
22 A. It is actually a contractor, but he is a 23 part of the CPRT organization.
24 Q. Okay. Who is that individual?
25 A. Mark Steelman.
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83 1 MR. STILLMAN: Why don't you spell
' 2 that.
3 THE WITNESS: S-t-e-e-1-m-a-n.
4 MR. STILLMAN: Want to make sure it 5 was pretty clear it was not a blood relative.
i 6 Q. (BY MS. GARDE) Who is his direct l 7 supervisor?
8 A. I'm not sure.
9 Q. Does the OQT rely on his judgment as to 10 what NRC documents it needs to review to determine 11 whether there were findings regarding a CPRT that 12 should be reviewed by the OQT?
13 A. At this time, yes.
14 Q. Okay. Does the OOT conduct special 15 reviews of CPRT act i vi ti es ?
16 A. Upon request, yes.
17 ! Q. Is there a trigger for that request? I 18 mean, is there some event that must occur for a 19 review to be --
for the OQT to do a special review?
20 A. A request.
21 Q. Just a request?
22 A. Yes.
23 Q. Okay. Is there a separate individual or '
l 24 group of individuals who have the authotity to make 25 that request?
UNITED AMERICAN REPORTING SERVICES, INC.
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84 1 A. The program' document provides for the SRT, 2 special reviews upon the-request of the SRT.
3 Q. Does the OQT have any authority to stop 4 work on the CPRT?
5 A. No.
6 Q. Does the OQT have the ability to make such 7j a recommendation?
8 A. Yes.
t 9! Q. To who? Who would you make the 10 recommendation to?
11'; A. SRT.
I 12 j Q. Does the OQT have any authority to mandate 13! resolution of concerns it may raise in its project 14' reports, periodic status reports?
I 15! A. No.
I 16l Q. Is there any requirement for feedback to I
17 ti.e OQT in response to ths issues identified in 18 periodic status reports?
19 HR. STILLMAN: Are you referring to 20, some sort of a requirement in the OQT or CpRT program I
21 plan?
22 MS. G A RDE : Any plant r equi rement . .
23 MR. STILLMAN: You are not asking as
. 24 to whether Mr. Streeter has to -- whether there might 25 be some kind of legal requirement, I take it?
UNITED AMERICAN REPORTING SERVICES, INC.
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85 1 MS. GARDE: Procedural requirement.
2 MR. STILLMAN: Procedural requirement 3 of the program.
4 A. OQT program document provides for the OQT 5 to resolve issues at the review team leader level and 6 below. And if the issues are not resolved to the 7 satisfaction of the OQT, it provides for elevation of 8 those issues to the S RT .
9 Q. (BY MS. GARDE) On what form is the 10 resolution of issues with RTLs or below recorded?
11 A. Periodic status reports.
12: Q. And that information comes to the person 13 preparing the periodic status report either in 14 writing or orally?
l t
15 A. Yes.
16 Q. Are the memos that this i nf ormati on is '
4 17 reported to the OOT on kept in a file? Is there a 18 central filing system for the OQT?
19 A. OQT files are part of the CPRT central 20 files.
21 Q. At what occasion will the OQT cease to 20 exist?
23 A. The OQT program document provides for the 24 discretion of the SRT to terminate the OQT when the
'25 level of the activities of the CPRT j u.s t i f i e s such UNITED AMERICAN REPORTING SERVICES, INC.
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L I 86 1 termination in the eyes of the S RT . April 1987, I 2 recommended to SRT that, in my view, that the level 3 of activities had reached that, and I recommended 4 disbanding the OOT. S RT accepted that recommendation 5 and said the OQT as a body was disbanded, terminated 6 as of the issuance of the final report approximately 7 June 1987.
8! Q. Does the OQT have as one of its duties to i
9j make a determination on whether or not the CPRT I
l oi program was adequately implemented?
11' MR. STILLMAN: The entirety of the $
12 ! program or specific aspect?
, 13 MS. GARDE: Entirety of the program.
14 j A. The OQT's charter is to assure the j 15 l effective implementation of the QA programs for the !
16 CPRT.
17 Q. (BY MS. GARDE) Okay. As to my question i
18 on the overall CP RT program, is it your testimony 19{that the OQT has no responsibility for making a ,
e i .
20! determination on the adequacy of the implementation? !
I i
21 A. Not directly. j 22 Q. Okay. Only through its review of the 23 QA/QC?
24 A. (No response).
25 THE REPORTER: Is that a "yes"?
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87 1 THE WITNESS: Yes.
2 MR. STILLMAN: There was no oral 3 answer. Remember, you have to speak up.
4 Q. (BY MS. GARDE) Did the OQT conduct --
5 Strike that.
6 Did the OQT de velop a procedure to i
7' o ver vi ew the quality aspects of the CPRT done under 1
8 Rev. 0? i 9 MR. STILLMAN: Could you read back .
10 that question, please? l I
11 (Record read back.
I 12 MR. STILLMAN: Do you understand the '
13 question?
14 THE WITNESS: I'm not sure.
15i Q. (BY MS. GARDE) Okay. Are you familiar 16 wi th Revi sion 0 of the C P RT ?
17' A. No. I have not reviewed the document.
18 Q. Are you aware that there was --
whether i
19- there was work done under a CP RT program plan in 1984?:
20 A. Not specifically. I'm aware that work 21 was --
some activity was done in that time frame. ,
l l l 22 Q. Okay. Are you aware that the CPRT had '
23 ongoing work in the first four months of 1985?
. 24 MR. STILLMAN: Are you representing 25 that to be the case?
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88 1 MS. GARDE: I'm asking him if he is 2 aware of whether there was CP RT work going on.
3 A. I have no direct knowledge of that.
4 Q. (BY MS. GARDS) Okay. Do you have a 5 general knowledge regarding how long work has been 6j going on under a program entitled the CPRT? ;
I I 71 A. I have a general knowledge, yes. ,
t 8 Q. Okay. In your role as a member of the 9 OQT, all right, are you aware of whether there was 10 any review done to determine the quality aspects of j 11 the CPRT work in the fall of 1984 or the spring of ;
12, 19857 i 13 > A. I am not aware of any specific review that 14 you are describing. i 15 Q. Would you be aware of whether the OQT had i
- 16. conducted such a review?
i 17 A. Yes. j 18 Q. Are you aware of the procedures that are 19 in place for retention of control documentation at 20 the site? j l
21 MR. STILLMAN: Do you understand the 1 22 question?
23 A. Are you talki ng about the CPRT for the 24 whole site?
f 25 Q. (BY MS. GARDE) I'm talking about the site ,
UNITED AMERICAN REPORTING SERVICES, INC.
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^
89 1 documentation.
2 A. I'm aware that documents exist.
3 Q. Is that a requirement of 10CFR50, 4 Appendix B, as you know that document?
5 MR. STILLMAN: Are you asking for his i
6 legal co ncl us i on ?
- 7. MS. GARDE: No. He is not a lawyer.
8 I'm not asking for his legal conclusion.
9 MR. STILLMAN: Are you asking him for 10 his personal interpretation of particular regulations 11 or understanding of procedures as of their intent?
12 MS. GARDE: I want to know -- the 13 program that he just referred to that he knows exist, 14 if he knows if that program is a 10CFR50, Appendix B i
15 program regarding site documentation r et ent i on .
t 16 MR. STILLMAN: Is the question f 17 whether certain procedures were promulgated with the i
18 intent to comply with certain regulations? Is that l 19 what you are getting at? ,
20 MS. GARDE: That is a good way to ask 21 the question. That is what I'm getting at. i 22 A. The answer is yes.
23 MS. GARDE: Do you want to give up 24 all your money and go to work for GAP 7 He doesn't.
25 Q. (BY'MS. GARDE) All right. Do you know UNITE D A!4E RI CI.N REPORTING SERVICES, INC.
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90 1 whether CPRT generated paper recording deficiencies 2 that are sent to your office, your function, on the 3- deviation reports and the out of scope observations, 4 are included in the site documentation program?
5 MR. STILLMAN: Let's stop for a 6 second. You have used a term in your question, 7 "deficiency," which is acceptable to more than naa i
8 interpretation, and --
l 9 MS. GARDE: I thought I clarified 10- that to mean only two types of paper, deviation 11 reports and out of scope observations. '
i 12' MR. STILLMAN: All right. And you ! -
13i also asked Mr. Streeter about whether certain things 14 came to him in his function, and he has testified as i
- 15. to two hats he wears. I just don't want him to be
! I 16i confused on which hat you want him to put on in i l i 17 answering the question. -
18j Q. (BY MS. GARDE) Okay. In your function as ;
I 19 the director of quality assurance, you testified 20 before regarding the receipt of CPRT deficiency paper.
I'm asking you specifically about deviation r e, . i r t s s' and out of scope observations generated by the CPRT.
I
' +
As to those two classes of documents, cnce
, i t ho s e documents are received in your office, do they 25 become a site document? '
j l
UNITED AMERICAN REPORTING S;;UIr7S, INC.
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91 1 A. I'm not sure that there is a specific 2 requirement .f o r those pieces of paper to become a 3 site document.
4 Q. Are they retained by your office?
5 A. I believe that they are retained in the 6 document control system for the site.
7 Q. But your office doesn't keep them in its 8 office?
9 A. I don't believe we keep any personal l
10 ccpies of those, l' t
i 11' O. Are you aware of a procedure which 12 requires that the deviation reports or the out of 13 scope obs ervati on memos are maintained in the same !
l 14 place as all other documentation regarding each 15 specific component or pr oce s s ?
16 MR. STILLMAN: That is a pretty long 17 question. Could you read it back, please?
18 (Record read back.
19 A. No.
I 20 Q. (BY MS. G A RbE ) Would you be aware of such 21 a procedure?
22 A. Not necessarily.
23 Q. Who would be?
24 A. Phillip Halstead, manager of QC.
25 O. Oh, okay. Have you -- Strike that.
UNITED A!!ERI CAN REPORTING SERVICES, INC.
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92 1 Do you have an understanding of what the 2 following sentence means, and I'm reading from page 3 13 o f 45 of Revi si on 3 of the program plan.
4 "The CPRT will not perform inspections, 5 calculations, or designs of record for CPSES."
6 The question is --
7! A. I have my own understanding.
I 8l Q. What is your own understanding of what i
9i that means?
10 A. It means that the docum'ntation produced 11 as a result of the CPRT effort will not be the
)
l 12: records required by 10CFR50, Appendix B, criterion 17, I believe. They are required to justify or to 13l 14! demonstrate the acceptability of quality related 15 items.
16 MS. GARDE: Okay. I don't think I 17! have any more questions. Let me just ask Mrs. Ellis i
18l a question. ' -
i 19! (Recess.
20 MS. GARDEt No more questions. I 21 have no more questions er this witness.
22 (Deposition concluded at 11 :4 0 a .m .
23 24 25 UNITED AMERICAN REPORTING SERVICES, INC.
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-as 93 ,
1 CORRECTIONS AND SIGNATURE 8
2 PAGE LINE CORRECTION REASON FOR CHANGE 3
- (SEE ATTACHED) 4-5 6
7 8
9 10 11 12 I, JOHN FRANKLIN STREETER, have read the 13 foregoing deposition and hereby affix my signature 14 that same is true and correct, except as noted 15 herein.
16
^
17 ~
J EE FRAEKLIN STREETER 18 19 20 SUBSCRIBED AND SWORN to before me by the said 21 witness on this the_dAd f . day of_ h d , 1987.
22 l
23
- M ed. .
24 ,', NOTA PUBLIC IN AND FOR THE
, E1STE OF TEXAS 25 14y commi s s ion expires: Mg ff,/98/
UNITED AMERICAN REPORTING SERVICES, INC.
n a t t.a c mevne (914) ann nton
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ERRATA SHEET
~
John Franklin Streeter I (October 16, 1987) ,
Page (line)_ Correction 6(23) Correct "Yankee Row" to "Yankee Rowe" 15(16) Insert "and" between "engineering" and "operations" 16(7), (9) and (13) Correct "Kennefick" to "Kenefic" 17(2) Correct "individual" to "individuals" 18(5), 18(12), 19(1), Change "three" to "two" 19(9), 19(25), 20(13) 20(21), 21(1), 22(2), 23(11),
24(13), and 39(8) 18(18), 25(14), 27(21), Correct "program plan" 39(10-11), 40(4) and (10) to "Program Plan" ,
37(9) Remove the words "in the" preceding the word "reporting" 41(22) and (23), Correct "Bradewood" to 42(14) and (23) "Braidwood" 44(8) Remove the word "that" preceding the word "any" 44(9) Correct "any" to "into" and "to" to "the" 47(14) Correct "individuals make" to "individual makes" 47(18) Correct "then" to "that" and insert the word "an" between the words "in" and "acceptable" 53(10) Correct "unconformance" to "nonconformance" 54(2), 56(19) Correct "fuel pool winder"
' to "fuel pool liner"
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Page (line) Correction 56(22) Correct "fuel pool winders" (I to "fuel pool liners" 58(11) Correct "a CPRT" to "the CPRT" 58(19) Correct "for" to "from" 61(10)- Correct "document-in NCR" to "document, an NCR,"
61(10)and 62(9) Correct "site" to "side" 61(15). Correct "invalid. It" to "invalid and" 61(17) Correct "everyone" to "every one" 62(4) Correct "NRC" to "ERC" 63(16) Remove "on Don Foreman's ,
report" 69(6) Insert "the" between "is"
- and "overview" l
70(22) Delete "of" 70(24) Insert "to" before "closure" and "and" after "closure" 72(3) Correct "in" to "and" 74(9) Insert "part of" after "are" 74(10) Correct "the Terra's" to "Tera's" 74(17), (20) and (23), Correct "Terra" to "Tera" 76(25), 77(23) 75(17) Change "We" to "OQT members" 75(19) Insert "for" before "the" 76(15) Change "individuals" to "OQT members" h
~2-
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w Page (line)1 Correction 82(15) and 82(16) Change "with the CP- .with the OQT and that individual" to "between the CPRT NRC coordinator and the OQT" 88(23) Correct "CPRT for the" to "CPRT or the" 90(7) Correct "acceptable" to "susceptible" 92(13) Correct "believe. They" to "believe, that" Exhibit 1 Correct "John G. Streeter" to "John F. Streeter" l
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94 y 1 C E RT I F. I CA T E 2-
-3 I, James M. Shaw, RPR, Certified Shorthand iLY 4 Reporter in and for-the State of Texas, do hereby 5 cert'fy that, pursuant to the agreement hereinbefore 6 set forth, there came before me on the 16th day of 7f October, A. D., 1987, at 8:45 o' clock a.m., at the 8' offices of Worsham, Forsythe, Sampels & Wooldridge, 9,
4 2001 Bryan Tower, Suite 3200, Dallas, Texas, the I
10l following~ named p e r.' .,n , to-wit: JOHN FRANKLIN 11 ST REETE R, who was by me duly sworn to testi f y the 12 truth and nothing but the truth of his knowledge 13! touching and concerning the matters in controversy in 14 this cause; and that he was thereupon examined upon 15 his oath and his examination reduced to writing under my supervi sion; that the deposition is a true record 16l!
17l of the testimony given by the witness, same to be l
18' sworn and subscribed to before any notary public, i
19' pursuant to the agreement of all parties.
- 20, l
I
, 21 1 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 i
l
'24 taken, and further that I am not a relative or b .
25 employee of any attorney or counsel employed by the UNITED AMERICAN REPORTING S E RVI CES , INC.
rf. c . ..
95 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 1907 7 ,!
i i
i 9'
JAMES_ _ _ 93:2_
M. SHAW,M_ _. . R
_ _?R,
_ _CSR i
10 IN AN FOR THE S PATE OF TEXAS 2414 North Akard, Suite 600 j l
11 Dallas, Texas 75201 (214) 855-5300 12 My commission expires:
13: December 31, 1988 CS R No. 1694 14 ;
15 16 17 18 19 20 21 22 23 24 .
25 .
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