ML20203E908
| ML20203E908 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 07/23/1986 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| CON-#386-172 OL, NUDOCS 8607300010 | |
| Download: ML20203E908 (170) | |
Text
ORIGl'N AL O UMIED STATES NUCLEAR REGULATORY COMMISSION IN THE MATTER OF: DOCKET NO:
BRAIDWOOD STATION 50-456/457-OL UNITS 1 6 2 COMMONWEALTH EDISON COMPANY (EVIDENTIARY HEARING)
O LOCATION: JOLIET, ILLINOIS PAGES: 8459 - 8629 DATE: WEDNESDAY, JULY 23, 1986 T/$.0/ To$ ht.u
//9/-/ .
OI ace-FEDERAL REPORTERS, INC.
O OfficialReporters 444 North CapitolStreet Washington, D.C. 20001 6 (202) 347-3700 73 ggg $$$
T NATIONWIDE COVERACE
8459 O
1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _X 5 :
In the Matter of: :
6 : Docket No. 50-456 COMMONWEALTH EDISON COMPANY : 50-457 7 :
(Braidwood Station, Units 1 :
8 and 2) :
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _X 9
10 Page: 8459 - 8629 11 College of St. Francis 12 500 North Wilcox Joliet, Illinois 60431 l 13
! Wednesday, July 23, 1986 l 14 15 The hearing in the above-entitled matter convened l
16 at 2:00 P. M.
17 BEFORE:
1 18 JUDGE HERBERT GROSSMAN, Chairman 19 Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission 20 Washington, D. C.
21 JUDGE RICHARD F. COLE, Member, Atomic Safety and Licensing Board 22 U. S. Nuclear Regulatory Commission Washington, D. C.
23 JUDGE A. DIXON CALLIHAN, Member, 24 Atomic Safety and Licensing Board
() 25 U. S. Nuclear Regulatory Commission Washington, D. C.
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1 APPEARANCES:
2 On behalf of the Applicant:
3 MICHAEL I. MILLER, ESQ. ,
JOSEPH GALLO, ESQ.
4 ELENA Z. KEZELIS, ESQ.
Isham, Lincoln & Beale 5 Three First National Plaza Chicago, Illinois 60602 6
7 On behalf of the Nuclear Regulatory Commission Staff:
8 ELAINE I. CHAN, ESQ.
9 GREGORY ALAN BERRY, ESQ.
U. S. Nuclear Regulatory Commission 10 7335 Old Georgetown Road Bethesda, Maryland 20014 11 On behalf of the Intervenort l 12 l ,
ROBERT GUILD, ESQ.
I 13 l
l 14 15 16 17
, 18 i
19 20 21 22 23 24 O 25 l
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O 1 EXHIBIT INDEX MARKED RECEIVED 2 Intervenors' Exhibit No. 66 8507 8515 Intervenors' Exhibit No. 67 8598 8618 3 Intervenors' Exhibit No. 68 8606 8618 Intervenors' Exhibit No. 69 8621 8628 4
. TCCTIMONY OF ROBERT DUANE HUNTER 2
5 DIRECT EXAMINATION 6 BY MR. GUILD: 8469 7 BOARD EXAMINATION BY JUDGE CALLIHAN: 8539 8
)
DIRECT EXAMINATION
, 9 (Con cinued. )
BY MR. GUILD: 8541 10 BOARD EXAMINATION 11 JUDGE GROSSMAN: 8571 l
12 DIRECT EXAMINATION (Continued.) .
13 BY MR. GUILD: 8571 14 BOARD EXAMINATION BY JUDGE GROSSMAN: 8573 15 DIRECT EXAMINATION 16 (Continued . )
BY MR. GUILD: 8574 17 BOARD EXAMINATION 18 BY JUDGE GROSSMAN: 8618 19 DIRECT EXAMINATION 20 (Continued.)
l BY MR. GUILD: 8619 21 VOIR DIRE EXAMINATION 22 BY MR. GALLO: 8623 23 24 O 25 i Sonntaa Reporting Service,_Ltd.
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1 JUDGE GROSSMAN: The hearing is reconvened.
i 2 This is the 42nd day of hearing.
i
- 3 Before we call the witness, there are a few
, 4 preliminary matters, j One, we've issued a memorandum and order denying I l 5 I
i 6 the contention on overstressed structural columns.
1 7 We don't have a copy, because I signed that on my lI 8 way out of the office this morning and didn't have a 9 chance to get it reproduced.
T 10 Secondly, we've issued a Notice of Intent to l
11 Disclose on the protective order to OI, Office of 12 Investigations, with regard to the matter that we had
(])
13 been discussing recently, and the protective order would j 14 limit those matters to trial counsel, but we have to 15 wait for a response from OI.
, 16 In it, we also mention that there's another OI 17 investigation that was mentioned to us that is 18 marginally relevant to this proceeding, because it does 19 involve a QC Inspector who was harassed or intimidated 20 by a crafts person, and the only relevance would be with 21 regard to the response of QC management to that.
22 I don't know that that has much significance, but 23 we've asked OI to release that, and apparently there 24 isn't any objection.
O 25 -
They just moved on it. Apparently they are Sonntag Reporting Service, Ltd.
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1 completing that report or sending forward what they've 2 completed, and I guess it just hasn't reached anyone who 3 could decide to release it; so we've urged them to do 4 that now.
5 But now, also, in our Notice of Intent to Disclose, 6 we've indicated that we intend to authorize a subpoena 7 that had been requested, and we indicated that we would 8 issue such subpoena on July 29th, which is next Tuesday, 9 unless we hear otherwise from the Commission or its 10 authorized representative.
11 We did get Applicant's pleading, but we don't find 12 that what Intervenors have done has been untimely, and
(]}
13 we do consider the matters in that investigdtion to be 14 relevant to this proceeding, and we don't have to act on
. 15 the alternative. request to admit a new contention with 16 regard to that.
17 The only question is whether the matters would be 18 released.
19 As far as the subpoena goes, we don't see any 20 grounds for denying the subpoena, which, really, would 21 depend on whether the matters are relevant, which they 22 are.
23 Of course, the person subpoenaed can always move to 24 quash, but we would think that, under the circumstances, O 25 serving a subpoena and having him testify under Sonntaq Reporting Service, Ltd.
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l protective order would probably be more beneficial to 2 him, in any event, than having to fight a subpoena, 3 which I think he might not prevail on, anyway; but we'll 4 see what the Commission has to say on it, if anything, 5 by next Tuesday.
6 With that, :f there are no further preliminary 7 matters --
8 MR. BERRY: Just one question, Mr.
9 Chairman -- just one question, Mr. Chairman, for 10 clarification.
11 Did I understand the Board to say that -- that it
(} 12 did -- no further action is required on the Applicant's -- on the Intervencre' motion to admit the 13 l'
'. 14 Late-Filed Contention; that the Board has ruled that it 15 is --
16 JUDGE GROSSMAN: With regard to that matter 17 under investigation?
l 18 MR. BURRY: Yes.
19 J'UDGE GROSSMAN: Well, yes, we've decided 20 that it's relevant; and, of course, we know more about j 21 the investigation than the parties do at this point, 22 other than OI.
23 MR. BERRY: I just want to be clear as to 24 just what the Board's ruling is just for my own l
O 25 information.
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1 Has the Board ruled that it's within the scope of 2 the existing contention?
3 JUDGE GROSSMAN: Yes, that that's what our 4 ruling is.
5 MR. GALLO: Judge Grossman, will we see the 6 order prior to any filing by OI?
7 JUDGE GROSSMAN: Our order, no.
8 I'm telling you basically what I can 'tell you about 9 what we've done.
10 Otherwise, we've discussed in the order the 11 relevance of that matter to the proceeding here; but, I l'2 obviously, we can't ' disclose that to the parties,
(}
13 because it would be disclosing matters in the 14 investigation, and we're not authorized to do that.
15 MR. GALLO: Judge Grossman, is the potential 16 issue, if raised by OI, one of compromising their 17 investigation as opposed to protecting the confidence of 18 the individual involved?
19 JUDGE GROSSMAN: Both, because they promised 20 protection to the individual and they didn't breach it, 21 at least not officially or knowingly. Perhaps someone l 22 in their office did -- no one knows that -- but, 23 nevertheless, they still offered him that, and he asked l
l 24 for that; and I understand that the subject is not -- or O 25 the alleger is not amenable to withdrawing his request Sonntaq Reporting Service, Ltd.
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1 for confidentiality, so it's that, plus compromising the 2 investigation, also.
3 But I'm not even at liberty to tell you what's been 4* done or what hasn't been done in the investigation, so 5 that you just have to brief it in the dark as far as 6 those problems go.
7 It's not as though there's any great exclusion to 8 the problems with regard to investigations that are 9 going on; and I'm not sure that the Policy Statement 10 isn't the best procedure that they could have devised 11 under the circumstances, but that's certainly what we 12 have to work under.
[}
13 Any further questions on that?
14 MR. GALLO: I have a different preliminary 15 matters. ,
16 JUDGE GROSSMAN: Oh, okay.
17 Mr. Gallo.
18 MR. GALLO: As the Board will recall, I took 19 custody of Mr. Martin's notebooks and other materials, 20 and over the recess, we have had those materials 21 Xeroxed, and with the permission -- I don't know if the 22 Board wants to receive them at this point, but --
23 JUDGE GROSSMAN: I think Judge Cole does, but 24 I don't.
O 25 (Laughter.)
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1 MR. GALLO: I gave one to the Staff and to 2 Mr. Guild.
3 The front page shows a blank for the exhibit 4 number, because I anticipate that they will become an 5 exhibit, a group exhibit, through either the admission 6 by -- or the introduction by Intervenors or by 7 Applicant.
8 Now, what they consist of is -- the booklets 9 themselves have been -- of which there are eight -- have 10 been Xeroxed page by page, and each book -- each book 11 had been stapled together, and I'd say each one is 12 approximately three-eighths of an inch thick; and then l
(])
13 the inspection results on the hangers is a unit; and 14 then there was an unmarked black notebook, which has l 15 been just designated as such; and then there was some 16 miscellaneous material furnished initially before the 17 hearing got under way by Mr. Martin -- that's one 18 group -- and then there was some additional 19 miscellaneous material provided just prior to the l
20 recess -- and that's the last group -- so, altogether --
21 and I shall return Mr. Martin's originals when we see 22 him next.
l 23 JUDGE GROSSMAN: Okay, fine.
24 I suggest, though, whichever counsel is examining O 25 him have the originals at the time, because there were a Sonntac Reporting Service, Ltd.
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1 lot of highlightings in the originals that may not come 2 out quite the same in the copies.
3 MR. GALLO: Well, I'm told that the copying 4 took that into account. We have a Xerox machine that 1
5 can be adjusted to take that highlighting problem into 6 account.
7 But, in any event, maybe I should give custody of I
8 che originals to the Board.
1 9 The Board can make them available as appropriate.
10 JUDGE GROSSMAN: Perhaps you ought to give 11 custody to other counsel, either Mr. Guild or Mr. Berry,
{} 12 and the other one get custody the next day or whenever i 13 it's convenient.
14 Well, Mr. Guild, you will be examining, so I think 15 Mr. Guild ought to get custody, in fact.
16 MR. GUILD: I'll be happy to take custody; 17 and I'll make it available to other counsel if they 18 would like to review the documents.
19 JUDGE GROSSMAN: Well, you already have it in 20 total for Mr. Guild.
21 Any further preliminary matters before we go on to 22 the next witness?
23 (No response.)
24 JUDGE GROSSMAN: No. Fine.
O 25 Mr. Guild, why don't you call your next witness, Sonntag Reporting Service, Ltd.
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1 please.
2 MR. GUILD: Thank you, Mr. Chairman.
3 Intervenors would call Robert Hunter to the stand.
4 Mr. Hunter, if you would step forward and be sworn.
i 5 JUDGE GROSSMAN: Mr. Hunter, remain standing.
6 Raise your right hand.
7 (The witness was thereupon duly sworn.)
8 JUDGE GROSSMAN: Please be seated.
9 MR. GUILD: Mr. Hunter, there's a microphone 10 on the table in front of you, and if you put that around 11 your neck, I think we can all hear you.
12 ROBERT DUANE HUNTER l
13 called as a witness by the Intervenors, having been first 14 duly sworn, was examined and testified as follows:
15 DIRECT EXAMINATION 16 BY MR. GUILD:
17 0 Would you state your full name and your residence 18 address for the record, please?
! 19 A Robert Duane Hunter. My permanent address is Route 4, 20 Box 141, Centralia, Missouri.
21 Q And do you go by R. D.?
f 22 A Right.
I 23 Q All right, sir.
24 You were formerly employed as a Level II Quality 25 Control Inspector under the working direction of the L.
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1 K. Comstock Company at Braidwood, were you not?
2 A Yes, at one time I was.
3 Q All right.
4 And technically working for BESTCO, a job shop at 5 the time?
6 A Yes, that was my last job.
7 0 All right.
8 And what was your last day of employment for BESTCO 9 under the Comstock agreement?
10 A I believe it was March the 26th, if I'm not mistaken.
11 Q All right, sir.
12 Would you state your date --
13 JUDGE CALLIHAN: What year?
14 THE WITNESS: 1986.
15 JUDGE CALLIHAN: Thank you.
16 MR. GUILD: Thank you, Judge.
l 17 BY MR. GUILD:
i 18 0 Would you state your date of birth for the record, Mr.
19 Hunter?
20 A November the 4th, 1931.
21 Q All right, sir.
22 Are you a welder by trade?
23 A Yes, I am.
24 Q All right, sir.
25 And how long have you been a welder?
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1 A I went through aircraft welders school in 1949, and I've 2 probably been in the trade ever since that.
3 0 Was that with the United States Air Force?
4 A Yes.
5 0 All right, sir.
6 Would you recount briefly, for the record and the 7 parties, your job experience beginning with that 8 training as a welder?
9 A Yes. On December the 18th,1953, I was honorably 10 discharged from the U. S. Air Force. I returned to my 11 home; at that time with my parents.
12 I worked at a few maintenance jobs for people, like
[}
13 A. B. Chance Company, which is now a division of Emerson 14 Electric, in maintenance.
15 0 Can you spell the name of the company?
16 A A. B. Chance Company?
17 0 Yes.
18 A C-H-A-N-C-E.
19 Q The initials A. B.?
20 A Yes, A. B. Chance company.
21 That's an electrical hardware manufacturing 22 concern.
23 0 All right, sir.
24 Did you do weld work for them?
() 25 A Yes. Like I say, it was maintenance work -- we rebuilt Sonntag Reporting Service, Ltd.
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1 a drop forge -- but I did both maintenance welding and 2 production welding --
3 Q All right.
4 A -- while I was employed at that time.
5 In 1956 to 1957, I attended Arkansas Polytechnic 6 College at Russell, Arkansas, majoring in general 7 agriculture. I received an associate degree in general 8 agriculture.
9 I returned to Missouri; worked for the University 10 of Missouri for a short period of time as a herdsman for 11 the university.
12 0 Cows --
}
13 A Lack of money --
14 0 -- livestock?
15 A Yes, it was dairy -- it was dairy department.
16 Q All right, sir.
17 A As everyone knows, the pay wasn't too good, so I went 18 into c'onstruction with a concern called Bill Reinheart 19 Construction.
20 Q All right.
21 A In that capacity, I did a little bit of everything.
- 22 We did commercial buildings, state and federal 23 buildings, homes, one thing and another.
24 In 1960 to '64, I was employed by National Sugar 25 Manufacturing Company in a capacity of millwright, Sonntaq Reporting Service, Ltd.
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l welder, production superintendent and so forth.
l 2 Q A sugar mill?
3 A Yes, it was a -- it was a beat -- beat plant in 4 Colorado.
5 Q All right, sir.
6 A From 1964, you might say, to probably '67, with 7 dif ferent construction companies in the pipeline, pipe 8 laying, transportation, distribution system as a pipe 9 welder.
10 I believe there was approximately three years with 11 Allis-Chalmers as a millwright, plant maintenance man.
12 In the --
13 O Let me int'errupt you.
l 14 When you did the pipe welding work, was it to any 15 code or standard, Mr. Hunter?
f 16 A Yes; that was AWS Coder right.
17 All right, sir.
f Q 18 I'm sorry I interrupted you.
l 19 From '64 --
l 20 A Yes, yes.
l 21 0 -- after the pipe weld jobs, what did you do then?
22 A Worked for Allis-Chalmers approximately three years on 1
23 two different occasions as a millwright, plant 24 maintenance man, plant modification, setting up of O 25 equipment and so forth.
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i 1 Q What was the nature of Chalmers' work that you were 2 involved in?
3 A That was a manufacturing plant.
4 Q They manufactured heavy equipment, farm implements?
! 5 A Farm equipment.
- 6 Q All right, sir.
7 A At Zener Division, mostly, at Independence, Missouri.
, 8 Q That took you to 1974?
9 A That -- up to about '72.
10 And then from '72 to '74, I run a small fab shop or 11 custom manufacturing plant.
12 Q Did you do weld work at that time?
}
i 13 A Yes, all work: Machinist work, weld work'and l 14 everything.
15 Q All right. ,
16 You were self-employed then?
'17 A Self-employed; right.
18 7 - '75, '76, in that area, I was maintenance 19 superintendent for Ohrslen Brake Lever in Mobeler, I
20 Missouri.
21 Q Can you spell the last name that came up?
22 A Ohrslen?
23 Q Yes.
l 24 A O-H-R-S-L-E-N.
i l
([) 25 Q What was the nature of their work?
l .
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kJ 1 A It was all plant and facility maintenance, supervision.
2 Q What sort of work did they do?
3 A They had contracts with all the major automotice 4 manufacturers. They built things such as brake levers, 5 clutch levers, dozens of different things for the 6 different automotive manufacturers, International, 7 Caterpillar, everybody. They worked for everyone.
8 0 All right, sir.
9 A Prom '76 to '79, I worked as an instructor in the public 10 school system teaching basic welding more than anything 11 else. _
In '79 I went to Norco, Louisiana, for Shell Oil
{} 12 13 Company -- or, actually,.the contractor was 14 Pullman-Kellogg, as a weld inspector, and tested welders 15 at the union facility there in Metairie for some eight 16 months.
17 0 In Louisiana?
18 A Yes.
19 0 All right. ,
20 Were you working to any codes or --
21 A Yes --
22 0 -- any code?
23 A -- it was all code work.
24 Q What was the code involved?
25 A ANSI, AWS.
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1 0 Were these pressure vessels you were working on?
2 A Yes. j i
3 0 All right.
4 Pipeline work?
5 A It was refinery.
6 Q Refinery?
7 A Yes, breaking down of petroleum. j 8 Q Did this involve X-ray pipe welding? l l
9 A Oh, yes.
10 0 Work subject to radiographic inspection?
11 A Yes; a lot of it. ,
l
{} 12 13 Q All right.
After Pullman-Kellog then?
i 14 A I went with -- worked for an outfit called Project 15 Co.nstruction Cooperation; and they had a contract with 16 Amoco here in Chicago to build the Whitney Canyon 17 Project. That was up until 1982.
18 In '83 I come with -- with Comstock.
19 Q All right.
20 The '82 job, what was the nature of that facility?
21 A That was a sour gas refinery unit at Evanston, Wyoming.
22 Q That extracted --
23 A Yes, salt.
24 Q -- gas -- sulfur gas?
O 25 A Right.
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2 And did that involve any code welding or welding 3 inspection?
4 A Oh, yes, all of that's coded work.
5 Q Was that code pipe welding?
6 A Well, yes, we did the whole -- the one. company did the 7 whole job, so we covered the whole construction area.
8 0 was that the AWS Code?
9 A AWS, ANSI.
10 Q ASME?
11 A Yes, 12 Q All right, sir.
q 13 Then in October of 1983, you joined the L. K.
14 Comstock Company --
15 A That's true.
16 Q -- at Braidwood?
17 A That's true.
18 Q All right, sir.
19 When you came on in October of '83 -- well, before l
20 I begin this -- and after your employment with Comstock 21 terminated in the spring of 1986, Mr. Hunter, what work 22 have you done since then?
l 23 A At the present time, I am employed by Telecom -- or, l
24 actually, U. S. Sprint --
'25 0 All right.
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1 A -- as a general area inspector. -
2 Q All right.
3 You do quality control inspection work for them?
4 A Yes.
5 Q What's the nature of their business?
6 A Actually, communications. ,
7 Q They run lines --
8 A Yes.
9 Q -- for telephone communications?
10 A Right.
j 11 Q All right, sir.
~
12 Are you also self-employed in the farming business
)
13 as well? ,
14 A Oh, yes.
15 I have been for the last 25, 30 years, yes.
16 Q All right.
17 What kind of farming do you do do?
18 A I only have a small farm. I have some pure bred Mary 19 Gray cattle;, some good ones and some not so good, of 20 course.
21 Q All right, sir.
22 Now --
23 A Expensive hobby today.
24 Q All right.
25 Back to October, '83:
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l 1 You joined Comstock, ani you did so as a Level II 2 Quality Control Inspector?
l 3 A That's correct.
4 Q All right.
5 And what areas did you become certified in at l
6 Comstock?
7 A Welding and receiving.
8 0 Okay.
9 How quickly after you started did you become 10 certified in welding?
11 A Oh, approximately 30 days or less.
12 Q All right,
[}
13 And how much later did you get your receipt j .
14 certification?
15 A It was probably.a year or so; maybe -- maybe even -- ,
16 might even have been 18 months.
17 Q All right.
j 18 Did you do principally weld inspection work at 19 Comstock?
20 A Yes, I did.
21 Q All right.
l 22 Did you do some, but little, receipt inspection?
23 A Yes, that's correct.
l Now, when you came on as a Weld Inspector, for whom did l
24 Q 25 you work directly?
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1 A At that time a young man by the name of Bruce Brown was 2 considered the Lead Inspector.
3 0 What other Weld Inspectors worked with you at that time, l
4 Mr. Hunter?
5 A Klatchko, Mark Klatchko.
6 Q Klatchko?
7 A Yes, Klatchko.
l 8 Q Well, any others?
9 A Well, at that time they was the only two, actually, Leads that we had.
10 11 Q All right.
12 How about other Weld Inspectors, non-Leads but
)
13 Level II Weld Inspectors beside yourself? Who else was 14 there at that time?
15 A The day I come in, a fellow by the name of Bill Nolker l 16 came in with a lot of experience.
17 Q Can you spell his last name for the record?
18 A 3-0-L-K-E-R, if I'm not mistaken.
19 Q All right, sir.
20 A There wasn't too many Weld Inspectors. I would say 21 probably less than 12.
22 Q All right.
23 Can you recall any of the names of the others?
24 A I'm not -- I couldn't recall them right offhand who had 25 their certificates -- I mean, who had their Sonntag Reporting Service, Ltd.
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i 1 certifications and who didn't.
2 Q All right,. sir.
3 Above Mr. Brown -- if he was the Lead in welding, l
i 4 who was above him in the chain of supervision?
5 A We had both -- Larry Seese had just come on the job, I 6 believe, approximately 10 days before I did, or maybe 7 even a week before I did, as assistant manager, and Irv l 8 DeWald as manager.
9 Q All right.
10 Was Mr. Seese in your chain of command? Was he 11 over weld inspection at the time?
12 A Well, at the time I -- I couldn't say whether Larry was 13 in charge of welding or just Irv.
14 I think it was just Irv pretty well took care of 15 that.
16 Q All right.
17 And at that time, after getting certified 18 approximately a month into your tenure, what sort of I
19 work did they have you doing, Mr. Hunter?
l l
20 A Pretty well everything. At the time we not only looked 21 at hangers, but we also looked at pans; any type of 22 welding that was going on that Comstock was doing.
23 Q Okay.
24 These are cable pan hangers --
1 25 A Yes.
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1 0 -- and cable pans?
2 A Right.
3 Q All right.
4 Now, did you become aware that there was a backlog 5 in the conduct of inspections of installed electrical 6 work?
7 A Yes. I'd say for the first 12 months that I was here, 8 we just worked on backlog alone. We didn't have no 9 current or no in-process welding going on at all, 10 inspection -- weld inspection. Everything was 11 backlogged.
12 Q Your work was trying to address and correct this 13 backlog?
14 A Yes, it was trying to catch up with things that they had 15 done years before.
16 0 Okay.
17 And were you aware that Mr. DeWald himself had 18 previously performed weld inspection work when he was a 19 Level II?
20 A Of course, yes.
21 Well, of course, naturally, when you come on a 22 site, you find out what the manager done before and 23 things like that.
24 So someone said, "Well, Irv had been here as an 25 Inspector before he left and come back as a manager."
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1 Q All right.
2 And were you aware that Mr. Richard Martin had 3 previously been a Weld Inspector?
4 A Yes.
l l 5 0 All right.
6 Do you know -- did you have occasion to be asked to 7 review any of Mr. Martin's past inspection work?
8 A Yes. When I first come in and started inspecting, Irv 9 and I was talking, and Irv said, "Would you check Mr.
10 Martin's welds out," you know --
11 Q All right.
12 A -- and I -- actually, I said, "Yes," and he asked me to 13 give him no written report or anything like that; and I 14 made an honest report to him of what I thought the young 15 man was lacking..
16 Q All right. .
l 17 Well, let me ask you, before you tell me what you 18 thought, if you have any understanding why Mr. DeWald 19 asked you to perform this work?
20 A Well, I'm pretty sure he realized that I had had a lot 21 of welding background, had actually done a lot of l 22 welding.
23 Q All right.
24 So he asked you to go out and look at Martin's 25 work.
I I
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1 How did he identify or you identify what Mr. Martin 2 had previously inspected?
l 3 A By his stamp.
4 Q Okay.
l l 5 What, did Mr. Marcin have a unique identifying QC l
6 stamp?
7 A Yes, every Inspector -- every Inspector has, at that 8 time, either a config, a letter or something. Not a 9 number, just a config or a letter.
10 Q All right.
11 And you were informed what Mr. Martin's stamp was?
{} 12 A Yes; I was, yes.
And did you -- were you told to look for his work in the 13 Q 14 field --
l 15 A Well, I'm sure I was, I'm sure I was.
16 0 -- by Mr. DeWald?
17 A Whether it was -- whether it was in the steam tunnel 18 area or the -- or the containment or where, yes.
19 0 Okay.
20 DeWald sent you out, said, "Look for Martin's l 21 work," and told you what his stamp was; is that the way l
l 22 it happened?
23 A Well, he told me to check certain welds, yes.
24 Q And did he identify components to you to look at, Mr.
25 DeWald?
I l
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1 A Oh, I'm sure he did, I'm sure he did.
2 Q And did you do as he asked?
3 A Yes, I give him an answer, appraisal, of what I thought.
4 Q All right.
5 And what did you tell Mr. DeWald of Mr. Martin's --
6 of your review of Mr. Martin's work?
7 A I said that he was lacking in certain areas.
8 Q And what was the basis for that conclusion on your part?
l 9 A Well, he -- he might buy one weld today that -- it was 10 really, really, really rough, you know, maybe -- and at 11 that tine we had a lot of rough welds -- and maybe the 12 next one, that was a pretty fair weld, as far as
[
l 13 conforming to -- to the criteria, well, maybe -- maybe 14 it should have been bought, maybe he rejected it. Maybe l 15 it was just the opposite on the next one.
16 In other words, he wasn't consistent.
17 O All right, all right.
18 And among those inconsistent inspections, you 19 observed conditions that, in your opinion, were rough or 20 rejectable but that had been accepted by Mr. Martin?
21 A Well, I wouldn't -- I wouldn't say that they were 22 rejectable.
l 23 I would just say that he would reject one that 1
24 maybe he should have bought, and maybe he would accept 25 the -- the next one but that he shouldn't have bought.
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1 Q All right.
2 When you say "shouldn't have bought," that means --
3 A That means there was something lacking, either undercut 4 or maybe have a little cold lap, things of that nature.
5 In other words --
6 Q Conditions that, in your opinion, were rejectable?
7 A Yes, it would have been rejectable; right.
8 Q All right, sir.
9 Was Mr. Martin at that time performing weld 10 inspections, to your knowledge?
11 A If I'm not mistaken, Mr. Martin kept his stamp and his 12 hammer for approximately three months after I -- after
{) 13 I -- I mean, when I -- when I' arrived on the job, he had 14 his stamp for approximately three months.
15 Q All right.
16 And I take it, from your answer, you understood l 17 that he lost his stamp --
18 A That's right, that's my understanding.
19 Q -- three months later?
l 20 A Right.
21 Q What was your understanding of the basis for Mr. Martin 22 losing his stamp?
I 23 A Well, I think someone said that he had too many PTL 24 rejections.
25 Q Pittsburgh Testing Laboratory --
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1 A Right.
2 Q -- did the overview rejections --
3 A Right.
4 0 -- on a sample basis?
5 A Yes.
6 Q You understood Mr. Martin's work had too high a 7 rejection rate?
8 A That's true.
9 Q Do you remember what Mr. Martin's stamp was?
10 A Not offhand.
11 I know at one time he did have -- he also had J, 12 the seme as Mr. Irv DeWald; but the only way they kept 13 up with that was the time period -- the time the hammer 14 was checked to a certain man until it was returned to a
( 15 certain man.
16 Q All right.
17 So Mr. Martin and Mr. DeWald both had the Weld 18 Inspector stamp symbol J; is that correct?
19 A If I'm not mistaken, that's correct.
20 Q But perhaps at different periods of time?
21 A Right, it was a different period of time.
22 Q Did Mr. Martin have any other stamp during another 23 period of time?
24 A I can't recall it right offhand, but I'm sure he did.
25 0 All right.
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1 You believe he had a second stamp, Mr. Martin did?
2 A I think so.
3 Q But you can't recall what it was at this time?
l 4 A I can't recall.
5 Q All right, sir.
6 In any event, at that time you were aware of what 7 his symbol was and --
8 A Yes.
9 Q -- you --
10 A Oh, yes.
11 0 -- knew you were looking at a Rick Martin weld 12 inspection --
)
13 A Right.
14 0 -- when you went to the field?
15 A Right.
16 Q All right, cir.
17 What, if anything, did Mr. DeWald say to you when 18 you made this report to him about Mr. Martin's work?
19 A Well, he -- he said that the young man didn't have --
20 probably didn't have the experience, even, to -- to 21 actually make a bona fide judgment on close welds.
22 In other words, he probably went from a Level I to 23 a Level II too soon.
l 24 Q Level I QC Inspector to a Level II QC Inspector?
25 A Right, right.
Sonntag Reporting Service, Ltd.
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8489 1 Q Were you aware that Mr. Martin had previously worked as 2 a Level I Weld Inspector?
3 A Yes, he did.
4 I don't know for -- for the period of time, I don't 5 know.
6 Q All right.
7 Did you become aware of who trained Mr. Martin in 8 weld inspection?
9 A Well, naturally, you hear things; and the first thing 10 was that he was Irv DeWald's protege.
11 Q That Mr. Martin was Irv's protege?
1 12 A Right.
13 Q You used a term " bought off" or " buy off."
14 By that do you mean accept --
, 15 A Yes, accept or reject.
16 0 -- accept weld inspections?
17 A Right.
18 Q All right.
19 When you say " bought off," you mean accept, do you 20 not?
21 A Right.
j 22 Q Did you have occasion to go to the field with Mr.
23 Martin, at about this time, to accompany him in his weld 24 inspection?
l O 25 A Yes, I'm sure that I accompanied Rick, you know, on a l
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1 few times on his inspections.
2 Q All right.
3 At about this period of time?
4 A At about this period of time; early -- probably --
5 probably early '84.
6 Q Did you have occasion to discuss with Mr. Martin the 7 deficiencies in his inspection work and the causes of 8 those deficiencies?
9 A Well, I'm sure we talked about it, I'm sure we did.
10 0 All right.
11 And what, if anything, did Mr. Martin tell you about -- in his judgment, about his training background?
{) 12 13 A Well, I'm pretty sure --
14 MR. GALLO: Obj ection.
15 The last answer from the witness, in answer to the 16 question, "Did you have occasion to talk to Mr. Martin I 17 about the deficiencies," was -- the witness' answer was, 18 "I'm sure we did, I'm sure we did."
19 THE WITNESS: I'm sure I did.
20 MR. GALLO: That conveys to me no present 21 recollection of the conversation.
22 He's about now to elicit some testimony in answer 23 to a question of what that recollection was.
24 MR. GUILD: I think the record will reflect 25 it's more a figure of speech on the witness' part than Sonntag Reporting Service, Ltd.
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1 it is --
2 JUDGE GROSSMAN: It sounds like it might be; 3 but I think you better clear it up and ask him.
4 BY MR. GUILD:
l 5 Q Do you, in fact, recall having discussed the subject of 6 Mr. Martin's training with Mr. Martin at about this 7 time?
8 A Yes, I did.
9 Q All right, sir.
10 And what was the substance of Mr. Martin's l
11 statement to you on that subject?
12 A I explained to Mr. Martin what the face of a weld should 13 look like, what the toe of a weld should look like --
14 Q I'm sorry.
15 The toe of the weld?
i 16 A Yes, the toe of the weld.
l 17 Q All right.
18 A I also explained to him whether they could be -- the l 19 legs of the weld, the legs of a fillet weld --
l 20 Q All right.
21 A -- what a crater was.
22 He didn't know -- he didn't know -- he didn't know 1
1 23 what a rod crater was --
l 24 0 I don't either, so why don't you tell me?
25 A -- simple things.
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1 Q What is a rod crater?
2 A When you pop the rod end out of the crater.
l l 3 0 It leaves a crater or a depression?
4 A Yes; and the crater can start what we call fish eyes or 5 cracks, crater cracks.
6 Q All right, sir.
7 A He didn't know what a crater crack was.
l 8 0 You explained these things to Mr. Martin?
9 A Yes, I sure did, I sure did.
10 Q Did Mr. Martin describe to you what the source of his 11 training had been in weld inspection?
12 A Well, I'm pretty sure that he told me that Mr. Irv 13 DeWald had given him most of his training, weld
! 14 training.
15 Q Did you become aware of the methods that were previously 16 employed at Comstock, during Mr. DeWald and Mr. Martin's 17 tenure as Level II Inspectors, to perform weld 18 inspections in the field?
19 A Well, the program changed about every other day, so as 20 far as the program the day they done it, I don't know.
21 Q All right.
22 Did you have occasion then or later to review old 23 weld inspection reports from this period of time, 24 including reports prepared by Mr. DeWald and Mr. Martin?
25 A Oh, yes.
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1 Q And what was the occasion on which you happened to 2 review such reports, Mr. Hunter?
3 A Different -- different programs, either AVO programs or 4 reinspection programs or something of that order, when 5 you went to the vault and pulled -- pulled their .
, 6 documents out.
7 Q All right.
8 What does AVO stand for, Mr. Hunter?
9 A Avoid Verbal Orders.
I 10 0 Is that the title on a speed memo or a document?
11 A Well, I'm sure it's a -- yes, I'm -- it's on -- it's on 12 a speed memo, I'm sure.
)
13 Q The name is printed on the face of t'he document?
14 A AVO; right.
15 Q It's called an AVO.
16 It's a blank form for writing instructions or 17 comments?
18 A Right, that's true.
19 Q Now, when you, on those occasions, happened to go to the 20 vault to look at past documents, that was when you would 21 encounter the past inspection checklists by Mr. DeWald 22 and Mr. Martin?
23 A Oh, yes.
24 Q Now, did you understand that those checklists reflected 25 an identification of the installations inspected on the Sonntag Reporting Service, Ltd.
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a 1 basis of grid references?
2 Did you observe grid references on those documents?
3 A Yes, it said, "So many" - "so many hangers on this 4 grid."
5 0 All right.
6 Would it give letter and number coordinates 7 identifying a location at a particular elevation in the 8 plant?
9 A Yes, it give -- give that location; right.
10 Q All right.
11 And that would be the identification of what had l
12 been inspected by the Inspector on that Form 19?
13 A That's true.
14 0 All right.
15 And then it would list a total number of welds 16 within that grid location?
17 A Yes.
18 Q Now, did you have occasion to discuss with Mr. Martin 19 his practice in using the checklists with those sorts of 20 references on them?
21 A Yes.
22 Q And did Mr. Martin inform you how he had learned to 23 complete inspection documents in that form?
24 A Yes.
25 Q What did he tell you?
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1 A He said that was the way it was done at that time and 2 that was the way he was instructed to do it by Mr. Irv 3 DeWald.
4 Q All right.
5 Now, on those documents, did you ever have occasion 6 to review Form 19 checklists that documented large 7 numbers of welds on a single checklist, say, in excess
! 8 of 100? -
9 A Oh, yes.
10 0 Was it common to find checklists with more than a 11 hundred welds listed on them?
i
{} 12 13 A Yes, at one time it was.
How about in excess of 500?
Q 14 A I've probably seen that many on a checklist.
15 Q Did you become aware, in reviewing documents, that there 16 were instances where Weld Inspectors, in Mr. DeWald and 17 Mr. Martin's day, had inspected in excess of a thousand 18 welds on a single day?
19 A I've never seen -- I've never seen that inspection.
20 I was informed that it was there, but I've never 21 seen it.
22 Q All right.
23 Well, that's a single checklist.
24 Now, you have never seen a checklist with more than 25 a thousand welds on it; correct?
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1 A That's correct.
2 Q All right.
3 How about multiple checklists with the same date 4 reflecting the performance of, in total, more than a 5 thousand welds in a single day?
6 A Oh, yes, I've seen several of those.
7 Q All right.
8 Now, to be clear:
9 Each checklist would list less than a thousand, but 10 would show the same date as the date on which the 11 inspection was at least signed off?
12 A That's true.
13 D And if you totaled the number of welds up, there would 14 be more than a thousand on the same date; correct?
15 A That's true.
16 Q And who were the Inspectors that you recall associated 17 with those checklists?
18 A Well, Mr. Baker and Mr. Irv DeWald was the two main 19 ones. There was probably one or two others; Kass and 20 two or three others.
21 Q Let me ask the names again.
22 Parker, who was that? Do you recall who that was?
23 A That was an Inspector who there was at one time.
24 He had left before I arrived, of course.
I
' 0 25 Q Can you recall his first name?
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1 A Not offhand.
2 Q All right.
3 And Mr. DeWald we know.
4 And who was the third gentleman?
5 A Kass, I believe, K-A-S-S or K-A --
6 Q How about Kast?
7 A Yes, Kast.
8 Q Mike Kast?
9 A Right, Mike Kast.
10 JUDGE GROSSMAN: Excuse me.
11 You are talking about multiple lists signed by the 12 same person?
13 THE WITNESS: Th'e same day.
14 JUDGE GROSSMAN: Okay.
15 But by the same person on the same day?
16 THE WITNESS: That's correct.
17 JUDGE GROSSMAN: Okay.
18 BY MR. GUILD:
19 0 I know you've just answered the question in the 20 negative. You said you hadn't seen any thousand-plus 21 single checklists.
22 Had you ever heard that Mr. DeWald, when he was a 23 Level II, had inspected in excess of a thousand welds 24 in a single day?
25 A I had heard that, yes.
l
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1 Q Had you ever heard that Mr. DeWald, when he was a Level 2 II Weld Inspector, had signed off on a single checklist 3 in excess of a thousand welds on a single day?
4 A Well, like I say, I -- I heard about the one that was 5 supposed to have been floating around.
6 I never saw it.
7 0 Okay.
8 was that fact discussed commonly among the QC 9 Inspectors?
10 A Oh, yes.
11 MR. GALLO: Objection; form of the question.
I don't know what fact is being referred to, but it l
{) 12 13 sure isn't a thousand welds.
14 MR. GUILD: That remains to be seen, Mr.
15 Chairman.
16 But I don't mean to suggest that the matter is l
17 established by my stating it that way.
18 It is a fact in the sense that I pose it to the 19 witness as a fact.
l 20 BY MR. GUILD:
21 0 The performance of Mr. DeWald -- by Mr. DeWald of in 22 excess of a thousand weld inspections on a single 23 inspection report was discussed commonly among QC 24 Inspectors?
l 25 A Yes, it was.
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1 Q All right.
2 You didn't see the document personally, but --
3 A I never saw the document, sir.
4 0 All right, all right.
5 Did you ever talk to anyone who claimed to have 6 seen the document?
i 7 A Well, just -- you know, I mean, just general 8 conversation. Most everybody said they had seen it. I l
9 never.
10 0 Okay.
11 Now, at the time you came on, you learned that 12 there was a backlog of QC inspections?
)
- 13 A That is correct.
14 0 Were those just in the weld inspection area or were they 15 in other disciplines as well?
16 A No, there was other disciplines, too.
17 0 You were doing weld inspection work?
18 A Right.
l 19 Q Now, had you ever heard any mention of a belief or fact 20 that Comstock was in danger of losing its contract for l
21 the electrical work because of this backlog?
22 A Yes.
23 Q Did you ever hear that from Mr. DeWald?
24 A Oh, yes.
1 25 We used to have -- we used to have weekly meetings, 1
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1 and Irv would try to bring us up where we stood on each 2 area or each project we was working on; and at one time 3 we had 32 different projects going. I remember that, 4 32.
5 0 All right.
6 These were special projects?
7 A These were all special projects; right.
8 Q All right.
9 And was it in that context that Mr. DeWald 10 mentioned that Comstock might lose the contract?
l 11 7 Yes. He said that -- he would say that Comstock give 12 Con Ed the word that there would be a certain project
{) 13 through with -- or up to a certain point at a certain 14 date; right.
15 Q All right.
16 And what reference, if any, did he make to the loss 17 of the contract?
18 A Well, he would always say, you know, "If we want to keep 19 our job, we've got to" - "we've got to keep up." You 20 know, "We've got to" - "we've got to get these projects 21 up to the promised date."
22 Q Okay.
23 Was that a common reference for Mr. DeWald to make?
24 A Yes, it was, at that time.
25 Q All right.
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1 And you say "these meetings."
2 Are these the general meetings of QC Inspectors 3 that took place on' Fridays?
4 A Usually on Friday, yes.
5 0 All right.
6 Can you recall any of the special projects on which 7 you worked, Mr. Hunter?
8 A Well, yes. I was on what they called the pan project 9 for approximately eight months.
10 Pan runs was pan to Unistrut.
11 Q Cable pans, now?
12 A Yes, cable pans.
[}
13 Q All right.
14 And can you recall what year that eight months took 15 place in?
16 A Late '84 to mid '85, I would say.
17 0 All right.
18 How about any other special projects on which you l 19 worked?
l l 20 A Yes. When I left there, I was on the AVO project; but 21 before that, there was several audits that -- come up 22 with an audit, find out that they had to get so many 23 inspections on certain things done, so that was called a 24 special project. They would usually give it a number.
25 0 All right.
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8502 1 Do you recall Mr. Marino coming to the site in 2 April of 1984?
3 A Yes, I do.
4 Q All right.
5 Mr. Marino was the Pittsburgh QA Manager for 6 Comstock, was he not?
7 A That is correct.
8 0 All right.
9 And can you recall the substance of what Mr. Marino 10 had to say in April of '84?
11 A Well, he wanted everyone to be certified across the
{} 12 13 board -- that was the first thing -- and he made all kind of little promises.
14 I took Mr. Marino to the jobsite for approximately 15 one-half-day myself and showed him some o,f the things 16 that the QC Inspectors were doing and tried to explain l
l 17 some of the problems that QC had at the time.
l 18 Well, Mr. Marino was -- he had already made up his 19 mind of what he was going to do when he come down, I'm l
20 sure.
l 21 Q Mr. Marino announced a Comstock pay restructuring plan?
22 A That's correct.
23 Q And, in substance, did that involve a 50-cent-per-hour 24 increment for each additional certification?
25 A Right.
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8503' I d
w 1 hR. G ALLO: Objection. Leading the witness 2 since this started,'
3 I think he ought to -- Counsel ought to be directed 4 to cease doing that leading.
5 MR. GUILD: Well, I'm not leading the man.
6 JUDGE GROSUMAN: Yes.
7 Mr. Gallo, these are things that; we've ~ heard from 8 everybody, and he's moving him through preliminary 9 questioning.
10 I don't think we want to ho3d the hearing up for 11 things that aren't in controversy.
4 12 Is there a problem with that 50 cent an hour?
[}
13 MR. GALLO: No, there's not a problem with 14 that.
15 But if, indeed, that's the Board's ruling, it seems .,
16 to me the testimony 14 cumulativo and Irrelevant and.we ,
17 ought to move o'n'to something new.
18 JUDGE GROSSMAN: Well, I assume that we're 19 laying a foundation for the controversial testimony, and
^
20 so let's just continue along this way. -
21 I don't think you ought to slow it up, Mr.~ Guild.
22 MR. GUILD: Indeed, Mr. Chairman, the only way 23 I can inform the witness about the foundation for my 24 next questions is by proceedi,69 O 25 JUDGE GROSSMAN: Proceed the way you are Sonntac Reporting Service, Ltd.
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1 going, e 2 BY MR. GUILD:
i 3 Q You took Mr. Marino to the field.
4 Was that before or after he made his talk to the 5 Inspectors on site?
6 A I'm pretty sure it was probably before.
7 Q All right.
8 And did you advise or recommend or make any 9 suggestions to him about how they should handle problems i 10 on the job?
11 A Yes. I explained to him that some of us -- there was 12 three'or four of us older Inspectorafthat come there,
)
13 you know, as Weld Inspectors. We didn't come there as l
! 14 cable pullers; we didn't come there, you know, to run l
l 15 conduit; we didn't come there to do a lot of things; and 16 we explained to him that we thought it would'be much 17 better if he set it up as a group of -- in the 18 electrical system, a group in the mechanical system, 19 whatever -- whatever the group -- whatever the fellow 20 was -- whatever his specialty was, rather than try to 21 certify him across -- across the board, because I think 22 there was 9 certs at the time or 11 -- 9, I 23 believe -- and we asked him -- said, "Can I" --
24 actually, "Can everybody be competent in all 9 certs,"
25 because you might -- you might do a cable pull today, it Sonntag Reporting Service, Ltd.
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1 might be six months, it might be a year, before you done 2 another cable pull, you know.
3 "Oh, yes, it would be much better for everyone to 4 be certified across the board." That was his answer.
5 0 All right, sir.
l 6 And then subsquently he announced a cross 7 certification plan --
8 A Yes. ,
9 Q -- that's been referred to?
l 10 A Yes, that's true.
11 Q You mentioned Mr. Marino made promises or you referred l
12 to promises.
13 What was the nature of the promises that you are 14 referring to?
15 A Oh, yeah; that everybody would get trained no matter 16 what. You know, I mean, you just put in for your 17 training and it would take care of it and everything 18 like that.
19 It wouldn't -- it wouldn't be one guy coming in and 20 having five certs before the next one and all that.
21 Q All right.
22 And, of course, for you to get additional pay, you 23 had to get additional certifications?
24 A That's true.
25 Q Even if you were going to be primarily a Weld Bonntag Reporting Service, Ltd.
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1 Inspector --
2 A Right.
3 Q -- you couldn't get your 50-cent-a-cert increment --
4 A That's true.
5 Q -- without additional certs?
6 All right. Now, you said that was a promise.
7 Was that a promise that was kept?
8 A Not by 100 percent, no way.
9 Q And in what regard, in your program, was the promise not 10 kept?
11 A Some got trained in several different area, some got no 12 training, just according to what you were working on.
13 If you were working a hot project, one they claimed 14 to have by a certain date, you had to stay on that 15 project.
16 Q And by " stay on that project," you mean not take the 17 time to get trained in another area?
18 A Right, that's true.
19 Q You couldn't get trained, you couldn't get certified?
20 A That's true.
21 Q Now, did you have occasion to request training so that 22 you could cross certify?
i 23 A Yes, I did.
24 Q Let me show you a ceries of documents, Mr. Hunter, 25 and --
l Sonntag Reporting Service, Ltd.
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8507 1 (Indicating.)
2 A Mr. Marino said that -- put everything on speed memos.
3 Q All right.
4 To request training; is that what I understand?
5 A Right, that's true.
6 Q And you did so, did you not?
7 A (Indicating.)
8 Q You've got to answer orally so that the Court Reporter 9 can pick you up.
10 A Do what, sir?
11 Q You nodded your head a moment ago.
12 I asked you if you put your requests on speed
[} ,
13 memos --
14 A Yes, sir.
15 0 -- and you nodded your head.
16 A Yes, sir.
. 17 0 I've shown you a series of documents --
18 MR. GUILD: And I apologize to the Board.
19 They are out of order, not in sequence.
20 I ask that this be marked as Group Exhibit 66 for 21 identification.
22 (Indicating.)
23 (The document was thereupon marked i 24 Intervenors' Exhibit No. 66 for 25 identification as of July 23, 1986.)
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O 1 BY MR. GUILD:
2 Q If you look through this stack of paper that I have put 3 before you, Mr. Hunter, you will see that there is a 4 document dated August 17, 1984, addressed to Mr. Marino.
5 Do you see that, sir?
6 It's a read and reply memo.
7 Do you find that, Mr. Hunter?
8 A Yes, sir, I do.
9 Q Okay.
10 And why did you send Mr. Marino that read and reply 11 memo?
! 12 A I had requested training before to either Mr. Irv DeWald
[}
13 at the time or whoever was in charge of training.
14 Nothing had been done, so I sent this one to Mr.
15 Bob Marino.
j 16 0 I take it that you asked Mr. DeWald and others orally 17 for such training; is that right?
18 A I am sure that there was probably even some speed memos l
19 that went to him.
20 0 Okay.
21 A I don't have them in my possession, but I'm sure there 22 were.
23 Q All right.
24 And what was the response, if anything, by Mr.
O 25 DeWald to the previous requests you had made for Sonntag Reporting Service, Ltd.
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1 training?
2 A "Just as quick as we caught up on a certain project, you 3 know, we would get training."
4 Q But in the meantime, stick to the project you are on?
5 A Yes, yes.
6 Q Okay.
7 And you were doing weld inspection at that time, I 8 take it?
I 9 A That's correct.
10 0 So you finally wrote this memo of August 17th to Mr.
11 Marino?
{} 12 13 A Right.
And what, if any, response did you get from him?
Q 14 A None whatsoever.
15 Q Did you get any, response from anyone else to the August 16 17th Marino memo?
17 A No, I never did.
l 18 Q Now, in that memo of August 17th, you request to be l
i 19 trained in CEA.
l l 20 That's concrete expansion anchors; right?
21 A Correct.
22 Q Cable pulling, calibrations, conduit and et cetera.
l 23 Did you get training in those areas?
l 24 A No, I never.
25 Q Never did?
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1 A Never did.
2 Q Now, the last page in the package of documents that I 3 have put before you bears a date of March 21, 1985, and 4 it is entitled " Performance Evaluation Form."
5 " Certification Area," it says " configurations," and 6 it appears to be signed by John Miner.
7 Did you take training in the area of 8 configurations?
9 A Yes, I did.
10 Q Okay.
11 And can you identify this last document to me?
12 Can you tell us what it is?
)
13 A You had to have an evaluation before you cou'1d'go out 14 and take your practical, and this was my evaluation from 15 the fellow that I took training under, John Miner.
16 Q That was Mr. Miner?
17 A Yes.
18 Q I take it that it reflects a favorable evaluation of 19 your ability to do configurations?
20 A I think so.
21 Q Okay.
22 The last line says, "I feel Mr. Hunter is ready to l
23 take his examination."
24 Did you shortly thereafter take an examination in 25 configurations?
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1 A Well, I tried to, but it was turned down.
2 The day before or day or two before -- I say a day 3 or two.
4 At least a short time before I went out to take my 5 practical, someone -- I don't know who it was -- anyway, 6 they come up that in order to take a practical, you had 7 to have a supervisor with you.
8 There was no supervisor the day I took my practical 9 so I just just forgot it.
10 I did -- I did take my practical.
11 Q You did take a practical?
12 A Oh, yes.
i
(])
13 Q But they didn't count it --
14 A Right.
15 0 -- because you didn't have a supervisor along?
16 A That's true.
17 Q All right.
18 Now, the top page of the stack of memos that I have 19 shown you is dated June 28, 1985, and it's addressed to 20 Mr. DeWald, Mr. Simile, Mr. Cordy and Mr. High, from 21 you, with a reply that appears to be signed by Mr.
22 Simile.
23 What were the circumstances of your sending this 24 memo?
O 25 A This was about the time that, in order to get the top Sonntag Reporting Service, Ltd.
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1 money that Brand Testing -- or Comstock was going to 2 pay -- I guess Brand Testing -- you had to have three 3 certs, so I requested that, any three certs.
4 Q All right.
5 At the time, in June of '85, when you sent this 6 memo, what were your certification areas?
7 A Welding and receiving.
8 Q All right.
9 And when did you.get your receiving certification?
1 10 I may have asked you that already. I apologize if i 11 I did.
12 A That I would have to'look up. I can't tell you right
({J 13 offhand.
l 14 It was approximately one year after I arrived at i
! 15 the site; approximately one year.
16 Q So at the time of June of '85, in any event, you had the 17 two certifications?
18 A Yes, I did.
19 Q But you needed one more; correct?
20 A (Indicating.)
21 Q Is that co.cect?
l 22 A That's correct.
l 23 Q And Mr. Simile -- is that Mr. Simile's response to your
! 24 memo?
O 25 A No. I believe that's Mr. Seese.
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1 Q Do you recognize that signature at the bottom there?
2 A I believe that is Mr. Seese.
3 0 Well, I hate to argue with a witness about that, but --
4 A I don't know whether it's Mr. Seese or Mr. Simile. I 5 really don't.
6 MR. GUILD: Okay.
7 I just think, Mr. Chairman, the record will reflect 8 a comparison of the signatures appears, to this Counsel, 9 in any event, to be Mr. Simile.
10 BY MR. GUILD:
11 Q Did you discuss it with anyone other than receiving this
() 12 written memo from whoever?
13 A That's all I received, just this.
14 Q And, in substance, whoever, Mr. Seese or Mr. Simile, 15 said, "Due to the present workload, training will be 16 scheduled at a later date"?
17 A That's true.
18 Q Did you get the training in the third cert?
19 A No, I never; no, I never.
20 Q You never did.
21 Looking at the last of the series of documents, the 22 July 12, '85 document, entitled, " Configuration."
! 23 Do you see that?
24 A Yes.
25 Q You asked to take a practical in configurations, and --
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v 1 A Yes.
2 Q -- I see that -- is that your note at the bottom, "No 3 reply was given"?
4 A Yes; it's my initials, yes.
5 Q All right.
6 Ultimately, you did get a configuration?
7 A No, I never.
8 Q Oh, you didn't?
9 A No, I never.
10 Q I'm sorry. Okay.
11 That's correct.
12 Receiving was the only other --
13 A Right.-
! 14 Q -- certification?
15 All right, sir.
16 JUDGE GROSSMAN: Why don't we --
17 BY MR. GUILD:
- 18 0 Did you get an oral reply --
19 JUDGE GROSSMAN: We're going to take a break.
l 20 MR. GUILD: If I could just finish, Mr.
21 Chairman.
22 JUDGE GROSSMAN: Oh, all right.
23 BY MR. GUILD:
24 Q Did you get any oral reply from any supervision to your O 25 July, '85, memo requesting configuration training?
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1 A Not that I know of.
2 MR. GUILD: All right, sir, 3 Mr. Chairman, before we recess, I'd ask that 4 Exhibit 66 be received in evidence.
5 JUDGE GROSSMAN: Any objection?
6 MR. GALLO: No objection.
7 The first sheet is Mr. Simile's signature.
r 8 JUDGE GROSSMAN: Okay, fine.
9 I accept that.
10 MR. GUILD: Thank you.
11 MR. BERRY: No objection.
l () 12 JUDGE GROSSMAN: Okay.
13 Received.
14 (The document was thereupon received into
! 15 evidence as Intervenors' Exhibit No. 66.)
16 JUDGE GROSSMAN: We'll take a 10-minute minute l
17 break.
18 (WHEREUPON, a recess was had, after which j
19 the hearing was resumed as follows:)
20 JUDGE GROSSMAN: We're back in session.
21 Mr. Guild.
22 MR. GUILD: Thank you, Mr. Chairman.
23 BY MR. GUILD:
24 Q I asked you a few moments ago, Mr. Hunter, about the 25 backlog, and I believe you testified that you were aware i
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1 of one in inspections from the time you came on the 2 site, at least -- at least for a year after you were on 3 the job, in any event; correct?
4 A Yes, I'm sure it was probably over a year that we worked 5 nothing except backlog.
6 Q Now, do you recall a time when Mr. DeWald, during that 7 period, spoke to the Inspectors about completing the 8 weld inspection checklists with respect to the remarks 9 section of the form?
10 A Well, at one time Mr. DeWald made the remark, or maybe 11 it come out in a memo, you didn't have to worry about Q 12 the remarks section because the top of the Form 19 or 13 the inspection checklist would take c$re of everything 14 as far as accept or reject.
15 0 What was the reason, if you know, why Mr. DeWald raised l 16 this issue? Why was he concerned about it, if you
(
17 know?
18 A Some of the fellows wanted to add notes into the remarks 29 about some of the conditions that they found during 20 their inspection.
l Such as deficiencies they identified?
j 21 Q 22 A Well, maybe not so much deficiencies, but the number of 23 welds that was missing; maybe where they -- even though 24 they took a Form 30 or ICR to track it, they would still 25 know where the -- where the welds were missing and Sonntaq Reporting Service, Ltd.
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1 things like that on the hanger or whatever they was 2 inspecting.
3 Q All right.
4 So there may be some other documentation for a 5 deficiency.
6 But so that looking just at the checklist, one 7 would be able to see what the discrepancy were?
8 A That's true.
9 Q All right.
10 And was it Mr. DeWald's position that it took too 11 much time to fill out this portion of the form?
12 A Yes, I believe that was one of the things.
(])
! 13 ' Q All right.
14 And because of the backlog, he was trying to save 15 time, I take it?
! 16 A I'm sure -- I'm sure he was.
17 Q And what were the --
18 JUDGE GROSSMAN: Mr. --
19 MR. GUILD: Mr. Chairman.
20 JUDGE GROSSMAN: Yes. You are leading a 21 little took much on this, Mr. Guild.
22 MR. GUILD: Yes. I'm referring, really, to 23 deposition testimony and trying to refresh the witness' 24 recollection.
O 25 JUDGE GROSSMAN: Oh, okay. I see.
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V 1 BY MR. GUILD:
2 Q Do you recall so testifying in your deposition about the 3 checklists?
4 A Yes, I do.
5 0 All right.
6 Did the Inspectors respond at all, to your 7 recollection, to Mr. DeWald?
8 A Well -- well, yes. A lot of us tried to explain to Irv i
9 that we needed that space down there to add notes and 10 things that you actualsy found in the inspection area.
I 11 Q All right.
12 To more completely document your inspection?
(])
13 A Yes.
14 Q What was Mr. DeWald's response to those comments from 15 the Inspectors?
I 16 A Well, he said that there will be a new Form 19 coming 17 out in a few days, so we will change all that, and we'll 18 make sure there's enough space for all of us to add the 19 notations down there.
20 Q All right.
21 And was there a revision of the Form 19?
22 A Yes, yes.
23 I would say, in the two-and-a-half years I was 24 there, there were probably 7 to 10 revisions of the Form I
() 25 19 alone.
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l 1 Q All right. l 1
2 Well, didn't they, in fact, reduce the size of the 3 remarks section to limit the amount of commentary that 4 an Inspector could note on a form?
! 5 A Yes, at one time they did.
i 6 Q And was that at about the time that Mr. DeWald --
7 A Yes.
i 8 Q -- discussed this?
i 9 A It was in that area, yes.
10 Q < So was it, in effect, Mr. DeWald's remedy to this 11 problem to -- or the way he followed through on his Q 12 instructions was to revise the Form 19 to reduce the I 13 size of the remarks section; correct?
I 14 MR. GALLO: I'll object.
~
15 Again, he's leading the witness on a new area.
I 16 THE WITNESS: The question?
17 MR. GUILD: Okay.
18 JUDGE GROSSMAN: Well, we'll have an answer 19 to the question.
20 Was this on deposition?
21 MR. GUILD: It was, Mr. Chairman.
22 MR. GALLO: Well, my recollection of the 23 deposition is certainly the matters -- the subject was 24 on a deposition, but not this particular matter.
j O 25 Perhaps Counsel can inform me otherwise by Sonntaq Reporting Service, Ltd.
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1 referring to the page of the transcript.
2 JUDGE GROSSMAN: Well, let's see if we can 3 assure it.
4 Did Mr. DeWald take any action after the Inspectors 5 requested that there be more room to make remarks?
6 THE WITNESS: Yes.
7 JUDGE GROSSMAN: Now, what action did he take 8 after that?
9 THE WITNESS: Mr. DeWald said, "Well, if 10 that's the way the Inspectors feel, that they actually 11 need to add some notations or some comments in this
() 12 section, that it would be enlarged."
13 JUDGE GROSSMAN: Okay.
14 So did he then enlarge it?
I -
15 THE WITNESS: Yes, he did.
16 JUDGE GROSSMAN: Oh, okay.
17 BY MR. GUILD:
18 Q Did he subsequently reduce it, the size of the Form 19 19 remarks section?
20 A Yes, previously he did.
21 Q In which order did things happen, Mr. Hunter?
22 A He reduced it first and then the Inspectors complained 23 that they needed more space.
24 0 I see.
C) 25 And then it went back to the old size?
l l
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, 1 A Yes, it did.
2 Q I see.
! 3 A Enlarged even, if if I'm not mistaken.
4 Q Okay.
5 Did you have occasion to work with Mr. Saklak 6 during the first year or so that you were on the job, 7 during the period when there was a backlog of 8 inspections?
9 A Mr. Saklak, if I'm not mistaken, was in charge of 1 10 welding, so if I did, it would be under just one of his
< 11 special programs.
Saklak never was the direct supervisor of weld
] 12 13 Q
inspections, was he?
14 A No, he wasn't.
15 Q He wasn't trained as a welder or Weld Inspector, was he?
16 A No, he wasn't.
17 Q But during some special programs, you did work for 18 Saklak?
l 19 A Yes.
20 0 Can you identify which programs -- in which programs you l
21 worked under him?
22 A Well, the numbers I don't remember; but what they was 23 usually was it would be a -- a cable pan run that they 24 needed to have cables pulled in, things on that order.
O 25 In other words, if they needed -- needed the
)
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1 inspections done right fast on a pan run or something in 2 that order, why, I was usually assigned to his crew to 3 do the weld inspections on the hangers or on the pans or 4 something of that order, yes.
5 0 All right.
6 Did you have an opportunity to observe Mr. Saklak, 7 either during that time or otherwise, in the way he 8 interacted with other QC Inspectors?
9 A Oh, yes. We set all in the same room at the time pretty 10 well. We only had the one area for Weld Inspectors to 11 write up their Form 19's or whatever -- whatever --
12 whatever they were doing.
(])
13 0 All right.
14 So you sat in the same room even when you weren't 15 working directly under Saklsk?
16 A Yes, I did.
l 17 Q And during that whole period of time, you were in a i 18 position where you could observe Mr. Saklak?
- 19 A Yeah, I could; yes, I could.
i 20 0 And how did he -- can you describe his demeanor or the 21 way he acted towards other Inspectors?
22 A Well, he was a little bit overbearing to people that he 23 thought that he could -- could intimidate.
24 The older fellows, such as I was, and two or three f
I
() 25 others, he never really give us problems to as far as, Sonntag Reporting Service, Ltd.
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'O 1 you know, how -- or getting loud or anything like that; 2 but some of the Inspectors I've heard him shout at.
3 Q Raise his voice?
4 A Oh, yes.
5 0 Was he verbally abusive towards Inspectors?
6 A Yes, he was.
7 Q Did he use profanity?
8 A I can't ever say that I ever heard him take God's name 9 in vein to a fellow, no.
10 Q How about other colorful language?
11 A Oh, yeah, yeah: "You little so and so," you know.
12 Did y.ou ever observe Mr. Saklak interacting with Rick l (]) Q 13 Martin, for example?
14 A Yes. He give Rick a hard -- a hard way to go.
15 0 All right. ,
16 And in what way do you mean that?
17 A I mean, he was -- he was loud and boisterous and things 18 of that nature.
19 0 Was Mr. Martin provoking in his behavior? Was he loud 20 to Mr. Saklak in the first instance?
21 A No, he wasn't.
22 Rick is a very quiet-type person.
I 23 Q All right.
24 What, if anything, did you observe brought on Mr.
O 25 Saklak being abusive toward Mr. Martin?
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1 A Nothing that I can recall.
2 Q All right.
3 Did Mr. Martin ever complain to you about Mr.
. 4 Saklak's conduct toward him?
5 A Well, no more than the other Inspectors.
6 Q What was the substance of complaints, if any, that you 7 got from Martin and the others?
I 8 A Well, usually, "He thinks he knows it all," or, you 9 know, "Who does he think he is," or something like that.
10 Q Did Mr. Saklak ever assign you to a special project, Mr.
11 Hunter?
() 12 A No more than working special projects.
And what sorts of special project did he assign you to?
13 Q 14 A Well, I worked the pan detail up in the spreader room l
15 for about four months. This was under his direction.
16 Not that he was a Weld Inspector, but he was having 17 the -- this was one of his projects that was going on at f
18 the time --
19 Q All right.
20 A -- to see that everything was ready for the cable being 21 pulled through the pans.
22 Q All right, i 23 Now, where is the location you are referring to?
24 A 463 Elevation.
() 25 0 Okay.
1 l
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1 Is it -- physically where is it -- where is that-4 2 located?
3 A It's up in the top of the building.
4 Q All right.
5 Is that above the control room?
6 A Yes, it is.
7 Q All right.
8 And is this a place where all of the -- where 9 cables come in for the --
10 A Control --
11 q -- termination of the control room?
12 A That's true.
({}
13 0 It requires you to climb a ladder to get up in there?
14 A Oh, yes.
15 0 Is it a congested location?
16 A Oh, yes, very congested.
17 The trays are very close together.
18 Q All right.
19 And is it the case that it was not a -- it was an 20 undesirable place to work for most Inspectors?
l 21 A Oh, yes. Warm, hot, whatever you want to call it.
22 Q Okay.
23 You are a relatively large man yourself, are you 24 not?
O 25 A Yes, I am.
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1 0 Can you state what your weight is, for the record, and 2 your size?
3 A 230 pounds.
4 Q How tall are you, sir?
5 A 5 foot 8.
6 Q Why did Mr. Saklak assign you to the upper cable 7 spreading room, if you know?
i 8 A I never knowed, unless he just wanted to see a fat man 9 climb the ladder.
10 Q Did he seem to take some pleasure in assigning you to 11 climb a ladder?
12 A Well, you know, naturally he would laugh. You know, you
(])
13 think -- you think, "So Hunter can make it through the 14 hole" --
15 0 Okay, 16 A -- things like that, you know.
17 0 I assume you did as you were instructed and worked 18 there?
19 A Oh, yes, I worked there.
20 Q Did you complain to him about that?
21 A Oh, no.
22 0 Why not?
23 A I figured somebody had to do the job.
24 0 All right.
() 25 Did you have occasion to work on a special project, i
Sonntag Reporting Service, Ltd. _ _
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8527 1 during the fall of 1984, along with an Inspector named 2 named Dean Peterson?
3 A Yes, I did.
4 Q And what was the nature of that special project?
4 5 A This was -- this was -- this was a pan detail --
6 Q Was this --
7 A -- reinspection of welds on pans.
8 Q Okay.
9 This was not the same project as was in the upper 10 cable spreading room, was it?
11 A Not necessarily, no.
(} 12 Q Okay.
13 A It was just according to where -- wherever they had to 14 have reinspection on pans.
15 Q Okay.
16 And what was the nature of the reinspection, if you 17 know?
18 A Usually --
19 0 Why were you doing it?
- 20 A I don't think all the documentation could be found in 21 the vault on some of the welds on the Unistrut to the 22 pans.
23 0 Okay.
24 Is this -- do I understand correctly the cable pans O 25 are horizontal galvanized material in which the cables Sonntaq Reporting Service, Ltd.
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O 1 are run?
2 A That's true.
3 Q All right.
4 And they lay on a horizontal Unistrut member; is l 5 that correct?
6 A Well, it could be Unistrut, tube steel or -- you know, 7 yes, usually -- usually Unistrut.
8 Q Are these the welds between the horizontal member and
! 9 the pan?
10 A That's true.
11 0 These were the subject of this special project?
12 A Right.
(])
13 Q Now, who was supervising the special project, then, Mr.
l 14 Hunter? .
15 A The Lead at that time?
16 Q Yes.
17 can you recall who the Lead was?
18 A I want to say Mark Klatchko, but I wouldn't swear that 19 he was the Lead at the time.
20 0 How about:
21 Do you know a John Walters?
22 A Yes. John Walters was more of a -- yes, John Walters 23 was -- I guess was considered the Lead, but he is also f
l 24 part of management.
() 25 0 All right.
I I
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1 So he was above the Lead, in effect?
2 A Today he is.
3 At the time I wouldn't swear whether John was above 4 the Lead or not.
5 Q Okay.
6 But was he involved in supervising the project?
7 A Yes, he was.
8 Q All right.
9 And was Mr. Ken Worthington involved in the I 10 project?
11 A To what capacity, I couldn't tell you, but, yes.
12 Q Okay.
(]}
13 Now, I asked you whether you worked with Mr.
14 Peterson. You said you did.
15 Can you recall other Inspectors who worked with you 16 on this project?
17 A Well on this project?
18 Q Yes, on the project involving Walters and the cable 19 pans.
20 A I'm pretty sure that John Miner probably worked to a 21 certain extent. I don't know how much.
22 Q All right.
23 Now, there was a reinspection program, was there 24 not?
O 25 A This was another one of these reinspection programs.
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l Q All right.
2 In the course of this reinspection program, was it 3 required for you or for QC to have the welds to be 4 reinspected cleaned of paint by the craft?
5 A Well, there's two different -- there's two different 6 things there.
7 Mr. Irv DeWald at one time said, " Don't worry about 8 the" - "the Galvanox. Just inspect the weld, make sure 9 there was no cracks, no undercut," stuff like that.
10 Q Okay. Let me ask you to stop there.
11 Now, what is Galvanox?
12 A That's a paint that they use, a protection coating.
({}
13 0 Is it a p'rimer, in effect?
14 A It's the same thing as a primer.
15 0 Is it a heavy, thick paint?
16 A Yes, it is pretty heavy.
17 Q What color does it appear?
18 A It's gray.
19 0 Okay.
20 Sprayed on the --
21 A Usually painted.
22 O I'm sorry?
23 A Usually painted.
24 Q Painted with a brush?
l
() 25 A Usually with a brush.
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i 73 -
U 1 0 okay.
2 And'is it painted after the weld is performed and 3 ini'pected? ,
4 A Oh, yes, yes.
5 0 Okay. ,
6 Now, again, I interrupted you.
7 DeWald at one time said, " Don't worry about the 8 Galvanox"? ,
4 9 A Right.
'10 Q Did you understand that to mean don't remove the 11 s Galvanox?
12 A Right.
[]) .
'13 Q You just inspect through it?
14 A Right. <
15 Q All right.
16 A This only lacted fer a few days, however. '
i 17 0 All right.
l 18 Why was that?
l l 19 A Too many of the Inspectors complained, "How could you 20 see a weld if you couldn't" -- you know, "a crack if the 21 paint covered it or something."
l 22 O Okay.
I i
23 A crack is a rejectable condition, I take it?
24 t. Right, right; an MCR condition. -
O 25 0 Was it your opinion, as well, that the Galvanox coating I
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1 might obscure a crack?
2 A Oh, yes.
3 Q How about any other rejectable conditions:
4 Are there others that a Galvanox coating might 5 obscure?
6 A Oh, it could; undercut, cold lap, anything.
7 Q Porosity?
8 A Oh, sure.
9 Q Did Mr. DeWald explain any basic for instructing the 10 Inspectors to not worry about the Galvanox?
11 A As far as I can remember, no.
12 Okay.
(]) O 13 Inspectors complained, and he, in effect, rescinded ,
14 that direction?
15 A Yes, this is -- this is correct.
16 Q Now, then, after that brief period, it was required 17 that, in order for you to inspect these cable pan velds, 18 you had to get the craft to remove the paint?-
l 19 A That's correct.
20 0 Now, was there paint, other than just the Galvanox, on 21 these components?
22 A The project that we was working on at that time, no.
l i 23 There was just -- just the --
24 Q Okay.
O 25 A -- just the weld to attachment pan.
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1 Q All right.
2 And those just were covered with galvanized?
3 A Yes.
4 Q Now, generally speaking, is there other paint applied to 5 the electrical installation aside from the Galvanox?
6 A Oh, yes, they have a brown paint that they use on 7 Unistrut -- I mean, on tube steel and -- and aux steel, 8 what'they call aux steel.
9 Q Does that go over the Galvanox?
10 A No. There's no -- there is no Galvanox there at that 11 time.
12 Q All right.
(])
13 So two different kinds of paint on different types 14 of electrical components?
15 A Right, that's true.
16 Q And both of them are added after the initial 17 installation and installation inspection --
18 A That's true.
19 0 -- generally speaking?
20 A Yes.
21 Q All right.
22 And in the course of a reinspection program, you 23 would encounter a weld or a component with welds on it 24 in a painted condition --
i
() 25 A Oh, yes.
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1 0 -- unless the paint was removed?
2 A That's true to a great extent.
3 Q And in this cable pan walkdown program -- I'm sorry --
4 the cable pan inspection program -- reinspection 5 program -- did you need to have craft remove the paint 6 from the welds?
7 A Yes.
8 Q Now, do you recall Mr. Peterson ever bringing to your 9 attention problems that he encountered with respect to 10 painted welds?
I 11 A Oh, yes. Dean said that they wasn't doing a good enough 12 job taking the paint off. He couldn't tell what the toe
{])
13 of the weld looked like; first one thing and another.
14 Q All right.
15 Now, this is a weld between a structural member --
16 at least a Unistrut and the cable pan; correct?
l 17 A Right.
l l 18 0 All right.
l
- 19 The cable pan is a galvanized material?
20 A Right.
l l 21 Q Now, does the existence of galvanizing have any effect i
22 on the ability to detect undercut, for example?
l 23 A Oh, yes. Usually -- usually you have some heat l
24 distortion at the -- at your toe of your weld, so you O 25 don't know whether it's curled galvanized or actually Sonntaa Reporting Service, Ltd.
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~
1 undercut.
2 Q Okay.
3 Now, by " curled galvanized," do I understand you 4 correctly, this would be in effect, a metallic or 5 chemical film on the metal that could curl under heat --
6 A That's true.
7 Q -- and could appear to be undercut?
8 A That's true.
9 Q All right.
10 But without removing it, you wouldn't know whether 11 it was, in fact, an undercut condition in the weld or 12 just this curled galvanized --
}
(~}
13 A That's true.
14 0 -- or paint?
15 A That's true.
16 Q All right.
17 What, in substance, did Mr. Peterson tell you about l
18 the problems he was encountering?
19 A Well, he said he wasn't going to buy one unless it's 20 cleaned up, you know, where he could actually tell 21 whether it was undercut or just burnt galvanized.
22 Q All right.
23 Did you learn that Mr. Peterson brought this 24 complaint to his management's attention?
O 25 A Yes, I heard he did.
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1 Q Okay.
2 And who did you hear he told that?
3 A Oh, I don't know. Among the group, you know.
4 We all sit together whenever we were filling out 5 your Form 19's.
6 Each -- each project usually sits -- sits in a 7 certain area in a certain group.
8 O All right.
9 Did you understand that Mr. Peterson raised this 10 concern to either Mr. Walters or Mr. Worthington?
11 A Yes, I believe he did.
12 ' MR. G ALLO : Objection, objection.
j []}
13 - This is about the sixth or seventh leading question 14 in a row on this whole subject; and it's clearly new 15 material . ,
16 I think Counsel ought to be cautioned for the third 17 time to stop leading this witness.
l 18 MR. GUILD: Only by count for Applicant; 19 because it seems to me that the parties are not in
- 20 dispute, and I'm trying to expedite the project.
21 MR. GALLO: As far as I know, this is a brand l 22 new area, and I've never heard heard of it before, and l
23 it's never been the subject of any other witness in this 24 proceeding, and he's leading him unconscionably in this
() 25 regard, and I ask that he be cautioned against it.
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1 JUDGE GROSSMAN: Is this in a deposition?
2 MR. GUILD: No, sir; but it was in live 3 testimony that Mr. Gallo apparently missed with respect 4 to Mr. Peterson.
5 JUDGE GROSSMAN: Well --
6 MR. GUILD: I don't believe it's a matter in 7 dispute.
8 JUDGE GROSSMAN: -- if we can't put our 9 finger on it, I think you are going to have to ask 10 neutral questions.
11 MR. GUILD: I'd be happy to.
12 JUDGE GROSSMAN: But I'll say to Mr. Gallo,
(}
13 if there's no dispute about it, it goes faster with 14 leading questions.
l l
15 That's a decision you have to make.
16 As far as we know --
17 MR. GALLO: I understand that general rule.
18 MR. GUILD: I believe, if Mr. Miller were 19 present, he would acknowledge that there, indeed, has 20 been testimony to this effect he certainly sat through.
21 JUDGE GROSSMAN: Well, I'm not going to put 22 Mr. Miller on the spot.
23 MR. GUILD: There he is right behind the 24 post.
O 25 MR. MILLER: If I might just have one second Sonntag Reporting Service, Ltd.
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U 1 to talk with Mr. Gallo.
2 MR. GALLO: Yes. I'm informed by my 3 colleague that this matter was, indeed, inquired into 4 with Mr. Peterson, and he was -- Mr. Peterson, 5 apparently, when he testified -- and I wasn't present 6 during Mr. Peterson's testimony -- had inquired -- had 7 been questioned on this whole area.
8 So clearlp the leading objection may not be 9 appropriate.
10 But if my colleague is correct, and then apparently 11 Mr. Guild has the same memory, then the inquiry of this
(} 12 witness is really not material.
The principal witness has already testified on the l 13 14 point, apparently; and why are we replicating that 15 testimony through this witness on a hearsay basis?
16 MR. GUILD: I'd be happy to state without --
17 I'd just as soon not do it in front of the witness.
18 JUDGE GROSSMAN: I would assume it's 19 corroboration, and I would assume that you are not 20 accepting Mr. Peterson's testimony as conclusive, and so 21 he's entitled to do that --
22 MR. GALLO: Well --
23 JUDGE GROSSMAN: -- unless you want to 24 stipulate that everything is so, and I don't think we O 25 ought to waste time doing it; and I think the easiest Sonntaa Reporting Service, Ltd.
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1 way to do it is the way Mr. Guild is doing it now, until 2 we come to a part that you think is actually disputed, 3 and then we can insist that he ask neutral questions; 4 but, otherwise, it would just take a lot of unnecessary 5 time.
6 So why don't we just continue now --
7 MR. GALLO: You may be correct.
8 JUDGE GROSSMAN: -- the way we're going until 9 there is a specific area that you believe is disputed, 10 Mr. Gallo, and then we'll hold Mr. Guild to neutral 11 questions.
12 MR. GALLO: Well, I would only observe, in
[]}
13 answer to your point, Judge Grossman, of course, now I 14 will have to conduct questioning into this area to 15 demonstrate the. depth of the witness' or the lack of 16 this witness', if that is the case, personal knowledge 17 on the subject.
18 This is the delay factor that he has incurred in 19 this whole business.
20 JUDGE GROSSMAN: Well, there's no alternative 21 to that.
22 He's certainly entitled to corroborate the other 23 witness' testimony, if there are matters that aren't 24 stipulated to, and so we'll just have to do it; but we
( 25 don't want to slow it any more than is necessary.
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1 Continue, Mr. Guild.
2 JUDGE CALLIHAN: Excuse me, Mr. Guild.
3 MR. GUILD: Yes, sir, sure, Judge.
4 JUDGE CALLIHAN: Let me clarify something.
5 BOARD EXAMINATION 6 BY JUDGE CALLIHAN:
7 Q Mr. Hunter, you have used the word " galvanized" on 8 several occasions recently.
9 To me, galvanized is a zinc coating on sheet steel.
10 A That's true.
11 Q Did you use the word " galvanized" in connection with a
{) 12 13 quote, " paint," unquote, in your testimony in the last 10 or 15 minutes?
14 A Did I do what, sir?
15 0 Use the word " galvanized" to describe what you put on 16 with a brush as you state?
17 A I believe it was Galvanox. That was a brand name, 18 Galvanox. That was a brand name.
19 Q I'm sorry. Thank you very much.
20 What is that, anyhow?
21 A It's just a -- I don't know what base it is, but it's --
22 but it's a coating that they use to protect welds on 23 galvanized.
24 In other words, it's something that will not let it O 25 rust through or something like that like ordinary paint Sonntag Reporting Service, Ltd.
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\J l would.
2 JUDGE CALLIHAN: Thank you very much for the 3 clarification.
4 I'm sorry to interrupt.
5 MR. GUILD: That's fine, Judge.
6 DIRECT EXAMINATION 7 (Continued. )
8 BY MR. GUILD:
9 Q At the time that you and Mr. Peterson and the others 10 were performing this special project on the cable pan 11 welds, were you required to turn in daily status reports of the numbers and identities of the inspections that
{ 12 you per' formed?
13 14 A Oh, yes, yes, everybody had to write the Form 19's on l
l 15 all their inspections.
16 It doesn't matter whether it was 2 welds on a 17 hanger or whether it was 24 or 40 or whatever it was, 18 how many -- how many pans across the hanger.
19 Q These status reports listing the installations that were l 20 the subject of inspections, they got turned into the l
21 management or supervision, did they not?
22 A Turned into the vault.
23 MR. GALLO: Objection, objection; the form of 24 the question.
25 It is not my understanding that the status report Sonntag Reporting Service, Ltd.
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1 and the Form 19 is the same thing.
2 JUDGE GROSSMAN: Yes. Mr. Guild, please ask 3 neutral questions where it's called for.
4 MR. GUILD: If I misspoke, I apologize.
5 BY MR. GUILD:
6 Q I meant to say the status reports listing the 7 installations that had been inspected, not the Form 8 19's, those status reports were turned into supervision, 9 were they not?
10 A That's true.
11 MR. GUILD: All right.
{} 12 13 Is there a dispute about that?
JUDGE GROSSMAN: The objection wasn't to l 14 saying they were turned into supervision, but the wrong 15 form.
16 MR. GALLO: Well, I don't know what this 17 witness' testimony on this point is.
18 They've been using different terms.
19 The witness testified as the Form 19's being 20 furnished in this answer to Mr. Guild's questioning 21 using status reports.
22 I don't know what the status of the record is.
23 I guess I'll have to wait my turn to clarify it.
24 MR. GUILD: I don't think it's certainly a O 25 material point and I don't mean to confuse the record.
1 i
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1 BY MR. GUILD:
2 0 You turned in your Form 19's to your supervision at the 3 end of a day, did you not?
4 A That's true.
5 0 Okay.
6 And didn't you compile a list of the components 7 that were reflected on those Form 19's?
8 A Yes, we did.
9 Q Okay.
10 That's a status report?
11 A That was part of the status report; right.
And that list was turned in along with the Form 19's; l
{) 12 13 Q
correct?
14 A Yes.
15 Q Okay.
16 Now, did it ever come to your attention, in 17 connection with this project, that any of the Inspectors 18 were ever criticized or cautioned by their supervision l 19 because of not turning in enough inspections in their l 20 daily statuses?
l 21 A Well, let's put it this way:
22 The little weekly meetings we would have at the
(
1 j 23 time, Mr. Irv DeWaldawould stress that we had to get 24 more done in order to finish the project at a certain 25 time.
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1 As far as him coming right out and saying, "Let's 2 do so many welds," I don't think I ever heard Irv tell 3 anyone they had to do so many welds.
4 Q All right.
5 I take it no one ever criticized you for your low 6 production level, low number of inspections per day, for 7 example?
8 A No, I don't think so.
9 Q All right.
10 And do you have any understanding of how your 11 productivity compared to others in terms of inspections
{} 12 13 A per day?
Yes. I'm sure I was one of the top -- as far as units 14 inspected, I'm pretty sure I was the top one during the 15 time I worked for them.
16 Q In terms of number of weld inspections per day?
l l 17 A In terms of units inspected; right.
18 Q All right.
19 And can you give me an approximation on the 20 average, over a long period of time, how many weld 21 inspections you turned in a day, Mr. Hunter?
22 A Well, I would say that I probably averaged better than 23 five units -- that's five hangers -- per day.
t 24 Q Okay.
I O 25 Would you do more than 10 on occasion?
Sonntag Reporting Service, Ltd.
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1 A Oh, I have, yes.
2 Q All right.
3 Now, did it ever come to your attention -- I'm 4 talking now about this special project in the fall of 5 '84 on the cable pan hangers --
6 A Right.
7 Q -- that any of the other Inspectors who worked with you 8 were criticized for the low level of production that 9 they were turning in in a day?
10 A Yes.
11 Q And can you identify any particular Inspector who
{} 12 13 A brought such a criticism to your attention?
Well, like I say, Mr. Peterson was one that they told 14 hip he wasn't getting enough done.
15 Q All right.
16 A That's -- I mean, that was the rumor that I heard.
17 Mr. DeWald never did come out and say that in front 18 of the group as a whole or anything.
19 Q Well, did you understand that from Mr. Peterson?
20 A I understood that from Mr. Peterson.
21 Q All right.
22 And did Mr. Peterson, in that connection, mention 23 the problems he was encountering with the welds in a 24 painted condition?
! 25 A Yes. That's when he said that he wanted -- that's when i
I' i
Sonntaq Reporting Service, Ltd.
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- C:)
I he told me he wanted the welds cleaned up to where he l
2 could actually visually inspect it.
3 Q All right.
4 And was Mr. Peterson, to your knowledge, 5 subsquently transferred off that special project?
6 A Well, he didn't last too long on it, yes.
7 Q Okay.
8 Did you have occasion to work en a project 9 involving the review of documents in or near the vault, 10 Mr. Hunter?
11 A Yes, I did.
12 Q All right.
{~ )
13 And can you describe generally what that project i 14 was?
15 A This was -- one of th,e audits that they said that had to 16 catch up on the last one was the AVO project.
17 Q Before the AVO project, did you happen to work on 18 document -- any document work involving documents in or 19 near the vault?
l 20 A In or near the vault?
21 Q Yes.
22 A Yes. These was usually on a reinspection program.
23 Q Do you recall any instances where Mr. Saklak gave l 24 instructions to persons involved in such a document 25 review project?
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1 A No more so than, "We have to" - "We have to get this 2 completed or else we won't be on the job," or something 3 like that.
4 Q Do you recall any instances in which Mr. Saklak engaged 5 in the practice, that you referred to, as " shopping 6 around" among Inspectors?
7 A Yes. If someone had'a document that they couldn't buy, 8 because they hadn't done the research or something like 9 that, Mr. Saklak might take it away from them and give 10 it to some other Inspector to see if he could buy it.
11 That happe.ned quite a bit.
{} 12 O Is that, in effect, the practice of shopping around?
I would say that's what we call shopping around.
I 13 A 14 Q All right.
15 Does that mean, in essence, looking for an 16 Inspector, in turn, one after another, who will agree to j 17 buy off or sign off a document?
18 A Well, maybe -- maybe one Inspector might have already 19 done the research or something like that, so, actually, 20 it's not saying that Mr. Saklak was trying to get 21 someone to buy something that actually hadn't been done, 22 but he was trying to get someone to sign it, where at i
23 least the vault would have it in the vault, saying that l
l 24 it had been done.
O 25 0 All right.
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O V
1 But it would be an instance where the first person 2 Mr. Saklak tried, for one reason or another, would not 3 sign the document?
4 A That's true.
5 Q And he would try others who finally would sign it?
6 A Right.
7 Q Did you have occasion to work in or near the vault in a 8 project where Mr. Terry Gorman was performing inspection 9 work?
10 A Yes.
11 Terry and I come on the job the same day. Terry 12 worked the vault for appro'ximately, I would say, 20
[}
13 months while I was there.
14 Q All right.
15 And did you happen, on occasion, to observe an 16 instance where Mr. Bowers, the vault supervisor, was 17 instructing Mr. Gorman to sign off a document?
18 A Yes. This was part of the AVO program.
19 Q All right.
20 And can you tell us approximately when this 21 occurred?
22 A When this took place?
23 Q Yes.
24 A I would say some time prior to the first of 1986.
O 25 0 Okay.
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1 Late '85?
2 A I would late '85.
3 0 All right.
4 And what were the circumstances that you observed 5 involving Mr. Bowers and Mr. Gorman?
6 A I believe Mr. Gorman -- at that time Mr. Gorman was 7 upstairs working in our group or the AVO group, and he 8 brought a document up and said, "Mr. Gorman, this has 9 been done," and, of course, Terry asked him, "Well, when 10 and who" - "and who did it," and one thing led to 11 another, and he wanted Mr. Gorman to put his name on it, 12 and Mr. Gorman said, "Not until I research it"; and Mr.
{]}
13 Gorman actually did take about two hours and researched 14 the drawing.
15 I'm pretty.sure it was just'a drawing rev.
16 Q Was it your understanding that Mr. Bowers wanted him to 17 sign it off?
18 A Yes; because he said he had already taken care of it.
19 Q All right.
20 He wanted Mr. -- he wanted Mr. Gorman to simply 21 rely on Bowers' assurance that it had been taken care l 22 of --
23 A Right.
l 24 0 -- without Gorman himself doing the research first?
O 25 A Right.
t t
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1 Q Did you observe any other instances of Mr. Bowers trying 2 to get Inspectors to sign off documents?
3 A Well, Mr. Bowers come there approximately a 4 year-and-a-half ago. He come into a situation where 5 there was a lot of things that I'm sure that he felt 6 should be brought up-to-date, so, naturally, he assigned 7 a lot of people to review documents -- in fact, he had a 8 document review crew there -- and there was a lot of 9 things that was missing, and, naturally, when the 10 document review crew would bring it to an Inspector, the 11 Inspector didn't want to correct it right then. He wanted to do some research, especially on drawing revs.
{} 12 This was pretty well what it was.
13 14 Q Reinvestigations to Sargent & Lundy drawings?
15 A Yes.
16 0 What sort of research involving those revisions?
17- A Well, usually you had to go and check the print at the 18 time the inspection was made and make sure that there 19 was no changes between the time the inspection was made 20 and the time it was accepted.
21 Q And this was for an old inspection; is that right?
22 A Usually -- usually they was for old inspections.
23 Q All right.
24 It would require the Inspector doing research to go O 25 back to the drawing that was the current revision at the Sonntaa Reporting Service, Ltd.
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8551
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1 time the original inspection was done?
2 A At the time the original hanger was installed or 3 whatever was done; right.
4 0' All right.
I 5 And that's what took research time?
6 A That's what took research time.
7 0 You were involved in a program that you referred to 8 as -- a special program you referred to as the AVO 9 program.
10 Can you describe what that was, please?
11 A I am not for sure when the AVO program was started, but 12 I believe it ended some time in '83.
- 13 It was a -- you might say a speed memo from the l
14 field telling the engineers -- or telling Sargent &
15 Lundy what had to be done to hurry up.
16 If a hanger had been insta11ed and they needed to 17 run a pipe through it with a hanger, maybe move it three 18 inches, five inches, whatever it was, they -- the field 19 engineer or the field superintendent, he wrote back that 20 the hanger had to be moved three, five inches, whatever 21 it was, take care of the obstacle that was coming 22 through that area.
23 So, actually, they were just -- they were just 24 field directives. In other words, they was just like an 25 engineer sitting out in the field and saying, "We can't Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
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s_/
1 do this. We have to do so and so. " He would write the 2 AVO --
3 Q All right.
4 A -- and -- yes, and it would be taken care of that way.
5 0 All right.
6 Now, I take it an AVO, in fact, could reflect an 7 actual change in the design or specification of an 8 installation?
9 A No, I don't think so; not in -- not in -- not -- in the 10 specs I don't think it could.
11 It could maybe change the design, but not the 12 specs.
13 Q Okay. -
14 But design in the sense of moving something a 15 couple of inches, let's say?
16 A That's true.
17 Q All right.
l 18 And that would be a change in the specification, 19 would it not?
20 A Well, it would be a change in configuration. I wouldn't 21 say in specifications, I'd say in config.
22 (Indicating.)
23 Q All right, all right.
l 24 But a change in the standards to which a particular 25 piece of installation would be installed and inspected; Sonntaq Reporting Service, Ltd.
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Geneva, Illinois 60134
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1 three inches left as opposed to the original 2 configuration, say?
3 A Right.
4 Q Okay.
5 These were not Engineering Change Notices, were 6 they?
7 A No, this wasn't considered an Engineering Change Notice.
8 Q All right.
l 9 They weren't --
q 10 A I believe -- I believe the construction area 11 superintendent issued these, if I'm not mistaken.
12 Q All right.
("} '
13 Were these issued by Sargent & Lundy?
14 A No, no. These was from craft,
- 15 Q Issued in the field by the craft?
16 A Right.
17 Q All right, sir.
18 And I take it these were not control documents that 19 were specified as a part of the Comstock QA program or 20 procedures at the time?
21 A No, it wasn't.
22 Q All right.
23 And was the AVO program that you were assigned to 24 work in to deal with the use cf these uncontrolled 25 documents?
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1 A Well, yes, they were trying to bring them up and see if 2 they could find this document in the -- in the vault 3 that related to the AVO numbers and to whatever had been 4 done.
5 Q Okay.
6 Now, would you explain generally how the program --
7 the AVO program -- corrective action program -- now that 8 you were involved in, how it worked? What exactly were 9 you to do?
10 A Well, this program lasted, while I was there, 11 approximately seven months. It changed probably a dozen 12 times from the time -- from the time I got there.
{) 13 At one time, Irv DeWaid says, "We don't have to 14 worry about no AVO's," and then they come along and run 15 an audit, and they found out that they had to -- to 16 justify the AVO's, so some of these AVO's actually had
, 17 inspections which would be current, which -- I mean, l
18 which they considered current, I believe it was, after a 19 certain day in '82 -- anything that's been done after a 20 certain date in '82, that was considered current.
l 21 Anything before that, you had to make sure that the i 22 document was in the vault and had been inspected and 23 bought off after the AVO was written.
24 0 All right.
25 So let me see if I'm clear:
Sonntaq Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262 t
8555 1 The AVO's ceased being used, the Avoid Verbal Order 2 memo --
3 A I believe so.
4 0 -- ceased being used, some time in 1982?
5 A In '83, I believe; the last one I can recall.
6 Q All right, 1983.
7 Then you, in essence, were to determine whether or 8 not the final inspection for the component took into 9 account the directive on the AVO --
10 A That's true.
11 0 -- for that component?
/~3 12 A That's true.
U 13 Q All right.
14 If there was an inspection that postdated the date 15 of the AVO program's termination, the date of -- the 16 1983 date, then you would determine -- or consider that 17 the component was acceptable; is that true?
18 A The question again?
19 0 Okay.
20 You looked for -- you do document research. You 21 take an AVO for a particular component, you look at the 22 inspection documentation for that same component, and 23 determine that the inspection documents came after the 24 AVO ceased being used.
()
25 If you found thereafter a valid inspection document Sonntag Reporting Service, Ltd.
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1 that postdated the AVO, then the component was 2 acceptable?
3 A That's true.
4 Q And it was a matter of matching up the AVO with a 5 document package for the particular component?
6 A That's true.
7 Q Did you start with the AVO as the first step in this 8 program?
9 A Usually others -- usually they give you an AVO number 10 and a hanger number; and the engineer, I believe -- I 11 can't recall -- I believe it was Mr. Chapman -- I'm not 12 for sure -- anyway, he had did this research two or
(]}
13 three months before we started the program, and he went 14 to the vault -- he was supposed to, at least -- and 1,5 checked the valid inspection forms.
16 Okay. If he found one that wasn't valid, he turned 17 it over to Comstock or -- and Comstock issued it to the 18 group that we was working in -- there was about seven of 19 us -- and we went from there.
l 20 We -- we collected -- we collected the drawings --
21 this is before the new rev, Rev A-Rev O come out --
22 approximately 30 days, 60 days that we started the 23 program, and then the new Rev A and Rev 0 come out, and 24 we inspected to -- just to the drawing, whatever the O 25 walkdown had been.
Sonntaa Reporting Service, Ltd.
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1 They had a walkdown on a lot of this stuff, 2 approximately a year before the program was started, to 3 see the -- see that they were there.
4 In~other words, a lot of these other hangers, a lot 5 of this other stuffr had been cut down, been deleted.
6 Some of it had been completely done away it and all 7 that.
8 Q All right.
9 A What they were -- what they were actually looking for 10 was documents to see what they had in the plant is what 11 it was.
Okay.
{) 12 13 Q
Now, you did this program, the AVO program, up
\
- 14 until you were terminated; is that right?
15 A That's right.
16 Q And that who have been in March of 1986 --
17 A That's correct.
18 Q -- correct?
l 19 And so you had been working on this program for 20 seven months up until that point?
21 A Approximately seven months; right.
22 Q All right, sir.
23 Later '85, then, into '86, I take it from what you 24 said, that you were given a paper -- a stack of paper, 25 including the AVO, and were assigned to determine Sonntag Reporting Service, Ltd.
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1 whether or not you could track the document package and 2 establish that the component was final inspected?
3 A That's true.
4 Q All right.
5 Now, what were you to do in the instances where you 6 couldn't determine that the component was final 7 inspected?
8 A Reinspect it.
9 Q All right.
10 Now, in some cases, you found inspection documents 11 for these components, but they were not complete; is 12 that true?
[}
13 A That's true.
14 Q And in those cases, you would have to perform some sort 15 of reinspection as well, would you not?
16 A That's true.
17 Q Now, what would you do with the -- by way of the 18 reinspection of these components?
19 A Well, when we first started, if it just called for a i
20 hanger and you went to inspect -- to the field, you 21 inspected just the hanger; and then whenever the new Rev 22 A-Rev 0 drawings come out, Sargent Lundy, you inspected 23 to whatever the drawing was.
24 In other words, what I'm saying is when the program 25 was first started, the hanger might have a hanger, it l
l Sonntaq Reporting Service, Ltd.
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k 1 ' might have braces. ,'
2 If it didn't call for the braces, the 500 number, you didn't worry c'cous the bra'ces.
3 You just looked at 4 the hanger. They were in the vault that way.
5 After th$ Rev A-Rev O's come out, whatever is on 6 the drawing is what you. looked at.
7 Q All right. Let me be clear now.
8 In some instances they had done a final -- a 9 walkdown --
10 A Right.
11 0 -- and had produced this Rev A-Rev 0 drawing?
l 12 A Yes. .
)
I 13 Q And the Rev A-Rev O drawing reflecting the' actual l
14 as-built components in the field?
l 15 A That'is correct. -
l 16 Q All right. ,
17 And in some instances, the actual'as-built ,
18 component, in the case of a hanger, had a brace on it?
19 A Oh, yes. ,
20 Q And if you were inspecting per the AVO program to the 21 Rev A or Rev O drawing, and it showed a brace, you 22 inspected that brace? -
23 A That's true.
24 Q All right.
But if you didn't inspect the Rev A-Rev O drawing 25 l
Sonntaa Reporting Service, Ltd.
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1 and just used the non-walkdown package, even if there 2 was a brace, you didn't inspect the brace?
3 A True.
4 Q You just inspected the hanger?
5 A That's right.
6 Q All right.
7 Who performed this AVO program along with you?
8 A Oh, at one time, there was probably seven or eight of us 9 in the same program.
10 One of them was Anderson; one of them was named 11 Hudson; a boy by the name of Asmussen; a boy by the --
12 O Is that Mr. Asmussen?
[}
13 A Yes.
I 14 Q Danny Asmussen?
15 A Yes.
16 Q All right.
! 17 A A boy by the name of Tom -- Tom -- the last name -- he 18 was sitting right next to vi: ,:nd I can't think of his 19 last name. He was a R'Js'. tan toy.
20 Mr, Gorman was in the program for awhile.
21 Q Gorman?
22 A Yes.
23 Q Terry Gorman?
24 A Terry Gorman was in.
25 A Val -- Valerie -- the young lady, I can't Sonntag Reporting Service, Ltd.
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1 think -- she was in for awhile.
2 There was another young lady in the program for a 3 small -- for awhile.
4 In other words, there was probably -- altogether ,
1 5 there was probably eight or ten, maybe even twelve, 6 people in that program at one time while I was there.
7 Q All right.
8 And was there a Mr. Arndt in the program as.well?
9 A Who?
10 Q Arndt.
11 A Yes, Arndt was in that program for a few days.
12 0 Okay.
{}
13 And he was terminated along with you?
14 A Right.
15 Q Now, these hangers that you went to look at, I take it 16 that they had all been --- many of them had been 17 previously inspected; is that true?
'18 A Oh, yes, yes, that's true, i 19 0 Could you tell that they had been previously inspected 20 by the existence of Weld Inspector stamps on the 21 components?
22 A Yes, there was a good many of them that maybe had two or 23 three different Inspectors' stamps on them.
24 Q And by each weld, for a hanger that had been previously 25 inspected, you would find one or more QC Inspector l
l Sonntag Reporting Service, Ltd.
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1 stamps by it?~
2 A A good many times, yes.
3 Q All right.
4 Now, some of these hangers were fabricated by 5 non-Comstock vendors, were they not?
6 A That's true.
7 Q All right.
8 And in the situation where it was a vendor-supplied 9 hanger, do I understand correctly that Comstock would 10 simply inspect the attachment welds attaching the hanger 11 to whatever mounting component there was?
12 A Yes; just -- just -- just strictly the field attachment;
{}
l 13 right.
14 Q For example, if the hanger was to be mounted to an 15 overhead horizontal beam, a structural member, there 16 would be welds of the two vertical components of the 17 hanger?
18 A Yes.
I 19 MR. GALLO: Objection.
! 20 By God, I beat the witness' answer.
21 I'd like to excuse the witr.ess.
22 JUDGE GROSSMAN: Oh, okay.
23 Could you step out in the hallway for a few 24 minutes.
25 (Witness excused.)
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1 MR. GALLO: My objection, again, Judge 2 Grossman, is leading.
3 The questioning is leading; and we are, indeed, in 4 the area involving Mr. Hunter's termination --
5 JUDGE GROSSMAN: Oh, okay.
6 MR. GALLO: -- and I think the last 7 half-a-dozen questions about the various activities that 8 Mr. Hunter was involved in was all based on leading 9 questions.
10 MR. GUILD: Well, you know, Mr. Chairman --
11 JUDGE GROSSMAN: Well, was there anything 12 controversial about what the job requirements were or
/"}
i 13 what he was required to do?
14 MR. GALLO: Well, I'm not prepared to parse it 15 in that fashion.
16 I think that, as some point, controversy or
( 17 non-controversy has to reach its outer limit.
l
! 18 We're clearly in a new area involved in the 19 contention, and I think the excuse of trying to save 20 time no longer pertains.
21 JUDGE GROSSMAN: Oh, okay.
i 22 If that's the judgment, let's not lead him, Mr.
23 Guild. Let's just ask neutral questions and have him i 24 explain it all.
l
() 25 MR. GUILD: All right. I'll be happy to do l
l Sonntaq Reporting Service, Ltd.
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1 I
8564 (2) l 1 that, Mr. Chairman.
I 2 I really was just trying to save time.
3 I can't imagine there's any controversy that you 4 attach to a vendor hanger with attachment welds.
5 But be that as it may, Mr. Chairman, I'd be happy 6 to abide by the Board's directive.
7 JUDGE GROSSMAN: On the last question, I 8 can't believe there's any controversy, too, naless there 9 aren't two verticals or whatever the question stated; 10 but I think you are just trying to alert us to this 11 area.
12 MR. GALLO: Yes.
)
13 JUDGE GROSSMAN: And, fine, let's keep that 14 in mind, Mr. Guild.
15 MR. GUILD: I'd be happy to, Mr. Chairman.
16 BY MR. GUILD:
17 Q Mr. Hunter, I'm going to have to ask you to tell me in 18 your own words how these hangers are fabricated.
l 19 A Okay. At one time -- at one time Commonwealth Edison 20 used a lot of vendor suppliers. In other words, the 21 hanger was built outside the power plant site, was 22 bought off site.
23 Today, they don't use too many vendor suppliers as 24 far as hangers or things like that, but they build a lot l 25 of them over in the fab shop, and they call them fab l
1 Sonntag Reporting Service, Ltd.
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1 shop hangers.
2 Okay. Maybe the only weld that's built in 3 the -- that's done in the job site or in the plant is 4 just the connection welds.
5 There is a few hangers still built -- being built 6 in the -- in the plant, as far as that goes, on fab 7 tables, you know, or in certain areas.
8 (Indicating.)
9 Q What's a connection weld?
10 A A connection weld is a weld that puts a unit to the 11 structural steel or to the aux steel or wherever the
("3 12 hanger is going to be attached from.
\.)
13 Attachment welds we should be calling them instead 14 of connection welds.
15 Q All right.
16 Can you describe a typical attachment weld as you 17 just used the term?
18 Let's take a horizontal beam and a hanger that you
- 19 are going to suspend from a horizontal beam.
20 A Okay. It could be -- it could be done several ways.
21 It could be attached directly to the beam or to 22 what's called to a LV plate.
23 Q Say again.
24 A It could be attached with a DV plate.
l 25 Q D as in dog, V as in Victor?
i l
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1 A D as in dog and V as in Victor.
2 Q What does that stands for?
3 A The term DV -- I'm not for sure --
4 Q Okay.
5 A --
but it is -- it is -- it is -- let me think a little 6 bit.
7 Anyway, it's just the unit they put between the 8 hanger or the unit that they are' hanging and the column 9 or to the aux steel. They use them on both.
10 (Indicating.)
11 Q All right, sir.
12 In any event, do I understand correctly that these
)
13 attachment wel'ds are the welds that are actually 14 performed in the field?
15 A That's true, that's true.
16 0 The hanger --
17 A That is the two welds or four welds or how many is 18 actually made in the field; right.
19 Q Okay.
20 That's in the case -- let me finish my question now 21 so you make sure you are answering the question I'm 22 trying to ask.
l l 23 In the case where the hanger is either fabbed up in 24 the fab shop or is a vendor-supplied hanger -- in those 25 two cases, the only field welds would be the attachment Sonntag Reporting Service, Ltd.
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v 1 welds to the mounting member; in this case, of the 2 example, the horizontal beam?
3 A That's correct.
4 Q Okay.
5 Now, do I understand correctly that if it's a 6 vendor-supplied hanger, whether the hanger is supplied 7 to Edison or Comstock, it's the vendor's responsibility 8 to perform the QC weld inspections on the fabrication 9 welds for that hanger?
10 A That's true.
11 Q These would be the welds that hold the -- say the B
() 12 13 hanger, the horizontal member, to the two vertical members?
14 A Usually that is correct.
l 15 0 And if it's a fab shop fabricated hanger, fabricated in 16 Comstock's fab shop, it would be the responsibility of a
( 17 QC Inspector in the fab shop to QC inspect the 18 fabrication weld for that hanger?
19 A That is true.
20 Q In both those cases, it would be the field QC 21 Inspector's responsibility to inspect only the 22 attachment welds?
23 A Usually that is correct.
24 Q All right.
O 25 Now, if you got a vendor-supplied hanger and it was Sonntaa Reporting Service, Ltd.
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1 installed in the field by Comstock craft, before it was 2 installed by the craft, would the hanger be painted at 3 all?
4 A Usually it was painted before they come to the jobsite.
5 Q And what was it painted with when it came to the 6 jobsite?
J 7 A If it was galvanized, it was Galvanox. If it was 8 structural steel, it was painted brown.
9 Q Okay.
10 And do I understand -- well, and what would the 11 condition of the field welds be, the attachment welds be, when the initial QC inspection was to be performed
{) 12 13 on the installation of the hanger?
l 14 A What was the condition of what now?
15 0 Of the field weld, the attachment weld.
16 A The attachment weld should be left unpainted till the QC 17 fellow does his inspection, and then they can paint it.
18 Q Okay.
19 That's the way the system is supposed to work?
20 A That's the way the system is supposed to work.
21 Q Okay.
22 Now, in the AVO program, you were inspecting 23 components that had, in many cases, been previously 24 final QC inspected; correct?
O 25 A Oh, yes.
Sonntag Reporting Service, Ltd.
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1 Q And so do I understand that, consistent with your last 2 answer, those attachment welds themselves would also be 3 painted --
l 4 A Oh, yes.
5 Q -- if the program was working the way it was supposed to 6 work?
7 A Right.
8 Q All right.
l 9 Now, when you were sent out to do these AVO 10 inspections of hangers that happened to be the subject 11 of an Avoid Verbal Order non-control document, what were 12 your instructions during the course of this program,
)
13 this seven months, with respect to documenting the 14 condition of the vendor weld on hangers?
15 A We did,not look at a vendor weld. It didn't matter 16 whether it was painted, whether it was rusty or what, 17 you still didn't look at a vendor weld.
18 They had already been bought off before they come 19 to the jobsite. '
20 Q All right.
21 What are your instructions with respect to 22 documenting the existence or number of vendor welds on l
23 the Form 19 checklist that you were using to perform 24 your AVO reinspection?
l 25 A Okay. That changed two or three different times.
l l
l Sonntag Reporting Service, Ltd.
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8570 1 I wouldn't say that it all changed during the AVO 2 program, but that changed two or three different times.
3 At one time we didn't worry about any vendor welds.
4 You didn't even count them. Like they didn't even 5 exist.
6 You only counted the welds that Comstock welders 7 made. In other words, the welds that the Comstock 8 welders put in --
9 Q Made in the field?
10 A -- in the field or in the fab shop or whenever it was 11 at.
12 0 Let's say you were inspecting the field installation of
)
13 a hanger under the instruction that you are describing 14 now, and let's assume that there are 4 attachment welds 15 on that hanger and 20 vendor welds.
16 How many welds would you list on the Form 19 under 17 that instruction?
18 A Well, the last year or so, we would list 24; but you 19 should also note, in the -- in the remarks section, how 20 many was actually vendor welds.
21 Q All right.
22 Now, is that pursuant to a Comstock procedure?
23 A As far as I know, yes.
24 0 Well, I mean, is there a written procedure of Comstock l O' 25 that says, " List vendor welds, list attachment welds, Sonntaq Reporting Service, Ltd.
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1 put them in the remarks section"?
2 A The last procedure, I couldn't tell you whether it 3 specified that you put the vendor welds in the remarks 4 section of the Form 19 or not. I couldn't say.
5 JUDGE GROSSMAN: Excuse me.
6 MR. GUILD: All right, sir.
7 BOARD EXAMINATION 8 BY JUDGE GROSSMAN:
9 0 I believe you answered that at one time you ignored 10 vendor welds?
l 11 A That's true.
12 0 I thought Mr. Guild asked you the question as to what 13 you did in that circumstance with regard to 20 vendor 14 welds and 4 attachment welds, and then you went on to l 15 what you did later, i 16 But with regard to the initial period in which you ,
17 didn't concern yourself with vendor welds, you would 18 only count 4 attachment welds; is that correct?
19 A You would count 4 field welds as would be listed on your 20 Form 19, 4 field welds.
21 Q You wouldn't list anything with regard to the vendor 22 welds?
23 A At one time, we didn't list nothing, just like it wasn't 24 there.
25 JUDGE GROSSMAN: Okay, fine. Okay.
l Sonntag Reporting Service, Ltd.
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8572 1 DIRECT EXAMINATION 2 (Continued.)
3 BY MR. GUILD:
4 Q All right.
5 Now, at a later time, as you just testified, you 6 would list both the field and the vendor welds --
7 A That's true.
l 8 0 -- in the portion of the Form 19 where it says " total 9 welds"?
10 A Right.
11 0 okay.
12 But am I correct in understanding your testimony
)
13 that at that later time, you may only inspect the 14 attachment welds, but you would list all of the welds on l 15 the Form 19? <
16 A You would list all welds, whether they were attachment l
17 welds, vendor welds, fab shop welds or what.
18 You had to put this number -- the total number of 19 welds on the hanger.
20 Q Even if the total number of welds in that case would not 21 reflect the total number of welds you inspected --
22 A That's true.
23 0 -- necessarily?
l 24 A That's true.
25 0 Simply the total number of welds on the component --
1 f
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1 A Right.
2 0 -- vendor, fab shop and attachment?
3 A Right.
4 Q All right.
5 Were there any other kind of welds besides those 6 three?
7 A No, not on that jobsite.
8 0 okay.
9 When the changes were made to the AVO program, most 10 particularly with respect to documentation of weld 11 inspections, were these changes made orally or were they 12 made in a change to the Comstock procedures?
i
(])
13 A Well, both.
14 I'm pretty sure that some days we would come in, 15 you know, and some of the Inspectors would say, "We 16 can't do it this way, we can't do it that way," and they 17 would get together with management, you know, and they 18 would come back -- or get with the Lead, you know, and 19 come back and maybe the Lead would say, "Let's" --
20 "Let's do it this way until we find out."
21 In other words, it was a constant changing 22 procedure there for about the first 90, 120 days. I 23 mean, you didn't know what -- how you was going to do it 24 from the -- from one day to the next.
l
(:) 25 In fact, if I was not mistaken, there was no Sonntag Reporting Service, Ltd.
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V 1 procedure written before the AVO program started.
\
2 MR. GUILD: Mr. Chairman --
3 JUDGE GROSSMAN: Excuse me.
4 I'm not sure you tied it down.
5 We had two different systems mentioned, i
6 BOARD EXAMINATION 7 BY JUDGE GROSSMAN:
i 8 Q Was that all?
9 In no case did you ever inspect fab shop or vendor 10 welds; is that correct?
l 11 A There was -- there was a memo -- or it was in the
() 12 procedures that -- that the vendor welds wasn't the 13 responsibility of Comstock engineers.
i 14 0 Okay.
I 15 So in no case -- there were only two situations 16 that you had there.
17 One was where you counted all the welds and the 18 other was initially where you counted only field welds; 19 is that it?
20 A That is correct.
21 Q Oh, okay.
22 And that covers the waterfront? There was no 23 other system?
f 24 A No other system that I know of.
l O 25 JUDGE GROSSMAN: Okay, fine.
l I
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)
1 DIRECT EXAMINATION 2 (Continued.)
3 BY MR. GUILD:
4 Q Now, the record will reflect that you were identified as 5 a witness -- prospective witness in this proceeding, Mr.
6 Hunter, in February of 1986.
7 That's not a question. That's just a statement.
8 You were.
9 And your deposition was taken in this case on two 10 dates.
11 Do you recall your deposition being taken?
() 12 A Yes.
l 13 MR. GUILD: All right.
14 Mr. Chairman, I submit that the witness' deposition 15 was taken January 28, 1986, at Braidwood Station -- it 16 was a partial deposition -- and it was completed on 17 February 25, 1986.
18 Now, Mr. Chairman, I'd ask that -- I want to i
19 establish only that the witness' deposition was taken in 20 the proceeding and he's so testified, and then I want to 21 simply ask that the Board take notice of the existence l 22 and content of Mr. Hunter's deposition by way of the 1
- 23 transcript of that deposition.
l 24 Now, I don't propose to submit this deposition 0 25 transcript as an exhibit in evidence. I don't intend to Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 i (312) 232-0262
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8576
, (
l demonstrate or prove the substance of the matters that 2 he's testified to in that deposition.
3 He has responded to questions live from the witness 4 stand appropriately.
5 But since the fact of his testimony in deposition 6 and the substance of his testimony in deposition has an 7 asserted bearing on his termination from employment, I 8 would ask that the Board take notice of that deposition I
9 and of its content.
10 I can mark it as an exhibit. I don't propose to 11 offer it in evidence; but I would formally request that 12 the Board take notice of Mr. Hunter's deposition.
(])
l 13 I would ask Counsel to stipulate --
14 JUDGE GROSSMAN: Okay. If I understand 15 correctly, Mr. Guild is asking that we just take 16 notice -- that we take official notice of the fact that 17 he testified to certain things on the deposition, but 18 not to establish the truth of what he testified to in 19 the deposition, but only that he said these things.
20 I assume Mr. Guild's going to tie that in with the 21 subsequent termination.
22 Is that correct, Mr. Guild?
23 MR. GUILD: Yes, sir, that's my intention.
24 JUDGE GROSSMAN: Do you have any objection to 25 that, Mr. Gallo?
Sonntaq Reporting Service, Ltd.
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8577 1 MR. GALLO: Well, I have no objection to 2 taking notice of whether the deposition has occurred.
3 I take it that if Mr. Guild, through the 4 examination of this witness, fails to make the linkage 5 in the heretofore undefined areas in the deposition to 6 ,
the witness' termination, that a motion to strike would 7 lie.
8 JUDGE GROSSMAN: It might; but it would be 9 unnecessary.
10 In other words, he's not using what he said in the 11 deposition to prove the truth of what was said there, 12 but he's only going to make an argument, I take it, that
({}
13 things that he said there had some effect on his 14 termination.
15 I don't think you can -- and if it doesn't -- if he 16 can't tie it in, there's no reason to strike; but I 17 think there's no problem with our -- no objection to our 18 taking into account the fact that these things were l 19 said. I don't see any objection to that.
20 That's all you are offering it for?
21 MR. GUILD: It is, Mr. Chairman.
22 I would simply note, pursuant to the Commission 23 rules, the deposition, I'm informed, has been filed with I
24 the secretary of the Commission, it's in the Docket, O 25 it's subsequently been served on all the parties. They l
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1 have notice of what it says.
2 And, again, I don't offer it to prove the substance, 3 of what Mr. Hunter testified to; only that he testified 4 to these things.
5 JUDGE GROSSMAN: Okay.
6 Does Staff have any problem with that?
7 MR. BERRY: No objection.
8 JUDGE GROSSMAN: Okay. We'll do that, Mr.
9 Guild.
10 MR. GUILD: Thank you, Mr. Chairman.
11 JUDGE GROSSMAN: We'll take notice of that.
1 12 BY MR. GUILD:
(])
13 Q Mr. Hunter, you went to Chicago -- I mean, you went over 14 to the -- to the -- strike that.
15 In January,-- on January the 28th, 1986, 16 Commonwealth Edison Company subpoenaed you for a 17 deposition, and Ms. Kezelis asked you questions.
18 Do you recall?
19 A That's correct.
20 0 All right.
21 And where was that deposition taken?
22 A On the jobsite, what they call the red trailer, 23 approximately 150, 200 feet from the QC office.
24 0 All right.
O 25 That's the lawyer trailer, the Edison lawyer Sonntaa Reportino Service, Ltd.
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1 trailer?
2 A I imagine it's the lawyer trailer.
3 At least they call it the red trailer.
4 Q The red trailer.
5 were any of your co-workers or your supervisor 6 aware that you were having your deposition taken?
7 A I'm pretty sure they were all aware that I was going 8 over to give my deposition.
9 0 I don't want you to speculate or you to guess.
10 But do have any --
11 A That's what I was told.
(]) 12 O Who told you that? ,
j 13 A I'm pretty sure it was Tony simile.
l 14 Q Mr. Simile?
~
15 A Yes, I'm sure he did.
16 0 And subsequently, you had to come back and you went to 17 Chicago the second time on the 25th of February?
18 A Yes, that's right.
19 Q Again, you were under subpoena to Commonwealth Edison, 20 were you not?
l 21 A That's correct.
22 Q And you went to Ms. Kezelis' office in downtown Chicago, i 23 did you not?
l 24 A That's true.
25 0 She asked you questions, did she?
l
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Le 1 A Yes.
2 Q And were your supervision and colleagues aware that you 3 were going to Chicago that day for your deposition?
4 A Oh, yes, yes.
5 Q How do you know that?
6 A I'm sure that I had to tell them that I would.be going.
7 In other words, I'm sure that I received a letter
! 8 or notification in some way that told them that -- that 9 I should report to Chicago at a certain time, certain 10 date --
11 Q All right, sir.
12 A -- to finish the deposition.
({}
13 ' O Now, you were, indeed, terminated from L. K. Comstock, 14 were you not --
l 15 A I was --
16 0 -- or BESTCO?
17 You were terminated by BESTCO?
18 A I was terminated by BESTCO.
19 0 Would you describe the circumstances of your 20 termination?
21 A Well, actually, the termination went on for about a week 22 or so.
23 Like I say, really the first three or four days, 24 you hear all kind of rumors, you know, and things like
() 25 that.
l l
Sonntag Reporting Service, Ltd.
l Geneva, Illinois bu144 l (312) 232-0262
8581 1 I was given a list of 13 hangers they said was 2 painted.
3 I myself checked the 13 hangers, and I agreed that 4 some of them was painted on the day that I went out and 5 looked at them the second time. I agreed with some of 6 them; some of them I didn't agree with.
7 When I was terminated, Mr. Bill Skidmore, who at 8 that time was site manager for BESTCO, whenever he wrote 9 up my termination papers -- at first he wanted me not to 10 take a termination, he wanted me to just leave the site, 11 and I said, "No, I don't think I can do that," and --
12 anyway, when the termination papers was coming through,
(]) '
13 I think you will see that it says I failed to follow 14 procedures or failed to follow instructions or whatever 15 the -- whatever -- whatever he put on it, I don't -- I 16 can't recall it offhand, but he also marked on there 17 that I was eligible for rehire.
18 He didn't believe some of the things that it was 19 alleged that I did.
20 0 All right.
21 How do you know that?
22 A Well, he told me so.
23 0 Let me go back in time.
24 You were performing work under the AVO program?
O 25 A That's true.
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1 Q All right.
2 And I take it, from your last answer, you were 3 performing the field inspection that you earlier 4 described --
5 A Right.
6 0 -- the reinspections of hangers?
7 A Right.
8 Q And were you doing this by yourself or in the company of 9 others?
10 A Well, for the first -- probably the first seven 11 months -- I'm -- until the last three or four days, I
() 12 was pretty well by myself, yes.
13 The last three or four days, I had a young man by 14 the name of Arndt with me.
15 0 All right.
16 And can you identify Mr. Arndt? What was his l
, 17 first name l
18 I'm putting you on the spot, Mr. Hunter.
19 Was it Richard?
20 A No, his name wasn't Richard.
21 0 I'm guessing wrong then. Okay.
22 A I've got it written down.
23 To recall his first name right off, I can't.
24 JUDGE GROSSMAN: Mr. Simile, maybe you can l
25 help us.
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1 MR. SIMILE: Ron, Ron Arndt.
2 THE WITNESS: Ron.
3 MR. GUILD: Ron?
4 THE WITNESS: I know it wasn't Richard.
5 BY MR. GUILD:
6 0 You and Mr. Arndt worked together the last couple of 7 days?
8 A Couple or few days; right.
9 0 was he a new employee at that time?
10 A Yes. He hadn't been with the company but a very short
, 11 time.
I 12 You were in the process of training him; is that right?
({} O 13 A Yes, in the procedures that we was using td track the 14 documents and everything in the AVO program; right.
15 Q Now, was Mr. Arndt a brand new green QC Inspector?
16 A Oh, no, no. Mr. Arndt had been on several nuclear 17 sites.
18 In fact, he had just come off of a nuclear site 19 to -- to Braidwood.
20 0 Do you know what inspection work he had previously done?
21 A Yes. He was -- he was -- he was a qualified Weld 22 Inspector.
23 Q He had been a certified Level II Weld Inspector?
! 24 A Oh, yes, for several years.
(2) 25 Do you know how many years of weld inspection experience l
Q Sonntac Reporting Service, Ltd.
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1 Mr. Arndt had?
2 A I'm sure he had six or seven years inspection work.
3 Q Okay. And you stated that he did it on a nuclear job.
4 Do you know what code Mr. Arndt inspected to in his 5 previous work?
6 A I'm sure they worked with the same codes that they are 7 building the Braidwood plant to.
8 Q All right, sir.
9 That conclusion you reach from the course of 10 observing his work, that he worked to the same standards 11 and codes that you did?
(]) 12 A I'm sure he worked to the same standards and codes that 13 the Braidwood plant is being built to.
14 Q All right, sir.
l 15 What was the nature of your work with Mr. Arndt in i
16 the last few days of your employment at Comstock and 17 BESTCO?
18 A Mostly showing him the -- how to locate -- like I say, 19 to locate the documents, how to locate the hanger, what 20 to look for on the Rev A-Rev 0 drawings, the new 21 drawings that we was using.
22 MR. GALLO: Why don't we take five minutes.
23 JUDGE GROSSMAN: All right. We'll take a 24 five-minute break.
25 (WHEREUPON, a recess was had, after which Sonntag Reporting Service, Ltd.
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1 the hearing was resumed as follows:)
2 JUDGE GROSSMAN: We're back in session 3 Mr. Guild.
4 MR. GUILD: Thank you, Mr. Chairman.
5 BY MR. GUILD:
6 Q Mr. Hunter, you, before the break, were describing your 7 work with Mr. Arndt in the last few days of your 8 employment at Braidwood.
9 You stated that you were showing him how to do the 10 research and the review of the drawing revisions in ,
11 order to perform reinspections.
12 Did you and he both perform the reinspection work?
(])
13 A Yes, for about three days we worked together --
14 Q Okay.
15 A -- approximately.
16 Q And by that I mean, the visual inspection of the welds 17 on these hangers where reinspection was required because i 18 of an inability to trace the AVO's to a completed 19 checklist.
20 A That's true.
21 Q All right.
22 Can you describe how you and Mr. Arndt went about l 23 performing this field inspection work together?
24 A Mr. Arndt, the first day, he just followed me around to 25 see what I looked at, to see what I -- how I documented l
Sonntag Reporting Service, Ltd.
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1 it, to see how I stamped it; first one thing and 2 another.
3 In other words, it was just one of those kind of 4 training programs that he observed what I was actually 5 doing.
6 (Indicating.)
7 Q All right.
8 A The second day, he probably looked at one or two hangers 9 hisself.
10 I think maybe a total of three hangers is what Mr.
11 Arndt looked at.
12 0 All right.
(])
13 And did you work along with him when he did that 14 work?
15 A Oh, yes, I was usually with him whe,never he -- in other 16 words, he said -- after -- after he had watched me 17 document three or four different hangers, he said, "Let l
18 me try mine," you know.
! 19 Of course, he had his stamp, he was a -- he was 20 certified on the job, so, naturally, you know, he didn't 21 want to just stand back and let me do it all.
i 22 0 All right.
23 You were training him, but under the BESTCO 24 contract, his certification was good from his previous O 25 employment; is that my understanding?
Sonntag Reporting Service, Ltd.
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1 A No, I' don {t think so.
2 Q A1L ri'ght.
3 -
Why don't you tell me: ,
4 Was he certified before you performed the Avo? ,
?
'~
5 A He was certified by Comstock -- I mean -- yeah, by, 6 Comstock -- Comstock --
7 0 Okay.
8 A -- Com Ed, Com Ed.
9 His book would have been approved by Com Ed before 10 they certified his hammer.
11 Q' I see. 3
( 12 And how long did it.take him to train and receive
({}
l 13 his hammer, if you know?
- , /
l 14 A I'm sure Mr. Arntit was probably on the jobsite at least 15 30 days.
16 Q All right, sir. ;-
s 17 But at the time y.ou did the work with him, Arndt 18 had his certification in walding?
19 A The number of days I couldn't tell you.
20 Q No.
l 21 But he did have his certification --
22- A Yes, he did.
l 23 0 -- during this last week?
24 A Yes, he did.
() 25 Q And he had his own hammer --
Sonntaq Reporting Service, Ltd. '
Geneva, Illinois 60134 l (312) 232-0262
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1 A Yes, he did.
2 Q -- to stamp welds?
3 A Yes, he did.
4 Q But you worked on hangers together; is that right?
5 A Yes.
6 On the AVO program, I was considered his trainer.
7 Q okay.
8 Now, did you ever have occasion to -- did you have 9 occasion to observe Mr. Arndt's inspection activity?
10 A Oh, yes, I did.
11 Q All right.
12 Did he appear to you to be qualifie'd and
(])
13 knowledgeable as an Inspector?
l 14 A He was knowledgeable, he was knowledgable, as far as 15 weld inspection goes, yes.
16 Q All right.
17 Did you have confidence in hia ability to identify l
l 18 rejectable conditions --
19 A Yes, I did.
l 20 0 -- under the Comstock weld acceptance criteria?
l 21 A Yes, I did.
22 Q Now, on occcsion, when you were working together on the 23 same hanger, did you share the work on inspection and on 24 documenting the inspection?
25 A The -- whoever -- whoever filled out the document, that Sonntag Reporting Service, Ltd.
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1 was the stamp they used.
2 In other words, it wouldn't matter whether there 3 was 70 welds on one hanger and I looked at 70 welds, I 4 stamped 35 of them, Mr. Arndt used my hammer to stamp 35 5 or of them or whatever it was.
6 It was still my responsibility to -- to insure that 7 all 70 welds met the accepted criteria.
t 8 Q All right.
9 And you did that by -- well, did you v'isually 10 inspect all those welds yourself?
- 11 A Oh, yes.
12 Okay.
(]) Q 23 But I understand, from your last answer, that, on 14 occasion, you visibly -- visually inspected the weld 15 yourself, but under your direction, Mr. Arndt would
- 16 place your stamp by a weld; is that true?
, 17 A Well, if he was in a confined area or an area that was 18 hard for one man to -- to get to -- in other words, if 19 it was half-a-dozen pans running through one hanger, 20 it's true, one man may have looked at them all, but 21 instead of crawling from one side to the other to stamp 22 it or from climbing to top to bottom, one guy might 23 stamp the top, one guy the bottom.
24 That happens quite often.
O 25 Q When you say it happens quite often, did it happen with Sonntag Reporting Service, Ltd.
Geneva, Illinois bu144 (312) 232-0262
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(
l other Inspectors aside from yourself and Mr. Arndt?
2 A Oh, yes.
3 Q Did you observe other Inspectors doing that?
4 A Oh, yes, yes.
5 Q While another Inspector might stamp a weld for his 6 colleague, do I understand your testimony to be that the 7 Inspector who signs the checklist takes full 8 responsibility --
9 A That's true.
10 0 -- for the work?
11 a That's true.
(} 12 Q All right.
j 13 And in your case, if you have done that in the 14 past, have you inspected the work yourself?
15 A Oh, yes.
16 0 All right.
t l 17 When you come out to the -- you and Mr. Arndt 18 now -- when you come out to the hanger that you are 19 looking at -- let's say the hanger has 50 welds on it 20 total and some 20 of them are field welds.
21 It's a large hanger. Let's say it's 10 or 15 feet 22 tall. It covers a number of different elevations.
23 Would you stamp each weld as you inspected that
- 24 weld and wrote that weld -- well, would you stamp each O 25 weld at the time you inspected that specific weld?
Sonntaq Reporting Service, Ltd.
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1 A Not necessarily.
2 A lot of us -- in other words, if you had a 3 rejectable criteria, rather than writing it up as each 4 and every weld, you know, you would reject weld so and 5 so, location so and so, you know, and there would be no 6 stamp on it.
7 If it was an acceptable weld, the last criteria 8 that we was using, you stamped it, you wrote a Form 30 9 or an ICR or NCR, whatever is required, and turned it in 10 that way.
11 In other words, it might be -- the 50 welds, there
([) 12 might be 45 of them acceptable, but that had to be noted 13 on your Form 19, and 5 rejectable.
i 14 That had to be shown on a Form 30 or Form 14 or 15 whatever you was using.
~
16 0 All right, sir.
17 Now, I'm just trying to understand the sequence of 18 events.
19 You come out to the hanger to inspect the welds 20 that are required to be inspected?
l 21 A Right.
22 Q And those are the field welds, not the vendor welds?
23 A That's true.
24 Q All right.
25 Let's assume in my example there are 20 field Sonntag Reporting Service, Ltd.
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1 welds.
2 There are the attachment welds, plus there may be 3 some other welds on the hanger that may be field 4 performed; correct?
5 A Right.
6 Q Now, you go to inspect those welds.
7 Do you give them a once over before you complete 8 the work?
9 A Usually you make sure that all the welds are in place.
10 In other words, if there's something missing or 11 something like that, you can automatically write a Form 12 You know, it's just automatically ICR. In l (]) 30 on it.
13 other words, it's not completed.
14 Q All right.
15 Do you look to see whether or not the welds are in 16 an inspectable condition --
l 17 a That's true.
l 18 Q -- to determine whether or not they are free from paint 19 or dirt or rust, to be able to inspect?
20 A You make sure that they are visibly inspectable.
21 Q I'm sorry.
22 The last answer?
23 A You make sure that they are visibly inspectable.
l l
24 Q Now, I just want to show you a checklist, and this is O 25 just a random one, but it's a Form 19 Rev K 21086.
Sonntaq Reporting Service, Ltd.
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1 (Indicating.)
2 And is this one of the inspection criteria that 3 relates to the field observed condition of the weld, its 4 cleanliness, et cetera?
5 A It says, ' Weld sufficiently clean not to impair visual 6 inspection."
7 Q Okay.
8 Is there a reference to the Comstock weld 9 inspection procedure by that attribute?
10 A Yes; Paragraph 3.2.
11 Q That's 3.2 of the weld inspection procedure; correct?
12 A That's correct.
(])
13 0 All right.
14 Now, does that inspection procedure provision, to 15 the best of your knowledge, state anything about the
! 16 weld being free of paint?
17 A I believe it says that the weld should be sufficiently 18 clean of all foreign material.
19 Q All right.
20 Again, the criterion on the checklist reads we]d 21 was sufficiently cleaned as not to impair visual
! 22 inspection?
23 A That's true.
24 Q All right.
i
() 25 Now, does that require, in your opinion, judgment l
Sonntag Reporting Service, Ltd.
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8594 1 on the part of the Inspector?
! 2 A Yes, that is strictly a judgment call.
3 Q Some Inspectors may believe -- am I understanding you 4 that -- well, strike that.
- 5 All right. So you come to the hanger, and you and 6 Mr. Arndt are looking at the hanger.
! 7 Do you, at the outset or at some other time, l 8 determine whether or not the welds are in a sufficiently 9 clean state to allow an inspection?
10 When do you do that?
11 A You have to do that before you put your stamp to it --
12 0 ,Okay.
(]) .
13 A -- or before you fill out a Form 19.
14 Q All right.
15 So in the instance where you ultimately go back and 16 place your stamp next to the weld, indicating it's 17 acceptable, you've already looked at the weld once to l
18 determine that it's sufficiently clean of paint, et
, 19 cetera, to be able to inipect it?
l 20 A That is usually correct.
21 Q And if you look at the weld and determine that it's not 22 sufficiently clean -- per Paragraph 3.2, not 23 sufficiently clean to allow you to perform your visual l
24 inspection, what do you do?
25 A You don't stamp it and you write up a Form 30 for paint Sonntaq Reporting Service, Ltd.
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1 removal --
2 (Indicating.)
3 Q All right.
4 A -- or whatever -- whatever the problem is.
5 Q All right.
6 Well, is Form 30 an ICR?
7 A Form 30 is an ICR.
8 Q Okay.
9 So you would initially determine, before you 10 completed your inspection, that the first checkpoint on
! 11 the checklist was rejectable, and that is that.the weld l
12 was not sufficiently clean?
(])
13 A That's the first criteria you use.
14 Q All right, all right.
15 Now, you and Mr. Arndt completed ycur inspections, 16 as you described, during this couple-of-day period.
17 How did it come to your attention that you had been 18 alleged to have performed deficient work?
19 A Well, I don't know where I heard it -- well, I take that 20 back.
21 A young PTL Inspector said, "You fellows are 22 looking through paint," you know. I said, "No, we don't 23 look through no paint for welds."
l 24 He was following us on this AVO program checking 25 the accept and reject welds that PTL does.
l Sonntag Reporting Service, Ltd.
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1 I think they was at that time doing a 25-percent t
2 overview.
3 I don't know what the percent that they were doing.
4 Q But it was an overview; correct?
5 A Maybe it was a hundred percent. I don't know.
6 And, anyway, I pointed out on the vendor welds that l 7 was painted with old Galanox, the old gray Galvanox -- I 8 said, "Sure thems painted," but I said, "we don't even 4
9 have to look at them." "What do you mean you don't have 10 to look at them?"
11 One thing led to another. I think he got a little 1
wise; and like I say, I've got enough Scotch-Irish to
(]) 12 13 get my damper up whenever I know something, you know, so ,
14 one thing led to another; and about three or four days 15 later, why, I don't know who I heard it from -- whether P
16 it was from Brian Murphy or Tony Simile or someone j 17 said -- someone said, " Don't go back out and do anymore 18 inspections. I've got some questions."
19 Q Okay. Now, wait a minute. Let me stop you there.
20 Who is Brian Murphy?
21 A Brian Murphy was my Lead in the -- in the AVO program.
22 Q Okay.
23 A So I says, " Fine and dandy"; and that went along, like I 24 say -- I don't know -- three or four days.
25 I went out myself -- when I -- when I got a list of Sonntaq Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
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1 13, I went out myself.
2 O Now, the 13 what?
3 A 13 inspections that they requested.
4 Q Who's "they"?
5 A I imagine it was PTL. I don't know.
6 0 All right. You got a list.
7 -
And who gave you the list?
8 A I would say that Brian Murphy gave me the list. I would 9 say that, not knowing.
10 Q You seem to be surprised by a question about that.
11 Was Mr. Murphy your Lead?
() 12 A Right.
13 Q Could it have been anybody else who gave you the list?
14 A Oh, yes, it could have been Tony; it could have been 15 any -- it could have been anyone like that.
16 Q You recall that someone in supervision gave you that 17 list?
18 A I say that someone in supervision gave me a list.
l ,
l 19 0 They gave you a list of 13 hangers?
20 A Of the 13 they questioned, yes.
21 Q All right.
22 What did you do then?
23 A I myself went out and checked them at that time, which 24 was anywhere from a week to 2 weeks, maybe to 21 days.
25 From the time I had actually written the Form 19's i
i Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
. 8598 U,,
1 myself, accepted them, there was that much time period.
2 0 All right.
3 Were you doing the inspections on or about the 4 second week in March?
5 A That's true.
6 Q Say the 10th through the 15th?
7 A The 10th, yeah, to the 18th or 19th, whatever the date 8 the last one is.
9 Q All right.
10 And did you go back out to the field a week or so 11 later?
l () 12 A I went'out on the 25th and looked at them.
13 Q on the 25th of March?
14 A On the 25th of March.
15 Q All right, sir.
16 Let me show you a document, Mr. Hunter, which I'd 17 ask be marked as Intervenors' 67 for identification, 18 please.
19 (Indicating.)
20 (The document was thereupon marked 21 Intervenors' Exhibit No. 67 for 22 identification as of July 23, 1986.)
l 23 BY MR. GUILD:
l 24 0 Okay.
O 25 Mr. Hunter, can you identify the document I have l
Sonntaa Reporting Service, Ltd.
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8599 1 just given you?
2 It's a Xerox copy of an original document.
3 A Yes. This -- this is the day that I went out and looked 4 at the 13 hangers that they questioned.
5 0 All right.
6 Is this a list of 13 hangers?
7 A This is a list of hanger number, number of welds, 8 location, drawing number and so forth.
9 Q All right.
10 And is this in your handwriting?
11 A This is my handwriting; correct.
12
(]) 0 All right.
13 And is this the list that you prepared when you 14 went to the field on the 25th of March --
15 A This is on the 25th. ,
16 0 -- to re-examine the hangers that you had been told that 17 were found were questioned --
18 A Right.
19 0 -- is that right?
20 A That's correct.
21 Q All right.
22 Now, would you describe for the Board and parties 23 what you did on that day when you had the list?
l
( 24 JUDGE GROSSMAN: We don't know yet why they O 25 were questioned, I don't believe -- oh, I don't Sonntaa Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
8600 0
1 believe --
2 MR. GUILD: I don't know.
3 BY MR. GUILD:
- 4 Q Do you know why these were questioned? Were you told 5 why they were questioned?
6 A Not in so many words. Someone -- I believe it was Mr.
7 Tony simile -- said that, "Have you been looking through 8 paint," and I said, " Tony, I never looked at an 9 attachment weld through paint in my life."
10 Q All right.
11 And did you have an understanding that you were 12 being questioned about inspecting these hangers through
(])
13 paint?
14 A That's right.
- 15 Q All right.
I 16 But did anybody actually tell you those hangers 17 were supposed to have been inspected in a painted 18 condition?
19 A I believe someone -- probably Mr. Simile or Mr.
20 Sassman -- says, "You have some hangers that you 21 inspected and accepted that's painted," and I said, "I 22 never looked at an attachment weld through paint in my 23 life."
24 Q Now, you said Sassman..
O 25 You mean Seltmann?
Sonntag Reporting Service, Ltd.
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8601
, ()
1 A Seltmann.
2 Q Bob Seltmann, the QA Manager?
3 A Bob Seltmann.
4 Q Now, did he give you this list?
5 A I got this list from someone; and like I say, offhand, I 6 can't say it was Brian Murphy, Tony Simile or who, but 7 that was the list that I got.
8 0 When you got the list, did you understand these were the 9 hangers that are supposedly inspected through paint?
10 A That's correct.
11 Q Okay.
12 Now, what did you do?
(])
13 A I went out and did a visual inspection on them myself.
14 If you will notice over there, that is my mine 15 where it says, "no paint," " paint," hnd there is I think 16 some five that was painted -- at the time on March the 17 25th there was some five hangers that was painted.
18 Q All right. Now, let me start at the top here.
l 19 For Hanger 13 H 14, you got written above, "No l
l 20 paint"; is that right?
l 21 A Right, that's correct.
22 Q And that's 58 weld?s 23 A 58 welds.
24 0 Okay.
l
(:) 25 Are those vendor welds or field welds; do you know?
i Sonntaa Reportina Service, Ltd.
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1 A Not -- without my Form 19, I couldn't tell you.
2 Q All right.
3 Do you know how many of those 58 you were supposed 4 to inspect --
5 A Oh, yes.
6 0 -- as field welds?
7 A If I was looking -- if I was looking at them with the 8 Rev A-Rev O drawing, all 58, but if I didn't have the 9 Rev A-Rev O drawing, it might not be but just a few.
10 0 So 58 is --
11 A That is the number of welds that's on the hanger.
12
(]) A That's the total number of welds.
! 13 A That's the total number of welds; and --
14 Q And some portion of the welds were the welds you 15 inspected but not all of them?
16 A Yes, that's correct.
17 Q And you previously testified you only inspected the 18 field welds?
19 A I only inspected field welds.
20 Q Okay.
21 Looking down the list, for Hanger 14 H 6 -- do you 22 see that one?
23 A Yes.
24 Q That indicates 40 welds.
O 25 Is that the tolal welds on that one?
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 l
(312) 232-0262
8603 1
1 1 A That is the total number of welds.
2 Q What is the note by that particular hanger?
3 A It says vendor welds were painted. ;
4 In other words, without the Form 19, I don't know 5 how many vendor weld there actually were.
6 Q All right.
7 But you observed, when you looked into the field, 8 that the vendor registered metals were painted for that 9 hanger?
10 A That true.t 11 Q Hat's what that notation indicates?
12 A That's what that notation says.
(])
13 Also, I'm sure on my Form 19 notes that the vendor 14 welds were in place.
15 Q Okay.
16 Reading down, the Hanger No. 12 H 35, it says, what 17 appears to be, "48 welds;" is that right?
18 A That's right.
19 0 Am I read being correctly? Does it is say " painted" I
20 above that?
21 A It says " painted."
22 Q And did you observe those welds to be in a painted 23 condition when you went to the field on the 25th of 24 March?
O 25 A On the 25th they were painted; right.
l Sonntaq Reporting Service, Ltd.
Geneva, Illinois 60134
- (312) 232-0262
8604
( ,
1 Q Okay.
2 12 H 1, it shows 12 F, 12V.
3 A Field welds.
4 0 12 V, what does that mean?
5 A 12 field welds and 12 vendor welds.
6 0 So I'm you inspected the field welts; right?
7 A Yes, that's correct.
8 Q And it says " painted" by the 12 V.
9 Does that mean the vendor welds were painted?
10 A The vendor welds were painted.
11 That's usually with Galvanox.
12 That's what you observed on the 25th of March --
(]) Q 13 That's'true.
14 0 -- 1986?
15 Reading down the next one where, there's painted 16 indicated, hanger 14 H 47, shows 34 welds and painted; 17 correct?
l 18 A That's true.
19 0 They were painted when you went to the field on the 20 25th?
21 A On the 25th they were painted.
22 Q All right. -
23 19 H 43, 28 welds painted on the 25th; that's true.
24 19 L 44, 40 welds painted on the 25th; that's true.
()
l 25 0 All right. .
Sonntag Reporting Service, Ltd.
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1 Did you inspect any of the field welds, the 2 attachments welds, through paint?
l 3 A No attachment weld was ever looked at through paint.
l 4 MR. GALLO: Could I have that question and 5 answer read back, please.
6 (The record was thereupon read by the 7 Reporter) l 8 THE WITNESS: What did he say?
I 9 MR. GALLO: Thank you.
10 BY MR. GUILD:
11 Q Do you mean to say -- well, did you ever inspect any 12 attachment welds through paint?
I
(])
t 13 A No, I never.
14 Q Okay.
l 15 What did you do with this document, this list, and 1
16 notation of the field observed conditions on the 25th of 17 March, if anything, Mr. Hunter?
18 A I don't think there was ever anything done with it.
19 Q All right.
20 A It might have been shown to Tony, it might have been 21 shown to com Ed, BESTCO and Larry -- Larry.
22 Q To Com Ed, BESTCO?
23 A Yes.
24 It might have been even shown to the union steward, O 25 which was Larry Bossong at the time. They may have seen Sonntaq Reporting Service, Ltd.
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()
1 that.
2 Q All right.
l 3 Do you recall showing it to any of those people?
1 4 A I don't recall it, no.
5 0 All right.
6 Let me show you another document, which I'd ask be 7 marked as Intervenors' 68 for identification.
8 (Indicating.)
9 (The document was thereupon marked 10 Intervenors' Exhibit No. 68 for 11 identification as of July 23, 1986.)
12 BY MR. GUILD:
(])
13 0 I'm showing you a two page Xerox document, Mr. Hunter.
14 It bears the date 3/25/86. " Subject, The questioning of l
15 R. D. Hunter - Integrety - Ability - Honesty. To whom 16 it may concern." It appears to bear your signature on 17 the second page.
18 Can you identify this document?
19 A Yes, I wrote that.
20 Q Okay.
21 This is a Xerox copy of a document you wrote?
22 A I'm pretty sure it is, yes.
I 23 O All right.
24 And who did you -- who, if anybody, did you present 25 this document to?
l Sonntaq Reporting Service, Ltd.
Geneva, Illinois 60134 l (312) 232-0262 - -
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8607
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1 A Tom Skidmore got a copy.of this.
1 2 Q Now, Mr. Skidmore is whom?
l t
3 A He was manager of BESTCO project site.
4 Q All right.
5 He was the man responsible for formally taking 6 action with respect to your termination?
7 A Well, yes, he was -- he was the fellow that was 8 furnishing the QC Department with -- with the labor.
9 0 Okay.
10 When you referred earlier to a Mr. Skidmore, you 11 referred to him as the man who filled out the form that 12 said that you were eligible for rehire.
(~) . .
13 Is that the same gentleman?
14 A That's correct, that's correct.
15 Q Okay.
j 16 Now, the second -- several lines down, in the body 17 of this document, Intervenors' Exhibit 68 for 18 identification, it states as follows: "I have just 19 returned to the QC office from inspecting said hangers,"
20 and it goes on.
i l 21 Now, is that statement a reference to the field 22 reinspection that was documented on Exhibit 67, your 23 list of the hangers?
24 A I'm sure it is, yes.
l
() 25 0 Okay.
i l
Sonntaa Reporting Service, Ltd.
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1 Now, in substance, do I understand correctly that
! 2 you told Mr. Skidmore, through this writing, that you 3 had not inspected any attachment welds or field welds 4 through paint?
l 5 A I told him that there was never any attachment welds t
6 looked at by me through paint.
1 7 Hanger welds, I couldn't say, because that's a 8 different ball game. Hangers could have come in from 9 any place.
10 (Indicating . )
11 The fab shops paint their own hangers.
12 Whether it's -- ivhether it's tube steel or Unistrut
({}
13 or what, they paint it at the fab shop.
14 Q All right.
15 Now, you present -- you refer to several hangers in 16 this letter to Mr. Skidmore, the 3/25/86 document; and l 17 if you take a moment and refer, Mr. Hunter, to your list ,
l 18 of the hangers in the field, Exhibit 67, I want to ask 1
19 you about what appears to me to be a discrepancy.
20 You state, in part, in your letter, "I completely 21 disagree with Hanger 19 H 43 and 19 H 44," on drawing 22 such and such. "There may be some rust, dirt and debris 23 on the" -- I can't read it - " west plate" --
24 A Right.
O 25 0 - "to exbed, but the hanger" --
l Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
8609 O
1 A Right.
2 0 -
" welds are not painted."
3 All right. Now, I'm looking at your list, the list 4 of hangers.
5 And can you find those two hangers on that list?
6 A Yes, it says 29 weld painted and 40 welds painted.
7 Q All right.
8 Now, in fact, you went to the field and looked at 9 those two hangers, 19 H 43 and 19 H 44, and you observed 10 that they were, on the 25th of March, in a painted i
11 condition; is that right?
12 A On the 25th, they were painted; right.
(])
13 Q All right.
14 So you simply were mistaken when you listed those 15 two in the Skidmore letter, Exhibit 68, as not now 16 painted --
17 A Yes.
18 0 -- correct?
19 All right. Were those two hangers -- were the 20 attachment or field welds that you inspected on those 21 two hangers, 19 H 43 and 19 H 44 -- were they in a 22 painted condition when you performed the reinspection of 23 them at the earlier date?
( 24 A No. I'm sure that they had -- because they were in --
() 25 in an area where they had some rust and some dirt and Sonntag Reporting Service, Ltd.
Geneva, 1111nois bu144 (312) 232-0262
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1 dust, a lot of core holes being drilled and things like 2 that, I'm sure there was a lot of debris as far as that 3 goes on the hanger.
4 But the day I looked at them, the attachment welds 5 were not painted.
6 Q Okay.
7 Now, when you say you are sure there was a lot of 8 debris on the weld --
9 A Yes.
10 Q -- because of location, what was the location of these 11 hangers?
12 A It was against a concrete wall, which you notice L Wall
(~)
13 and Line 11 and 12 on Elevation 383.
14 Q All right, all right.
15 And why was there dust?
16 A Well, a lot of -- a lot of core holes was being drilled i 17 in that area at that time.
18 0 All right.
' .- 19 Did that cause concrete dust?
20 A Oh, yes.
l 21 Q All right.
22 That fell on to the --
23 A Oh, yes.
24 0 -- components?
25 A It just covers completely until they wipe it off and l
Sonntaa ReDortina Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
8611 0
1 everything like that.
2 Q You said you were sure there was rust on these 3 components.
4 Why do you say rust?
5 A This was an old hanger. There was a lot of -- there was 6 a lot of meisture in this area, so it doesn't take long 7 for it to rust.
i 8 Q All right.
l 9 Were these particular hangers, the attachment or 10 field welds, sufficiently cleaned so as not to impair 1
11 visual inspection at the time you reinspected them?
12 A At the time I reinspected'them?
(])
i 13 Q Yes. Not the 25th now, but the time you completed the
( 14 Form 19 checklist.
l l
15 A Yes, whenever the Form 19 was written, they were 16 sufficiently clean to make a judgment on them.
l 17 Q All right.
18 Now, what did Mr. Skidmore say, if anything, when 19 you presented him with this letter on or about the 25th i
20 of March, 1986?
f 21 A Well, first he said -- I believe maybe this was before 22 we went over -- he went over with Mr. Larry Bossong and 23 one of the fellows from Commonwealth Edison -- I can't 24 call his name off right now but I have it down some O 25 place -- anyway, we went over and we looked at them on i
Sonntag Reporting Service, Ltd.
i Geneva, Illinois bu134 l - _ _ _ _ _ _ (312(232-0262-__
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1 the -- on the 25th.
2 Q' All right.
t 3 A Some of them -- they all agreed that they were 4 sufficiently clean to make a judgment call.
i 5 There were about four or five that they said was 6 ques'tionable whether they was actually sufficiently 7 clean to make a judgment call and there were four or i 8 five they said was painted.
9 Q All right.
! 10 Now --
11 A Mr. Tom Skidmore said, "When was they painted, right 12 after they welded them, yesterday or today or when?"
(])
13 In other words, they didn't have any set program.
14 As far as the electricians, they furnished their own 15 clean-up people and their own paint people.
l 16 They had no set program as far as coming back and 17 repainting or painting the weld after the inspection had 18 been completed.
19 (Indicating.)
20 0 All right.
21 So they could have been -- as your understanding, 22 they could have been painted at any time after you 23 performed the inspections?
24 A That's what I say.
O 25 0 All right.
Sonntaa Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
(
8613
)
1 Now, what portion of the weld is required to be 2 cleaned, as a matter of course, in order to allow you to 3 perform a visual inspection?
4 A Fillet welds, which most of these were, just from toe to 5 toe and from the start of the weld to the end of the 6 weld.
7 Q All right.
8 Did you clean an area of the base metal around the 9 weld?
10 A Not usually, no.
11 Q All right.
12 Where did --
(])
13 A There was no reason to.
14 Q Where did you put your QC Inspector stamp?
15 A It was supposed.to be two inches of the -- approximately 16 of the weld, in other words, or wherever that is 17 physically -- wherever you are physically able to put 18 it. In other words, in the proximity of the weld.
19 Q All right.
20 Now, is it possible that you inspected a weld that 21 was, indeed, cleaned on the weld -- weldment itself, the 22 length and breadth of the weld -- is it possible you 23 inspected a weld that was cleaned but placed your stamp 24 on an adjacent portion of the base metal that was itself O 25 still painted?
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1 A Yes, that happens quite often.
- 2 Q All right.
3 And if you put your stamp on the adjacent part of a 4 base metal that was painted, would it be obvious to the i
5 observer that the stamp was made over a painted surface?
6 A Oh, sure.
7 Q Why was that?
8 A Well, usually the metal will show right up through, 9 because your stamp makes an indentation into your base 10 metal or to the steel where it leaves a bright, shiny 11 area, you know.
O 12 (Indicating.)
13 Q All right.
14 And that the existence of a bright shiny area, and, 15 therefore, the evident fact that the stamp had been 16 placed over paint doesn't indicate that the inspection 17 was performed through paint, does it?
18 A No, that's true.
19 Q Now, you state to Mr. Skidmore, in your letter, the 20 second paragraph, "I have never had my integrity or 21 ability, (honesty), questioned before," et cetera, 22 Now, had you ever been informed by your supervision 23 as to the quality of your weld inspection work, Mr.
24 Hunter?
25 A Approximately 30 days before I was terminated, I think I Sonntaa Reportino Service, Ltd.
Geneva, Illinois 60134 i
(312) 232-0262 ___--__ _- __.
9 . -
7 8615 7~3
%.)
1 seen my first evaluation from PTL.
j 2 Q All right.
3 What were the circumstances where that was brought 4 to your attention, your PTL' evaluation? ,
- 5 A I'm pretty sure Mr. Tony Simile sent word over to Mr. --
6' I believe the man's name was Baker, or Mr. Baker brought 7 .' word over that they wanted to see me over there.
8 c0 Who is Baker?
9 A Mr. Baker is -- I don't know what his title is; but they 10 brought him in from Ohioapproximately in September,
! 11 October of '85, and he took over as one of the
(]) 12 supervisors. ,
13 Q All right, sir.
( ,
14 He called you?
15 A He was a weld supervisor, if I'm not mistaken.
16 Q All right.
t x 17 Through Mr. Baker you were told that Mr. Simile t 18 wanted to see you?
l 19 A Yes, that Mr.. Simile or Mr. --
t 20 JUDGE GROSSMAN: Through Mr. Simile you were o -
! 21 told that Mr. Baker wanted to see you?
~
22 sTHE WITNESS: No. Mr. Baker told me that Mr.
23 Simile wanted'to see me.
24 JUDGE GROSSMAN: Oh, I see. Okay.
p O 25 A (Continuing.) And when I got over there, I went in to l
l Sonntag Reporting Service, Ltd. "~
Geneva, Illinois 60134 -
(312)* 232-0262
8616 l
O 1 see Mr. -- anyway, he says, "This is all a mistake."
2 BY MR. GUILD:
3 0 You can't remember the name of the person who --
4 a No, I can't remember the name of the person.
5 Q Can you describe the person's position? What job did 6 he hold?
7 A Yes, I'm pretty sure he was in charge of the training 8 program.
9 Q All right.
10 A He says, "It's all a mistake"; and that was the first 11 time that I had ever seen an evaluation on me.
12 All right.
(]) '
Q ,
13 What did he tell you was a mistake?
14 A Oh, he said, "You got one of the highest, if not the 15 highest, accept-reject scoring." You know, he said, 16 "You have one of the highest" --
17 Q Do you know whether or not your acceptance rate was 18 expressed in terms of a percentage of the work that was 19 reinspected?
l 20 A Oh, yes, yes.
21 Q And what --
22 A Well, as far as overall inspection.
23 Q All right.
24 And what was the percentage that you understood you O 25 scored in the PTL overinspection?
Sonntaa Reporting Service, Ltd.
l Geneva, Illinois 60134 l
(312) 232-0262
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1 A 99.25.
2 Q All right.
3 And do you understand -- do you have any 4 understanding of how that compared to other Weld 5 Inspectors?
6 A I think it was a little bit higher than anyone else.
7 Q All right, sir.
8 That was the substance of whoever this 9 supervisor --
10 A Yes.
l 11 0 -- was informed you?
12 A Right, right, that's true.
(])
13 Q All right.
14 Were you ever otherwise reprimanded or counseled 15 because of a poor or rejectable qual!.ty weld inspection 16 work?
17 A No, I wasn't.
la Q Okay.
f 19 JUDGE GROSSMAN: I'm sorry.
/
20 Is that 99 something percent good or bad?
21 .- I don't think that's clear from the questioning.
22 THE WITNESS: 99.25 good.
23 JUDGE GROSSMAN: Okay.
- i 24 BY MR. GUILD:
O 25 Q Of the welds that PTL overinspected of your work --
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
8618 O
1 A Right.
2 0 -- they found 99.25 percent acceptable?
3 A Right; criteria that -- that PTL used as far as whether 4 my welds was acceptable or rejectable.
5 0 Okay.
6 The degree to which you acceptably performed your 7 inspection work --
8 A Right.
9 Q -- called it correctly?
10 MR. GUILD: Mr. Chairman, I would at this 11 time move for the admission of Intervenors' Exhibits 67 O 12 and 68.
13 MR. GALLO: No objection.
14 MR. BERRY: No objection.
15 JUDGE GROSSMAN: Received.
16 (The documents were thereupon received 17 into evidence as Intervenors' Exhibits 18 Nos. 67 and 68.)
l l
19 BOARD EXAMINATION 20 BY JUDGE GROSSMAN:
I 21 Q By the way, I'm not sure.
l 1 22 When you had gone back to the welds, I believe you l
23 indicated that you had told those people that the welds l
1 24 were in inspectable condition when you had inspected O 25 them; is that correct?
Sonntaq Reporting Service, Ltd.
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1 A I said all attachment welds was -- met the criteria for 2 inspection.
3 Q Okay.
4 What did they say to you at that time?
5 A Oh, they said, "How could it, how could it, the paint on 6 it, the paint on it? Your stamp is through the paint."
7 Q Okay.
8 So they disagreed agreed with you at that time?
9 A Yes.
10 JUDGE GROSSMAN: Okay.
11 DIRECT EXAMINATION
() 12 (Continued.)
13 BY MR. GUILD:
14 Q And who is "they"? Who are you referring to as they?
15 A Tony Simile.
16 I don't think maybe the Commonwealth Edison man 17 made the remark or anything like that.
18 Q All right.
19 Now, in the body of your letter, Exhibit 68 in 20 evidence, you refer, on the second page, to a standard.
21 The quote is, "Have you studied NCIG-Ol Section 2, 2.1 22 and 2.2 or does this apply to the Braidwood job?"
23 What does that refer to, Mr. Hunter?
24 A Okay. The NCIG-Ol was a -- an inspection criteria that O 25 I believe it was 13 utilities got together and said, l
Sonntaq Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
8620 0
1 "We're costing us top money te everybody inspect to a 2 certain standard, so let's standardize the inspection."
3 So what they did --
4 Q All right.
5 A -- they wrote up this very short, but straightforward 6 inspection criteria or guide, and if I'm not mistaken, 7 Commonwealth Edison accepted it, and was to implement it
- 8 into the procedures for the QC Department at Braidwood.
9 Q All right.
10 And is this a guide for the interpretation of the 11 AWS Dl.1 welding code?
12 A Yes, this has to qualify under AWS Dl.1 in order to be
(])
13 used by the Nuclear Regulatory Commission.
, 14 Q So it's an interpretation of Dl.1; is that right?
15 A No, it's not an interpretation.
16 0 What is *he relationship of Dl.1, if you know?
17 A I would say that it was just a companion to Dl.1 --
18 Q All right.
19 A -- AWS Dl.l.
20 Q Did it replace Dl.1 as an acceptable criteria?
21 A No, I don't think it can replace it.
22 Q All right, sir.
23 Mr. Hunter, let me show you an extract from that 24 document, the relevant portions that you referred to in O 25 your letter to Mr. Skidmore, which I ask be marked for Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
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1 identification as Intervenors' Exhibit 69. j 2 (Indicating.)
l 3 (The document was thereupon marked J 1
4 Intervenors' Exhibit No. 69 for 5 identification as of July 23, 1986.) ;
1 6 BY MR. GUILD:
7 Q Mr. Hunter, I wanted to show you the original of this 8 document.
9 The copies that have been marked for identification 10 have some highlighting on them that obscures the 11 language in phrts of it.
12 Did you highlight this document?
(])
13 A I highlighted this myself.
14 Q Okay.
15 Now, the portions that you cite to in your letter 16 to Mr. Skidmore are the general inspection guidelines 17 portion, Paragraphs 2.0, .1 and .2, are they not?
I 18 A That's correct.
! 19 Q All right.
20 And what -- what was the import or purpose of your 21 reference to these guidelines in your communication with 22 Mr. Skidmore?
l 23 A Whether I actually met the criteria as far as visual 24 inspection, whether I accepted or rejected a -- an 25 acceptable or rejectable item through visual Sonntaq Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
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1 examination.
2 Q All right.
3 What was the relevant portions, in your opinion, of 4 this guideline to that issue?
5 A Cn 3 -- on 2.2, Page 2 of 2, the third paragraph.
6 Q All right.
7 Can you read the first line of it?
8 A "The visual examination relies on the Inspector's 9 ability to detect the condition being checked using his 10 normal eyesight."
11 Q All right.
12 A "If a condition is so small that its relevance cannot be
(])
13 determined with ordinary eyesight, the condition is 14 acceptable."
15 0 All right. ,
16 A Okay.
17 And on the top of the page, it says, " Visual 18 inspection of welds is normally performed on the 19 as-welded surface. Surface conditioning by grinding, 20 buffing, filing and so forth is usually not required."
21 Q All right, okay.
22 Are there any other portions of these NCIG 23 guidelines, acceptable criteria for visual inspection, 24 that you were referring to in your Skidmore letter that O 25 you believe are~ relevant?
l Sonntag Reporting Service, Ltd.
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V 1 A Just the -- just the -- on 2.1, the third paragraph, 2 "Second-guessing has occurred because some people have a 3 different understanding of the meaning of the acceptance 4 criteria."
5 Q All right, sir.
6 MR. GUILD: Mr. Chairman, I would ask that 7 Intervenors' Exhibit 69 be received into evidence.
8 MR. GALLO: May I conduct some voir dire?
9 JUDGE GROSSMAN: Yes, you may.
10 VOIR DIRE EXAMINATION i 11 BY MR. GALLO:
() 12 Q Mr. Hunter, if I understood one of your answers to 13 counsel's questions, that you had provided the 14 highlighting that is shown on these two sheets; is that 15 correct? .
16 A Yes, I did.
17 Q And when did you do that highlighting?
18 A When did I do that?
19 0 Yes.
20 A Probably in September of '85.
21 0 September of '85 you did that highlighting.
22 And where did you obtain these two pages from?
23 A It was given -- oh, the whole -- the whole package was 24 given to us in the office of Commonwealth Edison l
() 25 whenever they presented this little program, and I'm --
l l Sonntaq Reporting Service, Ltd.
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1 I'm pretty sure it was probably September of '85.
2 MR. GUILD: Counsel, there's a date on the 3 face of the document, if it would help.
4 MR. GALLO: Yes. The document says October 5 of '85.
6 THE WITNESS: Well, maybe it was October.
7 BY MR. GALLO:
8 Q Now, could you tell me again how you came to be in 9 possession of these two pages in October of '85?
10 A Yes. The whole package was given to me.
! 11 MR. GUILD: Counsel, I'll stipulate that I
() 12 made a Xerox of only the relevant portions th'at were
- 13 cited in the Skidmore letter.
14 I have the entire document, if you would like to i 15 examine it.
16 BY MR. GALLO:
17 Q And who gave you the whole package?
18 A The people who presented the program there in the office 1
- 19 at Commonwealth Edison.
l .
20 Q was this a training session?
21 A It was a training session; right.
l 22 Q Did Commonwealth Edison representatives conduct the 23 training?
24 A I'm sure they did, yes.
O 25 0 Well, did they or didn't they?
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1 A I'm sure they did.
2 I -- the man's name I don't know, but I'm sure he 3 was -- he was an employee.
4 Q And it was your understanding that it was Commonwealth 5 Edison?
6 A That was my understanding.
7 Q And did he -- were there more -- was it just yourself in ,
8 attendance or was there a number of Comstock QC 9 Inspectors?
10 A Oh, there was a number of us.
11 Q Did each one of the Inspectors, including yourself, get 12 a copy of this NCIG-Ol?
(])
- 13 A I'm sure they passed it out to everyone.
i 14 Q How did you come by this yourself?
15 A They passed it out to us.
16 0 And you got it in that fashion?
17 A Yes.
18 Q And what was your understanding of what the purpose of 19 this training manual was?
20 A To standardize the techniques that was used in 21 inspection on utility construction jobs.
l 22 0 And, to your knowledge, was this guide incorporated into l
23 the Comstock weld inspection procedures?
l 24 A Yes, it was.
O 25 0 It was.
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1 To your knowledge, was this guideline in ef fect and 2 used by you at the time of your reinspections in March 3 of 19867 4 A It was in the procedures at that time, I'm pretty sure.
5 Q You are pretty sure that it was in the procedures at 6 Copmstock?
7 A Right.
8 I don't have the procedure with me, but I'm pretty 9 sure it was, yes.
10 Q So it's your testimony that this procedure was in effect 11 and applicable at the time of the -- well, what I will 12 refer to as the controversy over the painted hangers and
(])
13 the painted welds?
14 A Yes, it's my understanding that Commonwealth Edison 15 accepted this and the NRC.
16 Q Now, that's not my question.
17 My question is:
38 Was it your understanding that this guide -- these 19 guidelines were in effect at the time that you did the 20 inspections -- or the reinspections involving the 21 painted welds in March of 19867 22 A Yes, yes.
23 Q Did you provide this two-page document to Mr. Skidmore 1 24 at the time you wrote your letter that's entitled, "To O 25 whom it may concern," Intervenors' 687 l
{
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1 A I didn't write him a copy; no, I never.
2 Q You didn't provide him a copy?
3 A No, I didn't.
4 Q What caused you to do the highlighting that you -- that 5 you -- that you have indicated on these two pages?
6 A I thought that was the high points of -- of each of the 7 paragraphs that -- that the -- if you will notice, the 8 first highlight was, "Because of" - "because of the 9 numerous levels of inspection in the nuclear industry, 10 some inspectors may be concerned about being second 11 guessed. In an effort to assure all welds are 12 acceptable at all levels of inspection, an inspector may
(]) '
13 decide it is easier to reject any condition that is 14 questionable or not obviously acceptable. Using this 15 approach, an inspector may feel he is doing the best job i
16 possible. However, any inspector is not performing his l 17 job properly when acceptable welds are rejected."
18 Q All right.
19 Did you do -- I don't recall now.
20 Did you do the highlighting during the course of 21 this meeting that took place in September?
22 A Some of it I did, yes; some it I'm sure I did, yes.
23 0 Did you do any of it later on, do you recall?
24 A I'm sure they went through the procedures, I picked out
() 25 the points that should be made, like continuous l
l l
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! Geneva, Illinois 60134 l (312) 232-0262
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1 measurement, the full length weld is neither required 1
2 nor --
3 Q I'm just asking you as to when you did it.
4 Was it in September or October, 1985?
5 A Well, if this -- if this come out in October, it was in 6 October, instead of September, but I think the program
- 7 was given in September.
8 Q Was that the time --
9 A I don't have the notes with me.
i 10 Q But it was at the time that you came into the possession 11 of the document?
12 A That was the time.
(])
13 MR. GALLO: All right.
14 I have no objection.
15 JUDGE GROSSMAN: Any objection?
i 16 MR. BERRY: No objection.
17 JUDGE GROSSMAN: Received.
18 (The document was thereupon received into 19 evidence as Intervenors' Exhibit No. 69.)
i 20 JUDGE GROSSMAN: It is late.
21 Okay. We'll --
22 MR. GUILD: Yes, sir.
1 l 23 JUDGE GROSSMAN: -- recess, then, until 24 tomorrow at 9:00 o' clock.
O 25 THE WITNESS: At what time?
Sonntag Reporting Service, Ltd.
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8629 1 JUDGE GROSSMAN: 9:00 o' clock.
2 (WHEREUPON, at the hour of 5:10 P. M., the 3 hearing of the above-entitled matter was 4 continued to the 24th day of July, at the 5 hour of 9:00 o' clock A. M.)
6 7
8 9
10 11 12 C)
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15 16 l
17 18 19 20 21 I
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23 24 O 25 Sonntaa Reporting Service, Ltd.
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NO PAGE NUMBER CERTIFICATE OF OFFICIAL REPORTER j~\
x,))
\
This is to certify that the attached proceedings before the UNITED STATES NUCLEAR REGULATORY COMMISSION in the matter of:
NAME OF PROCEEDING: BRAIDWOOD STATION UNITS 1 42 COMMONWEALTil EDISON COMPANY (EVIDENTIARY llEARING)
DOCKET NO.: 50-456/457-OL PLACE: JOLIET, ILLINOIS DATE: WEDNESDAY, JULY 23, 1986 were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission.
( siert ) 3%dN (TYPED) U Gary L. Sonntag Official Reporter Reporter's Affiliation
,n v
m