ML20205T735
| ML20205T735 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 06/12/1986 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| CON-#286-622 OL, NUDOCS 8606160184 | |
| Download: ML20205T735 (243) | |
Text
OWGNAL UN11ED STATES O
NUCLEAR REGULATORY COMMISSION IN THE MATTER OF: DOCKET NO: 50-456 OL 50-457 OL COMMONWEALTH EDISON COMPANY (Braidwood Station, Units 1 & 2) l l
LOCATION: JOLIET, ILLINOIS PAGES: 3935 - 4177 DATE: THURSDAY, JUNE 12, 1986 g oI f 0;/
l ACE-FEDERAL REPORTERS, INC.
OfficialReporters 444 North Capitol Street 8606160104 86061g Washington, D.C. 20001 PDR ADOCK O S OOO 4 S c> (202) 347-3700 T pcp NATIONWIDE COVERAGE 1
3935 1
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 OL COMMONWEALTH EDISON COMPANY : 50-457 OL 7 :
(Braidwood Station, Units 1 :
8 and 2) :
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x 9
10 Page: 3935 - 4177 11 College of St. Francis 500 North Wilcox 12 Joliet, Illinois 13 Thursday, June 12, 1986.
14 The hearing in the above-entitled matter reconvened 15 at 9:00 A. M.
16 17 BEFORE:
18 JUDGE HERBERT GROSSMAN, Chairman Atomic Safety and Licensing Board 19 U. S. Nuclear Regulatory Commission Washington, D. C.
l 20 t
JUDGE RICHARD F. COLE, Member, 21 Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission 22 Washington, D. C.
23 JUDGE A. DIXON CALLIHAN, Member, Atomic Safety and Licensing Board 24 U. S. Nuclear Regulatory Commission Washington, D. C.
25 APPEARANCES:
[}
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( y On behalf of the Applicant:
2 MICHAEL I. MILLER, ESQ.
3 JOSEPH GALLO, ESQ.
ELENA Z. KEZELIS, ESQ.
4 Isham, Lincoln & Beale Three First National Plaza 5 Chicago, Illinois 60602 6 On behalf of the Nuclear Regulatory Commission Staff:
7 ELAINE I. CHAN, ESQ.
8 GREGORY ALAN BERRY, ESQ.
U. S. Nuclear Regulatory Commission 9 7335 Old Georgetown Road Bethesda, Maryland 20014 10 On behalf of the Intervenors:
11 ROBERT GUILD, ESQ.
12 CE) 14 15 16 l 17 1 18 19 20 l
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22 23 24
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1 EXHIBIT INDEX Marked Received Applicant's Exhibit No. 24 3966 4053 2 Applicant's Exhibit No. 25 3984 4053 Applicant's Exhibit No. 26 3989 4053 3 Applicant's Exhibit No. 27 3997 Applicant's Exhibit No. . 28 4053 4 Applicant's Exhibit No. 29 4079 Applicant's Exhibit No. 30 4095 5 Applicant's Exhibit No. 31 4115 Applicant's Exhibit No. 32 4118 6 Applicant's Exhibit No. 33 4136 Applicant's Exhibit No. 34 4143 7 Applicant's Exhibit No. 35 4147 Applicant's Exhibit No. 36 4149 8 Applicant's Exhibit No. 37 4160 Applicant's Exhibit No. 38 4165 9 Applicant's Exhibits 28 and 30 through 38 4175 10 TESTIMONY OF RICHARD ALLEN SNYDER 11 12 DIRECT EXAMINATION 13 O's / BY MR. MILLER 3946 14 BOARD EXAMINATION 15 BY JUDGE GROSSMAN: 4063 DIRECT EXAMINATION (Continued) 16 BY MR. MILLER: 4063 BOARD EXAMINATION 17 BY JUDGE GROSSMAN: 4067 DIRECT EXAMINATION (Continued) 18 BY MR. MILLER: 4068 BOARD EXAMINATION 19 BY JUDGE GROSSMAN: 4084 DIRECT EXAMINATION (Continued) 20 BY MR. MILLER: 4085 BOARD EXAMINATION 21 i BY JUDGE GROSSMAN: 4092 DIRECT EXAMINATION (Continued) 22 BY MR. MILLER: 4095 BOARD EXAMINATION 23 BY JUDGE GROSSMAN: 4102 DIRECT EXAMINATION (Continued) 24 BY MR. MILLER: 4102 BOARD EXAMINATION 25 BY JUDGE GROSSMAN: 4109
{} DIRECT EXAMINATION (Continued)
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1 BY MR. MILLER: 4114 BOARD EXAMINATION 2 BY JUDGE GROSSMAN: 4121 l 3 J
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3938 O 1 JUDGE GROSSMAN: The hearing is reconvened.
2 This is the 19th day of hearing.
3 I believe we are going to start with Mr. Snyder, 4 the QC Inspector.
5 Is that correct, Mr. Gallo?
6 MR. GALLO: Yes.
1 7 My colleague, Mr. Miller, will be conducting the 8 examination.
9 JUDGE GROSSMAN: Mr. Miller, would you call 10 your witness, then, please?
11 MR. GUILD: Mr. Chairman --
12 MR. MILLER: There is one preliminary matter 13 that Mr. Guild and I have discussed. It relates to the
[}
14 protective order that the Board issued.
15 I think all the parties would like to continue to 16 observe the requirements of that order with respect to 17 testimony, should the witness -- any witness -- desire 18 it.
! 19 Mr. Guild and I discussed whether or not it would I
20 be appropriate for the Board, when each QC Inspector is i 21 called as a witness, to state to them that, should they 22 believe that they are about to divulge information which 23 is confidential, that they should so indicate or tell 24 the Board and we can then make a determination as to the
- 25 nature of the information and appropriate protection i ()
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3939 O 1 with respect to the transcript and any exhibits that 2 were involved could occur.
! 3 JUDGE GROSSMAN: Is that correct, Mr. Guild?
4 Do you agree?
5 MR. GUILD: Let me state my position, Mr.
6 Chairman, as to the proposal that I think is 7 appropriate.
I 8 The outstanding protective order that Intervenors 9 sought covers a nar row class of information.
l 10 Essentially, it's names and identifying information that
} 11 come from Intervenors that relate to the three NRC 12 memoranda regarding the March 29th meeting.
[} 13 14 Essentially, they are the fact that certain named inspectors gave certain statements to the Nuclear 15 Regulatory Commission at that time. It's the connection l 16 between the name and the specific facts.
l 17 By agreement of the parties, where the individuals
- 18 desired it -- and those are 11 of the 16 named persons 19 in the unexpurgated ve rsion of the April 5th memo -- the 20 parties have extended that protection, although it's 21 beyond the formal scope of the order, to the deposition 22 testimony of those same persons.
23 Now, the order never reached beyond that, those
! 24 three memoranda; and it's only the agreement of the 4
25 parties that has taken it one step further.
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3940 1 We never contemplated the issue of testimony and 2 reach of that order to testimony, but now we are at this 3 Juncture; and I think all the parties are in agreement 4 that it's appropriate that when one of the 11 who sought 5 confidential treatment takes the stand, that it would be 6 appropriate for the Board to simply advise that witness 7 that up to this point confidential treatment has been 8 extended for that information and should they desire on 9 ,
the basis of some cause that confidential treatment be 10 afforded to their testimony in this proceeding, they 11 have a right to ask for it.
12 At that point I would suggest that an off the 13 record or in camera discussion take place, where the 14 Board and the parties reach some kind of -- the Board 15 assure itself that such protection is appropriate and if 16 it's appropriate, it be granted.
17 I don't know whether or not, in fact, anyone will 18 ask for such treatment. I simply believe that in order 19 to make the previous protection meaningful, that such an 20 opportunity ought to be extended to the witness.
21 MR. BERRY: Mr. Chairman.
22 JUDGE GROSSMAN: Mr. Berry.
23 MR. BERRY: The Staff agrees with what has 24 been said by the Applicant and the parties.
25 We would just note that generally transcripts --
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3941 4 ]\ 1 hearing transcripts -- received by the Staff are often 2 the subject of FOI requests and are placed in the public 3 document room.
4 So Staff would have a particular interest in 5 knowing what items or information the witness would seek 6 to have remain confidential so we can endeavor to make 7 sure that that information is kept out of the public 8 document room.
9 But in the whole we are in general agreement with 10 what has been said.
11 JUDGE GROSSMAN: We are not going to make a 12 selective determination on bits of testimony. We are 13 either going to decide that the testimony is going to be
)
14 in camera for that witness or it won't be; but it's 15 impractical to go and expurgate portions of testimony.
16 So if we decide beforehand that the testimony would
! 17 be confidential and pursuant to an extension of the 18 protective order, we will just ask the Reporter to take 19 it in camera and not to have that transcript of that 20 particular witness's testimony in the public document 21 room and be treated as confidential.
22 I can't see any -- is there any other practical way 23 of doing it?
24 MR. GUILD: I think there is, Mr. Chairman.
25 I think the class of likely protected information
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1 is a very narrow one.
2 I really think the only scope of protection is:
3 Did you go to the NRC on that date or do you know of 4 others that went to the NRC on that date?
5 To the extent that it requires the witness to, 6 essentially, divulge what has been treated in confidence 7 -- and that is the fact that they or others went on that 8 date by name -- then that information, it seems to me, 9 is narrow and a question is apparent when asked that 10 that can be maintained.
11 JUDGE GROSSMAN: So we are going to get it 1
12 all at one place.
r~% 13 Are we going to examine and cross examine with
(_)
14 regard to that particular item so we can tell the 15 Reporter at that juncture that until we tell him 16 otherwise, those few pages will be in camera?
17 Is that what I understand the agreement to be?
18 MR. MILLER: Well, we hadn't contemplated 19 that but I think it is a good suggestion.
20 MR. GUILD: It can be done, Judge.
21 MR. MILLER: There would be examination of 22 Mr. Snyder, for example, by me.
23 If some information that was otherwise protected 24 was going to be divulged, at that point go in camera and 25 any Cross Examination or Board questions on that narrow
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3943 O' 1 issue would take place and then I would just simply 2 resume my examination.
3 I think that would ease things for the Reporter and 4 make it an identifiable number of pages in the 5 transcript all together.
6 JUDGE COLE: Are we going to have a separate 7 transcript volume?
8 JUDGE GROSSMAN: Yes, it will be a few pages 9 of transcript. If I understand what you are proposing, 10 that's the only practical way of doing it.
11 Thereafter, I would expect that you would ask 12 questions without using names for what is going to be 13 public, though, you know, you might further have 14 occasion to ask that some further testimony be treated 15 in camera, also.
16 I mean, we are not going to limit you to just one 17 chance with each witness, just on things that might come 18 up later, but try to keep that to a minimum.
19 Yes, Mr. Guild. l 20 MR. GUILD: Let me just put one other thought 21 on the record.
22 Essentially, the only facts that I see within the 23 reach of this potential protection are, again, the 24 identifying information about who went.
25 I don't see any problem with putting in an in C)
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k- 1 camera copy of the April 5th memorandum, which 2 establishes, at least as a fact, names connected with 3 complaints and treating that -- continuing to treat that 4 -- in a sense as a protected document, the unexpurgated 5 version.
6 I have no desire to ask any of these witnesses who 7 else went or whether you went, so I am simply 8 anticipating that, perhaps, Applicant or the Staff may 9 have a desire to ask those questions.
10 Should they ask those questions, the answers might 11 be protected should the witness choose to seek 12 protection of that information.
13 Now, a simple answer is all you have got to do is 14 take the -- if it's a matter of establishing the fact of 15 who went to the NRC on that date, it's simply a matter 16 of taking that April 5th memo, making that an exhibit,
! 17 but a protected exhibit.
18 So long as none of the other parties need to 19 inquire beyond that, there may be no need for any 20 further in camera treatment of live testimony.
21 JUDGE GROSSMAN: Well, that would be 22 acceptable to us; but then it would be up to counsel as 23 to whether they want to pursue it that way.
24 MR. MILLER: One of the problems -- that 25 would work for one of the memos.
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's 1 One of the other memos has been coded by the NRC 2 inspectors who conducted the interview in such a way as 3 to make it very difficult, without asking very specific 4 questions of each individual who attended, who said what 5 on that day. i 6 JUDGE GROSSMAN: Okay.
7 MR. GUILD: That could be solved, it seems to 8 me.
9 I think Mr. Miller is right. That is a slightly 10 broader problem; but, nonetheless, it seems to me if we 11 do what I suggest, which is taking the April 5th memo 12 in, we have solved, at least, the vast part of the 13 problem.
)
14 Then, perhaps, if Mr. Miller need ask, it would 15 only apply to the six, as I understand it, who were the 16 subject of the first memo where there was the 17 identification Inspector X, A, B, C, et cetera. That's 18 six peopic.
i 19 JUDGE GROSSMAN: Well, okay. Counsel, 20 apparently, think they have a handle on this and can 21 work it out; and we have no objection to cooperating 22 with regard to confidentiallity.
23 So when the time is appropriate, Counsel will just l 24 mention it and we will take the necessary action.
25 Okay. Is there anything further on these
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3946 O 1 prelimina ry matte rs?
2 MR. MILLER: No, sir.
3 JUDGE GROSSMAN: Mr. Miller, would you please 4 call your next witness?
5 MR. MILLER: Yes. I would like to call Mr.
6 Richard Snyder. Mr. Snyder is seated at the witness 7 table.
8 Mr. Snyder, the Chairman will swear you, if you 9 would stand.
10 JUDGE GROSSMAN: Mr. Snyder, would you stand 11 please, raise your right hand.
12 (The witness was thereupon duly sworn.)
{} 13 14 JUDGE GROSSMAN: Okay.
RICHARD ALLEN SNYDER Please be seated.
15 called as a witness by the Applicant herein, having been 16 first duly' sworn, was examined and testified as follows:
17 DIRECT EXAMINATION 18 BY MR. MILLER 19 Q Mr. Snyder, we have met before. My name is Mike Miller.
20 I am one of the attorneys for Commonwealth Edison 21 Company.
22 Would you state your name for the record, please?
23 A Richa rd Allen Snyde r.
24 Q What is your current business address, Mr. Snyder?
25 A Business address, Braidwood Station, Braidwood, O
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2 Q The --
3 A I am not sure of the exact address there.
4 Bracev ille , Illinois, I believe is the address.
5 0 Thank you.
6 By whom are you currently employed, Mr. Snyder?
7 A BESTCO, which, I believe, is Brand Examination Service 8 Testing Company, something like that.
9 0 What are your duties at BESTCO?
10 A I am a Quality Control Inspector, namely calibrations 11 inspection.
12 Q Are you assigned to a specific scope of work at the
(~T 13 Braidwood Station by BESTCO?
U 14 A Not by BESTCO, no. I think Comstock actually hands the 15 work out, so to speak.
16 0 Is it correct that you conduct calibration inspections 17 for Comstock, although you are employed by BESTCO?
18 A That's true.
19 Q All right. How long have you been employed by BESTCO, 20 sir?
21 A Since July 2nd of '84.
22 Q All right. You may be off a year.
23 July 2nd of '84 by BESTCO?
24 A Excuse me. I was thinking -- that's right.
25 BESTCO, July 23rd, I believe, or 24th of '85. I am O
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1 sorry.
2 Q All right. Prior to that time by whom were you 3 employed?
4 A By Comstock.
5 Q Was that also as a Quality Control Inspector?
6 A Yes, sir.
7 Q When were you first employed by Comstock?
8 A July 2, '84.
9 Q That was at the Braidwood site?
10 A Yes, sir.
11 Q Prior to your employment by Comstock, by whom were you 12 employed, Mr. Snyder?
13 A I worked at Marble Hill nuclear plant,for Cherne 14 Contracting Corporation.
15 0 What was the scope of work of Cherne Contracting at 16 Marble Hill?
4 17 A I was a Receipt Inspector, training in calibrations at 18 the time the plant shut down.
19 0 All right, sir. What work did your employer do? Were 20 they the electrical?
21 A They were the piping contractor.
22 Q For how long had you been employed by Cherne Contractors 23 at Marble Hill?
24 A I started there December of '81 and I was terminated or 25 laid of f -- excuse me -- January of '84.
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} 1 When had you begun your training as a calibration Q
2 inspector at Marble Hill?
3 A I think I had four months training, which would have 4 made it probably August of '83.
5 Q How far along were you towards being certified as a 6 Calibration Inspector at Marble Hill?
7 A They required six months training. I believe that was 8 the owner's requirement, Public Service of Indiana.
9 Q Now, when you were working at Marble Hill, could you 10 just describe briefly the types of tools that the 11 calibration inspection function looked at?
j 12 A Probably our No. I was torque wrenches, rod cans, rod 13 ovens, which the welders used to store the rods in,
)
14 various measuring and test equipment, calipers, 15 micromete rs, oxygen analyze rs.
16 Q When you were hired by Comstock at Braidwood, were you 17 hired for a specific position, to your knowledge?
18 A Not to my knowledge, no, sir.
19 I was just hired as a Level 2 Inspector. I had no 1
20 idea where I was going to be, what I was going to be 21 trained in or inspecting.
22 Q All right. Did you submit a resume to Comstock?
23 A Yes, sir.
24 0 So they were aware of your prior experience, were they 25 not?
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('3/ 1 A Yes, sir, they had that.
2 Q When you came to Comstock, the first few days of your 3 employment there, who assigned you, if anyone did, to 4 the calibration area?
5 A Well, it was more than a few days. It was probably two 6 or three weeks; but I would say my supervisor, Rick 7 Saklak, at the time.
8 Q Prior to that time, what were your duties?
9 A Just reading, normal indoctrination to the Comstock 10 program.
11 Q When Mr. Saklak assigned you to the calibration area, 12 - did he tell you that, in eff5ct, you would have to have 13 specific training in the calibration inspection 14 procedures and techniques and so on?
15 A Yes, sir. I was assigned. I was given the job of 16 training -- well, I was a trainer, I guess -- trainee, 17 excuse me.
18 I was being trained by another inspector who was 19 running that department at the time.
20 Q Did Mr. Saklak specifically assign you to that other 21 inspector for your training?
22 A Yes. John Seeders was the other inspector. He was the 23 only man in that department and he would be the one to 24 train anyone else.
25 Q Prior to the time that you were assigned by Mr. Saklak n
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1 to work with Mr. Seeders as a trainee, had you had 2 occasion to look at the calibration procedure for L. K.
3 Comstock at the Braidwood site?
4 A I had occasion to. I am not -- I don't know that I did.
5 It would have been available if I wanted to.
6 I couldn't say whether I did or not.
7 0 Well, af te rwards, af ter you were assigned to Mr.
8 Seeders, did you then look at and study the calibration 9 inspection procedure?
10 A Yes, sir.
11 Q All right. What else did your training consist of?
12 A Commonwealth Edison had just set up a new program, a 13 training program; and this was the first phase of it. I 14 believe I was the first inspector that was trained in 15 calibration for quite some time.
16 But it required 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of on-the-job training, 17 one hour of formal lecture -- I am getting these kind of 18 turned around; but first one hour of formal lecture, 19 eight hours indoctrination and 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of on-the-job 20 training and then you would have to take a practical --
21 a written practical -- and a practical test in the 22 field.
23 Q I think you said there was a one-hour formal lecture.
24 Who conducted that lecture, do you recall?
25 ,
A That was John Seeders or the trainer's function, I O
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2 O What was the subject matter of that one-hour lecture, if 3 you recall?
4 A Basically, just to read the procedure, go over it, any T
5 questions that -- you know, they had an outline made up, 6 I believe, at that time just to kind of follow; but, 7 basically, all that was done was to read the procedure 8 with the certified inspector and answer any questions.
9 Q Can you recall -- and I know it's a while ago, almost 10 two years; but can you recall whether, when you looked 11 at the procedure, you had any questions of Mr. Seeders 12 regarding its content or interpretation?
{) 13 14 A I don't recall any.
I did have the opinion, maybe, that there was some 15 vagueness of how to go about some calibrations of 16 certain tools; and maybe at that time I asked but I 17 can't say for sure positively.
18 Q When you say there was some vagueness, that was as 19 compared to your experience --
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20 A Compared to the Cherne procedures I had worked to or 21 trained to at Marble Hill.
22 Q Can we impose on you to spell Cherne for the record?
23 A C-H-E-R-N-E.
24 0 Thank you.
25 I think you said that there was one hour of formal
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2 A Yes.
3 ~Q And then eight hours of --
4 A An eigh+.-hour indoctrination, in which, basically, we 5 went to the field, looked at the tools that we were 6 going to be working with, maybe even went through a few 7 of them as to how we was going to calibrate them, just 8 familiarization, really.
9 Q All right. And Mr. Seeders took you around to show you 10 the tools and so on?.
11 A Yes, sir.
12 Q The location in the plant?
13 A Yes, sir.
{;
14 0 Was there a specific location where the tools were 15 available for inspection?
16 A Yes, sir.
17 Q How was that identified?
'. 18 A That was in a tool crib. They call it Crib No. 4, LKC l 19 Crib No. 4, up on elevation 426 in the Aux Building at j '. . '
20 the plant.
21 Q Maybe you can describe for the record what a tool crib l 22 ,
consists of or what that tool crib consisted of?
23 A Yes. Well, that's where the men _ issue out tools daily 24 to the craf t men.
f 25 They generally put older gentlemen in there that s,
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3954 O 1 are waiting on retirement or whatever so that they can 2 hand out the tools that are required daily to do the job 3 and also hand out calibrated tools, torque wrenches, et 4 cetera, when the men need them.
5 0 What were the tools that were subject to the calibration
, 6 inspection program at Comstock when you got there in 7 July of 1984?
8 A They were, again, torque wrenches, wire -- lug crimpers, i 9 wire strippers, rod ovens, weld machines and a few other 10 measuring and testing items like micrometers and 11 calipe rs.
i 12 Q Would you just describe briefly for us the nature of the
{) 13 14 calibration inspection on a torque wrench?
That is, what is it that is being calibrated?
15 A It's just to verify the wrench.
16 The wrench has a dial on it that shows you when the 17 proper torque -- when you have attained the proper l 18 torque in the field; but that accuracy has to be 19 verified monthly per the Comstock procedure, to assure 20 that the men have an accurate tool in the field to do 21 the proper job.
22 Q All right. What is a -- I think you said a lug --
23 A A lug crimper or wire crimper, I think, either way.
l 24 It's just they strip the wire back an eighth of an 25 inch and have to slip a lug on there to terminate this,
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3955 1 to land this wire on this terminal board or piece of 2 equipment.
3 The crimper actually crimps the lug onto the end of 4 the wire so that it makes a tight connection.
5 0 A crimper, in my uneducated eyes, would it resemble a 6 pair of pliers, in a sense?
7 A Basically. It has various sizes that it can crimp. I 8 mean, it will only go so far.
9 It won't go like a pair of pliers all the way 10 closed, so it won't crush the lug. It will only close 11 so far.
12 0 What is the nature of the calibration inspection for a A 13 crimper?
V 14 A We have a set of calibrated --
15 MR. GUILD: Mr. Chairman, I would ask that 16 counsel route his questions in some time frame, since 17 variations in practice and procedure may be material to l 18 the answer.
19 MR. MILLER: Oh, I am sorry. I wanted to do j 20 that.
21 BY MR. MILLER:
I 22 Q When you arrived at the Braidwood site, what was the 23 nature of the calibration inspection for the crimper?
l l 24 A We had pin, various sizes, in thousandths denominations, l
25 that per the manufacturer you -- they call them go,
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3956 O 1 no-go pins. The one size will go and the other pin will 2 not go in the nest, we call it, which is the hole that 3 you are checking.
4 It's a basic check like that.
5 Q The nest is actually the receptacle in the tool?
6 A Yes, right.
7 It's either good or not good. It's a pretty simple 8 check, really.
9 Q All right. Then I think the next tool which you 10 identified --
11 JUDGE GROSSMAN: Excuse me. After you crimp 12 the -- do you crimp a sample lug and then take that lug
{} 13 14 and push it in a hole?
saying?
Is that, basically, what you are 15 -
THE WITNESS: No, sir. That wasn't part of 16 our function at the time; and if we did have a question, 17 you could do that to verify that the lug was crimped 18 prope rly.
19 But per the procedure, all we had t'o do was use the l 20 go, no-go pins; but, actually, that wasn't in our 21 procedure. That was the vagueness that I was referring 22 to.
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3957 O 1 exactly to do that only'; but if I had a. question, I 2 would make a crimp myself.
3 That never really comes about. I have done it a 4 few times, but you could do that.
5 JUDGE GROSSMAN: I see. Thank you.
6 MR. MILLER: Thank you.
7 BY MR. MILLER:
8 Q Mr. Snyder, I think that the next category of tool that 9 you identified was the wire stripper?
10 A Yes, sir.
11 Q Would you again briefly describe what that tool is?
12 A Again, it's -- it looks like a pair of pliers.
(} 13 14 You would put the wire up here and -- I guess you would hold it and it just skins the eighth inch off the 15 end of the wire, so that you can put the lug on.
16 (Indicating.)
17 Now, it has several holes in it for different size 18 wires; and, again, we would use the calibrated pins to 19 size the holes per the manuf acturer's specifications.
20 Q And, again, this was a go, no-go situation?
21 A No, sir. This was an actual size of the hole.
22 Ideal is the manufacturer of these strippers. They
- 23 sent us the literature. They tell us the size that hole 24 should be.
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\# 1 play with, so it can be anywhere in its range. It 2 doesn't have to be a go, no-go. If it's anywhere within 3 that 5 thousandths, the tool is acceptable per the 4 manufacturer.
5 So we actually do size the hole. The last pin to 6 go in, the largest pin to go in that hole would be the 7 size of that hole.
, 8 Q I see. But in order to determine the acceptability of 9 the hole, you use these pins that are supplied by the 10 manufacturer?
11 A They are purchased other than from the manufacturer.
12 Q All right. I see.
r~3 13 I think the next category of tools which you V
14 identified were weld rod ovens?
15 A Yes.
16 Q And we have had testimony on the record. I think those 17 have been described.
18 What is the nature of the calibration inspection 19 per the weld rod oven?
20 A These are portable rod ovens. We also have stationary 21 rod oven; but getting back to the portable rod oven, 22 it's a round can that the welder stores his rod in, and l 23 there is a lid on it.
i 24 We take the lid off, the can is plugged in, heated l
25 up and we set a three-inch diameter calibrated
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3959 1 thermometer in them. A dial thermometer we call them.
2 It's got a stem on them, say, eight inches long that 3 extends down in there and actually records the 4 temperature of that oven.
5 The oven is cycled on and off. They have a red 6 light at the bottom. When the element is heating, the 7 red light is on; when it's cooling off, the light will 8 go off.
9 Now, the way I do them is we --
10 Q If I could -- I am sorry to interrupt you.
11 A Okay.
12 Q But at the time you arrived at the Braidwood site --
(N 13 A Yes.
\~)
14 0 -- how were they calibrated?
15 A The same way as far as I can remember. That's been a 16 couple of years.
17 0 Okay. I am sorry I interrupted you. Please go ahead.
18 A No, that's okay.
, 19 It's just a matter of getting the minimum l
l 20 temperature of the can, when it shuts off we are l
21 watching that light; and as soon as that light kicks 22 back on, it's at its low point but it will continue to l
23 drop 5, 10, 20 degrees; and we actually watch the lowest 24 temperature of that can and record that as a minimum 25 temperature.
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V 1 Q I see. And --
2 A We initially checked the high end, also, when I came 3 there, which they later found out wasn't necessary.
4 We just wanted to know the minimum temperature.
5 Q All right. I think you said that Mr. Seeders took you 6 around and showed-you these various tools --
7 A Yes.
8 0 -- and their location?
9 A Yes.
10 0 Let me back up and just ask a question about the tool 11 crib.
12 Is there a -- I think you said that there is an
(^T 13 individual who hands out tools to the craft.
V 14 At Tool Crib No. 4 is that or when you arrived at 15 Braidwood was that one individual who was --
16 A No. There were -- let me count them here. They are 17 gone now, some of them.
16 Let's see. I believe there was four men in there.
19 Q So that --
20 A One man to handle the calibrated tools, three men up 21 f ront to hand out the other tools, which there were more 22 number of the other tools and they used them more than 23 the calibrated tools.
24 Q Where physically were the calibration inspections 25 conducted?
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I 1 A They were in the back corner of that crib on a work 2 bench, similar to these tables, maybe longer. That was 3 all we had.
4 Q All right. Now, I think you said the third aspect of 5 your training was 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of on-the-job training?
6 A Yes, sir.
7 Q Would you describe for us what that on-the-job training 8 consisted of?
9 A Well, it was just a matter of me watching over John's 10 shoulders as he performed his calibration.
11 Maybe after he would do the tool, I would do it 12 myself to get the same results. To just practice at it 13 is basically all it was.
14 0 When you say " John," you are talking about John Seeders; 15 correct?
16 A Yes. And I would fill out my own checklists, like he 17 would fill his out.
18 It would be turned in to the Training Department as 19 training.
20 0 I take it from what you have said that the eight hours 21 of indoctrination and t.he 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of on-the-job 22 training were pretty informal and you and Mr. Seeders 23 really were sort of just side by side as this process 24 was going on?
25 A Yes. It was a new program, like I said; and some of the O
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3962 1 people really didn't know how to train other people 2 maybe or they were -- everyone was new at it and they 4
3 didn't know how thorough maybe to be or whatever.
- 4 It was a kind of learn-as-you go thing, you know.
5 Q Did you have an impression as to whether Mr. Seeders was 6 being thorough in his training of you?
7 A I think as thorough as he could be.
8 I got the feeling that -- well, the whole 9 department at that time was reluctant to train other 10 people for fear of losing part of their job or being 11 transferred out, maybe, of that department.
12 Q Did you sense any of that reluctance on Mr. Seeders' J
13 part?
14 A I think so, yes.
15 Q Did he ever say anything to you?
l 16 A Not that I recall, no.
l 17 Q Now, after completing the training that you have 18 described, you then took two tests; is that correct?
19 A Yes, sir, a written test, which was 40 questions, I l 20 believe, and then a practical test, which is an actual
! 21 field calibration that we done on our own with the 22 inspector -- certified inspector -- looking over our 23 shoulder.
24 JUDGE GROSSMAN: Excuse me.
l 25 With regard to that prior question with regard to
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3963 1 Mr. Seede rs ' thoroughness, I understood the question to 2 ask whether he was thorough in performing his own 3 duties; and you answered with regard to thorough as far 4 as training.
5 Is that correct?
6 MR. MILLER: No, that wasn't my intention at 7 this point in time.
8 If my question was vague, I apologize for it. I 9 really was asking about his thoroughness in training Mr.
10 Snyder.
11 JUDGE GROSSMAN: Okay. That's fine.
12 MR. GUILD: That is the way I understood the l 13 question, Mr. Chairman.
14 JUDGE GROSSMAN: All right. I am sorry.
15 Please continue, Mr. Miller.
16 9Y MR. MILLER:
17 Q Again, was it Mr. Seeders that conducted the practical 18 examination for you?
19 A Yes, sir.
20 Q How did you do?
21 A Well, I passed.
22 You have to score 100 percent they call it on a 23 practical, which means no errors. I scored that, 24 evidently, in his opinion and he evaluated me as such.
25 Q In the practical examination did you calibrate -- did O
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3964 O' 1 you inspect the calibration of one tool or more than one 2 tool, do you recall?
3 A I believe at that time we were required to do two 4 acceptable tools, which means a good calibration and one 5 reject tool, which showed the ability that we could find 6 a bad tool in the field.
7 Q Were these all torque wrenches or were they different 8 kinda of tools?
9 A No, sir. You know, I really can't recall. I am sure it 10 was a crimper and a stripper and I couldn't tell you the 11 third tool.
12 Q Okay.
(~g 13 A I really cannot recall.
U 14 Q Can you tell us the date on which you were certified as 15 a Level 2 Quality Control Inspector with a certification 16 in calibration inspections?
17 A Yes, October 8th of '84.
18 Q Is that the date that your papers came through, so to 19 speak?
20 A Yes, sir. That was the date I could start signing my 21 name on a calibration certificate as the -- as a Level 2 22 certified inspector in calibrations. ,
23 Q How much prior to October 8th had you taken the i
24 practical examination?
25 A It was probably early August, I would say.
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3965 1 At that time, e.ga in , the whole training process was 2 slow; and as far as getting certified, it was a drawn 3 out affair; and that's the reason for the lapse of time.
4 0 When did you take your written examination?
5 A I would say the same day I took the practical -- well, 6 it had to have been before the practical, I believe.
7 The written had to come first, I believe, so that's 8 the way it was written.
9 Q And you passed the written test on the first try?
10 A Yes, sir.
11 Q Who administered the written examination?
12 A The Training Department.
13 Q Was that Mr. Dominique?
14 A No, I don't believe he was employed there at that time.
15 I could be wrong.
16 But when I got there the Training Coordinator, Rick 17 Whitehead, had been in a motorcycle accident and he was l 18 off in the hospital and Julie Bullock and Rodney Simms 19 were handling the Training Department at that time, I 20 believe; and they were -- Julie was an inspector and 21 Rodney was a QA inspector, I guess you would call him.
22 MR. MILLER: If I might have just one second 23 to see if some documents that I asked be copied are l 24 here.
25 MR. GUILD: Off the record.
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\2 1 (There followed a discussion outside the 2 record.)
3 MR. MILLER: Mr. Reporter, I would like you 4 to mark as Applicant's Exhibit 24 for identification a 5 document that bears on the f ront sheet the words, 6 " Procedure Tracking Sheet, Procedure 4.9.1, Revision C";
7 and it indicates CECO interim approval December 6, 1983.
8 It also bears a stamp Seeders' Deposition Exhibit 9 No. 4.
10 (The documents were thereupon marked 11 Applicant's Exhibit No. 24 for 12 identification as of June 12, 1986.)
13 BY MR. MILLER:
{
14 Q Mr. Snyder, calling your attention to this document, 15 which is Revision C of Procedure 4.9.1, I ask you .
16 whether you have ever seen a copy of that before today?
17 A Yes, sir.
18 Q Is that, in fact, the procedure that was effective for 19 calibration inspections when you arrived at the 20 Braidwood site in July of 1984?
21 A Yes, sir.
22 O I take it, then, that this is the procedure that you 23 reviewed and discussed with Mr. Seeders and used as part 24 of your training?
/'
25 A Yes, sir.
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3967 1 Q Okay. Do you recall whether the --
2 JUDGE GROSSMAN: Excuse me. I am sorry.
3 There was -- oh, okay. That's fine. It's the next 4 one that was later in time.
5 BY MR. MILLER:
6 Q Do you recall whether questions on your written 7 examination specifically tested your knowledge of the 8 calibration inspection procedure?
9 A Yes, sir. It came from -- basically all of it came from 10 -- the procedure.
11 Q Now, I would like you to turn, if you would, to 12 Paragraph 3.3.7, and it's on what is the fourth page of w 13 the exhibit.
(J 14 It has the -- it's identified as Page 3 of 7 in the 15 lower right-hand corner.
16 A Uh-huh.
17 Q When you were conducting your training, when you were 18 being trained by Mr. Seeders, did you have occasion to 19 discuss with him this provision in the procedure?
20 A I am sure it was discussed during my indoctrination. It 21 would have been.
22 I r'ead it during my training. I am not sure that 23 we discussed it any further than that.
24 It's pretty well explanatory there. I had no 25 questions about it, really.
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3968 O 1 0 That provision of the procedure you didn't regard as 2 vague?
3 A No, sir.
4 0 Would you explain for the Board what your understanding 5 was as to what a Calibration Inspector was to do under 6 this paragraph when an instrument that he calibrated was 7 found not to meet calibration requirements?
8 A Well, you write the Inspection Correction Report as it 9 states.
10 You would take the tool out of service, attach a 11 hold tag so that it doesn't get used in the field, write 12 the ICR, either repair the tool or await for the 13 engineer to tell you to repair the tool..
14 I believe per this procedure you couldn't repair 15 the tool on your own. It had co be an engineering 16 function to tell you to do that.
17 Q All right. The first step in the process was the 18 writing of an ICR.
l 19 Could you tell us: Is the ICR form attached to 20 this procedure?
I 21 A No, sir, I would say no.
I 22 O We will be looking at some ICR's a little later in your 23 examination, Mr. Snyder; but for now were blank ICR 24 forms available to all the QC Inspectors, including you 25 and Mr. Seeders, in July and August of 1984?
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3969 O 1 A Yes, sir.
2 Q Did they have some unique identifying number on them in 3 their blank condition?
4 A Yes, sir. They go by form numbers. Form 30, there it 5 is. I was trying to wrack my brain, but it's right 6 there in front of us.
7 Yes, it's got a form number in the lower right-hand 8 corner of all of our forms.
9 Q Were the actual ICR's that were written up by the 10 inspectors given a unique identifying number?
11 A Yes, sir. They were given a tracking number by the ICR 12 clerk, and she had a log that would state what that ICR 13 was written for and when it was written, et cetera.
14 Q All right. Where was this ICR clerk located?
15 A You mean in '84?
16 Q In the summer of '84. I am sorry.
17 A I believe she stayed in the vault at that time.
18 Q So that was back in the Comstock office; correct?
19 A Yes, right.
20 Q So when a nonconforming -- when a tool didn't meet its 21 calibration requirements, would you write up the ICR in 22 the tool crib?
23 A Well, you first should attach the hold tag; but you 24 should write it there on the spot. It's that way now.
25 I am not sure how the ICR procedure.was worded back Sonntag Reporting Service, Ltd.
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N/ 1 then. I know a lot of people may have come back to the 2 office to write them.
3 Q Do you know whether Mr. Seeders wrote them on the spot 4 or came back to the office?
5 A I am sure they were written in the office at that time.
6 Q Why are you sure of that, Mr. Snyder?
7 A Well, that was pretty wide practice, I think, in some 8 areas.
9 Now, I can't speak for all the inspectors; but a 10 lot of them were being written, I believe, in the 11 office.
12 Now, the hold tag should have been attached in the S 13 field. Maybe the man had too many inspections or (G
14 whatever going at the time, but I know for a fact that 15 they were written in the office, some of them.
16 I can't say a percentage or --
17 Q True. When you say "some" --
18 A Weren't written in the office, right.
19 Q And those are some of the ICR's relating to 20 out-of-calibration tools; correct?
21 A Yes, sir.
22 Because another thing is, if I can add --
23 Q Sure.
24 A -- the conditions in the tool crib were crowded, no 25 really available area.
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l 3971 1 You could make room to write a piece of paper; but 2 it was easier for a lot of them, more convenient, to go 3 back to the office.
4 Q You referred to a hold tag.
5 Would you describe for us what the hold tag was?
6 A It's a yellow card, about this size, 3 by 5, that says 7 " hold," on one side.
8 .On the other side you give a description for that 9 hold tag being placed upon an item.
10 It would, also, you would sign it and date it or, 11 at least, I always dated mine.
12 They didn't have a provision to date it but any rs 13 time you sign anything, you ought to date it; and it
\_),
14 also had room for the ICR number, an NCR number that you 15 could later go and put on the tag or the ICR would put 16 on the tag for you.
17 Q How was the hold tag physically attached, if it was, to 18 the tools that were out of calibration?
19 A They have a little ring, eyelet I think you call them, 20 in the end of the tag; and you would use a wire or a tie 21 wrap, they call them, these little plastic wraps, to 22 attach it to the tool so it wouldn't come off. -
l l 23 Q All right. You --
j 24 A Or you could tape it on, too.
l 25 Q Okay. After the ICR was written and a number obtained Sonntag Reporting Service, Ltd.
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3972 1 for the ICR from the ICR clerk, how was the ICR 2 dispositioned for an out-of-calibration tool, say, a 3 torque wrench?
4 A Well, in '84 the problem with the ICR's, the form was, 5 in my opinion, no good, because -- and I stated that, my 6 concern about it, because you write the ICR, the 7 inspector would.
8 The ICR would go to the foreman in the field then; I
9 and then when he would do the work -- in my case, there 10 would be no work involved, really -- but in a case of, 11 say, a weld inspector or something, this ICR would go to 12 the field and tell the foreman of a problem; but the 13 foreman cannot take it upon himself to k:.ow how to fix 14 that problem without an engineer telling him how to fix 15 that problem.
16 So it was the routing of the ICR that I had a 17 problem with, i 18 And then the ICR, the foreman, would have to come 19 to the engineer and say, " Hey, what am I going to do 20 here? How do we fix this problem," when, instead, the 21 ICR should have went from QC to the engineer to the 22 foreman, which is the way it is now, which back then 23 just caused more confusion then amongst the foreman.
24 Q Did you ever make a suggestion that the ICR routing be 25 changed, as you described?
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1 A Well, informally I made a comment to -- I couldn't -- I 2 don't know who now, whether it was my supervisor; but 3 the reason I noted that is because at Marble Hill -- I 4 compared it to my last job, and that's all I could 5 compare it to, that the engineer should be involved 6 before the thing goes to the field, because it tells him 7 nothing to do in the field.
8 JUDGE GROSSMAN: Excuse me.
9 I am not sure we got a complete answer on how those 10 ICR's were actually dispositioned.
11 THE WITNESS: Okay.
12 JUDGE GROSSMAN: They went --
13 THE WITNESS: I am sorry.
14 JUDGE GROSSMAN: Fine.
15 THE WITNESS: They would be dispositioned by 16 the engineer, that's his job; but what my point was 17 getting at is a lot of the older ICR's I have seen never 18 had an engineer involved at all.
19 JUDGE GROSSMAN: But were they actually 20 dispositioned or were they just left unresolved?
21 THE WITNESS: The ones that I have seen were 22 closed out without an engineer's involvement.
23 JUDGE GROSSMAN: Okay. In other words, they 24 went to the foreman in the field and he would just 25 disposition it himself?
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3974 1 THE WITNESS: Yes, sir -- well, the foreman 2 has a spot on there and the engineer has a spot to say 3 his statement. The engineer's spot would be blank.
4 Now, in my case of calibrated tools, the majority 5 of them I seen, they would -- the foreman would simply 6 say the tool was taken out of service or the tool was 7 sent off for repair and then the ICR would be closed by 8 an inspector, which mentioned nothing of the problem 9 that that tool may have created by being out of 10 tolerance in the field.
J 11 MR. MILLER: I wanted to ask you about that 12 specific but I don't want to if the Chairman --
{} 13 14 JUDGE GROSSMAN:
Which foreman are you talking about now?
I just want to continue.
You are 15 talking about a construction foreman?
16 THE WITNESS: Yes, sir. They are all 17 construction foremen.
18 JUDGE GROSSMAN: Okay.
19 BY MR. MILLER:
20 Q Let's talk specifically, if you would, about the 21 instances of calibration inspections.
22 Am I correct that the tool itself had to be 23 repaired if it was out of calibration?
24 A Yes, sir.
25 Q Would there also be an evaluation of the prior work.that
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'- 1 had been done with that tool?
2 A Yes, there should have been.
3 Q Am I correct that Paragraph 3.3.7.1 essentially calls 4 for that sort of analysis; right?
5 A Yes, sir, that's correct.
6 Q Why is it important, in your judgment, Mr. Snyde r, that 7 you don't just simply repair the tool but do this 8 additional analysis as well?
9 MR. GUILD: Mr. Chairman, I want to note an 10 objection.
11 That is a leading question and really should be 12 framed in a way that doesn't suggest the answer to the 13 question.
14 I understand we want to move things along; but 15 where the question presupposes the answer, I believe 16 it 's imprope r.
17 JUDGE GROSSMAN: Yes. Please reframe the 18 question as to whether first it was important or --
19 MR. MILLER: Sure.
20 BY MR. MILLER:
21 Q Did you regard the analysis of prior work conducted by 22 -- that had involved the use of an out-of-calibration 23 tool as a significant or an insignificant aspect of the 24 calibration inspection procedure?
25 A Well, it was important, in my opinion, to know what the Sonntag Reporting Service, Ltd.
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' 1 tool was used on in its out-of-calibrated state.
1 2 0 Why is that?
3 A Well, in a torque wrench, for example, you want to know 4 whether you have a bunch of loose bolts out there or 5 under-torqued bolts. They may not be loose but they may 6 not be per procedure tight enough or they may be too 7 tight, depending on how the tool was -- how far it was 8 out either way.
9 Q All right. Now, I think you said that there were two to 10 three weeks after you first came on site, July 2, 1984, 11 where there was a general indoctrination and then you 12 were assigned by Mr. Saklak to work with Mr. Seeders 13 At that point in time were you aware of any special 14 projects, other than routine calibration inspections of 15 instruments, that Mr. Seeders was involved in?
16 A I did become aware of a project that John had been l
17 assigned in late July, I believe, of '84.
l 18 I really didn't know the specifics of it, but it 19 was some kind of project that he was assigned.
20 Q Yes, sir. And then --
21 JUDGE GROSSMAN: Excuse me, Mr. Miller.
l 22 On the questions just before I believe you asked a 23 question as to whether the work performed by the 24 out-of-calibration tool would have been reviewed, was 25 reviewed?
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( 1 Was that in' ae prior secies of questions?
2 MR. MILLER: I don't know that that was in 3 the question but it was certainly the witness's answer.
4 MR. GUILD: I think the word was " evaluate,"
5 Mr. Chairman, which is the language that is used in the 6 procedure as I recall the question.
7 JUDGE GROSSMAN: Was the prior work 8 evaluated?
9 MR. MILLER: Yes, correct.
10 JUDGE GROSSMAN: I believe the answer was 11 that it should have been.
12 I don't believe you got the answer as to whether 13 that was the practice to do that at the time, which I
{~ ;
14 believe was your question.
15 Was that your question?
16 MR. MILLER: Well, I wanted to have an 17 explanation of the procedure but I will ask:
18 BY MR. MILLER:
I 19 Q With respect to calibration inspections which detected 20 an out-of-calibration instrument and in which an ICR was 21 written, was there, to your knowledge, an evaluation of 22 the prior work that had been done with the 23 out-of-calibration instrument?
24 A Not in the majority of the ICR's I have seen at that 25 time.
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3978 im 1 Q All right. Who was responsible for initiating the 2 evaluation of the prior work?
3 A Well, that would be Engineering's job to determine what 4 that tool was used on.
5 QC's function was to say, "You have got a bad tool 6 here." They are the craft tools. We as QC are supposed 7 to say, "You have got a good tool," or, "You have got a 8 bad tool."
9 Then the engineer will get involved and say what 10 the craft has used this tool on, so they can make an 11 evaluation and if it was enough re-work involved, maybe 12 an NCR would be written so the owner could get involved 13 and they could make a wider disposition, to either 14 re-work or accept it as is.
15 Q The document that triggered the engineering evaluation, 16 though, was the ICR Form 30; correct?
17 A Yes, sir.
18 Q Getting back to this special project with Mr. Seeders, 19 did you assist Mr. Seeders at all in this project, do 20 you recall?
21 A Yes, sir. One day I was still being trained -- I 22 believe it was July 25th of '84. It was on a Saturday.
23 I helped him. I at the time didn't understand what 24 we were doing but I was assigned to do something by him 25 and make notes, more or less, of some things and assist Sonntag Reporting Service, Ltd.
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3979 O 1 him in that way. i 2 Q Did Mr. Seeders tell you during the course of your 3 assistance to him on this Saturday why he was conducting 4 this special project?
5 A It was just something he was required to do per an audit 6 finding, I understood.
7 Bob Seltmann, our QA Manager, and Mr. Saklak had 8 determined that this information needed to be gotten, if 9 you can use that word, from the vault files or however 10 the means was from the files to close maybe an audit 11 finding.
12 I know there was an audit finding at that time by 4
13 Commonwealth Edison, I believe, and it pertained 14 somewhat to that.
15 MR. GUILD: Mr. Chairman, I take the 16 witness's last answer to reflect his understanding that 17 came from some source; and for the record to be clear, I 18 would simply ask that the source be specified.
19 BY MR. MILLER:
20 Q Was that your understanding from Mr. Seeders at the l
21 time?
22 A Yes, sir. You know, it's been so long. I know he would 23 have been the man to tell me, because I was his trainee, 24 why we were doing this.
25 Whether he explained it thoroughly I cannot recall, Sonntag Reporting Service, Ltd.
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3980 1 why we were doing it.
2 0 Did any part cf this special project involve a review of 3 files to determine whether an ICR had been written for 4 an out-of-calibration instrument? ,
5 A Yes, that is what it was about.
6 We reviewed the Form 77's, which is the cards, 5 by 7 7 or something, calibration ca rd. That's all we done 8 that day, was -- that's all I remember doing, was 9 looking at the cards.
10 We didn't go and look at calibration reports in the 11 vault that I recall.
12 0 okay. I think we ought to digress from the chronology 13 and, perhaps, have you explain, if you would, for the 14 record some of the forms that are attached to Procedure 15 4.9.1.
16 You have referred to a Form 77?
17 A Yes, sir.
18 0 Would you describe what this form is?
19 A It's a calibration card, we call them, that we keep in a 20 gray file card cabinet, you know, two drawers in it.
I 21 (Indicating.)
22 Each tool has a card on it. That, as you can see 23 there, every time you do a calibration, you record the i
24 standard, which is the item you checked that tool with, j 25 whether it be the pin sets, a standard number, the
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\ 1 procedure involved, which would have been 4.9.1, Rev C, 2 sign it and date it, any remarks, if any, and then carry 3 the next due date to the lef t column so that this card 4 would be re-filed under that due date.
5 It's a tickler file that comes forward all the 6 time. You do the-most current tools.
7 JUDGE bALLIHAN: Excuse me, Mr. Miller.
8 . Is that a'Comstock tool instrument sign-out log?
. 9 MR. MILLER: No, sir. It's got a Form 77 in 10 the lower right-hand corner that is attached ,
11 JUDGE CALLIHAN: Many of the numbers 12 describing the forms were chopped off in the fs 13 reproduction.
(_)
14 MR. MILLER: My apologies.
15 JUDGE CALLIHAN: That's all right, and it may 16- be.my omission.
17 JUDGE COLE: It's not on my copy, too.
18 JUDGE GROSSMAN: It's all of our copies.
19 MR. GUILD: Mr. Chairman, the Form 77 happens 20 to have a number somewhere else on the document, so you 21 can figure that out.
22 It's the last form in the package followed by a 23 number of correspondence.
24 JUDGE GROSSMAN: The form number is up above 25 the block of boxes.
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\> 1 JUDGE CALLIHAN: There we are. Thank you. I 2 am sorry.
3 BY MR. MILLER:
4 Q When you arrived at Comstock in July of 1984, 5 approximately how many Form 77's were there for tools 6 that were calibrated on a periodic basis?
7 A 200, approximately; maybe more, I will say that.
8 JUDGE GROSSMAN: Excuse me. Could you repeat 9 that question?
10 THE WITNESS: Maybe more --
11 JUDGE GROSSMAN: I am sorry. I am just 12 asking the Reporter.
13 What was the question, Mr. Reporter?
14 (The question was thereupon read by the 15 Reporte r . )
16 JUDGE GROSSMAN: Okay, fine. Thank you.
17 A (Contin uing . ) If I could add, I was talking in terms 18 of tools only, because once you fill a card here, you 19 continue to another card.
20 There could have been a thousand cards but there 21 was only 200 or more tools involved that a current 77 22 would be involved with.
23 Now, this whole file cabinet was full of cards when 24 I came there, which, like I said, this was probably a 25 two by two file cabinet, two feet wide or deep.
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3983 k- 1 But John's practice was to keep all the cards in 2 this file, even the full cards, which when I got 3 involved, we weeded out the full cards and forwarded 4 them to the vault package, to keep only the current card 5 in there, because it was just too many cards and it 6 wasn't necessary, I felt.
7 BY MR. MILLER:
8 Q So you ncw have a much reduced stack of Form 77's; 9 correct?
10 A Yes, sir, yes, sir. Every time I get one full, I just 11 forward it en to the vault, so it goes in the permanent 12 record.
(~T 13 Q Now, when a calibration inspection was performed, was LJ 14 there a form that was filled out that recorded the 15 results of that inspection?
16 A Yes, sir, Form 23-A, which is on here, for variable 17 instrument records I believe is the title of it --
18 Variable Instrument Calibration Record.
19 MR. MILLER: It's this.
20 (Indicating.)
21 THE WITNESS: That A is cut off, I believe, 22 down there.
23 (Indicating.)
24 Maybe I am looking at it wrong. The A must bs cut 25 off of my copy on that form number, but it is a 23-A.
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3984 1 That would be filled out upon a calibration of a 2 tool, except a torque wrench.
3 Now, a torque wrench had a Form 23, which is the 4 reason I wanted to note that here.
5 That was in another procedure, 4.9.4, which wasn't 6 in this 4.9.1 procedure.
7 The report looks very similar except the Form 23 8 doesn't have the lines at the bottom for a QC Inspector 9 or date or the Level 2 review and the title would be 10 different; but that's it.
11 MR. MILLER: Well, I don't have copies at the 12 moment but I am going to ask the Reporter to mark as 13 Applicant's Exhibit 25 for identification a document
,/' }
14 that has on the front page, "Irocedure Tracking Sheet, 15 Procedure No. 4.9.4," and indicates final approval date 16 of May 22, 1981.
17 (The documents were thereupon marked 18 Applicant's Exhibit No. 25 for 19 identification as of June 12, 1986.)
20 BY MR. MILLER:
21 Q Mr. Snyder, I show you what has been marked as 22 Applicant's Exhibit No. 25 for identification and ask 23 you if that's the procedure to which you referred in 24 your previous answer?
25 A Yes, sir.
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($) 1 MR. GUILD: Do you want to show the Judges? l 2 MR. MILLER: Yes. This is the procedure.
3 This is the form.
4, I will get copies at a break, Judge.
5 BY MR. MILLER:
6 Q Mr. Snyder, what was your understanding of the 7 dif ference between the Form 23 that has the heading, 8 " Torque Wrench Calibration Record," and the Form 23-A, 9 which has the heading, " Variable Instrument Calibration 10 Record"?
11 A Excuse me. Did you ask what the difference was, my --
12 Q What was your understanding of the reason for the 13 dif fe rence?
14 A Oh, I am sorry.
15 Well, the torque -- the 23 was the Torque Wrench 16 Calibration Record. That's the reason for that.
17 The difference I don't understand. You could have 18 used the 23-A. It was more informative, in my opinion, 19 because of the signatures and the review at the bottom; 20 but that's not the way they set it up.
21 Q Okay. How many different calibration inspections could 22 be recorded on one Form 23 or 23-A?
23 A It's set up for four; but they used to do that from the 24 records I had seen early, late '70's, early '80's --
25 they used to put four inspections on these.
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' 1 But it wasn't practical later, because you would 2 have to go to the vault each month -- each week in a 3 torque wrench case -- and pull this back out, take it 4 back to the field with you and add another inspection 5 here.
6 This was a controlled document after you have 7 information on it, and maybe back then they weren't 8 keeping them in the vault, I couldn't say, you know; but 9 they would, at least, have to take them in and out of 10 the office, with old information on it that shouldn't be 11 lost or destroyed.
12 MR. GUILD: Again, Mr. Chairman, if the 13 witness could route that testimony in time, I believe it 14 would establish what specifically he was being 15 responsive to.
16 MR. MILLER: 'I think he said the late '70's.
17 A (Con tin uing. ) Late 1979, early '80's, probably up to 18 '82.
19 I think John quit that after that because of that 20 reason. They just couldn't be taking them in and out of 21 the records vault each week.
22 Our torque wrenches at that time were calibrated 23 weekly, and that's just too much paper in and out, you 24 know.
25 BY MR. MILLER:
O .
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\# 1 So what was the practice when you arrived at Braidwood Q
2 in terms of how much information was recorded on these 3 forms?
4 A He would just put one inspection o'n there; and, really, 5 I believe he would have more information than you could 6 get in one of them quarters there and he would just 7 carry it down into the next quarter below it, with his 8 readings, because the blocks weren't big enough at that 9 time.
10 Q When you arrived at Braidwood, under Revision C of 4.9.1 11 were there any of the tools that were exempt, if you 12 will, from filling out or having filled out a Form 23 or
{} 13 14 A 23-A to record the calibration?
Yes. The wire crimpers and strippers were not -- there 15 was not a 23-A being filled out on them inspections from 16 what I later found out when I got involved with the 17 training and that.
18 Q Well, I take it you observed that the Form 23-A was not 19 being filled out for the crimpers or strippers.
20 Was there something in the procedure, to your 21 knowledge, which said that such forms should not or did 22 not have to be filled out for those crimpers and 23 st rippe rs?
24 A No, sir.
25 0 When you read the procedure, became familiar with it, in O
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3988 1 July and August of 1984, what was your understanding as 2 to the form that was required when a calibration 3 inspection of a crimper or stripper took place?
4 A Well, it's worded, I believe, all calibrated tools will 5 require the initiation of a 23-A; and that's pretty cut 6 and dried, too.
7 Now, I cannot recall if I was -- how I was trained 8 on crimpers or strippers. For some reason, I just don't 9 recall.
10 You would have to go back to my training, whether I 11 -- I am sure that to have some training, I would have 12 had to have filled some out; and I haven't seen my 13 training records since then. I don't know what the case
{
14 was there.
15 But what I was leading at, I think I would have 16 questioned that if we were actually calibrating the tool 17 and not filling out a report on it.
18 JUDGE GROSSMAN: Excuse me.
19 The question presupposed that an inspection was j 20 actually performed on those tools at that time.
21 Was there an inspection performed on those tools?
22 THE WITNESS: Yes, sir.
23 JUDGE GROSSMAN: Okay.
24 BY MR. MILLER:
25 Q And from what form would you be able to tell whether an l %)
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( l inspection was performed?
2 A Well, the Form 77 would be signed on the date of 3 inspection, certifying there was an inspection made.
4 Now, the 23-A would have your information to that 5 inspection on it.
6 JUDGE GROSSMAN: Ms. Kezelis, did you want to 7 have a recess now?
8 MR. MILLER: We were debating it among 9 ourselves and decided we would go a little bit further 10 if everybody else was agreeable.
11 I would like to have the Reporter mark as 12 Applicant's Exhibit 26 for identification, a document gg 13 that is in handwriting and it's multi-page.
V 14 It bears the date July 28, 1984, in the upper 15 right-hand corner of the first page.
16 . (The documents were thereupon marked 17 Applicant's Exhibit No. 26 for 18 identification as of June 12, 1986.)
19 BY MR. MILLER: -
20 0 This document, Mr. Snyder, has -- I believe it's almost 21 all in handwriting and I will represent to you that 22 there are different portions of the document.
23 I ask that you go back about six pages to the page 24 that precedes the Form Personnel Instruction Log.
25 A Okay.
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1 Q It's the page that has Mr. Seeders' signature on it.
2 A Okay.
- 3 Q If we just look at those first six pages of what we have 4 marked as Exhibit 26, can you tell me whether or not you 5 have ever seen those six pages prior to today?
I i
6 A Yes, sir.
7 0 When did you see them?
j 8 A Well, this was the research that John had performed on 9 that Saturday we worked; and I have seen it since, 10 because it's in some information at work that we are 11 working on, an NCR; and it happens to be in that folder, i
12 too, as some information that has been there for two
- 13 years.
I 14 0 Looking at the next page of the exhibit, there is a 15 Personnel Instruction Log.
16 Is that your signature in the left-hand column?
17 h Yes, sir.
18 Q Can you tell us the date on which this training took 19 place?
l 20 A 7-21-84 is the date in the upper right.
l
! 21 That would be the only way -- that would be the i
i 22 date of the -- and it's a Level 2 reviewed by Bruce 23 Brown on the same date.
24 Q Now, you then have some additional pages in the exhibit, l
25 five of them, that are in the same handwriting as the O
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k- 1 first six pages, and then the handwriting changes for 2 the last five pages of the exhibit?
3 A Yes, sir.
4 Q Are any of those pages in your handwriting?
5 A Yes, sir. Those last five pages are my handwriting.
6 Q All right. Can you describe for the record what the 7 different columns on these pages represent?
8 A Well, the Column No. 1 is the tool -- description of the 9 tool -- which is portable rod oven in that case.
10 Column 2 is the tool identification number, the 11 unique control number of that tool.
12 No. 3 is the ICR column. If an ICR did apply to 4 s 13 that tool at one time or another, that is the ICR that (b 14 goes with that tool.
15 And then the date in the right-hand column just 16 must have been either the date the ICR was written or --
17 that's probably what it had to be, the date it was 18 written, because I believe this information came off of 19 the Form 77's, the initial information.
20 I probably -- I say I did have to do some further i
21 research on these ICR's to know when they were written, 22 actually.
23 I believe so. I -- I --
24 0 Well, all right.
25 A It's been a long time here.
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l 1 Q l appreciate that.
2 On the Form 77 card in the Remarks Section, what 3 information, if any, was recorded there?
4 A This information in this right-hand column, probably a 5 lot of it came from the Form 77. So he would write, if 6 the tool was out of tolerance, the date it was out and 7 say ICR was written or removed from service.
8 Very few times would you find an ICR number, but 9 that was -- at least he wrote it per the Form 77 and 10 that's probably this information, maybe, came right of f 11 the ca rd. ,
12 0 All right. So if I understand, on some occasions, at 4
13 least, the ICR number was indicated on a Form 77?
14 A Yes, I would say in some cases, yes.
15 Q Do you recall on this Saturday, July 21, 1984, reviewing 16 the ICR log to develop the information that is in the 17 third column?
18 A That was July 25th, if I can correct you, I think.
19 Q Is it July 25th?
l 20 A Is that right?
21 That's what I had said earlier, anyway; but --
22 Q Ms. Kezelis, who happens to have in her checkbook a 1984 l 23 calendar, advises me that July 21st was a Saturday.
24 A Excuse me. I am sorry.
25 Q Do you recall that you worked on a Saturday?
l
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3993 1 I don't mean to --
2 A I had the 25th in my mind for some reason, but that's 3 okay.
4 To get back to your question, did I get this from 5 the ICR log?
6 After setting here and thinking about my statement 7 a few minutes ago, I would say no.
8 I believe this information came directly off of the 9 Form 77.
10 Q Mr. Seeders, was he working side by side with you during 11 that day?
12 A Yes, sir.
13 Q To your knowledge, was he looking at any other document 14 other than the Form 777 15 A Well, per the earlier sheet, he mentions a Form 8.
16 0 Well, I am asking about your recollection, Mr. Snyder.
17 Do you remember him doing any further looking at 18 documentation other than Form 77?
19 A No, sir, I cannot recall at that time.
20 You know, he was free to move around and could have 21 looked at anything, I suppose.
22 Q I unde rstand that. I am really just asking for your -
23 recollection of the events.
24 A Okay, 25 Q The sheets that you filled out deal with portable rod
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3994 1 ovens, torque wrench tester, welding machine, crimpe rs 2 and so on.
3 A Uh-huh.
4 Q Wire strippers.
5 Were these all of the tools in those different 6 categories of tool?
7 That is, did you look at the Form 77 for every 8 portable rod oven?
9 A No, I would say no.
10 0 All right.
11 A It's not all there. There are more tools than that. I 12 didn't look at all of them.
13 Q How did you decide -- well, first of all, did Mr.
14 Seeders give you any direction as to which tools you 15 ' should look at and which you should not?
16 A Looking at this -- well, I cannot recall.
17 I am sure he gave me a stack of cards, because 18 that's what we were looking at, the 77's, and said, 19 "Here, look at these and record the information."
20 That would be my recollection.
21 Q Well, you have got four columns with information?
22 A Yes.
23 Q Do you recall specifically what it was you were looking 24 for as you recorded this information in your 25 handwriting?
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1 A Well, again, as pertained to, apparently, the audit 2 finding.
1 3 I can't say specifically, no. I would be maybe not i
j 4 sure of myself, because, as you stated earlier, we were 2
5 -- the audit finding was to see if the ICR's were 6 written for out-of-tolerance tools, which that would be 7 my opinion of what we were doing here.
8 JUDGE GROSSMAN: Excuse me.
9 I just want to get straight now as to whether or
) 10 not it's your recollection that was hazy or the fact 1
1 11 that at the time you performed this task, you really 12 weren't fully cognizant of what was involved, only Mr.
i 13 Seeders was and you worked under his direction.
14 Is that the situation or is it now that your 15 recollection is hazy? /
16 THE WITNESS: I would say both.
17 I was a trainee. I didn't realize what this was l 18 really doing for us. I at the time, if I remember 19 right, could not see what this information maybe was l
20 going to prove.
- 21 I was doing it but -- and, again, it's been two l
22 years and I am hazy on the facts there; but, as I
! 23 recall, John Seeders was also vague on his instructions 24 of what to -- actually, what they were looking for.
25 JUDGE GROSSMAN: Okay. That's fine. I just
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/ 1 want truthful answers without your guessing now.
2 THE WITNESS: I understand.
3 JUDGE GROSSMAN: And I want to find out what 4 the basis is.
5 That's fine. Thank you.
6 BY MR. MILLER:
7 Q Mr. Snyder, at this point in time, July 21st of 1984, 8 were you aware of the Edison audit finding?
9 A Yes, I had heard it. You know, when you work around the 10 office or work with John, I know I heard it. .
11 He was being audited in July of '84.
12 JUDGE GROSSMAN: Mr. Miller, we are about 13 ready for the break, so when you think it's appropriate, 14 that's fine.
15 MR. MILLER: This would be a good time.
16 JUDGE GROSSMAN: It is, okay. We will take 17 ten minutes then.
18 (WHEREUPON, a recess was had, af ter which l
19 the hearing was resumed as follows:)
20 JUDGE GROSSMAN: Okay. We are back in 21 session.
22 MR. MILLER: I would just like the record to 23 reflect that I have distributed to the Board and the 24 parties copies of Applicant's Exhibit 23, which had been 25 withdrawn for copying some days ago, and 25, which was i
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3997 1 just identified this morning, and I have returned to the 2 Court Reporter the marked copy of Exhibit 23.
3 BY MR. MILLER:
4 Q Mr. Snyder, we referred to this Commonwealth Edison 5 audit finding and I would like to show you a document 6 that is a Commonwealth Edison -- I think I probably 7 ought to have it marked as an exhibit for 8 identification, at least.
9 It's a Commonwealth Edison audit report, 10 QA-20-84-528 and the report date is shown as May 21, t
11 1984.
12 (The documents were thereupon marked 13 Applicant's Exhibit No. 27 for 14 identification as of June 12, 1986.)
15 JUDGE GROSSMAN: You only have one copy?
16 MR. MILLER: I only have one copy at this 17 time, your Honor.
18 JUDGE GROSSMAN: At this time, that's fine.
19 BY MR. MILLER:
20 0 Mr. Snyder, I show you a document that has been 21 previously marked as Applicant's Exhibit 27 for 22 identification and ask you if you saw that document in 23 July of 1984 when you came to the Braidwood site or 24 shortly after that?
25 A No, sir, I did not see it.
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3998 O 1 Q Item 3 of this document states, "During the review of !
l 2 the calibration records for various instruments / gauges, l 3 several instances were noted where the instrument was 4 found out of calibration. The following were found out 5 of calibration with no evaluation of previous 6 inspections or test results."
7 Then there are three instruments listed, a crimper, 8 a pin g'auge set and a plug gauge set and there is an 9 indication that for the crimper an ICR was generated.
10 However, it did not include an evaluation of past work.
! 11 That for the pin gauge set on two occasions no ICR 12 was generated, although it was found out of calibration.
{} 13 14 And for the plug gauge set, it was found out of calibration but no ICR was generated.
15 You can examine this. It's Page -- it's Attachment 16 B to the audit report, Page 3.
17 MR. GUILD: Mr. Chairman, I assume this is a 18 foundation for some question which itsel f may be 19 legitimate; but, certainly, Mr. Miller reading the 20 document into the record does not establish that as 21 evidence.
22 JUDGE GROSSMAN: That is certainly the case.
23 I am sure Mr. Miller doesn't intend to have that 24 stand for any evidence.
25 BY MR. MILLER:
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k- 1 Q Having looked at the document, Mr. Snyder, can you tell 2 whether or not that is the audit finding to which you 3 referred in your previous testimony?
4 MR. GUILD: Well, Mr. Chairman, I do object 5 to that.
6 Now, that is a vague question, since it's not clear 7 at all what counsel is referring to when he refers to 8 the witness't past testimony.
9 JUDGE GROSSMAN: I don't myself know what you 10 are referring to.
11 So if you could just make the question more 12 specific, so we all understand what it means.
13 MR. MILLER: Yes. Well, I apologize for not 14 having copies.
15 BY MR. MILLER:
16 Q I am referring to Item 3 on Page 3 of Attachment B, 17 which deals with the out-of-calibration instruments that 18 were found.
19 JUDGE GROSSMAN: Okay. Our problem is that 20 we don't know what audit finding he referred to before 21 that time.
22 MR. MILLER: Thank you. I beg your pardon.
t 23 BY MR. MILLER:
24 0 I think you testified previously, Mr. Snyder, that it 25 was your understanding that this special project that i (
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1 you worked with Mr. Seeders on during early July and 2 specifically on July 21st involved the "closecut or was 3 connected to an audit finding; is that correct?
4 A Yes, sir.
5 Q And having now looked at the audit report and the 6 specific item that I directed you to, do you know 7 whether or not it is this audit finding that you were 8 referring to or that was the reason for the special 9 project that you testified to earlier?
10 MR. GUILD: Objection.
11 The witness's own testimony establishes that at 12 least, given his knowledge that has been the subject of
{} 13 14 his testimony -- and that was as of, July, '84 -- he is not competent to answer that question.
15 I don't presuppose that Mr. Snyder doesn't have 16 later knowledge that may give him a basis for answering 17 the question; but, really, since the question references 18 his prior testimony, that prior testimony discloses very 19 limited knowledge and no foundation for answering this 20 pending question.
21 JUDGE GROSSMAN: Well, I think we will allow 22 the question, because I think Mr. Snyder will indicate 23 what he knew at the time in his answer.
l 24 So why don't you just answer the question?
I 25 THE WITNESS: Could you rephrase the
(~)h l \-
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s- 1 question?
2 MR. MILLER: Sure.
3 Mr. Reporter, why don't you read it back, please?
4 (The question was thereupon read by the 5 Reporter.)
6 A No, I do not know that.
7 BY MR. MILLER:
8 Q It appears from what we have marked as Applicant's 9 Exhibit 26 that you did not review the Form 77's for any 10 torque wrenches; is that correct?
11 A Evidently not, if there is not any in here.
12 Let me briefly -- torque wrench tester, which is fs 13 the standard, and that looks like it. That is the L-)
14 standard that we used to check torque wrenches.
15 No, there is no torque wrenches here.
16 Q Is that just happenstance or did Mr. Seeders --
17 A It looks like John got involved with the wrenches on his 18 earlier pages here. I am sure that he handled them and 19 I kind of handled the odd tools here it looks like.
20 Now, if I can recall, these aren't all the tools.
21 I think we stated that earlier; but these were the tools 22 -- the Form 77's that may have had a problem mentioned 23 on them. That's the reason they were recorded.
24 Now, there were more tools that the Form 77 did not 25 state any problems.
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4002 1 0 When you say problems, what problems?
2 A Well, he says there is ICR's referenced on that tool, 3 removed f rom service, anything that I seen on that 77 4 that might have signaled a tool that was out of 5 tolerance at one time or another.
6 Q Well, having given us that answer, do you now recall 7 that you, in fact, reviewed all the Form 77's and only 8 noted down the ones that had, what you just 9 characterized, as problems?
10 A Well, I myself didn't review them all. I think we 11 shared that work.
1 12 But, yet, we would have looked at all of them in
, 13 the card file at that time, which he had all of them in 14 there. That's all we did, was started from the front i
15 and worked through them.
16 Q All right. If the Form 77's didn't indicate -- well, 17 -
could you describe for us the nature of the problems 18 that would have caused you to make a notation when you 19 were doing that review on July 21st?
20 A Well, he says on my first sheet here, " Removed from l
t 21 se rv ice . " There is a slash there under ICR column, so 22 there was no ICR referenced there; but we needed to know 23 why it was removed from service, was there a problem 24 there, which would have needed further review.
25 Now, at the same time I went ahead and mentioned if O
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( l there was an ICR written, I went ahead and noted that, 2 also.
3 So, apparently, the evidence of this audit -- this 4 would show that in this case an ICR was written for the 5 tool out of tolerance, you know.
< 6 Q Do you know when Mr. Seeders had become the Level 2 7 Calibration Inspector for Comstock?
8 A I don't know the date. I would be guessing at the year.
9 I really don't know.
10 0 Okay. I see in the column under ICR number, that there 11 is a reference to GIR's?
12 A Yes.
13 0 What is a GIR, sir?
}
14 A That is a General Inspection Report, which -- I believe 15 it's Form 104.
16 0 What is'the function of a General Inspection Report?
i 17 A Well, it's just more or less -- it's not an inspection 18 report.
19 It's more or less an observation that somebody 20 would make and, for the record, instead of putting it on 21 a piece of paper, you had this General Inspection Report 22 to make a statement on; and the statement could say 23 anything, you know.
24 0 Well, in July of 1984, ,Mr. Snyder, what was your i 25 understanding about the use of General Inspection
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/~T 1 Reports to record discrepancies in calibrated tools?
2 A Well, that wouldn't be the proper way to record a 3 discrepancy in a tool, on a GIR.
4 MR. GUILD: Mr. Chairman, the record should 5 simply reflect that the reference in the document is to 6 GIR's with dates associated with '83, not '84.
7 MR. MILLER: No. My question was what was 8 his understanding in 1984 as to the use of the GIR.
9 I believe the question was clear.
10 BY MR. MILLER:
11 0 There is eight hours of training documented for that 12 day.
13 Other than going through the Form 77's, the file
/}
14 folder or file cabinet from front to back, did you do 15 anything else in the eight hours?
16 A I would say no. My recollection would be no.
17 You know, this indoctrination, the way it was back 18 then -- and it still is -- whatever the trainer sees fit IS to indoctrinate the trainee into the area of inspection, 20 whether it be reviewing paper work -- and, evidently, 21 per the Training Department at that time -- this was 22 acceptable.
23 Q All right.
24 A Now, excuse me. This isn't indoctrination here. This 25 is actual OJT.
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'J 1 I don't know when my first date of training was, 2 but it looks to me like this is on-the-job training and 3 not indoctrination, so anything can apply on-the-job 4 training.
5 0 When you were finished on that Saturday, did you 6 understand that you had completed -- you and Mr. Seede rs 7 together had completed -- the special project that he 8 had been assigned?
9 A Well, with him as my trainer, it was, apparently, 10 evident that we got the information. I as a trainee got 11 the information I needed to to satisfy my trainer.
12 I don't know whether we satisfied everyone else or 13 whether we got all the information that was needed. I 14 couldn't say.
15 JUDGE GROSSMAN: Excuse me.
16 In other words, you had satisfied what was required i 17 of you; but you don't know --
18 THE WITNESS: Yes, sir.
19 JUDGE GROSSMAN: -- whether Mr. Seeders had 20 satisfied what was required of him?
21 THE WITNESS: Yes, sir.
22 John Seeders was like my boss. He was a fellow 23 inspector but he was more or less telling me what to do 24 or how to do it that day or that whole 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> training 25 process I done what he told me, more or less, because O
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2 I wasn't required to go off on my own and do 3 anything on my own.
4 JUDGE GROSSMAN: So, in other words, you just 5 focused on what your requirements were and you didn't 6 really become interested in what he was required to do; 7 that was his job?
8 THE WITNESS: Yes, sir. I knew that he had 9 his job and I had mine to do.
10 BY MR. MILLER:
11 Q Well, after you finished on this Saturday, did Mr.
12 Seeders assign you to any further duties, if you will, 13 with respect to this special project?
[}
14 A I would say no.
15 Q And in the time, days, following that Saturday, what did 16 you do, I mean as a trainee?
17 A Well, again, that Monday we would have took up where we 18 normally left off.
19 I mean tools were due on Monday. He would 20 calibrate them, I would do my inspection over his 21 shoulder and fill out my report, also.
22 I don't know how long my training lasted after this 23 date of 7-21.
24 Q Because it's your recollection that you completed it, 25 took your examination in early August?
()
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4007 l O( > 1 A That's the best of my recollection.
2 Q Right. Now, on the second page of Applicant's Exhibit 3 26 there is a reference to some other forms.
4 You have talked about Form 77 and the Form 30.
5 Could you describe for the record what the Form 8 6 comprises?
7 A Yes. Well, in the procedure here it's the control of 8 measuring and test equipment, I believe is the title of 9 the form.
10 When a new tool is purchased, this is a form that 11 is filled out by the inspector, stating some information 12 about the tool, the unique control number, who 13 manufactured the tool, what size or type of tool and the 14 initial calibration of that tool and the procedure 15 involved, basically.
16 It's just an information cover sheet to go in the 17 vault package for that tool.
18 0 When you were doing your review on that Saturday, July 19 21st, assisting Mr. Seeders, what, if anything, did he 20 say about looking at the Form 8?
21 A I don't recall. I never looked at them that I recall, 22 but I do not recall discussing them with him.
23 Q Did you on that Saturday have occasion to look at any of 24 the individual files for a specific tool?
25 A Not that I recall, no, sir. I spent all day flipping CT V
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2 O The Form 77's?
3 A Yes, sir.
4 Q And Mr. Seeders was doing the same thing as far as you 5 could see?
6 A Yes. I know he was involved; but, like I said, he could 7 have been doing anything else, looking at other forms, 8 per his statement.
9 I don't know. I can't say that he only looked at 10 Form 77's.
11 Q But he did look at some Form 77's with you?
12 A Well, I know he had to to get me started; but how many 13 others, I couldn't say.
14 Q There is another reference to, on the second page of 15 Exhibit 26, Form 76.
16 What is the nature of that form, sir?
17 A That is an Inventory Control Log.
18 Again, when a new tool come on site, it would be 19 recorded on that log; and the log has five columns, I 20 believe, or six, maybe, and it tells, again, the type of 21 tool, the -- excuse me, the tool control numbe r, the 22 type of tool, the manufacturer, serial number, . frequency 23 of calibration and a remarks column, something to that 24 effect.
25 0 Is this, at least, some of the information on the Form O
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.2 A Only -- well, yes. They should be filled out at the 3 same time, which is still the way we do it. They have 4 to be identical forms as far as that goes.
5 But this is just a log. It's a lined sheet of 6 paper, the 76. That is just a continuous list of tools 7 is all it is.
8 Q Did Mr. Seeders show you Exhibit 26 as it now appears, 9 that is first pages in his handwriting, your training 10 record and then the further pages in his handwriting and 11 your handwriting, before he submitted it, if he did, or 12 before he -- on or about July 28th, which is the date up 13 here?
14 (Indicating.)
15 A I don't recall him showing it to me. He just took my 16 information and turned it in, I suppose, with his.
17 Q In early August of 1984, Mr. Snyder, were you attending 18 any classes in calibration inspection?
19 A What type of classes are you referring to?
20 Q Well, this would have been a class conducted by Mr.
21 Seeders in which you and other inspectors were present.
22 Do you recall that at all?
23 A Vaguely, I recall that John did give some sort of class.
24 I don't recall what it was about.
25 I remember some training class and probably Sonntag Reporting Service, Ltd.
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4010 O 1 inspectors that were certified in calibration were 2 there.
3 I cannot recall what it was about.
4 0 Do you recall in the training class that you attended 5 that Mr. Seeders talked about subjects unrelated to 6 calibrations?
7 MR. GUILD: Mr. Chairman, the witness has 8 first stated that he doesn't recall; and now counsel by 9 supplying an answer is prompting the witness with a 10 leading question.
11 It's improper.
12 JUDGE GROSSMAN: Well, he is trying to 13 refresh his recollection.
(V~)
14 MR. GUILD: I don't believe he is entitled to 15 do that, Mr. Chairman, by his question.
16 This is a leading question. It's not proper 17 examination of this witness, and the witness has already 18 stated that he can't recall.
19 He is supplying an answer to a witness.
20 JUDGE GROSSMAN: He is trying to refresh his 21 recollection. I think it's proper in this case to lead 22 a little bit in trying to get the answer.
23 I think the witness has so far demonstrated that he 24 is answering pretty candidly and I don't think it looks 25 like a witness who could be led to either side.
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'/ 1 So we are going to allow the question.
2 A I do not recall any other -- any conversations. It's 3 been too long. I really cannot.
4 BY MR. MILLER:
5 0 As you sit here today, Mr. Snyder, do you recall having 6 an impression of the class as to whether it was properly 7 conducted, whether it was informative?
8 A Again, I -- it's been too long.
9 I had forgotten about that until you had mentioned 10 it. I me an , it's just very vague that there was a 11 class. I really can't say. I don't know. I don't 12 recall.
(~T 13 Q In these classroom sessions, just generally, was the LJ 14 class given a copy of the outline from which the 15 instructor was leading the class?
16 A Well, if it was a procedure change, there should have 17 been a copy given to everyone. Maybe not, though.
18 It could have been read out and the corrected 19 procedure or whatever would be copied and distributed 20 after the class or later in the day.
21 Q Do you have any recollection that this class that you 22 vaguely recall was started and ended on time?
23 A No, sir, I could not say. I do not know.
24 Q Do you recall whether the instructor was present 25 continuously during the instruction period?
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\q N~' 1 A No, sir.
.2 Q Do you remember whether a man named -- well, do you know 3 a man named Jeff Dominique?
4 A Yes, sir.
5 Q Do you recall whether or not he was present at this 6 class that you attended?
7 A No, sir, I cannot recall that.
8 JUDGE GROSSMAN: By the way, this is the kind 9 of answer that we would like.
10 If you don't recall, please don't try to supply 11 what you think anyone is looking for, just what you can 12 recall.
13 THE WITNESS: I can't say and I wouldn't --
14 JUDGE GROSSMAN: It has been a long time and 15 that's a fine answer if you don't have any recollection.
16 BY MR. MILLER:
17 Q Mr. Snyder, were you present in the middle of August 18 when Mr. Seeders and Mr. Saklak had words with one 19 another?
20 A If it's the incident that I think you are talking about, 21 which they got into a little argument, I would say yes, 22 I was there.
23 JUDGE CALLIHAN: 1984, Mr. Miller?
24 MR. MILLER: Yes. I am sorry.
25 BY MR. MILLER:
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\~) 1 Q Prior to that time had you observed any interaction 2 between Mr. Saklak and Mr. Seeders?
3 A No, no personal conf rontations between them two, no.
4 I -- no, no.
5 Q Had you observed any interaction between Mr. Seeders and 6 Mr. Seltmann?
7 A No.
8 Q Would you describe for us the best you can what happened 9 when Mr. Snyde r -- I am sor ry -- when Mr. Seede rs and 10 Mr. Saklak had words?
11 A I don't remember the subject.
12 I was setting there and I believe Rick was asking 13 -- the subject was this. I do recall now. He was 14 asking John, I thought, if he had this done or something 15 about this for the audit finding.
16 They both may be hot tempered men at times. I 17 don't know. They just kind of clashed. You know, 18 words, they got louder.
19 And I can't recall what was said. It was just Rick 20 was wanting something out of John; and John, I don't 21 know what his reply was, but there was friction there 22 and they just kind of boiled over.
23 And I walked out, because I was new on the job and 24 I just didn' t want to get involved in that. I mean, I 25 didn't want to be a witness to it, which I turned out to Sonntag Reporting Service, Ltd.
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O 1 be.
2 But I don't recall what the argument was about, 3 other than the audit finding. I think Mr. Seltmann was 4 involved, some information from Mr. Seltmann that Rick 5 wanted from John.
6 Now, if you are saying that was the middle of 7 August or early August, then it would have been after 8 this, so -- I don't -- you know, if it was involved in 9 this, then this was already finished here.
10 (Indicating.)
11 Q Well, let me just ask you a few questions.
12 When you refer to Rick, you are referring to Rick 13 Saklak?
(VT 14 A Rick Saklak, yes.
15 Q Do you have any independent knowledge as to the date on 16 which Applicant's Exhibit 26, this report, was turned in 17 by Mr. Seeders, if it was, to Mr. Saklak?
18 A No, sir, I do not know.
19 Q All right. When Mr. Saklak first addressed Mr. Seeders, l
l 20 how would you characterize his tone?
l 21 A Again, I cannot recall the exact conversation. He was 22 just asking for something from John.
23 And you know how it is when two people are 24 discussing something, maybe that -- trying to cover l
l 25 themselves or something, I don't know. Maybe they felt C:)
l i
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\~/ 1 defensive towards each other.
2 They just -- Rick wanted something and John said --
3 well, I can't say what John said, because I don't know, 4 but he either couldn't supply it or he had given all the 5 information he could give; and they just was kind of 6 stating that to each other.
7 It wasn't a cussing-out session. It was just loud 8 voices of each other. They are both big men, and that's 9 the reason I got out.
10 (Laughter.-)
11 I don't recall the conversation exactly, so I can't 12 say how it -- how they argued with each other.
13 Q All right. Subsequent to this event, were you 14 interviewed by Mr. DeWald with respect to your 15 recollection?
16 A Before?
17 Q No, after.
18 A After, okay. I am sorry.
19 Q After.
20 A Yes,'<e were. I -- yes, that was the incident where Irv 21 called us -- Irv DeWald called us -- into his office --
22 there wen other people that heard it, too -- and asked l
l 23 us what happened.
24 He was on vacation, I believe, at that time, the 25 manager was; and he just wanted to know why they were O
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2 And I probably should have done my homework and 3 read up on that but I know it's written down --
4 Q We will get to that.
5 A -- what the argument was; but --
6 Q First I would like your best recollection now.
7 When you were interviewed by Mr. DeWald, were you 8 interviewed alone or with others?
9 A Alone.
10 Q All right. Could you describe Mr. DeWald's manner when 11 he -- did he ask you questions?
12 A Yes. You know, that's the way it started out. I 13 suppose anyone could have elaborated on an answer or 14 whatever; but whatever they felt like.
15 It was a pretty calm, quiet session there at his 16 desk; and he was taking notes of what we were saying.
17 There was no secretary there taking notes.
18 He had a habit, I think, of writing stuff down and 19 having it typed up later.
20 Q Did you feel under any pressure from Mr. DeWald to 21 respond to questions in a certain way?
22 A No, sir. I was new. I told him I was going'to be 23 honest; and that's what he, I think, expressed that he 24 wanted and that was the only way to be.
25 So I had no pressure at all. You know, it was just Sonntag Reporting Service, Ltd.
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4017 1 I was a witness to it and told him what I seen.
2 Q All right. After the notes were typed up, were you 3 shown them?
4 A Yes, sir.
5 Q Were you asked to sign the note?
6 A Yes, sir.
~
7 Q And did you do that?
8 A Yes, sir.
9 - Q Again, what, if anything, was said by Mr. DeWald with 10 respect to corrections that you might have had to it?
11 A Well, I think -- I don't know that there was any 12 instructions.
13 If I didn't agree, I wouldn't have signed it.
14 That's basic QC practice, if anything; but he just asked 15 me to read it, I believe, and if I agreed, to sign it; 16 and I suppose that's the instruction.
17 There was no pressure to sign anything.
18 Q I would like to now show you, Mr. Snyder, a document 19 which is a portion of Attachment 5 to Mr. DeWald's 20 testimony.
21 I don't know whether the Board has copies available 22 or not. Do you have another one?
23 Excuse me. Let's see if we can locate other copies 24 for the Board. I apologize.
25 I apologize, Mr. Chairman. I don't know whether O
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(/) 1 the Board has prior transcripts.
2 JUDGE GROSSMAN: DeWald transcript?
3 MR. BERRY: It would be in DeWald's 4 testimony.
5 JUDGE COLE: I was just looking but I don't 6 know what you are looking for.
7 MR. BERRY: It is in there.
8 MR. MILLER: Yes. Thank you very much, Judge 9 Cole.
10 It is also an exhibit to Mr. Snyder's deposition.
11 It's Deposition Exhibit 4.
12 BY MR. MILLER:
13 Q Mr. Snyder, first of all, we are looking at a page in 14 the document that was an attachment to Mr. DeWald's 15 testimony, which bears the Bates Stamp No. 2015.
16 Is that a -- first of all, is that your signature 17 in the lower right-hand corner?
18 A Yes, sir.
19 Q And there is a date of September 26, 1984.
20 Is that the date that you signed it?
21 A Yes, sir.
22 Q How much prior to September 26, 1984, did the interview 23 I with Mr. DeWald take place?
24 A A day or two.
25 Q Now, the best you can recall, are the questions that are Sonntag Reporting Se rvice, Ltd.
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\# 1 indicated there the questions that were asked of you by 2 Mr. DeWald during the course of the interview?
3 A Yes, I would say those are the questions.
4 Q All right. In your first answer -- well, the question 5 establishes that the incident that is being referred to 6 took place on a Friday, August 17, 1984, and your 7 response indicates that you worked with Mr. Seeders the 8 prior Saturday on the review of his calibration records.
9 My first question is: What review of calibration 10 records were you referring to?
11 A Well, it couldn't have been this other exhibit, because 12 the dates wouldn't be the same.
13 So I can just only say here that this had to have
}
14 been part of my training. I see the conflict there of 15 dates; but I cannot recall exactly what review -- you 16 know, a review of calibration records could have been 17 anything. It's not saying what it was.
18 Q Mr. Snyder, during this time period, that is mid July to 19 mid August, did you work with Mr. Seeders on more than 20 one Saturday?
21 A I can't -- I couldn't be sure. I don't recall working 22 with him other than on this project here, but I could 23 not say.
24 (Indicating.)
25 0 All right. When you say, "on this project here," you O
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4020 0 1 were referring to Applicant's Exhibit 26?
2 A Yes.
3 Q The second sentence of your first response says, "Both 4 individuals became very offensive to each other."
5 What did they say to one another that you believed 6 was offensive?
7 A Well, again, I don't recall the language. It's just an 8 argument over some information that Rick needed.
9 You know, you can be loud and be offensive, I say; 10 but I don't think there was a name-calling incident.
11 Q Were curse words used?
12 A I would say no. I think if it was that hot -- you know, 13 I don't think that John would have set there and cussed 14 his boss out, I mean in front of people. I just don't 15 think that happened that way.
16 Q But Mr. Saklak raised his voice, didn't he?
17 A Oh, yes. I believe Rick raised his first and then right 18 away, you know, it's a defensive thing and John -- they 19 both tried to get as loud as the other one, I guess.
20 They weren't screaming on the top of their lungs, 21 but it was loud enough that cverybody could hear it and 22 they were both aggravated, I think.
23 Q You could tell that --
24 A Yes.
25 0 -- from their facial expression?
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1 A Yes.
2 0 The next sentence then says, as you have testified, that 3 you got up and left the room.
4 Was that when they started to get loud with one 5 another?
6 A Yes. It just kept getting louder. One of them would 7 say something and the other guy would get louder and 8 louder.
9 And I just didn't want to hear it. There was other 10 people in the room. I just tried to stay clear of those 11 things.
12 O You then go on to -- the response says that Mr. Seeders
{} 13 14 also became defensive with Mr. Seltmann on a previous occasion.
15 Having looked at this document now, can you recall 16 the previous occasion when Mr. Seeders was defensive 17 with Mr. Seltmann?
18 A Defensive?
19 Q Yes, sir.
, 20 If that's not what I said --
l 21 A I thought you said offensive.
22 Q No.
23 A Yes, I recall.
24 Bob Seltmann is our QA Manager. He was needing the 25 response to that audit finding and he simply asked John O
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.) 1 if the information -- if he had finished the job or 2 whatever; and I don't remember the response, actually.
3 Maybe it was just a defensive response, that he, 4 apparently, didn't have it done yet.
S Q Well --
6 A That's pretty general, I know; but I cannot say what the 7 men said exactly.
8 I know that Mr. Seltmann wanted this response, 9 because there was a deadline, I am sure, on the audit 10 response and it was probably getting close, if not 11 overdue, and they needed the information to answer the 12 audit finding.
13 0 When Mr. Seltmann made the request of Mr. Seeders that
(]}
14 you observed, did he raise his voice to him?
15 A No.
16 Q Did Mr. Seeders raise his voice in response to Mr.
17 Seltmann's request?
18 A Not raise his voice, I don't think. It was probably 19 more -- I call it a cocky attitude, you know, it wasn't l 20 done.
l l 21 I don't think you raise your voice -- I know he 22 didn't raise his voice like the Saklak incident. It was 23 just that he did not have the work done; and I know John i
l 24 was under pressure to get this done as well as get his 25 other work done and he didn't have it done. So --
l
(~)
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4023 1 (Indicating.)
2 Q Did he ask Mr. Seltmann for an extension of time to get
- 3 it done?
4 A I can't recall. I am sure the statement -- the fact 5 came up that he didn't have it done and maybe he wasn't 6 going to get it done, on time, or, you know, it's just 7 then --
8 Q I think you said in the prior response that he had a 9 cocky attitude?
10 A Yes.
11 Q How could you tell that, from the words he used, from 12 his body language?
(} 13 A I would say body language. You know, you can tell.
14 And maybe that's John's nature. I didn't know the 15 man that long. It was a month here, maybe less, that I 16 had been to work.
I i 17 But you can tell people's attitudes, I think, after l
18 you have set around them for a month.
19 Q Did Mr. Seltmann react to Mr. Seeders' cocky attitude?
. 20 A No, not in a -- the manner? You probably want to know, 21 whether it was loud or offensive back to him.
}
22 No. Bob Seltmann is a pretty mild mannered man, I 23 think. I have never really seen him raise his voice to i 24 anyone.
i 25 I am sure he just walked out and continued to O
NJ l
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1 handle it through Mr. Saklak, the Supervisor, which is 2 probably the channel it should have went through to 3 begin with.
4 Q Your last sentence says, "As an outsider just coming 5 into a new environment," I think you have just testified 6 that you were there approximately a month, "Mr. Seeders 7 was instrumental in instigating possible unrest."
8 What did that mean?
9 A Well, at that time we were crowded in a room half this 10 size, 60 some inspectors. Of course, some of them went 11 to the field every morning, but the fire went on that 12 summer at the of fice and forced us all down to one end;
{} 13 14 and it was crowded. People everywhere, loud.
And John's table was out in the middle of the room, 15 about like this, about six people sitting around a table 16 cvice this long I would say, yeah; but my impression was 17 that he just liked for other people to notice him or 18 maybe he would like to crack a joke or make a comment 19 and get a laugh out of the crowd. You know what I am 20 saying.
21 Maybe that's his nature. He is a happy-go-lucky 22 guy and some people just liked to get a response from 23 other people like that.
24 That was -- that's my whole -- well, I said here 25 instigating possible unrest. Well, there was a union O
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(/ 1 problem' going on, there was money problems and John 2 would say his mind, I am sure, out in front of the whole 3 room and anybody else that was of that attitude would 4 make their statements. You know, you could hear 5 everyone talking in the room.
6 He had been there longer than a lot of them; and my 7 opinion was that, you know, they are just statements 8 made, whether it's about management or whatever, that 9 you can get a response from people out of or a laugh or 10 whatever you want to get out of them.
11 JUDGE GROSSMAN: Excuse me.
12 This phrase, "Mr. Seeders was instrumental in 13 instigating possible unrest," were those your words or g(_s) 14 were those an interpretation of Mr. DeWald of what you 15 said?
16 THE WITNESS: Well, I went through this 17 before in my last inte rview; and that's not my words 18 talking there, I really don't believe, although I signed 19 this and I agreed with that.
20 I believe when this was typed up, that it was 21 formalized more. I did say possible -- I don't believe 22 I used that word personally; but I don't know what else 23 words you would use there, you know.
24 JUDGE GROSSMAN: You don't think you would 25 ordinarily say, " instrumental in instigating"? That
! (~
1
(-)'
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4026 1 doesn't sound like your kind of phrase?
2 THE WITNESS: I would say no, but I know I ,
3 said something to that effect, because that was the way 4 I felt.
5 Now, I did sign it. I agreed with that, so, you 6 know, it's a word change maybe -- of course, a word can 7 mean a big difference -- but that's, basically, what I 8 meant, yes.
9 BY MR. MILLER:
10 Q I think you said --
11 A And maybe I elaborated too much there, because --
12 Q No, sir. I think it was quite helpful, because you told s 13 us, essentially, what you observed and that was the I
14 thrust of my question.
I 15 You did say that John was surrounded by other 16 inspectors at this table, that is John Seeders, and that 17 he would crack jokes.
18 Were the jokes directed at the management of 19 Comstock generally or individuals?
20 A Well, I would say both, you know, because there was such 21 friction there, I could feel it; and then to be all put 22 in one room like that for eight or ten hours a day, he 23 had seen more of what went on than I had because he had 24 been there longer.
25 A lot of the people were just fed up with what was O
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( l going on and their morale was poor, which led them to 2 make statements like that against management or against 3 any individual.
4 Q Also in your prior answer -- and if I don't have the 5 words exactly right, I apologize; but I think you 6 referred to a labor situation or a union matter, union 7 problems going on.
8 What was the nature of that problem as you observed 9 it in the summer of 1984?
10 A Well, I knew enough -- I don't really -- I knew very 11 little about the union at this point.
12 I know a couple of people had joined this union, 13 which is a nationwide Local 306; and they were starting O 14 to spread the word around the other inspectors that this i
15 union could support them or give them some support, you 16 know, on the job.
17 So I think people were looking ahead; and just a l 18 couple of months prior to this, from my understanding 19 after I got there, that people had been given a 4
20 significant raise, maybe to keep them happy, maybe. I 21 don't know.
22 I am saying there was a lot of tension about money.
23 They were bringing people in for more money than many 24 people that had been there for five years and that's 25 going to cause problems, especially when they were told O
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1 that that wasn't happening and the people found out it 2 was happening.
3 And at that time there was no work available. You 4 know, you would say, "Go get you another job if you 5 don't like it"; but in '84 like that there was no other 6 jobs of that caliber to go to; and a lot of these people 7 had been here or lived in the area all of their life and 8 didn't want to go out of state to find another nuclear 9 job.
10 Q Did you ever hear anybody suggest to a QC Inspector who 11 was complaining about something, if they didn't like it, 12 they could go find another job?
13 A Well, that's a pretty widely-used phrase. I don't know, 14 you know. "If you don't like it, you can be replaced,"
15 you know, or, "You can find you another job, you know, 16 quit complaining."
17 I think you hear that today. It's not by l 18 management, I wouldn't say.
19 You just -- you hear your fellow buddy over here 20 gripping or something, you say, "Well, go get you 21 another job or go find you a better job, you know," but 22 they wasn't going to do that, so they have to voice 23 their opinion.
24 Q In mid August you have been on the jobsite approximately 25 six, seven weeks, I guess.
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(/ 1 How long did it take you to feel this tension that 2 you have described with respect to money?
l 3 A Within two or three weeks, maybe less. I mean, maybe 4 two weeks, you know. I 5 It was just after you get out with the people -
6 well, my first week I spent in a trailer, where 7 management was, reading and you stay away from the other 8 inspectors kind of that way. Not that you are isolated 9 from them but you just have to read; and because of the 10 fire, that was the only place to go.
11 I didn't do my reading up in this room full of 12 inspectors; but when you are finished with that, then 13 you go out with them.
14 So a couple of weeks. It didn't take long, you 15 know.
16 Q Did Mr. Seeders ever discuss the money problem, the pay 17 problems, with you?
18 A No. It was just a -- you could probably talk to anyone 19 and they would discuss it with you, any inspector, or l 20 they knew what was going on.
21 I didn't have to really ask him or anyone, really.
22 You just got to listen, open your ears; but it was --
23 they were making very little money compared to a lot of 24 other jobs of this caliber.
25 And then they were promised more money, they were O
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<g kJ l given more money and then they were still hiring people 2 in for more money than that, and that --
3 Q Did you fall into that category, Mr. Snyder?
4 A No, sir. I started at 12 an hour. There was people 5 there making $16 an hour.
6 I was laid off, which wasn't mentioned, between my 7 Marble Hill job and this job for six months, because of 8 the lack of work, and my lack of experience, really.
9 Marble Hill was my first nuclear job, but I heard people 10 that were making more money, 11 Q Did you ever -- I think you talked about, in a prior 12 response, jokes that were directed at management 13 generally and at specific individuals as well.
14 Were any of those jokes ever told in the presence 15 of a particular individual they were about?
16 A No, I would say no.
17 You see, the room had a door on it we could close 18 and the management's office was down the hall.
- 19 They -- I remember it was said and pretty widely 20 known that Irv DeWald wouldn't come into the room 21 because he might catch somebody goofing off and he 22 didn't want to come in there and be faced with that.
23 You know, I mean, it was more or less a pretty 24 relaxed attitude there in that room; but if you had a 25 job, you went out in the field and done it and then you
(_
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, () 1 come back to that room.
2 That's where y'our desk was. It was just a counter 3 along the wall and you sat beside other inspectors. You 4 had people on both sides of you, very crowded.
5 Q What was your understanding of why Mr. DeWald wouldn't 6 want to come in and catch inspectors goofing off, I 7 believe were the words you used?
8 A Well, a lot of these people had worked with him as an 9 inspector, maybe, and I don't think wanted to be put on 10 the spot to have to fire somebody right there in front 11 of everyone else. That would be my opinion of it, 12 because a lot of people were just setting there all day 13 not doing anything, anyway.
s 14 He could have come in there. If you wanted to 15 manage a job with a firm hand, you could have came in 16 there and fired several people at any time of the day 17 for goofing off.
18 0 When you say goofing off, you mean not doing their 19 inspection functions?
20 A Yes. They may have papers in front of them, which, you 21 know, could make them look like they would be working; 22 but they would be over here, over there, talking, you 23 know.
24 (Indicating.)
! 25 It was just a pretty relaxed attitude there.
l l
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4032 (G~) 1 Did you ever observe Mr. Seeders goofing off?
Q 2 A Oh, I am sure.
3 Q Getting back to the interview, Mr. Snyde r, the question 4 as shown on the document is: "Do you feel that there is 5 harassment and intimidation?"
6 Do you see that?
7 A Yes, sir.
8 Q Are the words, " harassment and intimidation," the words 9 that Mr. DeWald used when he asked the question?
l 10 A I would say, yes.
11 It appeared when Irv got us in there that he knew 12 the questions that he was going to ask.
13 There is quite a difference in time here. He was
(]}
l 14 on vacation. This is a month later, it looks like to 15 me, at least; and I would say those were his questions, 16 yes.
17 Q Did he tell you what he meant when he used the words, 18 " harassment and intimidation"?
i 19 A No.
20 0 When he asked you that question, what did you understand 21 that he meant?
l 22 A People being picked on, maybe, by other people, whether l
23 -
it be management or whatever, or threatened to do 24 something that they didn't want to do.
25 You know, it's pretty general. You don't hear it a Sonntag Reporting Service, Ltd.
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\- lot anymore; but that's -- I can't explain it without a 1
2 dictionary any better than that. You know, I --
3 Q Your explanation is what we are after here.
4 Then your response as recorded there refers to one 5 specific occasion with Mr. Seltmann.
6 Beyond that one statement, Mr. Snyder, did you make 7 any general comments that you can now recall to Mr.
8 DeWald?
9 A No, sir. The reason it looks like I made this because 10 up in this above response we got to talking about Mr.
11 Seltmann's involvement with John and asking him, talking 12 with him.
(} 13 14 So, apparently, I just got going there and couldn't shut it down.
15 Q There you described Mr. Seeders as being offensive, and 16 I don't mean to hold you to the precise words; but did 17 you mean to denote anything other than what you have 18 already testified about, that is this cocky attitude?
19 A No. That offensive, it could be verbal, I think, or 20 cockiness. It wasn't a physical thing.
21 Q Now, the next question is, "What do you feel is the 22 root cause of the morale problem?"
23 At that point in time, Mr. Snyder, did you believe 24 that there was, in fact, a morale problem?
25 A Yes.
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1 Q Was that for all the reasons that you have just 2 testified to here earlier?
3 A Yes.
4 I forgot to mention training, but it was very much 5 a part of this. These new people were coming in and 6 management was telling the inspectors that had been 7 there to train these new people, a new guy that was 8 making $4 more an hour than him or whatever.
9 And that right there was a big problem, train him 10 to maybe take this guy's job, you know; and, besides 11 that, the training program was brand new then and some 12 people just felt like they didn't want to train other I
13 people.
O- 14 There was one person that I remember that way, that 15 he didn't want to train anyone. I don't know whether it 16 was fear he couldn't train someone or he didn't want i 17 someone to know what he was doing or maybe losing his 18 job.
19 You know, it's a combination of those things.
l l 20 Q Who was that individual?
! 21 A It was my lead, Larry Phillips.
22 When it was my turn to train in receipt inspection 23 with him, he had trained one other person before that; 24 but it was widely known that he didn't want to train l
25 anybody and he didn't want any more training. He just 1
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('T ,
(~/ 1 wanted that job and let it alone, you know. '
2 Q Do you know: Did Mr. Phillips indicate to you why he 3 wanted that Material Receipt Inspector's job?
4 A Well, he had done it for years. He has probably been 5 there longer than any inspectot n ow .
6 He is still doing the same job.
7 Q Is material receipt inspection more or less strenuous 8 than some of the other inspection tests?
9 A Maybe at times it's more demanding as far as -- if you 10 get two or three trucks in at one point, then you 11 cannot. You have to have help.
12 He did it by himself then and he still does, but I 7 13 don't know. That was his attitude about it.
~
14 Q Did you ever have any indication from Mr. Seeders that 15 he didn't want to train you because of the factors that 16 you described previously?
17 A No, I don't think -- I never recall that.
18 He might not have wanted to in his mind but he 19 never told me that.
20 Q Other than telling you, did you have any other 3
21 indication of an unwillingness to train you?
22 A No. You see, all of these people, who, all of a sudden, j 23 were told to train people what they knew or how to do 24 something, they were maybe unsure themselves of how they 25 were going to train people.
()
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4036 O 1 They didn't want, maybe, other people seeing how 2 they were doing things; and that never happened, I don't 3 think. They were never being monitored.
4 So more or less this was somebody looking over 5 their shoulder all the time; and it might scare some l 6 people, you know.
7 Q Did you tell Mr. Seeders that you had been in training 8 as a Calibration Inspector at Marble Hill?
l i 9 A Yes, he knew that. ;
10 Q Did you tell him about the differences that you observed 11 between practices at Braidwood and practices at Marble l 12 Hill?
13 A I probably did make some comments. I don't recall any.
)
14 There was differences, because I worked for the 15 piping contractor at Marble Hill, and you don't have the 16 same tools with the electricians. You have torque 17 wrenches and rod ovens. That's about the only similar i
18 tools there.
19 So I am sure there was discussions there on that.
20 When you are with a guy 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> or more, you are going 21 to talk about your old job and all of that.
22 Q But I take it you had a generally friendly and cordial 23 relationship with Mr. Seeders?
l 24 A Yes, yes.
l 25 0 The last question in your interview with Mr. DeWald asks
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) i 1 about your observation of Mr. Saklak. Again the words, 2 " harassment and intimidation," were used.
3 At that point in time, which is August of 198 --
4 August, mid August, 1984, had you had occasion to 5 observe Mr. Saklak?
6 ;A Yes. His office was in our room there where we were all 7 crowded. He had a desk there in the center there, also, 8 kind of . facing the f ront of the room.
9 Yes, I seen him every day.
10 0 Well, was Mr. Saklak present when inspectors were, again 11 to use your words, goofing off?
12 A Well, I am sure he was at times.
() 13 He -- he was out a lot, too, trying to train -- get himself trained; and at that same time they were setting
! 14 15 up a field office in' the building out in the plant, so 16 he could take so many people out there and they could 17 take care of this crowded problem, I think.
18 He was md a :. 'ot.
i 19 -
0 When he was preetat in this office with the QC ,
l 20 Inspectors, did he ever reprimand an inspector for l
l 21 goofing off?
22 A Not prior.to this, that I witnessed, t
i 23 Q Prior to the time that you gave the answers to Mr.
24 DeWald that'are recorded in that statement, had you I
25 observed Mr. Saklak being loud, in addition to the O
%J l
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l 4038 1 dispute with Mr. Seeders that you have previously 2 testified to?
3 A Well, he was a big man and a loud voice. I am sure he 4 raised his voice maybe. I don't know what at that time.
5 He just had a way of being strong voiced, anyway.
6 Q But that was a characteristic that you observed almost 7 from the first?
8 A Yes. I don't recall him shouting at anyone prior to 9 that.
10 Q All right. There are some QC Inspectors who have loud 11 voices, speak loudly?
12 A I suppose there are, yes.
13 No, he was just a big man. I think he was probably 14 the biggest one; and size has nothing to do with voice, 15 I guess; but his, for some reason -- maybe being the 16 boss, too, that made you notice his more, too; but you 17 can be -- anybody can be loud, I suppose, when they want 18 to be.
19 Q Prior to #his time did you ever hear Mr. Saklak using l 20 obscenities or curse words when he talked to an l
l 21 inspector?
22 A Well, not as far as jumping on somebody.
l 23 Q Just in normal conversation, so to speak?
l 24 A Yes. There was a lot of that going on out there.
25 Q Not just Mr. Saklak?
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4039 n'~' 1 A No, no. Right, it's true.
2 MR. MILLER: Your Honor, I have finished my 3 examination of Mr. Snyder on this document. I am going 4 to move onto another subject matter altogether.
5 If the Board would like to take the luncheon recess 6 now --
7 JUDGE GROSSMAN: I have one or two questions 8 on this and maybe that will take the time.
9 Maybe they were answered, but I see that you signed 10 two different places. You signed after the first three 11 questions and then you signed again after the fourth 12 question.
13 What is the reason for that?
[}
14 THE WITNESS: I think it was because of the 15 change of pages there, no other reason.
16 Maybe I got in a hurry when I signed it and just 17 signed -- no, no, that couldn't have been. I had to 18 read the thing.
19 It was just the two different pages. If it was all 20 on one page, I think one signature would have covered 21 it.
22 JUDGE GROSSMAN: But you were only in there 23 at one time?
24 THE WITNESS: Yes.
25 JUDGE GROSSMAN: It was all at one session?
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1 l 4040 O( / 1 THE WITNESS: Yes, sir.
2 JUDGE GROSSMAN: Now, you signed it not on 3 the date of the interview, did you?
4 THE WITNESS: No, sir. This was typed later.
5 That's what I just sitting here and noticed. I 6 told you a couple of days. It could have been a lot 7 longer because of these dates here. I don't know.
8 This incident happened on August 7th and I signed 9 it five weeks later; but our manager was on vacation; 10 our assistant, apparently, didn't want to get involved 11 and held it till our manager came back.
12 So he might h' ave been gone a couple of more weeks.
13 JUDGE GROSSMAN: How long was your interview 14 I with Mr. DeWald?
15 THE WITNESS: Ten, 15 minutes.
16 JUDGE GROSSMAN: Ten or 15 minutes?
17 THE WITNESS: Yes.
18 JUDGE GROSSMAN: This reflects four questions 19 and answers?
20 THE WITNESS: Yes.
21 JUDGE GROSSMAN: Is this what you recall was 22 the amount of questions and answers during that ten or 23 15 minutes?
24 THE WITNESS: Yes, sir, now.
25 JUDGE GROSSMAN: Now, looking at that first O
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1 response, in the second sentence, you indicate that both 2 Mr. Saklak and Mr. Seeders became offensive to each 3 other?
4 THE WITNESS: Yes.
5 JUDGE GROSSMAN: Do you see that?
6 THE WITNESS: Yes.
7 JUDGE GROSSMAN: Now, when you get to the 8 last sentence, you seem to single out Mr. Seeders as 9 being instrumental in instigating possible unrest.
10 Did you mean that only Mr. Seeders was instrumental 11 or were both -- or could Mr. Saklak have also been 12 instrumental?
gg 13 Do you understand what my question is?
LJ 14 THE WITNESS: You are right, and that's true.
I 15 You see, I am not trying to cover this now: but with 16 this lapse of time, I agreed with this, what was said 17 here.
18 Now, something could have been left out and I 19 wouldn't know it.
20 JUDGE GROSSMAN: Okay. When you say I am 21 right, I am not trying to tell you what the answer is.
22 THE WITNESS: No. I am --
23 JUDGE GROSSMAN: I am just trying to ask what 24 your recollection was and whether you intended to 25 exclude Mr. Saklak here --
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1 THE WITNESS: Yes.
2 JUDGE GROSSMAN: -- or whether that wasn't 3 what you had said, it was only part of what you said, 4 you see.
5 We are trying to find out what was said in the 6 inte rview.
7 THE WITNESS: Well, I am sure I, basically, 8 said that statement.
9 Now, whether it was asked in a different question 10 form, I could not -- I could not -- you know what I am 11 saying.
12 JUDGE GROSSMAN: Okay. In other words --
e 13 THE WITNESS: My answer could have been 14 merged in with this other response. I have no way of 15 knowing now and I wouldn't have had a way of knowing 16 then and I did not see the notes to compare -- that I 17 recall I did not see the notes to compare -- this with, 18 the notes that Irv made.
19 JUDGE GROSSMAN: Let me ask you of your 20 recollection now, not of the interview but of the 21 incident.
22 Would you say now that only Mr. Seeders was
, 23 instrumental in instigating possible unrest?
24 THE WITNESS: Unrest.
25 JUDGE GROSSMAN: Or that both of them were A
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'# 1 instrumental in instigating possible unrest?
2 MR. MILLER: Your Honor, excuse me.
3 I believe my prior examination of the witness 4 indicated that that sentence had a much broader meaning 5 than just the argument between Mr. Seeders and Mr.
6 Saklak.
7 I have no objection to the Board's question with 8 respect to probing the witness's recollection on that 9 incident or, indeed, the possible unrest; but to combine 10 the possible unrest language and tie it specifically to 11 the Saklak/ Seeders incident I believe gives it a 12 narrower construction than the witness has previously 13
("}
U testified here.
14 MR. GUILD: But, Mr. Chairman, the context 15 that reads in the sentence is clearly tying the unrest 16 to the specific instance. It goes on to state, "The 17 incident appeared to be a shouting match."
18 Mr. Miller may have broadened the concept in his 19 own questioning of the witness; but the fact remains 20 that I think the Chairman's question is consistent with 21 the language that appears on the document. The unrest 22 is tied clearly in the same sentence to the incident.
23 JUDGE GROSSMAN: Okay. Again, I want to 24 point out to the witness: I am not looking for any i
25 answer in particular.
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! 1 I just want your impression now of that incident ;
2 involving Mr. Saklak and Mr. Seeders and in particular 3 with regard to who was instrumental in instigating 4 possible unrest.
5 Is it your recollection now that it was only Mr.
6 Seeders -- that it was Mr. Seeders, that it was only Mr.
7 Seeders or that it was both Mr. Seeders and Mr. Saklak?
8 THE WITNESS: I would say both. No one man 9 said or did more than the other in that incident.
10 If I could say, after reading this, if I recall, 11 the way that is worded there in my response, is I am not 12 sure if that statement was tied to the Saklak/ Seeders
{} 13 14 incident.
If you read that -- maybe I am looking at it 15 deeper, because I know at the time there was friction
- 16 between Rick, Rick Saklak, and John.
i 17 And I believe in my honest opinion there was a case l 18 being built against Mr. Seeders as far as his work that 19 he was performing; and I may have been asked a question i 20 that I responded this way to, you see; but in that 21 incident neither one was more instigating than the l
22 other.
1 1
23 JUDGE GROSSMAN: Okay. You wished to break 24 for lunch now, Mr. Miller. I guess it's time.
25 MR. MILLER: Please, I --
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4045 b) 1 JUDGE GROSSMAN: If you want to follow up on 2 that, certainly.
3 MR. MILLER: Yes, I do, your Honor.
4 BY MR. MILLER:
5 Q Mr. Snyder, you said it was your belief that there was a 6 case being built against Mr. Seeders?
7 A Yes, sir.
8 Q On what did you base that belief at the time that you .
9 had your interview with Mr. DeWald?
10 A (No response.)
11 Q Well, let me back up. I apologize if I am confusing 12 you.
{} 13 At the time you had your interview with Mr. DeWald 14 in August of 1984, did you believe that there was, to 15 use your words, a case being built against Mr. Seeders?
16 A I cannot really answer that, because of the fact I don't 17 know when I was assigned to start the research in the 18 vault of the calibration files.
19 Now, if there is a.date there somewhere -- because, 20 you see, we are getting involved in dates and my memory, 21 also.
22 And I cannot say that, actually. I know that the 23 audit was there at this time.
24 0 Which audit, the earlier audit finding that you talked 25 about?
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4046 O 1 A That's right, the Ceco audit that this response was for.
2 And I know that John's opinion, I am sure -- this 3 is my opinion now -- was that he was being watched very 4 closely by management.
5 Q Mr. Seeders will have a chance himself to discuss that.
6 A Okay.
7 Q But when you say that there was a case being built 8 against him, what process are you attempting to 9 describe?
10 A Well, I was told to go to the vault, 11 I wasn't certified until October. So I was 12 basically with not a lot to do.
(} 13 So I believe it was Rick Saklak that assigned me to 14 the vault to start from the first package, the first 15 tool, and go through them all.
16 Myra Sproull was also told and Don Coss was 17 involved a little bit, also, and all three of us were 18 down there.
19 And it could have been involved with this audit 20 finding again; but as we researched more and more, it 21 was evident that there was problems there and deeper 22 than this audit response here.
23 (Indicating.)
24 Q When you say, "this audit response," you are referring 25 to Applicant's Exhibit No. 26, the handwritten document?
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4047 a
1 A Yes.
2 0 Were your instructions -- well, what were your 3 instructions from Mr. Saklak when he made this 4 assignment to you to do this records review in the 5 vault?
6 A There was nothing in writing. It was just -- we was 7 told to find the problems or find any problems that were 8 in the vault.
9 Myra Sproull was certified and so was Don Coss in 10 calibrations. I wasn't. So I think that's why they 11 were sent down there as certified people, too.
12 It was just anything we might run across that might
( 13 be wrong or not proper.
14 0 Well, what, if anything, was said by Mr. Saklak in his 15 conversation where you were told to find anything that 16 was wrong about Mr. Seeders?
17 A Nothing that I recall.
I 18 MR. MILLER: That is all I have.
19 JUDGE GROSSMAN: I have just one question to 20 follow up on that.
21 You said that you couldn't tell when you began to 22 believe that a case was being built up against Mr.
j 23 Seeders unless you had the date in which you were 24 assigned to the vault to see if there were any mistakes.
l 25 '
Is that the date on which you began to believe that
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4048 O 1 a case was being built against Mr. Seeders?
2 THE WITNESS: No, I would say no, not that 3 initial date.
4 The reason I was questioning the date was because 5 he wanted to know if I thought there was a case being 6 built prior to August 17th; but, you know, it was a 7 pretty close, tight-knit group there; and I was still 8 training with John, apparently, at that time.
9 And I am sure things were said that Rick was --
10 whether he was out to get John or whether he was trying 11 to build something against him, they just had a 12 personality clash; and, apparently, they couldn't forget
(} 13 it as individuals.
14 JUDGE GROSSMAN: Fine.
15 MR. MILLER: Could I have the last answer 16 read back, Mr. Reporter, please?
17 (The answer was thereupon read by the 18 Reporter.)
19 BY MR. MILLER:
20 0 My only question, Mr. Snyder -- and you have been on the 21 stand now for a long time without a break and I 22 appreciate that -- is:
23 Did Mr. Saklak make the statement or was that John 24 Seeders' speculation that you were reporting in your 25 last answer there, somebody was out to get him?
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4049 r^g O 1 A Well, that would have been John's speculation.
2 Like I said earlier, he felt the pressure. He may 3 have known he had problems, paper work problems in the 4 vault -- he should have known -- and that could cause 5 him to become defensive about the thing and feel like he 6 was under the gun then because he did have problems and 7 that he would be nailed for them.
8 MR. MILLER: Okay. This is --
9 JUDGE GROSSMAN: Fine. Why don't we recess l 10 until 1:15.
11 (WHEREUPON, the hearing of the 12 above-entitled matter was continued to
(} 13 the hour of 1:15 P. M.)
14 15 16 17 18 19 20 21 22 23 24 (2)
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\_]
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 OL COMMONWEALTH EDISON COMPANY : 50-457 OL 7 :
(Braidwood Station, Units 1 :
8 and 2) :
- _L
- __ ___L: __L lx 9
10 Met pursuant to recess. i 11 Thursday, June 12, 1986.
1:15 P. M.
12
) 13 14 JUDGE GROSSMAN: Let's go back on with the 15 hearing.
16 The hearing is reconvened, and, Mr. Snyder, you've 17 been sworn and you still remain under oath.
18 Mr. Miller will continue examining you.
19 MR. MILLER: Your Honor, at this time I'd 20 like to move Applicant's Exhibits 24, 25 and 26 into 21 evidence.
22 MR. GUILD: Mr. Chai rman, I have no objection 23 as to 24 and 25.
24 As to 26, I have no objection as to the pages of l
25 the exhibit that Mr. Snyder identified as representing l
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4051
() I his work.
2 I'm not certain for what purpose, if for any 3 limited purpose, Applicant offers the balance of 26, 4 which is Mr. Seeders' -- apparently Mr. Seeders' work.
l'
! 5 MR. MILLER : Your Honor, I think that the 6 relevance and materiality of the document to one of the 7 central issues in this case is apparent.
8 It's true that Mr. Seeders hasn't come yet to 9 authenticate it, but I don't believe there's any quarrel 10 about the fact that it's his work product.
11 JUDGE GROSSMAN: Is there a problem with I
i 12 authenticity, Mr. Guild?
() 13 MR. GUILD: Well, all I can say is that as I 14 recall -- perhaps Mr. Miller can just tell me -- I don't 15 recall ever seeing the Snyder portion of the document.
16 Now, Mr. Snyder indeed has authenticated that, and 17 that's not objectionable.
18 But if it's being represented as -- being i 19 represented by Mr. Miller as a certain thing -- and Mr.
l l 20 Seeders is really the only witness to competently .
21 testify about what the totality of the document 22 represents -- I do object to putting the document in, l 23 other than through Mr. Seeders, in its totality.
, 24 It's not an authenticity question per se. The 25 document appears to be a document in part that I've seen i
^
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4052 1 before, but it really goes to what the document should 2 stand f or and of what evidentiary significance it may 3 be.
4 MR. MILLER: The document does, in fact, bear 5 an exhibit stamp f rom Mr. Seeders' deposition. The 6 number is obliterated on the copy that's tendered to the 7 Board in evidence, but it's Seeders Deposition Exhibit 8 25 and, in fact, it has all the pages that this copy 9 has.
10 (Indicating.)
11 I will say Mr. Seeders, when he was examined about 12 this at his deposition, had a recollection that there I
(]) 13 was more to the document than just these pages; but he 14 never suggested that somehow this was not at least a 15 part of the document that he had prepared in July of 16 1984.
17 MR. GUILD: I would just ask that the 18 admission be conditional, subject to -- Mr. Seeders is 19 going to testify, it's clear -- that the admission be 20 conditional, subject to Mr. Seeders' examination on the 21 document.
22 JUDGE GROSSMAN: Okay. In other words, j 23 unless some problem arises with regard to the document, 24 Mr. Guild has no other objections; so other than that, 25 we'll -- did Staff have any objection?
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4053 1 MR. BERRY: With the limitation announced by 2 the Board, Staff has no objection.
3 JUDGE GROSSMAN: Okay. So we'll admit those 4 documents at this time and only reopen the question of 5 Applicant's Exhibit 26 if a problem arises in the 6 future.
7 (Applicant's Exhibits Nos. 24, 25 and 26 i
8 for identification were thereupon 9 received in evidence as Applicant's i
10 Exhibits Nos. 24, 25 and 26 in evidence.)
11 MR. MILLER : Thank you, your Honor.
12 I'd now like the Reporter to mark as Applicant's Exhibit 28 a document that's 27 pages. It bears the
(]) 13 14 title " Calibration Audit Report, 9/7/84."
15 (The document was thereupon marked 16 '
Applicant's Exhibit No. 28 for 17 identification as of June 12, 1986.)
i 18 BY MR. MILLER :
19 Q Mr. Snyder, you have a document in front of you that's 1
20 been marked as Applicant's Exhibit 28 for 21 identification.
22 MR. GUILD: 277 23 MR. MILLER : 28.
24 MR. GUILD: I'm sorry.
25 '
MR. MILLER : The audit report is 27, and we Sonntaa Reporting Service, Ltd.
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4054 O 1 didn't yet make additional copies of it.
2 MR. GUILD: I see.
3 MR. MILLER: It has not been moved into
,4 evidence yet, either.
5 JUDGE GROSSMAN: Well, with regard to 27, my 6 recollection is that it wasn't identified by the 7 witness.
8 MR. MILL ER : Correct.
9 JUDGE GROSSMAN: Okay.
10 BY MR. MILLER:
11 Q Now, Mr. Snyder, have you seen this document bef ore, 12 sir?
Yes, sir.
(]) 13 A 14 0 And was this prepared by you and Myra Sproull on or 15 about September 6th of 19847 16 A Yes. It was information that was compiled over two or 17 three months there -- two -- two months, probably.
18 We had written it out in longhand, but this is a 19 typed version of it.
20 Q You say that it had been compiled over two months?
I 21 A Well, this information back here is -- is what our i 22 findings was in the vault packages that we were sent 23 down there to determine if there was any problems that 24 we could see.
25 (Indicating.)
Sonntag nepor*ing carnica fFa-Geneva, Illinoi s 60134 (312) 232-0262
4055
, O 1 Q All right.
2 Well, taking back two months from September 6th 3 would put us I think to July 6th.
4 Do you believe that you started on this work on 5 July 6th?
6 A No. I guess the time seemed longer than what it was.
7 (Laughter.)
8 Maybe it was a month, then.
9 0 Well, prior to the luncheon recess, Mr. Snyder, you were 10 testifying about the assignment that you were given with i
11 respect to a review of the records in the vault; that 12 this document is the -- that is, Exhibit 28 -- is the Q 13 end product or at least a partial product of that 14 review; correct?
15 A Yes, sir.
16 Q All right.
17 Were you given that assignment after you observed 18 the disagreement between Mr. Saklak and Mr. Seeders on 19 which you were examined before lunch?
i 20 A I would say yes.
21 0 Okay.
22 Can we agree that that date is August 17th?
23 So sometime af ter August 17, 1984, you were given 24 the assignment to do the records review involved; is 25 that right?
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4056 1
1 A That's correct, yeah.
2 0 Okay.
3 Now, do you recall which individual gave you the 4 assignment?
I 5 A It was Rick Saklak, our supervisor.
6 Q And what did Mr. Saklak tell you the nature of your 7 assignment was?
8 A Just to go and review the vault packages on all 9 calibrated tools to come up with any problems -- and 10 write them down -- that we might find in that package, 11 paper problems.
11 Q And just as a matter of clarity, I notice that there's a l
C 13 reference to the Form 77 on the first page of Exhibit 14 28.
15 Did you, in fact, review Form 77's?
16 A Yes, we did.
17 Q All right.
18 And I think you testified earlier that Form 77's 19 are in this file cabinet.
20 Is that kept in the vault, also, sir?
l
! 21 A At night, yes, it's taken to the vault.
22 0 I see.
l l 23 Can you tell, from looking at this document --
24 well, let me back up.
25 I see that it's signed -- or there's your typed Sanntag napar*ing Saruira: r.t a _
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4057 1
O 1 signature and the typed signature of Myra Sproull.
2 Can you tell, by looking at the document, whether 3 you prepared a particular page or entry or Miss Sproull 1
! 4 did?
5 A No, sir. That could only be told on the originals that 6 -- my handwriting f rom her handwriting.
l 7 There was a third inspector, as I mentioned 8 earlier, Don Coss. He done very little of it. I guess 9 thats why his name is not on here as signing this -- or l
10 a part of this.
11 Q All right.
12 You point out -- or there's a statement made on No.
() 13 8 on the first page that the estimated completion date 14 is September 21, 1984.
! 15 Do you recall whether that review was complete as 16 of September 21, 19847 17 A No, sir, I don't recall. I have no idea.
I 18 0 I'd like you to turn, if you would, to the second page 19 of Exhibit 28.
20 Can you tell us what this page represents?
21 A Well, since we didn't have any direction, really, on 22 what to -- what,we were finding, we kind of made up our 23 own sheet here to chart the problems, more or less, that 24 we found.
25 Basically that's what these are. This upper lef t Sonntaa Reportino Service, Ltd.
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4058 O 1 corner says "no ICR written for out of calibration."
2 That "TW" is torque wrenches.
3 Those are all torque wrench numbers there, tool 4 numbers that when we reviewed that package of those i 5 tools, we found an incident where there was a report in 6 the package saying the tool was out of tolerance on 7 such-and-such a date and no evidence of it being written 8 up on an ICR.
9 Q How did you determine whether or not there was an ICR 10 written up?
11 A Well, there apparently was no -- no mention of it on the 12 Form 77, which we had already reviewed; and there was no
() 13 mention of it on the 23 form, which was rejecting the 14 tool. So we weren't told to go to the ICR file.
15 See, they have an ICR file over here and 16 calibration file over here; and that vault is so small, 17 people working in there daily, and we were kind of in 18 the way.
19 (Indicating.)
20 For time's sake, we just -- we weren' t told to 21 bounce off of the ICR log and see if this was actually 22 written up, be.cause it was just too time-consuming, you 23 see.
24 Q So these weren't checked against the ICR log?
25 A I -- there's more paper than this to the original snnneng nonnrei ng servi c. . r+a.
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l 4059 1
O 1 because I -- I'm thinking that we went through the ICR 2 log bef ore we started all of this.
3 Anytime a calibrated tool was mentioned as being 4 written up, we recorded that on a piece of paper so that 5 we could have some more information to bounce off of.
6 Now, it's not in this, evidently, and the 7 inf ormation where we reviewed the Form 77 's aren' t in 8 here, either, that I see.
9 But that's -- I know we went through the ICR log, 10 but it was not af ter we had found the problem in the 11 vault, I would say.
12 Now, we might have bounced the list here in the
, O 13 vautt-14 0 I'm sorry. I'm getting a little bit confused, Mr.
15 Snyder.
16 A Okay.
17 It's just that we had a list here f rom the ICR log.
18 0 Was that the first thing you did: create the list f rom
! 19 the ICR log?
20 A I believe so.
l 21 And then we went to the 77's, made another list 22 just basically like I had made on this exhibit here.
I 23 (Indicating.)
24 Q On Exhibit --
25 A I don't know what --
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4060 0 1 0 -- 26.
2 A And then we went to the vault, because we had to have 3 something to go by.
4 We knew the vault packages did not have copies of 5 the ICR's in the tool folder itself. They should have 6 had, really, to clarify the whole story; but they never 7 did do it that way, so --
8 Q Getting back to the second page of Exhibit 28, each of 9 these blocks represents a category of discrepancy in the 10 calibrated tool records; correct?
11 A Yes, sir.
12 Q All right.
And what did you -- or what document did you
(]) 13 14 reference, if any, to determine whether a discrepancy in l 15 the record was something that you ought to be keeping 16 track of?
17 A Well, all we had was our procedure, 4.9.1 Rev. C, to 18 fall back on --
19 0 Okay.
20 A -- because, like I said, we had no written instructions 21 on what we were to be doing down there.
22 The first few days we were kind of lost, I think, qg/hd$23 until we got -- determined how we was going to go about 24 this, because we never really had anybody down there 25 telling us what we were doing.
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4061 0 1 Q All right.
2 Your only instruction was to make a complete 3 review --
4 A Right.
5 0 -- of the documentation?
6 All right.
7 Now, if you could just look at the precedure -- I 8 believe you have a copy of it in front of you.
9 A Yes.
10 0 It's Exhibit 24 in evidence.
11 Just for the record, would you point the Board's 12 attention and that of the parties to the provision of 13 the procedure that was violated by the record
(])
14 discrepancies that you recorded?
15 MR. GUILD: Objection. That supposes the 16 answer to the question that hasn't been asked, and that 17 is whether or not the discrepancies were in violation of 18 any particular procedure.
19 MR. MILLER: I think that was the witness' 20 testimony two minutes ago.
21 MR. GUILD: I don't think it was. I think 22 the. witness' testimony was he had no direction, so all 23 they did was they went by the procedure.
24 But that does not presuppose the fact that you 25 supposed in your answer -- in your question; excuse me.
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l A
O 1 MR. MILLER: I believe the witness has l
2 testified, your Honor, that --
- 3 JUDGE GROSSMAN
- What procedure did you go 4 by, Mr. Snyder?
5 THE WITNESS: The current procedure at that 6 time, which was Rev. C, Revision C. .
i 3 7 JUDGE GROSSMAN: Okay.
8 I believe he did mention that, and now he's being 3
9 asked where in the rev procedure did he find what was 10 required that wasn't performed.
7 11 Isn' t that basically the question?
.I
! 12 MR. MILLER: Yes, sir.
l i () 13 JUDGE GROSSMAN: Could you then refer to that i
14 procedure and --
15 THE WITNESS : Yes.
16 There's one thing I want to state here, too: that
- 17 a lot of this inf ormation may have been prior to Rev. C, 18 also. There was Rev. A, B and other revs before that.
19 So just if I can clarify that --
f 20 BY MR. MILLD3:
l 21 Q I see.
22 You used Rev. C as the benchmark?
23 A Yes, sir.
24 The procedures, the way they' re written -- they 25 normally get a little better as they go. You i
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4063 O
V 1 incorporate things, and it's a possibility that --
2 BOARD EXAMINATION 3 BY JUDGE GROSSMAN:
4 Q Okay.
5 But you didn't go back into Rev. A and B, did you?
6 A No.
7 0 You just used Rev. C?
8 A Per that current requirement. That's what we reviewed 9 this by because of the time limit -- not the time limit 10 that we had; it was just that it was time-consuming 11 enough and we wasn' t -- we wasn' t going to get into the 12 old procedures.
() 13 JUDGE GROSSMAN: Okay, fine.
14 DIRECT EXAMINATION 15 (Continued) 16 BY MR. MILLER :
I 17 0 But the Rev. C did, in fact, apply to at least some of 18 the records that you were reviewing, did it not?
19 A Yes.
20 Q Okay.
21 We can determine that from the effective date of j 22 Rev. C7 23 A Right.
l 24 0 Okay, all right.
1 25 Now, my question to you remains: What provision of CE)
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! (312) 232-0262
l l 4064 O 1 4.9.1 Rev. C was the reference point for your conclusion 2 that no ICR was written for out-of-calibration torque 3 wrenches, as recorded in the upper lef t-hand corner of 4 Page 2 of Exhibit 28?
5 A Well, that would be Paragraph 3.3.7 in the procedure on 6 Page 3, which states that for an out-of-tolerance tool, 7 an ICR would be written. That would take care of that 8 particular instance.
9 0 All right.
10 Right next to it is a block that states, "GIR 11 written instead of ICR for out of calibration."
12 What does that mean, sir?
() 13 A Well, that was the General Inspection Report, where 14 apparently it was written that the tool was out of 15 tolerance.
16 But there was no record, as far as we could find, 17 where the ICR -- an ICR was written for evaluation.
18 Q And what provision of the procedure --
19 A Well, that would be that same paragraph that states that 20 the ICR should be written and not a GIR.
21 0 Doec a GIR have a serial number?
22 A I think it's Form 104.
23 Q I'm sorry.
24 Does it have an assigned number to track it?
25 A No, sir, no.
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4065
(
1 It's just a piece of paper -- well, it's very 2 similar to this sheet of blank paper, only it's got a 3 little bit of a heading on top, I believe, for General 4 Inspection Report. But it's -- there's no numbers 5 assigned to them.
4 6_ (Indica ting. )
7 MR. MILLER: Let the record' reflect the 8 witness was referring to the top page of Applicant's 9 Exhibit 26. ,
10 BY MR. MILLER :
11 Q All right.
12 The next block on the left side states, " Reference 13
(]) BY/BR/CEA for' disposition."
14 What discrepancy does that reflect, sir?
15 A Well, BY/BR/CEA is an anchor bolt procedure by --
16 approved by Edison, S & L; and it's what our anchor bolt 17 procedure was written off of, which -- we used torque 18 wrenches for anchor bolts, if you follow me so far.
- 19 Now, in BY/BR/CEA, it's stated that a torque wrench 20 can be within a 10 percent tolerance, plus or minus 10 21 percent for anchor bolts.
22 But in 4.9.1 Rev. C, in Paragr'aph 4.0, the 23 reference is plus or minus 4 percent for torque
?4 wrenches, which is what I have to keep a torque wrench i 25 and John had to keep a torque wrench within that '
I Sonntaa Reporting Service, Ltd.
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,(312) 232-0262 i -- --
4066 O 1 tolerance. So it's a tighter tolerance 4.9.1 required 2 than BY/BR/CEA. So there's a little discrepancy there.
3 But what we had found was that there was a lot of 4 GIR's -- maybe these should have been tied together with 5 GIR's, but they' re not here -- that were written saying 6 BY/BR/CEA -- that the tool was within 10 percent of 7 tolerance; it was out of the 4 percent, but it was 8 within 10 percent. So they were buying it off.
9 I believe most of these were on GIR's, saying no 10 rework. It was per a Doug Brown, which is Edison QA, 11 memo that I read; and it was just memos f rom a meeting 12 where this f act had been brought up: that BY/BR/CEA
(]) 13 will buy off a wrench that's within 10 percent 14 tolerance.
15 Now, that -- the minutes f rom that meeting was more 16 or less taken to buy off a wrench that was within 10 l
17 percent tolerance, which per -- per my procedure or the 18 procedure at that time, it was not acceptable.
19 Q All right.
20 In this memorandum, was there any reference to 21 Comstock Procedure 4.9.17 22 A I don' t believe so.
23 It was a discussion at Commonwealth Edison, I 24 believe, with -- amongst the QA; and I believe probably 25 our manager was there and probably our QA Manager snnneng napnreing noruica r+ a _
Geneva, Illinoi s 60134 (312) 232-0262
4067 O 1 himself.
2 I can't recall exactly. I know that's where this 3 came from, though.
4 Q All right.
5 The next -- well, just to finish up, the torque 6 wrenches that are identified in Exhibit 28 -- are they 7 just used for CEA's?
8 A No, sir. That was the problem, too.
9 They're used for cable pan torques, hanger torques.
10 You don' t really -- back then, you didn' t know what they 11 were using them on because they didn' t track them like 12 they do today.
13 It just -- you couldn' t buy them off per that one
(])
14 BY/BR/CEA when they use them on everything else.
15 0 When you say " buying of f," sir, what do you mean?
16 A Well, you couldn't assume that wrench was good because 17 it was within 10 percent tolerance, but it was good for 18 all other torques besides CEA's.
19 Besides that, it was violating 4.9.1 Rev. C, which 20 said that you should write that wrench up on an ICR.
1 21 BOARD EXAMINATION 22 BY JUDGE GROSSMAN:
23 Q By " buying off," you mean disposition the 24 nonconformance?
l 25 A I never -- don' t recall a nonconf ormance written.
(:)
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() 1 I think the -- l 2 Q I' m so r ry . I didn' t mean an NCR written.
3 But disposition whatever discrepancy was recorded 4 in whatever document; is that correct?
5 A Well, they were -- there was a statement -- and I recall 6 the statements -- that were written on GIR's, the ones I 7 recall, where the inspector was saying, "This wrench was 8 out of tolerance per 4.9.1 Rev. C, but it was within 9 tolerance per BY/BR/CEA. Theref ore, no action 10 required"; to that basic extent there.
11 0 I understand.
l l 12 So there may not have been -- it was a way of 13 avoiding writing up a discrepancy?
({}
14 A It didn't involve an engineer because it was just a 15 statement that was made and signed and dated and put in 16 the records.
17 You still may have had a bad wrench. It didn't say 18 whether the wrench was repaired or adjusted, or it may 19 have said it was put back in -- you know, they varied.
20 But the ones I recall all had an attachment of that 21 Doug Brown memorandum, the meeting minutes; and right 22 there it said one of them was -- they were talking about 23 this problem, and he was buying it per the minutes of 24 that meeting.
25 DIRECT EXAMINATION gnnnen g nonn r H ng Rorvi ce . T& d .
. Geneva, Illinois 60134
! (312) 232-0262
4069 O 1 (Continued) 2 BY MR. MILL ER :
3 Q You say "he was buying"?
4 A John -- in this case I recall, John Seeders was buying 5 the wrench -- accepting the wrench per the minutes of 6 that meeting.
7 0 Okay.
8 Now, the next block is "no rework mentioned on 9 ICR."
10 What does that refer to?
11 A Well, the ICR was written f or an out-of-tolerance torque 12 wrench, and maybe we did review some ICR's. Maybe there 13 was a copy in the vault package -- in the tool package
(])
14 itself. I can't say now.
15 But in this case, these ICR's we looked at had no 16 engineering disposition to accept the work per -- if you 17 go back to 4.9.1, Paragraph 3.3.7 -- excuse me.
18 Paragraph 3.3.7.1 requires an evaluation to be msde ,
19 for the validity of the previous inspections and test 20 results, which was not done. That's the reason that's 21 th er e.
22 Q All right.
23 Now, going back for just a second to Exhibit 26, 24 the handwritten --
25 A Uh-huh. <
C:)
)
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4070 O 1 0 -- report, on I believe it's probably the fif th page of 2 the exhibit -- maybe it's the sixth page, the one with 3 Mr. Seeders' signature on it --
4 A Yes.
5 0 -- there's a statement, the second line up f rom the 6 bottom, "all research completed as per 4.9.1-C. "
7 Did you see -- do you recall seeing that statement 8 on any of the ICR's where there was no rework mentioned 9 on the ICR?
10 A No, not on the ICR's.
11 The way the ICR is structured, you don't make a 12 statement like this. It's not his job to do the
() 13 research; it's the engineer's job.
14 I don't recall that statement on an ICR.
15 0 I see, okay, all right.
16 The next block is "no missing-tool report filed,"
17 and there's a number 45 in parentheses.
18 A Yeah.
19 Again per the procedure, when a tool was lost or 20 stolen, we were required to -- the craf t was required to 21 initiate a missing-tool report, which I think is 22 attached at the back of this procedure.
23 This report would go in the vault package of that 24 tool as the final document, basically, saying that tool 25 was lost or stolen and no longer around.
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(
l It was just the cap on the -- on the package; and 2 per the procedure, it was required, which, in those 3 packages, they were reported lost or stolen and there 4 was no Form 45.
5 0 All right.
6 Was it the responsibility of the QC Inspector to 7 initiate that Form 457 8 A No, sir; craf t, foreman -- the f oreman of the man who 9 lost the tool or the foreman who that tool was last 10 assigned to.
11 Now, the problem back then was the Form 45 never 12 always made it to QC, because there's no spot on there
() 13 for QC to sign that thing; and just so -- just so the 14 construction management got their copy, that's all they 15 really worried about.
16 Us, as QC, have to chase them down to get this 17 report.
18 Q How would QC become aware that the tool was missing if 19 there was no missing-tool report filed?
20 A Well, when it comes due the next week and the tool is 21 not there, it's somewhere but the man that last used it 22 can't tell you where it's at. So all of a sudden it's 23 gone.
24 A lot of tools are stolen out there and go home and 25 you never see them, you know, and some are lost. But Sonntag Reporting Service, Ltd.
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() I the majority of the guys take them home, and it creates i 2 a big problem -- a paperwork problem, a lot of 3 paper-shuffling.
4 But that's the only way to know. If it's not there 5 on its next due date, that's the only time I, as an 6 inspector, would know that tool is gone.
7 0 Okay.
8 And would you say the next due date -- that would 9 be the next due date on the Form 77 for calibration?
10 A Yes, sir.
11 Torque wrenches are weekly calibrations, so you 12 know pretty quick, within a week's time. If they don' t
() 13 turn it in at night, you'd have the crib man tell you 14 the next morning, " Hey, this tool didn't come back in."
15 So you
- tart looking for it.
16 But you can't really write it up until its due 17 date, because it could be out there somewhere.
18 Q All right.
l 19 The next block is " missing vendor calibration 20 reports."
21 What does that refer to, sir?
22 A These wrenches were sent off-site for repair, 23 recalibration, and returned to site; and for some 24 reason, the vendor -- the company that calibrated the 25 tool off-site -- there was no certificate of l
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4073 )
() 1 calibration, saying yes, they did adjust the tool and 2 did calibrate the tool.
3 Now, they probably done it, but the tool -- the 4 report was missing, whether it was misfiled or whatever, 5 but it wasn't there.
6 0 Was it the responsibility of the QC Inspector to see to 7 it that the report actually physically got into the 8 file?
9 A Just to see that it got into the basket to be filed.
10 That doesn't mean it got into the file.
11 Q All right.
12 There was a file clerk who handled it --
Yes.
(]) 13 A 14 0 -- afterwards; correct?
15 " Missing calibration reports" is the last block on 16 the left-hand side.
17 What does that refer to?
18 A Just that no indication -- the Form 77 stated a 19 calibration was performed, but there was no report in 20 the vault package for that date of the -- that the 77 21 was signed.
22 0 Once again, what responsibility did the QC Inspector 23 have for seeing to it that that calibration report got 24 into the file? ,
25 A Well, he would -- at that time there was a basket on the ennneng m ennr e ing g ruic _ r+a.
Geneva, Illinois 60134 (312) 232-0262 ;
4074 O 1 vault counter, and you would just put your reports in 2 the basket and the girls would file them.
3 0 Okay.
4 These are the Form 23 or 23 A's that you --
5 A 23A in this case.
6 Some of them -- there was a contractor on-site --
7 two contractors that were doing some of our calibration.
8 During the summer of '84, that's -- Phillips 9 Getschow took over our calibration of torque wrenches 10 100 percent; and some of them could have been Getschow 11 reports missing or PTL, Pittsburgh Testing, reports 12 missing. But they would only give us a copy, so they 13 always kept the original.
(])
14 If you did misplace one, you could always go back 15 to them and request a copy of their original.
16 0 All right.
l 17 Then the next page -- well, I'm sorry. The last 18 , block I didn't ask you about is "no QC verification for l
19 rework."
20 What does that refer to?
21 A Well, there was probably an ICR that was written on a 22 tool, a torque wrench, that the rework -- it was stated 23 on there by the field representative, the craf t person, 24 that the rework was performed; and he would sign it and 25 date it.
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4075 O 1 Now, to close that out properly, the QC Inspector 2 has to -- somebody has to oversee this rework being 3 done.
4 There has to be a QC verification somewhere; but 5 there was none attached to the ICR or stated on the ICR, 6 but it was closed out.
7 So all you had was a man saying yes, he did the 8 work, but there's no proof that it was done or overseen.
9 0 All right, sir.
10 Page 3 of 27 is -- of Exhibit 28 is headed up 11 " portable rod ovens."
12 A Uh-huh.
13
(]) Q I think that- the two boxes on the lef t -- is that the 14 identical discrepancy that you observed for torque 15 wrenches under the same heading?
16 A Yes, sir.
17 Q Okay.
18 The two boxes on the right, however, are different.
19 The first one is " wrong calibration due date for 20 standard used," paren, " (not 9-6-84) ," close paren.
21 What does that refer to, sir?
i 22 A I don' t know what that date means there. I really 23 couldn't say.
24 But the Form 23 A -- if you can look at it with me, I
l 25 maybe I can explain that.
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l O 1 Q All right. Let's make sure we' re on the same document.
2 A Okay. I'c's in Procedure 4.9.1 Rev. C.
3 Q That would be Intervenors' Exhibit -- excuse me; 4 Applicant's Exhibit 24 in evidence.
5 A Yes.
6 (Indicating.)
7 It's just -- right up here on the top heading on 8 the right, there's three lines that says " range" and 9 " reference" and " standard number." Then under the line 10 " standard number," you have " calibration due date" and 11 you have a slash there on that line.
12 So what was happening here -- the thermometer that
() 13 was being used to calibrate the rod oven -- this would 14 be filled out for the rod oven, too --
15 (Indica ting. )
16 Q The upper lef t-hand side of the f orm?
17 A Yeah, righ t.
18 The tool number would be up there, but you have to
' So 19 say what you' re using to calibrate that rod oven.
20 that's what your standard is here.
21 And he would put -- or, in this case again, John 22 would put the standard -- say, thermometer A965 -- but 23 the due date he would put of the oven itself, not the 24 due date of the standard.
25
- So you see the reason you need a standard due date nnnneng nonnrei ng norui c._ r+ a .
Geneva, Illinois 60134 (312) 232-0262
4077 O 1 is to know that you've got a good standard, while you' re 2 actually calibrating the oven, without having to dig 3 further, because it would state it right here.
4 But he apparently misunderstood on the form and was 5 putting the due date of the rod oven up here and not the 6 due date of the standard.
7 (Indica ting. )
8 The reason we knew that was because rod ovens are 9 calibrated every three months, and this date would 10 always be exactly three months af ter the date that the 11 rod oven was being calibrated.
12 0 All right, sir.
13 And we did verify that, also, with the Form 77.
(]) A 14 Q Can you tell us, Mr. Snyder, what the calibration 15 interval is for the thermometers that are used'as the 16 standard for calibrating rod ovens?
17 A Three months -- it is now. I believe it's been three i
18 months since Rev. -- way back. I would say three 19 months, but they' re not due the same date, you see.
l 20 They' re staggered.
21 Q All right.
22 The second block on the right of Page 3 of 27 of 23 Applicant's Exhibit 28 states "no recheck or rework of 24 out-of-calibration ovens."
25 What does that refer to, sir?
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(} l A Well, it's just again apparently the ICR -- maybe an ICR 2 was w ritten. Apparently it had to have been, because l 3 again it wasn't dispositioned by an engineer. It was 4 apparently closed out by the inspector without an 5 engineer getting involved.
6 As I stated I think earlier today, that was a f ault f 7 of the ICR form, in my opinion; and the thing should 8 have never came back to QC to close without an engineer
! 9 concurring with what rework was involved.
10 Q Now, the pages that follow contain inf ormation.
11 Perhaps you could just describe generally what the 12 information is that's recorded on the succeeding pages O 13 'of Exhibit 28.
14 A Well, I think this is typed from our notes that we took 15 as we were reviewing these packages. Like I said, we 16 started f rom Torque Wrench No.1 and went all the way 17 through the torque wrenches. This is just typed up from 18 our notes that we had in longhand.
I 19 Then we condensed it up to this cover sheet, the 20 majority of the problems we found. There might be 21 things back here that weren' t stated on the f ront, but 22 the repetitious problems were put on this cover sheet 23 here.
24 (Indicating.)
25 Q Pages 2 and 3 of this exhibit?
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l 4079 l
O 1 A Yes, right.
2 This was just typed from our notes that we took.
3 0 Okay.
4 Now, during the time that you were conducting this 5 review of the records in the vault, what was Mr. Seeders 6 doing, do you know?
7 A He was carrying on normal calibration duties.
8 MR. MILL ER : Now, I'd like to have the 9 Reporter mark for identification a document that is in 10 reverse order. I'll represent that it is a copy of a 11 portion of the L. K. Comstock inspection correction log; 12 and it begins with ICR No. 2293, which has a date of 13 January 18, 1983, and ends with ICR No. 7574, which is
(])
14 dated December 14, 1984.
15 (The document was thereupon marked 16 Applicant's Exhibit No. 29 for 17 identification as of June 12, 1986.)
18 MR. BERRY: Could you repeat the numbers?
19 MR. MILLER : Yes, ICR 2293 through ICR 7574.
20 BY MR. MILL ER :
21 Q Mr. Snyder, I'd like to place this document before you, 22 Applicant's Exhibit 29 for identification.
23 (Indicating.)
24 I want to ask you if you can describe it for the 25 record.
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l O 1 A Well, this is just -- like I said, it looks like our ICR 2 log that our ICR clerk would log the inf ormation on when 3 someone would write an ICR on a particular deficiency. l 4 MR. GUILD: Is this a Xerox of the ICR log?
5 MR. MILLER: That's correct.
6 MR. GUILD: It appears to be not an original 7 document.
l 8 MR. MILLER : That's correct. It is, in fact, 9 a Xeroxed copy of the ICR log.
10 MR. GUILD: Well, that's Mr. Miller's 11 statement, and I believe he hasn' t even asked the 12 witness to identify the document as such.
13 Okay.
(]) JUDGE GROSSMAN :
l 14 You know, Mr. Miller, you should tell counsel that 15 you' re going to use a Xerox of something so that he can 16 examine the original.
17 If there's any reason, Mr. Guild, that you think 18 you need the original -- do you think that might be an l 19 incomplete Xerox?
I 20 MR. GUILD: I have no knowledge. I've never l
21 been confronted with the document before, and this is 22 the first time that I've seen it. I'm not in a position 23 to stipulate to its authenticity or completeness.
l 24 It appears to be a copy, although it was 25 represented as being the document.
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I I
4081 1 MR. MILLER: I'm sorry. If I did that, I 2 misspoke. I didn't mean to represent that this was the 3 original document.
4 BY MR. MILLER :
5 0 Mr. Snyder, to your knowledge, is the original of the 6 ICR log a document that can be taken f rom the vault area 7 or wherever it's kept?
8 A No. The original is pretty well kept under the -- the 9 ICR clerk's guard or whatever. No one else really 10 messes with it.
11 I mean, you can go in and look up a number -- you 12 can now; I don't remember back then.
But it's just a log she keeps. This is a copy of
(]) 13 14 that log -- it appears to be.
15 0 All right.
16 Now, I'd like, if you would, for you to read --
17 MR. GUILD: Mr. Chairman, perhaps before Mr.
18 Miller goes f orward, he can simply explain f or the 19 record what he intends to do with the document that 20 would have seme bearing on our position on either its 21 admissibility or use for the purpose that he intends to 22 use it.
23 JUDGE GROSSMAN: Could you, Mr. Miller?
24 MR. MILLER : I will state now that I do not 25 intend to of fer this into evidence.
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4082 O 1 What I do intend to do is to show Mr. Snyder a 2 series of inspection reports for calibrated instruments 3 and Form -- copies of Form 77's that relate to those 4 incidents and ask him whether he can tell, by looking at 5 this log, whether an Inspection Correction Report was 6 written when an out-of-calibration condition was noted.
7 JUDGE GROSSMAN: Do you have any problem with 8 that, Mr. Guild?
9 MR. GUILD: Well, it certainly presupposec 10 the authenticity of the document as a complete 11 reflection of what those ICR's are.
12 Whether he intends to off er the document in evidence or not, I presume that he wants to rely on the
(]) 13 14 answers to the questions that rely on the witness' 15 consultation f rom the document -- or ref erence to the 16 document.
17 I think any answers that flow from the witness' I lb ref erence to the document depend on the authenticity of 19 the document itcelf.
20 MR. MILL ER : Well, your Honor --
21 JUDGE GROSSMAN: I'm not concerned with the 22 authenticity as much as the completeness.
23 If you're going to ask him whether something is 24 missing f rom the document, I think it's critical that we
- 25 know that it's a complete document and that what you' re mm.. .e ..pm. 1 2 m.. 4m.. t o.
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4083 O 1 asking him -- whether it's missing -- could be found in 2 some other part of the document.
3 MR. MILLER: Right.
4 JUDGE GROSSMAN: That is not here -- that 5 might not be here at the time.
6 MR. MILL ER : Yes, sir.
7 That -- the date range that I picked goes for some 8 -- well, I don't want to ma,ke representations before the 9 witness has answered some preliminary questions.
10 JUDGE GROSSMAN: Okay. We'll allow you to 11 use the document until there's an objection and it 12 appears that there might be some problem.
13 I think we'll let you proceed with using it the way
(])
l 14 you intend until we encounter a particular problem.
l 15 MR. GUILD: Mr. Chai rman, I do not waive any 16 objectione as to authenticity and stand by my -- my 17 objection.
18 The document has not been offered into evidence.
l 19 It's not been served on the parties. We've had no 1
l 20 opportunity to establish whether it's indeed authentic l
21 or complete, and that's what I meant.
22 JUDGE GROSSMAN : Okay. Well, Mr. Miller has 23 indicated -- the witness has indicated that there's a l 24 reason why the authentic document, the original, cannot 25 be produced here.
l t
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4084 O 1 I believe he's gone as f ar as to indicate that that 2 appears to be a copy of the document that can't be 3 produced.
4 MR. GUILD: May I ask the witness whether it 5 appears to be a complete copy of the complete document?
6 THE WITN ESS : Well, it -- we were writing 7 ICR's prior to '83, so it's just a portion of the whole 8 ICR sy stem. You can stack them logs up there probably 9 this tall.
10 (Indicating.)
11 ,
BOARD EXAMINATION 12 BY JUDGE GROSSMAN:
() 13 Q But with regard to the the dates that are included 14 there, does that appear to be a. complete document?
15 A Well, if it's -- I would say one way to find out is if 16 the numbers are continuous, that would be -- you know, 17 these are numerically numbered, one right af ter the 18 other.
19 Unless there's a page missing between the bottom 20 and the top, I would say it's all here for that portion.
21 0 I see.
22 So the original is numbered consecutively, and this 23 one is numbered consecutively; and so there can't really 24 be any page that's missing, assuming that these are 25 copies of that original document?
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4085 O 1 A Right.
2 There may physically be a page missing here, but 3 there shouldn' t be in the original, you know. That's --
4 but I'm sure we could take care of that problem if we 5 came across it right here. I don't, you know --
6 JUDGE GROSSMAN : Mr. Guild, do you have any 7 further questions on that?
8 MR. GUILD: I don't.
9 JUDGE GROSSMAN: Okay. You can proceed with 10 using that document, Mr. ' Mill er .
11 MR. MILL ER : Thank you.
12 DIRECT EXAMINATION 13 (Continued)
(])
14 BY MR. MILL ER :
15 Q Mr. Snyder, would you just read into the record what the 16 column headings are on this inspection correction log?
17 , A Okay. We've got a column "ICR number," which -- you 18 told me to read them.
19 0 Yes.
i l 20 A Next is "date," " description," "date to construction,"
21 " CECO disposition if required," "date from I
l 22 construction," " action completed,"
23 " assigned / reassigned," " reissued," " complete date,"
24 " comments," " system," " drawing" and " location. "
25 Q All right.
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!C:) 1 Do you know, Mr. Snyder, if it is possible to tell 2 f rom the ICR log which QC Inspector initiated an ICR?
3 A Yes. It's under the " assigned / reassigned" column. This 4 is the inspector that wrote the ICR.
5 (Indicating.)
6 She's also -- excuse me. I may be wrong here.
7 Like I said, I don' t see this very of ten; but she's 8 also got a name out here to the side under " comments,"
9 which doesn't apply -- isn't -- doesn't correlate with 10 the other name in some cases.
11 So I -- I can't -- if I can interpret those 12 headings, I'd say that's who wrote it.
{'; 13 Q The one under the " comments" section?
14 A I would say, if it was me, that the person under the 15 " assigned" would be the one that initiated the ICR.
16 MR. GUILD: Mr. Chairman, it appears I was 17 mistaken in assuming that the witness authored the 18 document that he's looking at, and it appitars that he's 19 just speculating about what entries appeac on the 20 document that were made by some other person.
21 That certainly is further grounds for being 22 improper to elicit evidence that's in reference to a 23 document that the witness is required to speculate to.
24 He can't sponsor it himself.
25 JUDGE GROSSMAN : The fact that the witness O
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4087 O
v 1 authored or didn't author the document really isn't a 2 concern.
3 The question is whether he is able to -- is 4 f amiliar with the document, knows what it's used for, 5 knows what the inf ormation is. To the extent that he 6 says he's not, well, then --
7 MR. GUILD: He can' t authenticate it.
8 JUDGE GROSSFaN: Pardon?
9 MR. GUILD: He cannot authenticate it.
10 JUDG E GROSSMAN : Well, no. He can 11 authenticate the document, but he can't explain 12 everything on the document.
13 That might interfere with using his answers as any
(])
14 evidence, but it doesn' t undermine the document.
15 MR. MILLER: Well, I was hoping to save a 16 little time with this, but let me just ask a few more 17 questions.
18 BY MR. MILL ER :
19 Q Mr. Snyder, I think you stated, in response to a 20 previous question, that one of the first things you did 21 in your recorda review was to check the ICR log for 22 ICR's written with respect to out-of-calibration 23 instruments; correct?
24 A That's correct.
25 Q Okay.
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4088 O 1 And is that -- within the dates that I read into 2 the record, is that the document that you checked?
3 A Yes.
4 Q All right.
5 Now, could you describe for us how, when you made 6 the check, you determined whether or not there was an 7 ICR written against an out-of-calibration tool or 8 instrument?
9 A Well, I believe we just started at the f ront here --
10 prior to this, actually. It was prior to '83.
11 We went all the way back; and anytime a calibrated 12 tool was mentioned under " description," we would record 13 that ICR number, possibly the date and the tool number.
(~)
14 0 Is all that information that you just described found in 15 the ICR log?
16 A Yes.
17 MR. GUILD: Mr. Chai rman, just pursuing this, 18 what is the reference to the description of an 19 "Out-of-calibration tool" as the witness used that term 20 with reference to the document before him?
21 MR. MILL ER : Well, let me -- let me represent 22 again that I have taken the liberty of marking, with 23 those little yellow tabs or paper clips, pages on which, 24 in my judgment, such an entry appears.
25 To save the witness thumbing through it, why snnneng nonnr ei ng servi ca _ r+a.
Geneva, Illinois 60134 (312) 232-0262
4089 O 1 doesn' t he turn to the top one where there's a yellow 2 tab and see if he can find on that page a reference to 3 an out-of-calibration tool.
4 THE WITNESS : Well, the two top ones talk 5 about Amp Crimper No. 1 and a rod oven overdue for 6 calibration; " amp crimper reported missing."
7 BY MR. MILL ER :
8 0 And it is that description which indicates to you that 9 that ICR number reflects an out-of-calibration tool or 10 instrument; correct?
11 A Yes, sir.
12 I can, by looking at this, tell you who wrote it 13 and who closed it now, because -- I couldn' t on this top
(])
14 cover because I don't think there was a calibrated tool 15 on there.
16 I know when this man, R. Nemeth, started working 17 for Comstock, so he couldn' t have possibly written the 18 ICR on that date.
19 0 Okay.
20 So based on your review -- what ICR number are we 21 looking at, sir?
22 A 7133.
23 Q And what is your belief as to the individual who wrote 24 that?
25 A It's John Seeders who wrote it.
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4090 1 (Indicating.)
2 -
MR. GUILD: All right. Now, the record 3 should reflect that since the document is not in 4 evidence, the witness' first answers with respect to the 5 first page of the document were that the column that 6 reads " assigned / reassigned" listed the name of the 7 initiating inspector.
8 He's now changed that characterization; and in a 9 column marked " comments," with respect to the entry that 10 he's talking about now, there happens to appear the name 11 " Seeders."
12 BY MR. MILLER:
13 Q Would you state why you believe that, with respect to
( })
14 ICR No. 7133, Mr. Seeders was the initiator and Mr.
15 Nemeth was the individual who closed it?
16 A Ray Nemeth didn't start working for Comstock until 17 January of '85, because he was my Lead and I -- I still 18 know the man. I've sat beside him, and I know when he 19 started work.
20 John Seeders was employed there at that time on 21 9/ 18/ 84 .
22 0 And what does the date 9/18/84 signify, as f ar as you 23 know?
24 A That's the date he wrote the tool -- reported the tool
, 25 missing and wrote the ICR. The " complete date" is the
()
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4091 O 1 date that Ray Nemeth closed that ICR out.
2 See, she, in " comments" -- she's telling them --
3 over here she's making a brief statement that "an amp 4 crimper was reported missing. "
5 (Indicating.)
6 Over here she says " amp crimper."
7 (Indicating.)
8 MR. GUILD: Who is "she" referring to?
9 THE WITNESS: Jackie Joyce I believe was our 10 ICR clerk then. She still is..
11 MR. GUILD: Your belief is this is Miss 12 Joyce's entries?
13 TH E WITN ESS : Well, that's my belief.
[]} I 14 could be wrong there.
15 BY MR. MILLER :
16 Q Earlier today, Mr. Snyder, you described the process 17 whereby an ICR got logged in.
18 Have you personally taken an ICR for an i
19 out-of-calibration tool and had it logged on this 20 Inspection Correction Report log?
21 A Did I personally log it?
22 Q No, no, no.
23 Have you personally taken it to be logged?
24 A Yes, sir.
25 Q Have you observed how that process takes place?
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() 1 A Normally we just put them in her basket, and she does it 2 on her own time.
3 Q I see.
4 A She'll turn over the copy of the ICR to us with the 5 number applied to it.
6 0 But am I correct that in conducting your research, 7 Applicant's Exhibit 28, your report -- yours and Miss 8 Sproull's report, you looked through the log, as you 9 have described, to determine the instances in which an 10 ICR was recorded for an out-of-calibration tool or 11 instrument?
12 A Yes, si r .
() 13 JUDGE GROSSMAN: Excuse me.
14 BOARD EXAMINATION 15 BY JUDGE GROSSMAN:
16 0 I must be missing something.
17 I understood that in making this report, which is 18 marked as Applicant's Exhibit 28, you were reporting 19 procedures that were incorrect; isn't that so?
20 A This was tools that were handled incorrectly per the 21 procedure.
22 Q Right, okay.
23 And if there was something wrong and an ICR should 24 have been written and was actually written, you wouldn' t 25 have shown it in thi's report?
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4093 O 1 (Indicating. )
2 A That's -- I think that's correct.
3 0 Okay.
4 Now, you just went over one entry; and I must have 5 missed something, because you indicated that that entry 6 showed that, in your opinion, John Seeders had initiated 7 an ICR. '
8 What was wrong, then, with regard to that 9 particular item?
10 A She says here that the tool was reported missing, which, 11 peri procedure, if it's lost or . stolen, we would write an 12 ICR.
~
13 It would require an ICR.
('} Q 14 But there was one that was initiated, wasn' t there?
15 A Yes, in this case.
l 16 Q Oh, so there was nothing wrong, then; and that wouldn' t 17 have been one of the items that you reported in your 18 report?
19 A Right. I agree.
20 JUDGE GROSSMAN : Okay. I thought I missed 21 something there.
22 MR. MILL ER : No. I was just using that as an 23 example, your Honor.
~
24 THE WITNESS : In fact, if I could state, too, 25 I don't believe we even reviewed the crimpers and
( ,
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4094 O 1 stripper files, because of the f act that there was no 2 23A's being initiated back then and there was no need 3 for us to look at an empty folder, you know.
4 I mean, they had a Form 8 in there and maybe 5 something else, but there was nothing else there so 6 there was no need for us to review it per this review 7 here.
8 (Indicating.)
9 BY JUDGE GROSSMAN:
10 Q Now, one other question, though, on --
11 MR. MILL ER : Excuse me. Just so the record 12 is clear, the witness was referring to Exhibit 28.
13 I beg your pardon.
(]}
14 JUDGE GROSSMAN: For "this," that is Exhibit 15 28, okay. That's what we'll understand that to be.
16 BY JUDGE GROSSMAN:
17 Q Now, with regard again to Document A.28, you were 18 looking for matters that didn't conform to the procedure 19 with regard to any inspector who had handled the matter; 20 is that correct?
21 A That's correct.
22 Q Not just John Seeders?
23 A That's right.
24 Q Oh, okay.
25 A There was two or three other inspectors prior to him snnntag nannreing noruica_ r+ a .
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1 4095 l l
O 1 that worked for Comstock in the area of calibration.
2 MR. MILL ER : Now, I'd like the Reporter to 3 mark as Applicant's Exhibit 30 for identification a 4 package of materials.
5 The first seven pages are Form 77's for a torque 6 wrench that has the control number A872.
7 The last two pages are torque wrench calibration 8 certificates with the letterhead of Phillips, Getschow 9 Company. The first one bears a date, in the upper 10 right-hand corner, of March 24, 1983. The second one 11 bears a date, in the lower right-hand corner, June 29, 12 1984.
13 (The documents were thereupon marked
(])
14 Applicant's Exhibit No. 30 for 15 identification as of June 12, 1986.)
16 DIRECT EXAMINATION 17 (Continued) l 18 BY MR. MILLER:
19 Q Now, first of all, Mr. Snyder, can you tell us what the 20 first five pages of this document appear to be?
21 A These are the -- some of the Form 77's applied to torque 22 wrench A872.
l 23 0 On the very top page, does your signature appear, sir?
l 24 A Yes, sir.
l 25 0 And then can you tell us what the last two pages of the I
(
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() 1 exhibit appear to be?
2 A The second to the last page is a Phillips Getschow 3 calibration report for torque wrench A872, and they do 4 find the tool out of acceptable tolerance.
5 Q How can you tell that the tool was found out of 6 acceptable tolerance?
7 A Well, they give us the percentage of error there as 8 found, and -- they figured the percentage out already.
9 But it's up to 10 percent, I guess, is the error at 10 45 pounds, which is out of the 4 percent stated at the 11 top of the form there.
12 0 On the line item " calibration accuracy requirements"?
13 A Yes, sir.
(])
14 Q And that -- what is the source of that 4 percent 15 criterion?
16 A From the 4.9.1 Rev. C procedure.
l
- 17 Q All right, sir.
1 18 And what is the last page of the exhibit?
19 A Let's see. This is another Getschow report. Let's see 20 the dates here.
21 It's 6/29/84. It was again out of tolerance of 10 22 percent maximum.
23 Q All right.
24 Now, I'd like you to go back, if you weald, to your 25 compilat. ion, Exhibit 28 in evidence --
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4097 O 1 A Uh-huh.
2 0 -- and I'd like you to tell us whether torque wrench 3 A872 is recorded in the upper lef t-hand block of Page 2 4 of 27 of that exhibit.
5 A Yes, sir.
6 Q All right.
7 I'd now like you to turn in that document to Page 8 11 of 27.
9 A Uh-huh.
10 MR. GUILD: I'm one step behind the witness.
11 Page 2 of --
12 MR. MILLER: I'm sorry. Bob, it's his l 13 report.
14 (Indicating.)
15 MR. GUILD: I see. Thank you.
16 MR. MILLER: Now move to Page 11.
17 BY MR. MILLER:
18 Q Now, on Page 11 of 27, Mr. Snyder, there is also, is 19 there not, a ref erence to torque wrench A8727 20 A Yes, sir.
21 Q All right.
22 Calling your attention simply to Item No. 2 under 23 torque wrench A872, can you tell, by looking at that 24 entry on Page 11 of Exhibit 28, whether that is the same 25 Phillips Getschow report that is the last page of l
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4098 O 1 Exhibit 29?
2 30. I beg your pardon; 30.
3 A Well, Item No. 2 says "out of calibration by PGC," which 4 is Phillips Getschow, "8/29/84"; and then it says 5 "6/29/84 no ICR written or anything written up."
6 Well, the 6/29/84 is the last report in this 7 exhibit. I can't keep these exhibits straight because 8 mine is not marked --
9 0 That's Exhibit 30, 10 A -- but it would be the same instance there, yes.
11 Q And can you tell, by looking at the Form 77 's which are 12 a part of Exhibit 30, whether there is a reference in Q 13 the Form 777 14 A. He says, "Out of calibration. NCR written #3294" --
, 15 well, excuse me.
16 Okay. 6/29/84 he did make that statement, 17 apparently -- unless he came back later, it looks like, 18 although he didn' t initial that. Someone dated it, 19 but --
20 MR. GUILD: Where is the witness referring 21 to, pleare?
22 THE WITNESS: It's pretty confusing there.
23 BY MR. MILLER:
i j 24 Q This is the second page of Exhibit 30 we' re on; correct? ,
l 25 A Yes, right.
l
(:) .
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4099 O 1 Q The line item June 29, 1984 -- is that what you' re 2 looking at --
3 A Yes, sir.
4 0 -- Mr. Snyder?
5 All right.
6 A See, it -- this Form 77 is a little different than the 7 current one, but -- well, in fact, this is the wrong 8 Form 77 for that piece, but he did sign it and date it 9 on 6/29/84 under "QC signature /date." The tool was due 10 6/ 29/ 84 .
11 Now, I never worked under this card, so I can't --
12 it's a little different than the one we work to now and 13 the one he should have been working to here.
(])
14 But it doesn't show the standard Phillips Getschow 15 on this card, but he did say in remarks, "Out of 16 calibration. NCR written #3294."
17 Q Now, what date does the record indicate that NCR was 18 written?
19 A Well, it shows 9/15/84 as a date there. Now --
20 0 All right, sir.
21 A -- I assume that's when it was written there.
22 Q Okay.
23 And, in fact, your audit report, Exhibit 2 8, is 24 dated September 7, 1984.
25 A W r;1 1 , that cover sheet is, yes.
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O 1 Q And were any of the entries that are found on the pages 2 that follow made af ter September 7th?
3 A I couldn't say that because, you see, I think we got a l 4 little date discrepancy here on this cover sheet of this 5 exhibit, whatever this is that you' ve got in your 6 hand --
7 (Indicating. )
8 Q Exhibit 28.
9 A -- because Myra and I signed this -- or it's dated with 10 our names down below 9/6/84.
11 But I believe all that is is a report f rom us to 12 Bob Seltmann, our QA Manager, on our progress on that
() 13 date, because, if you notice, Item 8 says, "As of 9/6/84 14 we are approximately 50 percent completed with the 15 review."
16 So we were reviewing later than that.
17 0 All right, si r .
18 Can you tell, by looking, whether or not Page 11 of 19 27 of the Exhibit 28 entry to torque wrench A872 was 20 completed before or af ter September 7, 19847 21 A No. I have no way of knowing.
22 0 Mr. Snyder, calling your attention again to Exhibit 23 30 --
l 24 A Uh-huh.
25 0 -- the entry on the Form 77 for June 29, 1984 --
i 1
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1 A Yes.
2 0 -- if there had been an indication that an NCR was 3 written on September 15, 1984, wouldn' t you have 4 recorded that in your review of the records?
5 A I wouldn' t have said that there was no ICR written --
6 that's true -- for that date.
7 MR. GUILD: If I can just ask counsel a 8 question, the entry on Exhibit 28, Page 11, says "out of 9 calibration by PGC 8/29/84."
10 MR. MILLER: Yes, sir.
11 MR. GUILD: Then it says "6/29/84 no ICR. "
12 Now, the dates you' ve been referring to in Exhibit
() 13 30, the Phillips Getschow report, is a date of 6/29/84.
14 MR. MILL ER : That's correct.
15 MR. GUILD: What's the 8/29/84?
16 MR. MILL ER : Well, let's ask the witness.
17 BY MR. MILLER:
18 0 What is the reference to 8/29/847 ,
l 19 A Apparently there was a report in the vault package dated 20 8/ 29/ 84 from Phillips Getschow, saying the tool was out i
21 of tolerance, although it's not referenced on the 77, 22 If you notice, on the 77 he has a calibration due 23 date of 9/6/84 above 6/29/84, which is apparently in 24 error, but it's not been one-lined and initialed and 25 dated off of there.
()
i i l l Sonntaa Reporting Service, Ltd. ! l l Geneva, Illinois 60134 l (312) 232-0262
4102 j O 1 So there is a void there between -- well, between 2 September and -- what is that? -- June, if you want to 3 look at that.
4 JUDGE GROSSMAN: Well, there is another 5 logical explanation.
6 BOARD EXAMINATION 7 BY JUDGE GROSSMAN:
8 Q This typewritten report was based on your handwritten 9 notes?
10 A Yes, sir.
11 Q Isn' t it possible that the "8/29/84" really was 12 " 6/ 29/ 84 "?
(]) 13 A That's true.
14 Like I say, we had hand-written everything, and 15 this could have been a typed error or something here.
16 DIRECT EXAMINATION 17 (Continued) 18 BY MR. MILLER:
19 Q Now, Mr. Snyder, let me just continue with your 20 observation that the 6/29/84 entry follows the 9/6/84 21 entry.
22 A Uh-huh.
23 Q Do you know whether or not Mr. Seeders put that 6/29/84 24 entry on sometime af ter September 6, 19847 25 A I do not know, sir.
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4103 O 1 See, the thing about this wrench -- it's -- it's a 2 weekly calibration; and that's what I can' t understand 3 here, because there's such a lapse of time here. You 4 know, it's calibrated every week, unless it's on hold.
5 I don' t -- I don't know how he got a due date of 6 9/6/84 in there to begin with, because above that 7 everything is dated April of '83.
8 MR. GUILD: The preceding page may answer the 9 question. It has a 9/6/84 date on it, the first line.
10 TH E WITN ESS : Oh, okay.
11 MR. GUILD: I don't mean to interrupt 12 counsel's examination, but --
(]) 13 A (Continuing. ) Here is what happened: He noticed that 14 the second page was no longer the current card. You see 15 the rev change 6/81 in the lower right-hand corner.
16 Then if you turn to the f ront page, it's a new 17 card. It's what he should have been working under. I 18 should have caught that.
I 19 But there it is, so I can't explain his 9/6/84 on 20 the second page, but he does have it properly on the 21 front page here.
22 MR. MILLER: All right.
23 BY MR. MILL ER :
24 Q Just keeping with the entry for June 29, 1984, can you 25 now tell, by independent examination of the ICR log, as i
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1 4104 O 1 to whether or not an ICR was written for this 2 out-of-calibration torque wrench, A872, on or about June 3 29, 1984?
4 A Now I'll have to look here.
5 You see, the date may not mean much on this ICR 6 log; but, if you'll notice here, here is an ICR No.
7 5677, dated 6/23/84. Then you -- you go to ICR 5708, 8 and it's dated 6/7/84.
9 So that should be the date it was written, but she 10 only logged it per number, not by date; so I can look 11 around 6/29, but it may be a shot in the dark here.
12 In fact, I don' t know that -- this could take a
{} 13 14 little time here because I may have to look at several.
You see, on the same page she's got 6/25 and 6/1 15 dates, 6/1 preceding -- af ter 6/25, 16 0 That's the same review you conducted when you went 17 through it originally?
18 A That's true.
19 0 I don't mean to suggest that it's necessarily easy. I 20 observed the same problem with the dates.
21 A Yeah, okay.
22 I think what we had there, though -- we just 23 flipped page to page, but I can do that here, so -- it's 24 easier to look for the name rather than the date, I 25 think.
O -
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l (2) 1 JUDGE GROSSMAN: Now, let me ask, while the 2 witness is looking f or that, whether we're not really 3 wasting some time here, Mr. Miller, in going through the 4 mechanics.
5 Apparently the witness testified that he had gone 6 through records and had found procedural problems with 7 certain matters here, and he listed them and he had them 8 in the report.
9 Now, I didn' t understand that there was any 10 question about the existence of those discrepancies, and 11 so it -- I'm losing the point of why we' re going through 12 the mechanics, other than you wanted to show us an
({) 13 example of that.
14 But that's gotten a little more complicated than I 15 think we really -- I think we' re learning more about it 16 than we really wanted to know.
17 MR. MILLER : Well, your Honor, I -- there 18 were two purposes: First was to spread on the record 19 just what the forms were, how they were filled out for l
l 20 specific tools and what this witness did to reach the l
21 conclusions that are set forth in his report.
22 Secondly, it seems to me that it is important to l
l l 23 get the witness back, if you will, and f amiliar with the 24 records that he reviewed, because my intention is to ask 25 him some further questions once he has gone through some Sonntaa Reporting Service, Ltd.
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4106 O 1 of these records.
2 I will tell you that I had identified some seven 3 examples of this.
4 I'm happy to identify the exhibits and then go 5 directly to the -- to the Form 77 or the calibration 6 reports and ask him whether they correspond with his 7 entries in his exhibit, Applicant's Exhibit 28, and i 8 leave for perhaps a stipulation by counsel that there, 1
9 in fact, are no ICR's in the ICR log for the instances 10 that I am questioning here.
11 I think it is -- there is an issue in this 12 proceeding as to the reasons f or Mr. Seeders' transfer.
() 13 Mr. Snyder was a person who had first-hand knowledge of 14 some of the discrepancies in the calibration records.
15 JUDGE GROSSMAN : Well, my recollection was 16 that not only was there a suggestion of discrepancies by 17 Applicant, but there was also the same suggestion by Mr.
l 18 Seeders. The only question was who was responsible for i 19 them.
t j
20 Now, do we have a disputed issue as to whether i 21 there were procedural discrepancies?
I
! 22 MR. GUILD: Mr. Chai rman, I'll be perfectly 23 prepared to, off the record, consider Mr. Miller's 24 proposal that the ICR log does not c,ontain entries f or 25 the particular examples that he submits.
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O 1 I don' t concede, without considering the matter 2 further, that that establishes that those deficiencies 3 were Mr. Seeders' fault.
4 MR. MILLER : Well, those are questions that I 5 intend to address to Mr. Snyder.
6 JUDGE GROSSMAN: Okay. So you need this in 7 order to support your position that this was Mr.
8 Seeders' fault?
9 MR. MILLER: Correct.
10 JUDGE GROSSMAN: Okay.
11 TH E WITNESS : I'm finished.
12 BY MR. MILLER :
() 13 Q You are finished?
14 A Well, I didn' t find anything within -- back to May --
15 f rom May to July -- September. I didn' t see anything on 16 that tool.
17 Q Thank you.
18 Now, can we agree that it's Mr. Seeders' signature 19 that appears on the second page of Applicant's Exhibit 20 30 on the line item dated June 29, 19847 21 A Yes, sir, that's his.
22 Q And that it's also his signature that appears on the 23 last page of the exhibit, which is the Phillips Getschow 24 torque wrench calibration certificate that also bears 25 the date June 29, 1984?
() '
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l l
O 1 A Yes, sir, that's his, also.
2' O Now, under the procedure 4.9 --
3 MR. GUILD: Yes, but Mr. Seeders' date is 4 7/ 2/ 84 , to be precise.
5 TH E WITN ESS : Right. The reason for that is 6 -- well, I don't know.
7 This could have been on a Saturday, even, and then 8 you wouldn't receive this paperwork until Monday 9 morning; so you can' t back-date -- or shouldn' t 10 back-date that document.
11 It's just a review by him that he did look at this 12 document.
13 MR. MILLER: All right.
l
({)
l 14 BY MR. MILLER:
15 0 And when he reviewed it, what responsibility, if any, 16 did he have for initiating an ICR?
17 A He should have written the ICR against the torque wrench 18 A872 per Procedure 4.9.1 Rev. C.
19 Q And based on your review both in September of 1984 as 20 reflected in Applicant's Exhibit 28 and today, he did 21 not do so; correct?
f 22 A Right.
23 Q Now, just to finish off on this exhibit, the next to the 24 last page has a Phillips Getschow torque wrench 25 calibration certificate. It has a date of March 24, nnnnen g nann r ei ng servi ca , r+a.
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4109 y 1983.
2 Mr. Seeders' signature has a date underneath it, 3 Nov ember 17, 1983.
4 Do you know under what circumstances --
5 MR. MILL ER : I'm sorry, Bob. It's the next 6 to the last page.
7 MR. GUILD: I've got you.
8 BY MR. MILLER :
9 Q Do you know under what circumstances this lapse of time 10 between the time the calibration was made and the time 11 Mr. Seeders signed his name -- why that took place?
12 A No. I couldn't say. I wasn't around. I -- I couldn ' t
() 13 say.
14 Apparently he f ailed to do it initially and somehow 15 seen it later.
I 16 JUDGE GROSSMAN: Excuse me.
17 BOARD EXAMINATION 1
18 BY JUDGE GROSSMAN:
19 Q Didn't it have to be tested by someone else -- in this ,
20 case, Don Casey -- before Mr. Seeders --
21 A Yes, sir.
22 Q -- could review that?
23 A Don Casey is the Phillips Getschow inspector that l
l 24 perf ormed the -- the test on the tool, and then Phillips 25 Getschow supplies us with this document with our tool
()
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4110 0 1 back.
2 This is what we review again to update our 77 and 3 say yes, we have another good tool.
4 (Indicating.)
5 0 Well, once it was reviewed by -- once it was tested by 6 Mr. Casey and went back --
7 A Uh-huh.
8 0 -- the QC Inspector -- the only thing he had to do, the 9 QC Inspector, was sign his name and date it; is that 10 correct?
11 A Yes, sir, with this document.
12 He had to update the 77 as a Comstock function, not
() 13 as a Getschow function; but Comstock -- we still have to 14 do our card and review Getschow's document just like 15 this tool went off-site and came back, although it did 16 not leave the site.
17 Q So, then, Mr. Seeders would have more to do than just 18 sign his name; is that what you' re saying?
19 A Yes. He signed the 77 here -- well, let's see -- well, 20 what's that?
21 March 24, '83. He signed it I think 3/21. It was 22 due 3/21. He signed it on 3/21 and said, " Tester out of i
23 calibration. Sent to PGC," okay.
24 The wrench was sent to PGC on 3/21/83. So our l
25 tester was on the blink then. He had -- at this time he f
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() I was testing wrenches himself. Our tester apparently was 2 out, not functioning, and he took the wrench to 3 Getschow.
4 0 Well, my question really is: You don't know that John 5 Seeders delayed in reviewing this; for all you know from 6 these documents, Don Casey didn't re' turn the instrument 7
and the test results until 11/17/83; .T is that correct?
8 I mean, you have no way of knowing, do you, which 9 of the two, either John Seeders or Don Casey, delayed in 10 completing this procedure?
11 A Well, Don Casey dated his report, on the top right-hand 12 corner, 3/24/83. That was apparently the date he did 13 this inspection, although he should have dated it down
(])
14 where he signed it.
15 But -- so there was no reason to hold a wrench for 16 six, seven months there of Comstock's, because Casey has 17 his own wrenches to do; and there was no reason -- you 18 wouldn' t accept the wrench without a report and put it 19 back in the field or send it for repair.
l 20 Q No, no.
l l 21 You' re looking now at that next to the last page; 22 is that correct?
23 A Yes.
24 0 You see on the top --
25 A Yes.
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1 0 -
"date , " and i t say s " 3/ 24/ 83 . " Right under that it i
2 says "due date: 3/31/ 83 ."
3 A Right.
4 Q Do you know that the first date recorded is the one in 5 which he completed the testing or could it be the date 6 on which he received the torque wrench for testing and 7 then noted the date by which he should return the tested 4
8 instrument?
i 9 A The practice was at that time to take the wrench over in i 10 the morning to Phillips Getschow. They would calibrate 11 it that day. We would pick it up the next morning.
12 This wrench has a weekly frequency, so there's Casey calibrated it, in my opinion,
(]) 13 seven days there.
14 3/24/83; and it was due for recalibration 3/31, a week 15 later.
- 16 0 But is --
i 17 A But --
I I
18 Q I'm sorry.
19 A Excuse me.
20 I don't know. That's a discrepancy, too.
l 1 21 This tool is no good, so it couldn't be due unless l 22 -- unless they adjusted it, which -- there is no 1
i 23 indication of that here.
l l
24 Now, Getschow had the ability to adjust our 25 wrenches, unless there's -- so there is a discrepancy O s m_....,..e-. 1 2 .. 4m.. < a.
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i 4113 i
O 1 there by casey, making that due 3/31, because it should 2 not -- it could not be due if it was no good.
3 Do you see what I'm saying?
4 0 But my only question is: Can you really pin the blame 5 on John Seeders, just by looking at these documents, for 6 the delay between March 24, ' 83, and November 17, '83?
7 A Let me look at his card again.
8 Well, on 4/5/83, he says, "Out of calibration.
9 Sent to Warehouse 1 for repair. GIR written 4/5/83."
10 0 I read that, and it suggested to me that at that time he 11 had not received the instrument back.
12 DoeLn't it appear that way to you?
13 A Well, he would have had to have the report to say it was
({)
14 out of calibration.
15 0 Well, that's why he sent the instrument away, isn't it?
16 A Yes.
17 0 Which was sometime in March of '837 18 A Right.
19 Q And then he reports in April that it was out of 20 calibration and sent away.
21 Doesn't that suggest that he hadn't yet received it 22 back?
23 A It was sent to Warehouse 1, which is on-site there, "for 24 repair," it says. That's a site warehouse there.
25 I can' t go along with, you know, what you' re Sonntaq Repor ting Service, Ltd.
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1 saying. It's just my opinion that he had the report on
, 2 4/5/83, at the latest, because he wrote a GIR saying the 3 tool was out of calibration.
4 0 In other words, you think he received -- he may have --
5 or he had received the tool back, and it was indicated 6 that the tool was now recalibrated?
7 A No.
8 He -- apparently Getschow didn' t adj ust it. Per 9 this report, they didn't adjust it; and per this card, 10 he's just making a statement that it's out of tolerance 11 -- excuse me. He says, "Out of calibration. Sent to 12 Warehouse 1 for repai r. "
13 Apparently he wrote a GIR saying the same thing and
(])
14 didn't write an ICR. He wrote a GIR.
15 DIRECT EXAMINATION 16 (Continued) 17 BY MR. MILLER:
[
18 Q Just to follow up, the GIR is not the appropriate l
19 document?
20 A Right.
21 MR. MILLER: Mr. Chairman, could we take a 22 brief recess at this point?
23 JUDGE GROSSMAN: Sure. 10 minutes.
24 (WHER EU PON , a recess was had, after which 25 the proceedings were resumed as follows:)
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\
4115 l
1 JUDGE GROSSMAN: We're back in session.
2 MR. MILL ER : I'd like the Reporter to mark as 3 Applicant's Exhibit 31 for identification a group of 4 documents.
5 The first seven pages of the exhibit are Form 77's 6 for torque wrench A985. The last two pages are -- well, 7 the next to the last page is a Phillips, Getschow 8 Company torque wrench calibration certification dated 9 3/28/83.
10 The last page is an L. K. Comstock & Company, Inc.,
11 torque wrench calibration record. It bears the date, in 12 the lef t-hand margin,1/11/84.
13 (The documents were thereupon marked
(])
14 Applicant's Exhibit No. 31 for 15 identification as of June 12, 1986.)
16 BY MR. MILLER:
17 Q Mr. Snyder, calling your attention to Exhibit 31, can we 18 agree that the first seven pages are copies of Form 77's 19 for torque wrench A9857 20 A Yes, sir, i
21 Q All right.
22 I'd now like to call your attention to the last 23 page, and that is a Form 23 that was filled out for that 1 24 torque wrench A985; correct?
25 A Yes, sir.
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l 4116 O 1 Q All right.
2 And do you recognize the initials of the inspector?
3 A Yes, sir.
4 0 Who is it?
5 A John Seeders.
6 Q All right.
7 There's an indication of a -- there's a checkmark 8 in the "rej ect" box. ,
9 What does that indicate, sir?
10 A That means he found the tool out of acceptable tolerance 11 per procedure.
12 0 All right.
(() 13 Going back once again to Applicant's Exhibit 28, 14 first of all, on Page 2 of the exhibit, is torque wrench 15 A985 in the upper left-hand block on that page?
16 A Page 27 17 Let's see. It must be missing -- oh, there it is.
18 Okay. I was missing it.
4 19 Q It is, in fact --
20 A Yes.
21 Q -- in that block?
22 A Yes. I see it there.
23 0 Turning to Page 13 of 27 of Exhibit 28, there again is a
! 24 reference to torque wrench A985, is there not?
25 A Yes, sir.
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1 4117 1 Q And Item No. 3 indicates that you reviewed these 2 documents in September of 1984, indicated that that 3 torque wrench was out of calibration, 1/11/84, "no 4 report written, no rework"; correct?
5 A Right, no ICR report written.
6 -
MR. MILL ER : I should state that Mr. Guild 7 and I have agreed that he will at some convenient time 8 review the ICR log and verify that, in fact, there was 9 no ICR written for this out-of-calibration condition j 10 that Mr. Snyder has just described on the record, so we l 11 can save the time of having Mr. Snyder pour through the 12 . documents.
13 JUDGE GROSSMAN: That sounds fine with us.
14 Is that correct, Mr. Guild?
15 MR. GUILD: I said I would review the i
16 document and consider stipulating to the examples that 17 Mr. Miller proposes, but I can't make that stipulation i
i 18 until I've performed that review.
19 MR. MILLER: Of course.
20 JUDGE GROSSMAN: That's fine. That's 21 satisfactory.
22 BY MR. MILLER:
23 0 Once again, Mr. Snyder, whose responsibility was it to 24 initiate an ICR for the out-of-calibration condition 25 that was recorded on January 11, 1984?
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- 1 A That would have been John seeders.
2 Q Thank you, sir.
3 And based on your records -- that is, Applicant's 4 Exhibit 28 -- did he do so?
1 5 A No, sir.
6 MR. MILLER: I'd like the Reporter to mark as 7 Applicant's Exhibit 32 for identification a group of 8 documents. The first five pages are copies of Form 77's 9 for torque wrench A1366.
1 10 The last page is a Phillips, Getschow Company f 11 torque wrench calibration certificate for torque wrench l
l 12 A1366. It bears a date, in the lower right-hand corner, 13 July 13, '84.
(])
14 (The documents were thereupon marked l 15 Applicant's Exhibit No. 32 for 16 identification as of June 12, 1986.)
l 17 BY MR. MILLER:
18 Q All right.
I 19 Mr. Snyder, can you describe for the record what 20 Exhibit 31 consists of?
21 A I thought this was 32.
i 22 Q 32. I beg your pardon.
23 A Yes. It's Form 77's for torque wrench A1366.
l 24 0 And what is the last page, sir?
l
, 25 A That's a Phillips Getschow calibration report for A1366,
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i 4119 O 1 dated 7/13/84.
2 Q All right.
3 Turning back again to Applicant's Exhibit 28 in 4 evidence, on Page 2 do you find torque wrench A1366 in 5 the upper lef t-hand block of Page 27 6 A Yes, sir. .
7 Q All right.
8 I'd now ask that you turn to Page 14 of Applicant's 9 Exhibit 28.
10 Is there an entry there f or torque wrench A1366?
11 A Yes, sir.
12 MR. GUILD: Excuse me. Page 137 13 MR. MILLER: 14.
(])
14 BY MR. MILL ER :
15 0 There's a Sentence No. 2 under that torque wrench.
16 Would you read that into the record, sir?
17 A "Out of calibration 7/13/84, no ICR written, nothing, 18 Form 77 states out of calibration, ICR written but I 19 can' t find anything. "
20 Q All right.
21 If we look at the first page of Applicant's Exhibit 22 32, is there an entry on the Form 77 for July 13, 1984, 23 for torque wrench A1366?
24 A Yes, sir.
25 0 And in the " remarks" column, what words appear?
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4120 O 1 A "Out of calibration. ICR written 7/13/84."
2 Q All right.
3 And there's Mr. Seeders' signature there, is there 4 not?
5 A Yes, sir.
6 Q Does Mr. Seeders' signature appear on the Phillips 7 Getschow torque wrench calibration certificate?
8 A Yes, sir.
9 Q Having discovered this out-of-calibration condition, 10 whose responsibility was it to initiate the ICR?
11 A. John Seeders'.
12 0 And as best you can tell from your research, did he do
' so?
Q 13 14 A No, sir.
15 I think there's a comma here that probably 16 shouldn't be there under that No. 2. I'm sure it's 17 supposed to say, " Form 77 states out of calibration."
18 Okay. It says that an ICR is written, but we 19 couldn't find one in the log.
20 MR. MILLER : Again, your Honor, subject to Mr.
21 Guild's review of the ICR log, we will perhaps be able.
22 to add that bit of evidence that, in fact, the ICR log 23 does not contain any ICR's for the out-of-calibration 24 condition.
25 MR. GUILD: Yes, perhaps so, Mr. Chairman, AnnnFa g Dann r ti ng Rarvi ce , T} d .
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i ' ,
4121 O 1 but I' don' t agree that that would establish that no ICR l 2 was w ritten. I don't believe that that f act would 3 establish that conclusion.
4 BY MR. MILLER :
5 0 Well,' Mr. Snyder, where else would one look, besides the 6 ICR log, to determine ~whether or not an ICR had, in 7 fact, been written?
8 A Well, that would be the first place to go, the log.
9 Then you would have to go to the vault files that 10 actually have the ICR's in them that were writte'n.
11 But everything in the file'should be reflected 12 here, in my opinion.
13 Okay.
(]) Q 14 That is, there isn' t, come second ICR log that 15 ~ supplerents or is in addition to the one that'you have 16 bef ore you f or the same time peried?
17 A No, not that I'm aware of.
18 BOARD EXAMINATION 19 BY JUDGE GROSSMAN:
20 0' Who makes the ent'y, r again, in the log?
21 A There's an ICR' clerk'.
22 I stated earliet' that Jackie Joyce was, but I think 23 I was wrong therer that when I first .got -hired, Tanya i
24 Rolan was actually doing that job.
25 0 Well, now, what are the mechanics for logging an ICR in?
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1 O 1 Does the QC Inspector give the ICR a number?
2 A No, sir.
3 He would write the ICR, take it to the clerk, turn 4 it in -- he would put his hold tag on the tool, take the 5 ICR to the clerk.
l 6 She would apply the number to the ICR and forward 7 it through the processing.
8 That's the last the inspector would see of that ICR 9 until it came back to him to close out when the work was 10 performed, the rework or whatever was involved.
11 Q Okay.
12 Well, why do you conclude, from looking at this 13 particular document, if you do so conclude, that Mr.
({}
14 Seeders didn' t write the ICR7 15 It could just as easily have been that Mr. Seeders 16 wrote the ICR and the clerk f ailed in her duty; is that 17 correct?
18 A That's a possibility, yes.
19 0 All right.
20 So you really can' t conclude one way or the other, 21 can you?
22 A Well, I think -- all I was saying is we could not find 23 one written.
24 0 That's all you're representing?
25 A Yes.
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l 4123 1
f O 1 JUDGE CALLIHAN: Mr. Snyder, look at the i 2 topmost page of Applicant's Exhibit 32. There's the 3 July 13, '84, entry which had been discussed. ,
4 Can you comment on the three following entries?- l 5 What happened on September 7th, do you reckon, ;
i j 6 1984? !
7 THE WITNESS: Well, I would say that, after i
I 8 71384, the wrench was sent off site -- either sent off i l 9 site for repair or it was held for those two months for i 10 some reason, taken back to Phillips Getschow on 9/7/84 f 11 and calibrated due 9/14/84.
i 12 I would say that the same -- they did calibrate it l
(} 13 14 again on 9/14; and he's got "on hold" in the remarks column, and the same for 9/21.
15 JUDGE CALLIHAN: Do we have any record of the 1 16 early September, '84, rec'alibration?
- 17 THE WITNESS: I don't know what this says l 18 here. !
19 I -- I could not answer that. I have no 20 recollection of that.
21 JUDGE CALLIHAN: What's the basis of your 22 statement that it was taken back to Phillips Getschow?
23 THE WITNESS: Well, under the calibration !
24 standard there, you see down under 9/7/84, that's PGC 25 8455.
I Sonntag Reporting Service, Ltd.
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4124 1 That's a Phillips Getschow standard, which, if you 2 notice on the back page, that is their analyzer standard i 3 number.
4 JUDGE CALLIHAN: All right. That's their --
5 THE WITNESS: Yes.
6 JUDGE CALLIHAN: -- that's their calibration 7 of the certificate?
8 THE WITNESS: Yes, sir.
9 JUDGE CALLIHAN: All right, sir.
10 Why, on the 24th -- on the 24th and the 21st of 11 September, 1984, do you think this is on hold?
12 THE WITNESS: My opinion is they didn't need 13 the tool in the field at that time.
14 JUDGE CALLIHAN: Okay.
15 THE WITNESS: That would be the only thing I 16 could say.
17 JUDGE CALLIHAN: In the final line on -- on 18 that control card, Form 77, is an entry in your writing?
19 THE WITNESS: Yes, sir.
20 JUDGE CALLIHAN: And what does it say and 21 what's your basis and what did you do about it?
22 THE WITNESS: Well, it was obviously missing, 23 lost or stolen. On 9/24/84, I wrote an ICR 7172.
24 I don't know why, now looking at this, I didn't 25 initial and date that comment.
!O v
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l 4125 1 That is my handwriting; because the practice is to j 2 initial and date any comments you make.
3 I --
4 JUDGE CALLIHAN: Now, do your records show --
5 I beg your pardon. I thought you were finished. I'm 6 sorry.
7 THE NITNESS: I do know probably why now, 8 thinking about it.
j 9 I was not certified 9/24/84. Maybe that was my 1
l 10 reasoning there.
i 11 (Indicating.)
12 I don't know. I really couldn't say. That was my
) r3 13 opinion.
V 14 Maybe, also, after I did get certified, I noted I 15 that the tool was missing on 9/24 and I simply did not 16 initial and date it.
1 I 17 JUDGE CALLIHAN: Well, continuing, however, 18 you issued apparently -- and correct me if I'm wrong --
19 an ICR 7172?
20 THE WITNESS: Yes, sir.
21 JUDGE CALLIHAN: Reporting a loss?
22 THE WITNESS: Yes, sir.
23 JUDGE CALLIHAN: Now, does your -- your super 24 file there show ICR 7172?
i 25 THE WITNESS: It should, if it's -- some of Sonntag Reporting Service, Ltd.
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(
1 these pages were turned around.
2 Was that for some reason?
3 I don't think I did. I may have done it, but -- I 4 mean, I'll straighten her out.
5 MR. MILLER: It wasn't a test, I promise you.
6 THE WITNESS: I'm used to shuffling papers.
7 Okay. There you go.
8 7172, yes, sir, it's here. It says, " Tool 9 missing," my name, "L. K. C. Ace 1366 torque wrench." I 10 wrote it.
11 Apparently I wrote the ICR on 10/3, so it was 3 12 days after I was certified.
1
{} 13 14 What had happened:
This tool was nowhere around when I got certified, 15 and there was no indication on the card after 9/21/84, 16 so after doing some research, the tool was termed lost, 17 I wrote the ICR; and still I don't know why I didn't 18 initial and date that comment.
19 JUDGE CALLIHAN: Your most recent search, 20 successful, for 7172, didn't show Mr. Seeders' July 13, 21 1984, ICR attached to it or accompanying it?
22 THE WITNESS: No, sir.
23 JUDGE CALLIHAN: Thank you.
24 JUDGE GROSSMAN: Was it your understanding 25 you couldn't initiate an ICR unless you were certified?
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( l THE WITNESS: No, I don't believe that's true.
2 You see, I didn't get this deeply involved until 3 after I got certified, because I think John Seeders' 4 last day was September 29th or something like that, and 5 there was a week there where I was not certified and 6 John was not there. Myra Sproull took over, 7 reluctantly, because she didn't want the job; but her 8 and I worked kind of beside each other 'on this; and, no, 9 I -- I believe you could write one if it was a 10 deficiency that -- you know, to warrant one.
11 Now, you may get static later, but I don't see a 12 problem with writing one, you know; and saying -- you
{} 13 can't close an ICR unless you are certified in the area 14 now. At that -- you cannot do that.
15 JUDGE GROSSMAN: I thought you had said that 16 you waited those 2 weeks between 9/24/84 and 10 whatever 17 it was, 14 o r --
18 THE WITNESS: 10 -- 10/11.
19 JUDGE GROSSMAN: -- 10/11 --
20 THE WITNESS: No.
21 JUDGE GROSSMAN: -- because you hadn't been 22 certified at the time?
23 THE WITNESS: No. I was certified 10/8; but I 24 didn't get -- see, there was so many things that we had 25 to try to straighten out at once, we couldn't do it all n
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I 4128 O 1 at once, and it was just a matter of coming to this tool 2 and saying, "Where is A1366," and after looking around, 3 it wasn't -- it wasn't there, so I wrote it at that 4 time.
5 It wasn't that I wouldn't have wrote it before that 6 date. It's just where I get to it, because we were --
7 we were taking things as they came at that time.
8 (Indicating.)
9 JUDGE CALLIHAN: Was Ms. Sproull certified?
10 THE WITNESS: Yes, sir.
11 JUDGE CALLIHAN: Level 2?
12 THE WITNESS: Yes, sir.
{} 13 MR. BERRY: Mr. Chairman, can I broach that 14 subject on the witness' present understanding on that 15 topic', since you brought it up now?
16 JUDGE GROSSMAN: We're on Mr. Miller's 17 examination, and while we can be rude about it, we 18 usually -- but, fine, if you want to ask him a question.
19 Do you have any objection, Mr. Miller?
20 MR. MILLER: No, sir.
21 MR. BERRY: I wasn't going to ask a question.
22 Since the Board brought that question up, I thought 23 the Board might like to follow up and have his present 24 understanding of that question. 1 l
25 The question is still now open as to whether -- i O
Sonntag Reporting Service, Ltd.
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4129 1 whether he could write an NCR -- excuse me -- an ICR at l l
2 the time, and I think now it would be an appropriate 3 place to have an answer to this question; but I only 4 brought it up because you just asked the witness that, 5 and --
6 JUDGE GROSSMAN: I think I asked him and he 7 answered.
8 Now, what --
9 THE WITNESS: I think the reason that doesn't 10 happen often is because if you are not certified, you 11 are -- you are not out in the field looking for problems 12 the majority of the time.
(} 13 You may be, you know, stuck in the office reading or whatever or -- or shuffling paper was a -- a big job 14 15 for an uncertified inspector, so you -- you may not be 16 in the field, so that wouldn't happen very often.
17 I -- I've never -- don't recall coming across a 18 problem like that; but I would say, you know, they can't 19 hurt you for writing one.
20 They may make another inspector go and look at -- a 21 certified inspector, and then rewrite it in his own --
22 in his own words or his own -- since he is certified, he 23 could maybe elaborate more on it.
24 (Indicating.)
25 BY MR. MILLER:
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
4130 O 1 O Mr. Synder, I just want to follow up on a few questions 2 that the Chairman asked you with respect to the torque 3 wrench calibration certificate that was dated July 13, j 4 1984, and the entry on the Phillips Getschow Form 77 for 5 that date.
6 MR. GUILD: You mean the Comstock Form 77.
7 MR. MILLER: I'm sorry. I mean the Comstock 8 Form 77. I beg your pardon.
9 THE WITNESS: Uh-huh.
! 10 BY MR. MILLER:
11 Q Can you tell, from looking, what the interval -- the 12 calibration interval on this tool was supposed to be?
l
(} 13 A Weekly.
! 14 Q All right.
15 A Now, it may lapse over a day or two, like I said, 16 because of weekends or whatever.
17 Normally, I would make a statement in the remarks 18 saying, " Tool not issued to the field since" - "since 19 it was sent to PGC," or whatever. You know, just a 20 small statement in the remarks section; but you wouldn't 21 write it up, because it was not issued to the field, you 22 see.
23 (Indicating.)
24 Q Okay. Now, at the very top of the page, the first page 25 of Exhibit 32, is another out-of-calibration indication
(')
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4131 1 for torque wrench A1366.
2 A Yes.
3 Q And there is, in your report, Exhibit 28, no indication 4 that there was a missing ICR on that occasion?
5 A .That's true.
6 Q Could you take just a minute and see whether you can 7 locate an ICR that was written for torque wrench A1366 8 on or about June 6, 1984?
9 A Uh-huh.
10 I either missed it -- let's see. I'm down to 5/31.
11 I guess I -- there could be a date. There's a 6/4, so 12 I'll look a little further here.
(} 13 Okay. There it is. Torque -- or just it says, "A1366, Seeders, date 6/5/84, ICR 5548, torque wrench
! 14
. 15 out of calibration."
16 MR. GUILD: Indeed, it does, Mr. Chairman; and 17 the page begins with an entry that is for 5/30/84, ends 18 with an entry that's for 5/24/84 at the bottom of the 19 page, and in the middle of the page is the entry in 20 question by the date 6/4/84.
21 The record should reflect that the witness thumbed 22 through perhaps 30 pages of the multi-page document to 23 find that entry.
24 JUDGE GROSSMAN: I was going to ask that.
25 Is that so, Mr. Snyder, that you did go through Sonntag Reoorting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
4132 1 about 35 pages or so?
2 THE WITNESS: Yes.
3 If I could explain, too.
4 JUDGE GROSSMAN: Sure.
5 THE WITNESS: I think now the reason is, l 6 thinking about this, we were issued hold tags that had '
7 the ICR number -- they had a number on them. In this 8 case -- well, excuse me. I cannot say that for '84 --
9 6/5/84. I'm sorry.
10 Later we were issued hold tags that had -- that 11 were prenumbered.
12 When we would write the ICR number, we would hang
{} 13 that tag, and that's the number that -- that she had j 14 another log that she would assign the ICR number to that 15 tag number, which made things very confusing; but I 16 cannot say that for this, so, yeah, there is several.
17 BY MR. MILLER:
18 Q Do you know any reason, Mr. Snyder, as to why the ICR's 19 are obviously in numerical order but they are not in 20 date order?
l 21 A I'm sure there's an explanation, but I --
22 O You don't know?
23 A -- I can't say.
l 24 You know, I know the inspectors did not hold these 25 ICR's in the field that long with that kind of a date on i
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l them; you know, write a date 5/14 and not turn it in for .
2 a month. That doesn't happen. So that cannot be the 3 explanation here, in my opinion.
4 And if -- if you will notice here, the "date to 5 construction" column, that's where every date matches on 6 the page.
7 So, you know, again, you would have to get a clerk 8 to answer this question, but that's -- that's what I see 9 here on these.
10 Now, the -- the ICR number, and then you've got a 11 date beside it, I would say that was a date the ICR was 11 written, but -- this column here.
(} 13 14 (Indicating.)
JUDGE GROSSMAN: Okay. The date that went on 15 for the ICR, was that the date the ICR was written or 16 was that the date it was logged?
17 THE WITNESS: Well, I would -- I would assume 18 this was the date-the ICR was written, but --
19 (Indicating.)
20 JUDGE GROSSMAN: Well, then it seems as 21 though --
22 THE WITNESS: It doesn't seem right then, and 23 then that's an assumption.
24 JUDGE GROSSMAN: Well, isn't it a logical 25 conclusion that the logging clerk didn't record the ICR Sonntag Reporting Service, Ltd.
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4134 1
1 until the -- what does "date to construction" mean?
2 THE WITNESS: The document would go out to 3 the field to have rework performed or whatever.
4 See, back here they didn't have a "date to 5 engineering," which is where it goes now.
6 JUDGE GROSSMAN: I see.
7 THE WITNESS: It went to the field, where it 8 should have always went to the engineer, in my opinion.
9 JUEGE GROSSMAN: Well, wouldn't it seem 10 logical, then, that the logging clerk kept the ICR's for 11 some time, and then when she sent them out to 12 construction, logged them in and put the date in which
(} 13 the ICR had originally been written, and so some of 14 those dates would go out of sequence?
15 Of course, she may have held the ICR on some of 16 them -- the ICR's longer for some than for others.
17 Does that seem logical to you?
18 THE WITNESS: Yes, sir, that's sounds 19 logical, because there's not very many days lapse here.
20 Well, they are talking six, seven days, a week. I 21 don't know if she had to hold so many; but you would 22 think they would process them right out to keep -- keep 23 these things moving, but that -- that's what it looks 24 like to me.
25 JUDGE GROSSMAN: All right. It's logical, Sonntag Reporting Service, Ltd.
ueneva, 11Ainois oulas (312) 232-0262
4135 1 but it's certainly not evidence, the fact that I 2 concluded that just offhand.
3 I'll agree to that.
4 BY MR. MILLER:
5 Q Mr. Synder, turning back yet again to Exhibit 32:
6 You recorded the ICR No. 7172 when the tool was 7 missing or stolen?
8 A Yes, sir.
9 Q How did you know that ICR number?
10 A Well, you just have to wait a day or -- or so, and you 11 can go ask the clerk or you could put a little yellow 12 stick-on on your ICR and say, "Give me a number back i r'T 13 when you get it logged," you know, and she would bring i (_/
l 14 you back the number.
15 e I just felt like, and still do, that that completes 16 that document more and you don't have to go searching 17 through massive amounts of paper to find out what the 18 ICR number was, because we knew that this date may be a l
19 problem here to find the things.
20 Q In your experience with the clerk or clerks who are l 21 responsible for logging ICR's, have you ever had any 22 experience in which an ICR that you wrote was not given 23 a number and properly logged in?
24 A No, sir.
25 Q Have you heard of any instance from any other inspector f')
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I 4136
() 1 in which an ICR was filled out by an inspector but was 2 not properly logged in by the ICR clerk?
3 A No, sir.
4 MR. GUILD: I assume the last answer doesn't 5 establish that fact, but it represents just what the 6 witness' understanding is?
7 JUDGE GROSSMAN: I think it speaks for 8 itself, Mr. Guild.
9 BY MR. MILLER:
10 0 Well, prior to the time Judge Grossman asked a question i 11 as to whether it was possible that the ICR clerk had not
- 12 properly logged in an ICR, had you ever had any reason l
{} 13 14 to consider that that was a reason for an ICR not appearing in the ICR log?
15 A No, sir.
16 MR. MILLER: I'd like to ask the Court 17 Reporter to mark, as Applicant's Exhibit 33 for 18 identification, a multi-page document.
19 The first six pages are copies of Form 77 for 20 torque wrench 9702; the last three pages of the exhibit 21 are copies of Phillips Getschow Company torque wrench 4
- 22 calibration certificates for torque wrench 9702.
9 23 (Indicating.)
24 (The document was thereupon marked i 25 Applicant's Exhibit No. 33 for
(:)
i Sonntag Reporting Service, Ltd.
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4137 O 1 identification as of June 12, 1986.)
2 BY MR. MILLER:
3 Q All right. Mr. Snyder, again, does torque wrench --
4 well, let me ask you this.
5 There is a torque wrench listed in the upper 6 left-hand box --
7 A Uh-huh.
8 Q -- on Page 2, and it's listed as A9702.
9 Is that the same torque wrench as the torque wrench 10 that -- whose record the -- for which the Form 77 that 11 the calibration documents are that I have just handed 12 you?
{} 13 A Yes, sir.
14 That A should not be on there.
15 0 on your document, on Exhibit 28?
16 A Yes, on the 20th.
17 Q How do you know that it shouldn't be there?
18 A Well, I just know that tool.
19 It was added there by the girl that typed this up, 20 I -- in my opinion. I mean, we didn't have an A9702 and 21 a 9702. <
22 There are some tools that have that -- that we have 23 like that, the A is the only difference in the number; 24 but the actual number should be 9702 --
25 Q Well --
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4138 O 1 A -- in my opinion.
J 2 Now, the only way to verify that is in the vault 3 package, the Form 8, if you have one attached here, 4 which I don't think there is.
5 Q Well, let's see if we can't see if we can find some 6 other evidence.
7 If you turn to Page 25 of 27, please --
8 A Okay.
i 9 Q -- of Exhibit 28.
10 A All right.
I 11 Q And there is an entry for torque wrench A9702?
12 A Uh-huh.
{} 13 Q The last line says, " Rejected 6/18/84 by PGC. No 14 documentation."
15 A Uh-huh.
16 Q And if we look at the Form 77 in Applicant's Exhibit 33,
, 17 we find an entry on that date indicating rejection by 18 -
PG, by Phillips Getschow?
19 A Yes.
20 Q Now, the next to the last page of the exhibit is the 21 torque wrench calibration certificate for 9702, and it 22 has Mr. Seeders' signature and the date June 18, 1984; 23 correct?
24 A Yes, sir.
i 25 Q And can you tell by looking at the calibration
() '
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4139 1 certificate whether or not the tool was in or out of 2 calibration?
3 A Yes, sir, it was out of acceptable tolerance.
4 0 Okay. And what responsibility did Mr. Seeders have with 5 respect to the initiation of an ICR after that condition 6 was reported to him?
7 A He should have initiated an ICR and placed a hold tag on 8 the tool.
9 Q And your research indicates -- well, what does your 10 research indicate?
11 A " Rejected 6/18/84 by PGC. No documentation."
12 0 Yes, sir.
13 What does that mean?
(])
14 Then was an ICR generated or not?
15 A Well, evidently so, because there is the report here.
16 I think, after we got further along in this 17 research, we tried to shorten our words. You know, 18 instead of -- writing out in longhand, it takes time; 19 but that's what that means, I'm sure, in my opinion.
20 Q "No documentation" means no ICR?
21 A Well, it could mean even no calibration report in that 22 case; but I'm sure that -- unless this report -- well, I 23 would say no ICR written.
24 Q All right.
25 JUDGE GROSSMAN: Again, this is a case, Mr.
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n U 1 Snyder, isn't it, in which on the Form 77 Mr. Seeders 2 apparently wrote that an ICR was written on 6/6/84?
3 THE WITNESS: Let's see. 6/6. I don't 4 see --
5 JUDGE GROSSMAN: Well, look at the date of 6 6/18/84.
7 THE WITNESS: 6/18 -- I'm sorry -- you said; 8 right?
9 JUDGE GROSSMAN: If you look over to the 10 right, it does say he wrote an ICR on 6/6/84?
11 THE WITNESS: Okay. Well, yeah.
12 I don't know how that's possible, but -- you know,
("1 13 writing the ICR before the tool was out of tolerance.
U 14 JUDGE GROSSMAN: Well, no.
15 I think if you look at the line before that --
16 THE WITNESS: Right.
17 JUDGE GROSSMAN: -- he apparently indicated 18 that he removed it from service at 6/7/84, and then l 19 apparently on where it says, " Calibration Due Date,"
l l 20 recorded the fact that he had written the ICR earlier.
21 THE WITNESS: Uh-huh.
l 22 JUDGE GROSSMAN: Do you see that?
23 THE WITNESS: Yes, sir.
! 24 JUDGE GROSSMAN: So it seems to suggest that 25 he might have taken the action on 6/6 and 6/7 and merely
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4141 l 1 recorded that on 6/18.
2 It does suggest that, doesn't it?
3 THE WITNESS: Yes, sir.
4 JUDGE GROSSMAN: But, again, you indicate 5 that you couldn't find the ICR; is that correct?
6 THE WITNESS: That's what this says. It 7 says, "No documentation."
8 Now, you know, I can't say that that means no ICR.
9 I just can't say that, because that's not what it 10 says --
11 MR. MILLER: Well --
12 THE WITNESS: -- but -- I'm sorry. I mean,
/~') 13 it could mean that, yes.
(_/
14 MR. MILLER: Yes.
15 BY MR. MILLER:
16 Q Well, Mr. Snyder, you found for us just a few minutes 17 ago an ICR that was, in fact, written on June 6, 1984, 18 for the preceding exhibit, Tool No. A1366?
19 A Yes, sir.
20 0 I'm sorry to do this, but would you take another minute 21 and see if you can locate --
22 A For 6/6/84 or 6/18/84, either one?
23 Q Either one for Tool 9702.
.24 A All right. Let's see.
25 JUDGE GROSSMAN: Excuse me.
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4142 1 On that log, was the tool number recorded with the 2 ICR?
3 THE WITNESS: Yes, sir. Out here in the 4 remarks section, she, I think, always recorded the tool 5 number, because it would be on the ICR.
6 JUDGE GROSSMAN: Could you write an ICR 7 covering more than one tool?
8 THE WITNESS: Possibly in a specific case.
9 Say a bunch of new tools came on site and they 10 failed calibration. You could write what we would call 11 a generic ICR or something saying, "All these tools were 12 no good"; but there would be no rework involved.
I
{} 13 You see, if a tool that needed rework is involved, 14 I would think you would singly write the ICR.
15 JUDGE GROSSMAN: So it's possible it wouldn't 16 apply to this case?
17 THE WITNESS: Right.
18 JUDGE GROSSMAN: I see.
19 And that ICR, in your opinion, then, won't cover 20 more than one tool, and it covered the other tool; is 21 that correct?
I 22 THE WITNESS: It would be on the tool itself; 23 right.
24 JUDGE GROSSMAN: Okay.
l l 25 THE WITNESS: Okay. I'll go back this way.
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4143 O 1 MR. GUILD: I just ask that the record should 2 reflect a minute was up about four minutes ago.
3 THE WITNESS: Well, I'm up to 7/26.
4 I don't know if you need me to go further.
5 MR. MILLER: No, sir. Why don't you quit.
6 We'll --
7 THE WITNESS: Okay.
8 MR. MILLER: -- leave it to the attorneys to 9 see if they can't agree to the existence or 10 non-existence of an entry reflecting the issuance of an 11 ICR.
12 I'd ask the Reporter to mark, as Applicant's e~3 13 Exhibit 34 for identification, a number of documents.
O The first 9 pages are Form 77 for torque wrench 14 15 10081; the next to the last page is a Phillips Getschow 16 Company torque wrench calibration certificate dated May 17 27, 1983; the last page is a Phillips Getschow Company 18 calibration certificate. It has a date in the bottom 19 right-hand corner of June 18, 1984.
l 20 (Indicating.)
21 (The document was thereupon marked 22 Applicant's Exhibit No. 34 for i
23 identification as of June 12, 1986.)
! 24 JUDGE GROSSMAN: Is this the last one of f
25 those groups of Form 77?
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I 4144 I
O 1 MR. MILLER: Yes, sir.
2 I have others, but I think I'm reaching the point 3 of finishing. i 4 JUDGE GROSSMAN: Just reaching that?
5 (Laughter.)
6 BY MR. MILLER:
7 Q Now, once again, Mr. Synder, is torque wrench 10081 8 listed in the upper left-hand block of the second page 9 of Exhibit 28?
10 A Yes, sir.
11 Q And would you turn now to Page 25 of 27.
12 A Yes, sir. ,
l
{} 13 14 Q All right. There is a reference there, is there not, to an activity that took place on May 27, 1983?
15 A Uh-huh.
i 16 Q Now, can you tell, by looking at the documents that have 17 been marked as Applicant's Exhibit 34, whether any of 18 those documents constitute the rejection -- or the 19 rejected 5/27/83 form?
20 A No, sir.
21 Q Well, I call your attention to the second to the last 22 page of the exhibit.
23 A Uh-huh.
24 Q There is a date of May 27, 1983, on that form, is there 25 not?
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1 4145 O 1 A Yes, sir.
2 Q Do you know whether that is the form which is referred 3 to on Page 25 of 27 on Exhibit 28?
4 A Yes, sir, I would say it's the same one.
5 0 All right. Turning to the Form 77 for torque wrench 6 10081, is there an entry for May 27, 1983?
7 A I'm looking at '84. Okay.
8 No, sir, I don't see one.
9 Q From looking at the Form 77, Mr. Snyder, could you tell 10 that this torque wrench was found to be out of 11 calibration by Phillips Getschow on May 27, 1983?
12 A No, sir.
{} 13 Q On that Phillips Getschow certification, there is Mr.
14 Seeders' signature and the date of November 17, 1983?
15 A Yes, sir.
16 Q Looking at the Form 77 for the month of November of 17 1983, can you tell that this wrench was found to be out 18 of calibration by Phillips Getschow?
19 A No, sir.
20 Q Your entry on Page 25 of 27 of Exhibit 28 goes on to 21 state, "No documentation," quote, "'ICR,'" close quote, 22 "Coss needs to accept / reject box 6-22-83."
23 Can you tell us what that means, Mr. Snyder?
24 A As we were reviewing these documents, you know, we would 25 run our sentences together, more or less, or maybe just O
\~/
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l 4146 O 1 a -- a period would separate them, but yet they were one 2 right after another, and I think what -- what this is 3 supposed to be is a -- a period after "ICR," and then 4 another statement, "Coss needs to be accept / reject box 5 on report dated 6-22-83," would be my opinion of that.
6 Now --
7 Q We understand from that entry that your research 8 indicated that there was no ICR initiated for this 9 torque wrench where it was found out of calibration as 10 reported by Phillips Getschow on May 27, 1983?
11 A That's correct.
12 0 Whose responsibility was to it initiate such an ICR?
{} 13 14 A Well, I can't say, because there's no 5 -- there's no May statements on the 77 and there's no May signature on 15 the Phillips Getschow report besides Don Coss', so I'm 16 not sure.
17 0 Well, excuse me.
18 Mr. Seeders' signature does appear on that report,.
19 does it not?
20 A Yes; but it's dated 11/17/83.
21 What I was just saying, that with Don Coss' being 22 so closely there on this Page 25 of 27, maybe he was 23 involved in that.
24 I couldn't say this; but there's no statement to l 25 verify either on the 77.
O j Sonntag Reporting Service, Ltd.
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4147 1 (Indicating.)
2 MR. MILLER: All right. I'd like the 3 Reporter to mark, as Applicant's Exhibit 35 for 4 identification, a group of exhibits -- a group of 5 documents, rather.
6 The first seven pages are copies of Form 77 for 7 torque wrench A174; the last page is a document that 8 also refers to torque wrench A174. It has a date in the 9 lower right-hand portion of it August 15, 1983.
10 (Indicating.)
11 (The document was thereupon marked 12 Applicant's Exhibit No. 35 for 13 identification as of June 12, 1986.)
(}
i 14 BY MR. MILLER:
15 Q Now, Mr. Snyder --
16 THE WITNESS: I think you forgot my copy.
17 MR. MILLER: I thought you had these all 18 memorized.
i ,
19 I beg your pardon.
l 20 (Indicating.)
21 THE WITNESS: That's all right.
22 (Laughter.)
23 MR. MILLER: Now, Mr. Chairman, if I might 24 just have a minute.
t I
25 BY MR. MILLER:
l l 'Sonntag Reporting Service, Ltd. l
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4148 O 1 Q Mr. Snyder, the last page of this exhibit, can you 2 describe what type of a document this is?
3 A This is a GIR, General Inspection Report, Form 104.
4 Q All right. Now, calling your attention to the second 5 page of the exhibit:
6 There's an entry on the Form 77 for August 15, 7 1983?
8 A Yes, sir.
9 Q And it refers, does it not, to a GIR being written?
10 A Yes, sir, 11 Q All right. Under Procedure 4.9.1, was it proper or 12 improper to write a GIR for that condition?
13 A The procedure requires an ICR to be written for
{}
14 damaged -- excuse me -- out-of-tolerance tools or other 15 due tools.
16 Q Well --
17 A A GIR would not be proper.
18 Q Now, I'd like to show you a document, Mr. Snyder, that 19 is an attachment to Mr. Seltmann's prepared testimony in 20 this case. It's Attachment 3 to that testimony, and 21 it's a memorandum dated September 25, 1984, from Mr.
22 Seltmann to Mr. DeWald, and I'd just like you to glance
~
23 at it and tell me whether you've ever seen it before.
24 (Indicating . )
25 A No, sir, not to my recollection.
O Sonntag Reporting Service, Ltd.
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1 Q Okay. Thank you.
2 EMR., MILL ~ER: Le"t's see. Where is that NCR 3 3406?
4 ,I'd likerto Reporter to mark / as Applicant's 5 Exhibit 36 for identification, a fiv'e-page document.
) 6 It's L.'K. Comstock & Company Non2Conformance Report No.
- 7 3406. It has a date in the upper right-hand corner of 8 October,9, 1984. ,y
~
9 (Indicating.)
10 (The document was thereupon mark,ed 11 Applicant's Exhibit No. 36-for 12 identification as of June. 12, 1986'.)
f
(} 13 BY MR. MILLER:
14 O Mr. Snyder, first of all, does your signature appear 15 anywhere on the front page of this document?-
16 A Yes, sir.
17 4 Q And that's about a third of the way down the first --
18 the front page?
19 A Yes, sir.
20 Q All_right.: The description of the non-conformance, did 21 you prepare that, sir?
22 A Yes, sir, i~
23,. Q Okay. There is a reference to review of L. K. C.
- 24 calibration records.
I 25 Is that the same review that we've been discussing Sonntag. Reporting Service, Ltd.
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4150 0 1 all afternoon, and that is, in part, memorialized in 2 Applicant's Exhibit 28?
3 A Yes, sir.
4 I might add that I did touch -- converse with my 5 supervisor before I wrote this, which was Rick Saklak.
6 I told -- well, I think we determined that we 7 needed something to get some of these ICR's moving or 8 get some of the tools out of the field that were being 9 written up there.
10 Q Well,'could you describe what the -- the nature of the 11 non-conforming condition was that you recorded on this 12 Non-Conformance Report?
{} 13 14 A Yes.
10/8 -- took over the calibration program 10/8/84, we There was -- when I was -- took over, which was 15 had several tools that were continually being out of 16 tolerance, repaired, put back in the field, open ICR's 17 piling up on them, and there were -- just had to be 18 something to get this moving again.
19 Per the procedure here, 4.9.1, Rev C, it told us to 20 remove the equipment from service and to return the 21 equipment immediately to the warehouse for storage when 22 an ICR was written.
23 So this paragraph in the procedure was being 24 violated, if you want to call it that, so we had to get 25 some kind of documentation to get the ICR's closed out O
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4151 1 or get them rolling, get the tools out of in field and 2 basically to see what we had.
3 0 Well, were the tools that were being repaired -- well, a 4 tool was found to be out of calibration; is that 5 correct?
6 A Yes, sir.
7 Q All right. Was the tool then recalibrated or repaired 8 as necessary?
9 A Yes. Like I said, Phillips Getschow, they were doing 10 that for us so that we didn't have to ship them off 11 site, which takes months to get them off and back.
12 They had the ability and the procedure, I 13 understand, to do that in their lab and recalibrate the i
(^T s/
14 tool and give it back to us.
15 Q Mr. Snyder, did the Procedure 4.9.1 require any further 16 action with respect to the -- a tool that was found out 17 of calibration before the ICR or NCR to be closed out?
18 A Yes, an evaluation to be made by someone on the validity 19 of the use of that tool.
20 Q All right. For prior work, sir?
21 A Yes, sir.
22 Q All right. Now, tools that are -- are listed in the i
i 23 succeeding pages --
24 A Uh-huh.
25 0 -- succeeding three pages of the NCR, were the tools O
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V 1 themselves, in fact, out of calibration when they were 2 released back to the field?
3 A I would say no.
4 You would have -- each tool would be an individual 5 case that you would have to do some research on.
6 Q Well, why don't you look at the last page, sir, and see 7 if that refreshes your recollection.
8 A Yes. That -- well, see, that -- that date there is 9 9/3/85, which I believe Rev D was in effect at that 10 time, which allowed us to put a tool back in the field 11 after it was repaired.
12 Q But prior to the time that the ICR or NCR was completely
{} 13 14 A closed out?
Yes, sir.
15 Q Under Rev C, what was the requirement, in terms of 16 holding the tool back, after an ICR had been written 17 against it for an uncalibrated condition?
18 A Well, the procedure required it to be held in Paragraph 19 3.3.7. Now, that's my interpretation of that; and my 20 prior experience on my last job, that was the case 21 there.
22 That way, you force the paper work to get -- to 23 flow and the rework to be done.
24 You know, you've got to keep this thing moving, 25 because in some of these tools, three or four ICR's were Sonntag Reporting Service, Ltd.
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4153 s
O 1 laying around and not closed out.
2 So I think it's kind of a thing to take care of 3 itself, but it wasn't being done here per the procedure.
4 (Indicating.)
5 Q All right. Whose responsibility was it to see that the 6 tool was not released to the field until the ICR had 7 been finally closed out under the procedure Rev C?
8 A Well, that would have been the inspector at the time, 9 John Seeders, or whoever was -- was performing 10 calibration at any time under this procedure.
11 Q Okay. I think you said that before you wrote this NCR 12 up, you discussed it with Mr. Saklak; is that correct?
13 A That's correct.
( }t 14 Q Wou).d you describe the nature of your conversation with 15 Mr. Saklak?
16 A Well, per the procedure here, we had a problem. We --
17 the reason they weren't holding the tools is because 18 every tool they had basically would have been locked up.
19 Now, that's -- basically what happened after this 20 NCR was written, these tools were called in and -- and 21 locked up per procedure; but my conversation with him 22 was just merely as guidance. In fact, I -- I'm sure he 23 helped me with the description. He had it typed up, 24 because I nevet have anything typed, and I signed it.
25 Q- Did he encourage you or discourage you from writing up Sonntag Reporting Ssrvice, Ltd.
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4154 O 1 this NRC or was he just neutral about it?
2 A Well, after my explanation to him, he -- he didn't know 3 the procedure, he was not certified in calibretion, and 4 I'm sure he didn't realize what was happening while he 5 was supervisor; and I'm sure he encouraged it, because 6 it's better for us to find the problem than for CECO or 7 NRC to come along or even our own QA to come along and 8 have an audit finding on us. At least we have something 9 covering us here.
10 (Indicating.)
11 Q It was probably the way I asked the question with the 12 word " encouraged."
(} 13 He encouraged you to actually initiate the NRC; is 14 that correct?
15 A Well, after discussion, it was -- it was just something 16 we had to do. It was a violation of procedure.
1 17 (Indicating.)
18 Q All right.
- 19 A But if I might add, an NCR of this depth, involving all 20 of our tools, to shut down work in the field, I felt l 21 like conferring with my supervisor before writing i
- 22 something like that so that management knew what was 23 going on.
24 Q All right, sir.
25 JUDGE GROSSMAN: Mr. -- are you -- oh, I'm Sonntag Reporting Service, Ltd.
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4155 l
4 I
1 sorry.
2 Are you through with this document?
3 MR. MILLER: I believe I am, yes, sir.
4 JUDGE GROSSMAd: Okay. Mr. Snyder, if you 5 will take a look at the third page of this document, it 6 has on the top, "ICR 5663 initiated 6/6/84," and right 7 underneath that, "NCR 2695 initiated 6/6/84."
8 Do you see those?
9 THE WITNESS: Yes, sir.
10 JUDGE GROSSMAN: Could you tell me what that 11 refers to?
12 THE WITNESS: Yes.
{} 13 These tools below that were on that ICR and also on 14 that NRC, apparently it was upgraded immediately to an 15 NCR, the ICR was, altd these tools were on those open 16 ICR -- excuse me -- NCR and ICR.
17 JUDGE GROSSMAN: Okay. Do you recall that 18 when you were looking for the ICR that you had indicated 19 did not exist for Tool No. 9702, I asked you whether the 1 20 ICR's could contain multiple tools?
21 THE WITNESS: Yes, sir.
22 JUDGE GROSSMAN: Okay. Do you recognize now i
23 that that torque wrench 9702 was included in the ICR l
24 5663?
25 THE WITNESS: Yes, sir, i Sonntag Reporting Service, Ltd.
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4156 O 1 JUDGE GROSSMAN: Okay.
2 BY MR. MILLER:
3 Q Can we -- could you turn quickly to ICR -- the log 4 simply for ICR 5663, please.
5 A Uh-huh. Yes, I've got it here.
6 Q And does that, in fact, indicate that there are multiple 7 tools that were found out of calibration?
8 A Yes, sir; it does, yes.
9 Q And is 9702 one of the tools so indicated?
10 A No, sir.
11 This is the clerk's writing here. You know, I -- I 12 don't know whether she couldn't get them all on there.
{} 13 14 She's got a full thing there.
on there.
I don't know. It's not 15 But, now, the way this is -- this is worded here, 16 or however you want to tell it, this could have been 17 on -- NCR 9702 could have been on NCR 5695 and not on 18 ICR 5663 per this document.
19 JUDGE GROSSMAN: So you can't tell --
20 THE WITNESS: It could be on either/or.
21 JUDGE GROSSMAN: -- from looking at this 22 page, whether it's the ICR or the NCR that contained 23 each one of these listed torque wrenches; is that so?
24 THE WITNESS: That's true.
25 JUDGE GROSSMAN: Okay. But, now, that NCR Sonntag Reporting Service, . Ltd.
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4157 O 1 was written the same day -- it was initiated the same 2 day as the ICR.
3 And I take it, then, Mr. Seeders was responsible 4 for both of these?
5 THE WITNESS: I would say yes.
6 JUDGE GROSSMAN: Okay.
7 THE WITNESS: I'm -- I'm familiar with NCR 8 2695. It was a big NCR, again on torque wrenches, 9 several torque wrenches.
10 I -- I can't recall actually the -- the incident.
11 I -- I do believe that several wrenches were sent to 12 Phillips Getschow because of a calibration question, and
{} 13 several wrenches failed Getschow's calibration.
Okay. To the extent, 14 JUDGE GROSSMAN:
15 though, that Mr. Seeders took into account each one of 16 these torque wrenches on either the ICR or the NCR on 17 that same date, it would appear, wouldn't it, to you 18 that he satisfied the documentation requirements?
19 THE WITNESS: Yes, he wrote the NCR and wrote 20 the ICR.
21 As long as it covered every tool involved, I'd say 22 that would take care of the problem initially.
23 MR. GUILD: Mr. Chairman, could I ask the 24 witness, since this document, the log, is not in 25 evidence, to read the entry that lists the tools that
[)
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4158 O 1 are associated with that ICR?
2 JUDGE GROSSMAN: That's on Page 2 of 27 --
3 MR. GUILD: No.
4 JUDGE GROSSMAN: -- for Applicant's Exhibit 5 28?
6 MR. GUILD: No, sir.
7 From the log that the witness was referr,ing 8 to --
9 JUDGE GROSSMAN: Oh.
10 MR. GUILD: -- there's an entry for the tools 11 that were associated with that ICR, and I would ask him 12 to read those entries for the record.
(} 13 JUDGE GROSSMAN: Okay. That's fine, yes.
14 MR. GUILD: Could you do that, Mr. Snyder, 15 please?
16 THE WITNESS: Uh-huh, yes.
17 Okay. These aren't in order, but I'll take them as 18 they come here.
19 A -- All61, A1367 --
20 MR. GUILD: Excuse me. If you could slow 21 down. I'm trying to follow you, too.
22 THE WITNESS: Excuse me. I'm sorry.
23 MR. GUILD: 1367.
24 THE WITNESS: A1368, A1640 -- 41. Yes, it's 25 kind of scribbled in here.
D O
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4159 l 1 A176, A183, A186, 393, A607, A917, A394, A828, 2 A927, 395, A831, A963, A532, A897, A972, A915 and A974. !
3 MR. GUILD: Mr. Chairman, I've compared that 4 with the list that appears on Page 4 of 7 of Applicant's 5 Exhibit 36 for identification, and by my checking, it 6 appears that those omitted tool numbers that Mr. Snyder 7 did not read that appear on that page of Applicant's 36 8 are 9702, A1645, A1687, 10081, and then there were two 9 tools where he read only -- A394 is listed on 10 Applicant's 36, but you read 394 without the A.
11 THE WITNESS: Excuse me. It's A394 here.
12 MR. GUILD: Right.
13 And an A395 listed on Applicant's 36.
[}
14 THE WITNESS: There's no A on 395 in this 15 log.
16 I know for a fact that there's no A on the tool.
17 We still have that torque wrench in -- in our system.
18 It is just a 394 -- or -- excuse me -- 395.
19 MR. MILLER: I'd like the Reporter to mark, 20 as Applicant's Exhibit 37 for identification, L. K.
21 Comstock & Company, Inc., Non-Conformance Report 3419, 22 at least the first five pages of it. It bears a date of 23 October 11, 1984.
24 (Indicating.)
25 (The document was thereupon marked Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262 i
4160
! 1 Applicant's Exhibit No. 37 for 2 identification as of June 12, 1986.)
3 BY MR. MILLER:
4 Q Mr. Snyder, I show you a document that's been previously 5 marked as Applicant's Exhibit 37 for identification.
6 (Indicating.)
7 Does your signature appear anywhere on the 8 document?
9 A No, sir, I don't believe so; not on the front page.
10 Q Did you have any role in the preparation of this 11 document?
12 A My only role was the investigation, if you want to call
(} 13 14 it, prior to my certification in the vault.
That's Applicant's Exhibit 28 that you are referring to?
0 i 15 A Yes, sir.
16 I did read the NCR after it was written, but I had 17 no -- no influence on it as far as writing it directly.
18 (Indicating.)
t 19 Q Who did prepare this document; do you know?
20 A That was Rick Saklak.
21 Q All right. Did he discuss any of the underlying facts 22 that were in your September 6th report with you before 23 he wrote this?
24 A We may have talked briefly, just to get the actual 25 paragraph in the procedure or whatever.
Sonntag Reporting Service, Ltd.
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4161 O 1 He knew, by reading our findings, that -- basically 2 that's directly what he took this f rom.
3 (Indicating.)
4 I know he did confer with QA Manager Seltmann.
5 They knew that we had a problem, again, and we had to 6 address it on an NCR to cover any future audits, 7 hopefully, and get started on some kind of corrective 8 action.
9 Q Now, Item No. 6 on Page 2 reflects some of the -- well, 10 reflects the condition that you described with respect 11 to Applicant's Exhibit --
12 A 28?
{} 13 0 -- 30 through 34, is that correct, the --
14 A The Form 77's we were looking at?
i 15 Q Right, and the calibration reports.
16 A Yes, yes, that's -- those are examples of that paragraph 17 there, I would say.
18 Q All right, sir.
19 In October of 1984, Mr. Snyder, based on your 20 review of the records, do you believe that Mr. Seeders 21 was performing his functions as a calibration inspector 22 in accordance with the provisions of Procedure 4.9.l?
23 A No. It was evident there was problems: Missing 24 documents, documents not initiated.
25 I had known that -- since September that there were Sonntag Reporting Service, Ltd.
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4162 1 problems there.
2 (Indicating.)
3 Q Did you ever talk with Mr. Seeders about your analysis 4 of these records?
5 A I'm sorry. I didn't hear that last part.
6 Q I'm sorry.
7 I say, did you ever discuss your findings with Mr.
8 Seeders?
9 A No, I don't believe so.
10 We kind of -- he knew what we were doing, and I 11 think we just kind of stayed away from each other. I 12 don't know why. It's just we never talked much after
(} 13 that, and I didn't really want to get -into a discussion i 14 with him about it.
15 I think he knew there was problems there, 16 evidently.
17 0 Did he ever say anything to you that would indicate that 18 he was aware of these problems?
19 A No.
20 Q Did he ever offer any explanation to you, for example, 21 on his failure to initiate an ICR?
22 A I've just -- you've just struck my memory a second 23 there.
24 But I think, briefly, I heard him say-that he had 25 initiated ICR's when he was supposed to or -- or reports
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4163 1
O 1 when he was supposed to; but that was very brief, and 2 maybe it was even a -- him talking with another 3 inspector or talking to a group of us.
4 He knew there were -- there were missing documents; 5 and other than that, I never heard him discuss it any 6 more.
7 (Indicating.)
8 Q Do you know whether there was any disciplinary action 9 directed at Mr. Seeders as a result of the evaluation of 10 his performance as a calibration inspector?
11 A Well, he was transferred to Engineering.
12 That resulted, in my opinion, from all of these l
{} 13 14 findings against him as an inspector.
All right, sir.
Q 15 I think when you began your testimony this morning, 16 you -- you made some comments about Procedure 4.9.1, Rev 17 C.
18 Has there subsequently been a revision to 4.9.1?
19 A Yes, sir. We're working currently on Rev E, which has 20 got instructions on how to calibrate tools -- well, Rev 21 D incorporated that; and like I said this morning, the 22 further along these procedures go, they get a little 23 better as far as helping the inspector out.
24 Of course, you get an inspector's input into the 25 procedure after awhile, and that's who has to work to O .
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4164 O 1 it, so that's who should be giving some input, I think.
2 (Indica ting . )
3 0 You say you are working on Revision E right now.
4 Does that mean you are in the process of revising 5 it?
6 A That is the current procedure right now, Rev E.
7 0 I see.
8 I'm sorry. I just didn't hear.
9 Was it Rev D or Rev E?
10 A Rev E.
11 Q Rev E. Thank you.
12 MR. MILLER: I'd like the Reporter to mark, 13 as Applicant's Exhibit 38 for identification, a document 14 that bears, on the cover, " Procedure Tracking Sheet" --
15 just a second - " Procedure Tracking Sheet, Procedure 16 4.9.1, Revision D," with an indication of an interim 17 approval date of April 29, 1985.
18 (Indicating.)
19 I have to apologize to the Board and to the 20 parties. I don't believe I have copies of that 21 document.
22 MR. GUILD: This is D as in dog?
23 MR. MILLER: D as in dog.
24 JUDGE GROSSMAN: And what section is this on?
25 MR. MILLER: 4.9.1, sir.
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, 4165 O 1 (The document was thereupon marked 2 Applicant's Exhibit No. 38 for 3 identification as of June 12, 1986.)
4 BY MR. MILLER:
5 Q Mr. Snyder --
6 MR. MILLER: Well, let me just show this to 7 counsel for a second.
8 (Indicating.)
9 MR. GUILD: Okay.
10 BY MR. MILLER:
11 Q Mr. Synder, I show you a document that's been marked 12 Applicant's Exhibit 38 for identification and I ask you, r~% 13 sir, whether you are familiar with that procedure.
(_/
14 (Indicating,)
15 A Yes, sir.
16 Q All right. Are there changes to that procedure from the 17 Revision C?
18 A Yes, sir.
19 0 What role, if any, did you have in suggesting changes?
20 A Well, I set down and made my comments on a piece of 21 paper and turned them in to the QA Department, who 22 initiates our procedures, the corrections; and not 23 that -- it was just my opinion of the -- something that 24 might help us out.
25 Q Can you tell me the date on which you -- approximately D
ud 3
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4166 O 1 when you made those suggestions?
2 A It would be very tough.
3 Let's see. I'll say March of '85.
4 0 All right, sir.
5 And to whom in the QA Department did you submit
- 6 your written suggestions?
7 A Mr. Seltmann.
,8 Q All right. Do you know what became of those 9 suggestions?
10 A Well, they were -- most of them, I would say, were J
11 incorporated into the procedure; I mean, with their QA 12 approval.
(} 13 We discussed some of the changes and the reasons, and I would say some of them were incorporated.
14 15 (Indicating.)
16 Q All right. Can you give us an example of a change in 17 the procedure that you suggested that was incorporated?
18 A Yes. The Form 3, which is our tool sign-out log in the 19 Crib 4, was not being properly maintained, and I l 20 suggested that we create a surveillance to force the 21 craftman -- the craftmen that were updating this form to
- 22 do it properly, because I couldn't get cooperation from 23 the men until I had the right ICR's, and that was a I
24 suggestion of mine, that this would force us to do a 25 periodic surveillance of our own; and it says here to --
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4167 1 unsatisfactory results to be written on an ICR.
2 (Indicating.)
3 Q All right. What specific paragraph of the procedure 4 Revision D are you referring to?
5 A Paragraph 3.2.1.
6 Q And who was to conduct these surveillances?
7 A The QA inspector in charge of calibration.
8 Q And what activity was the surveillance to be directed 9 at?
10 A It's the Form 3, which is in the 4.9.1, Rev C. It's the 11 same form, but it's a form that the crib men actually 12 fill out.
(} 13 14 Each time a torque wrench leaves the -- the crib, he writes down the man's brass number that took that 15 wrench out and the date he took it out and the date he 16 brought it back.
17 (Indicating.)
18 So that there's a -- a slight tracking method there 19 that -- to that tool, at least who had it; not what they 20 used it on, but who had it.
21 Q Mr. Snyder, were there any suggestions that you made 22 that were not incorporated in Revision D; can you 23 recall?
24 A Not that I recall.
25 Q Did you speak with anyone in the QA Department besides Sonntag Reporting Service, Ltd.
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4168 b'~' 1 Mr. Seltmann regarding your suggestions?
2 A Yes, sir. Rod Simms was -- had worked under Mr.
3 Seltmann as a QA Engineer, I think his title was, and I 4 was working with him, too.
5 I took my initial changes, I think, to Mr.
6 Seltmann, and then I think we -- I worked with Mr. Simms 7 after that.
8 (Indicating . )
9 Q All right, sir.
10 What response, if any, did you get from Mr.
11 Seltmann when you handed him your -- your list of 12 suggestions?
13 A Well, I think he wanted some input, because, like I
(]}
14 said, I was the one that had to work to it.
15 What had been happening in the past was somebody 16 setting there writing a procedure and not -- that never 17 worked to it, so they didn't know what -- the guy that 18 had to go out in the field and work to, they didn't 19 realize the things he had to put up with.
l 20 So I think he encouraged my input, and I -- I was 21 happy to give it at the time. I felt like it would only 22 benefit myself as far as clarifying the procedure.
23 (Indicating) 24 MR. MILLER: Your Honor, at this time I would 25 like to move certain exhibits into evidence.
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4169 O 1 I do not believe that I have moved Exhibit 28 into 2 evidence yet.
- 3 JUDGE GROSSMAN: No, that's correct.
J 4 Nothing above 26 has been moved into evidence.
5 MR. MILLER: Right.
6 I now move Exhibit 28 and Exhibits 30 through 38 7 into evidence.
8 JUDGE GROSSMAN: Mr. Miller, let me ask you 9 first:
10 Are you going to, then, rest on this witness?
11 MR. MILLER: No. I have one major topic yet 12 to cover with him.
. I'\ 13 JUDGE GROSSMAN: Okay.
, \_/
14 Mr. Guild, do you want to object now or not object 15 or decide now or do you want to study these documents 16 overnight?
17 MR. GUILD: No, sir, I don't need to study 18 them overnight.
j 19 I just would make a couple of points, if I can 20 gather them up in a moment here,.
, 21 A number of these documents are documents that are 22 authored by Mr. Seeders, and as the examination has made 23 clear, the witness can speculate, interpret, offer his
- 24 opinion about what the meaning is of certain writings 25 that he didn't author, and, indeed, reaching a l
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'l conclusion about them may well be within the scope of 2 his work as he testified he performed a review.
3 But to the extent that the documents are being 4 offered for general purposes as exhibits in evidence, I 5 have the same general position I had about a previous 6 document that was offered that was authored by Mr.
7 Seeders, and that is that Mr. Seeders is the proper 8 witness to authenticate those documents and to identify 9 the circumstances under which they were prepared.
10 So I don't have any objection to them coming in 11 with the limitation that they are documents that this j 12 witness may offer an opinion about and perhaps reviewed
{} 13 14 in the course of his duties, but I don't concede the authenticity of the documents, and I believe that they i
15 are properly sponsored by Mr. Seeders.
- 16 MR. MILLER
- Your Honor, if there was ever a 17 document that fell within the strict definition of a 18 business record, it's these Form 77's and the other 19 calibration records which this witness has the 20 responsibility for maintaining, as he testified.
21 So I believe that it's appropriate that those 22 documents come in for all purposes at this time.
I 23 JUDGE GROSSMAN: I believe --
i i 24 MR. GUILD: Mr. Chairman, they simply are 25 not -- they are not complete. They are Xeroxs of copies
()
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4171 1 of parts of documents that obviously counsel has I
2 compiled for a particular purpose of illustrating
\1 points, phrhaps.
4 They simply are not self-authenticating as a 5 business record in the condition in which they appear.
6 My point, really, is this:
7 So long as it's understood that Mr. Seeders is 8 anticipated to be presented by Applicant and that 9 Applicant will then authenticate these documents through 1
10 Mr. Seeder's, he will have an opportunity to either say 11 yea or nay that this is, indeed, what it purports to be, 12 then.I have no objection, but I don't believe that these
{} 13 14 documents should be received into evidence for all purposes through Mr. Snyder, based on the opinion 15 evidence that he's expressed aaout the documents.
16 JUEGE GROSSMAN: Mr. Miller, you have Mr.
17 Seeders under subpoena, do you?
18 MR. MILLER: Oh, I do, your Honor.
I' 19 JUDGE GROSSMAN: And he is going to be in 20 here?
21 MR. MILLER: Yes.
22 But, your Honor, I don't want to be faced with the
! 23 position -- all after, Mr. Seeders has not been employed 24 as a calibration inspector for almost -- well, a i 25 year-and-a-half, anyway, and to have him say he doesn't i
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l 4172 1 recall or he's not sure, and then be faced with a 2 situation in which the witness who really could satisfy 3 all the requirements of the custodian of these documents 4 as a business record having been excused, I'm left with 5 some exhibits that are inadmissible.
6 MR. GUILD: Yes. The additional point, I 7 guess, Mr. Chairman, is obviously these were records --
8 or they are copies of records that were prepared during i
9 Mr. Seeders' tenure, and I think, as the witness' 4
10 testimony reflects, he has to surmise, to some extent, 11 about the circumstances of business practices that 12 occurred at the time that they were prepared.
- 13 That's an additional reason why I think the proper
/}
14 sponsor for the documents is, indeed, the witness who 15 prepared them.
16 JUDGE GROSSMAN: Well, the documents speak i
17 for themselves to a certain extent.
18 I am not happy with the state of the record with
, 19 regard to the interpretation of these documents, and I .
20 would expect that if you are going to use them, Mr.
21 Miller, Mr. Seeders ought to be available --
22 MR. MILLER: Oh --
23 JUDGE GROSSMAN: -- to answer.
24 So if, in fact, he doesn't show up, we are going to l 25 have a problem.
(,
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l But I think the documents -- we're going to have a 2 problem, not with the documents, but with the 3 interpretations and the speculations and so forth, but 4 the documents themselves appear to be, beyond question, 5 with regard to their being authentic -- copies of 6 authentic documents, and to a certain extent, fall 7 within the business records portion, at least as to Form 8 77.
9 As to other portions of certain of these documents 10 and other documents, I'm not sure that they would really 11 fit there, but they are authentic documents; and the 12 others -- for example, the ones compiled by the witness
(} 13 with regard to the Seeders incident -- I don't know would fit under that exception, anyway; but those are 14 15 sponsored by the witness himself, so we don't have that 16 problem.
(
17 So I think we'll accept the documents; and to the i
18 extent that -- to the extent that any problems are l 19 pointed out in the future, they be subject to I
l 20 appropriate motions; and we will expect that Mr. Seeders l
l 21 will be here to testify with regard to those documents.
22 MR. GUILD: Yes, sir.
23 I guess the objection goes to Documents proposed l
l 24 Applicant's Exhibits 30 through 35. Those are the 25 extracts from Mr. Seeders' calibrations records that Sonntag Reporting Service, Ltd.
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1 were the subject of Mr. Snyder's examination.
2 They simply are, on the face, not complete 1
3 documents. They are Xeroxes of extracts of documents; 4 and because, in particular, inferences are to be drawn 5 from the absence.of correlation between portions of
! 6 these documents and other documents, such as the log 7 that the witness was examining, I think that the 8 authenticity cf these documents an complete in n-9 themselves is in issue. ;
10 I don't doubt that these are accurate Xerox copies 11 of the pages that they purport to be. That is not the
- 12 point of the objection.
I 13 I guess, as the record stands, I would simply state
{])
14 my objection and belief that a key element to sponsoring 15 these is Mr. Seeders' testimony.
16 JUDGE GROSSMAN: Well, again, we'll admit l 17 them now; and if you discover certain of these -- if 18 certain of your concerns materialize or crystallize with l 19 Mr. Seeders' testimony, then we will reconsider our 20 ruling and entertain further motions with regard to 21 these documents.
l 22 So at this point, they are admitted; that l's, i
23 Applicant's Exhibits 30 through -- I'm sorry -- 28, and 24 30 through 38.
25 (Applicant's Exhibits Nos. 28 and 30 Sonntag Reporting Service, Ltd.
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4175 O 1 through 38 for identification were 2 thereupon received in evidence as 3 Applicant's Exhibits 28 and 30 through 4 38.)
5 MR. BERRY: Mr. Chairman.
6 JUDGE GROSSMAN: Yes. Oh, I'm sorry.
7 Mr. Berry, we didn't"give you an opportunity, and 8 so if you have something at variance with what we ruled 9 or any other comments, please give them now.
10 MR. BERRY: I don't believe the Staff -- the 11 Staff has any objection to the admission of the 12 documents.
() 13 We would request a clarification. We notice on the 14 Form 77's there is a note that says, " Specific 15 instructions on back," and in all the copies of the Form 16 77's provided in the Applicant exhibits, only the front 17 part of the Form 77 was copied.
18 MR. MILLER: If I could just ask the witness 19 a question, I think I can answer Mr. Berry's inquiry.
20 JUDGE GROSSMAN: Do you prefer that or do you 21 choose to voir dire the witness yourself?
22 MR. BERRY: No.
23 JUDGE GROSSMAN: Okay. Mr. Miller.
24 BY MR. MILLER:
25 Q Mr. Synder, would you turn to Applicant's Exhibit 24, Sonntag Reporting Service, Ltd.
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4176 O 1 which is Revision C of Procedure 4.9.1.
2 A Okay. Let's see here.
3 Form 7 -- or 77?
4 Q Well, yes. It's Applicant's Exhibit 24; but you've 5 anticipated me.
6 Would you turn to the page in that procedure in 7 which the Form 77's reproduced.
8 A Yes.
9 Q And does that page in the procedure have both the front 10 and the back of the Form 77?
11 A Yes, sir.
12 Q All right. Has there been any change in the back
(} 13 portion of the Form 77 through the various additions to 14 the form which you are aware of?
15 A No, sir. I believe it's stayed the same on Rev D and E 16 as this rev.
17 MR. BERRY: That answers my question.
18 Thank you.
19 JUDGE GROSSMAN: Does that clarify your ,
20 question?
^
21 MR. BERRY: That answers my question.
22 The Staff has no objection.
23 JUDGE GROSSMAN: Okay, fine.
24 So we've already admitted the documents.
25 You can go'on to your --
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I 4177 1 MR. MILLER: Your Honor, it is 5 minutes to
'. 2 5:00, and rather than break my examination, unless the 3 Board wishes to go well past 5:00 o' clock, I'd just as i 4 soon start at 9:00 in the morning.
5 JUDGE GROSSMAN: Okay. We can do that.
6 Now, how much longer do you think you are going to 7 have with the witnens, Mr. Miller?
8 MR. MILLER: I would hope 45 minutes or so.
9 ,
JUDGE GROSSMAN: 45 minutes.
10 How many days do you expect, Mr. Guild?
11 (Laughter.)
12 MR. GUILD: I don't, Mr. Chairman.
() 13 JUDGE GROSSMAN: You don't. Okay.
14 Well, we will recess until 9:00 o' clock tomorrow 15 morning.
16 MR. MILLER: Mr. Snyder, thank you.
l 17 MS. KEZELIS: Mr. Snyder, this is the witness l
18 fee.
! 19 (Indicating.)
20 Everybody can witness it.
l 21 MR. GUILD: How much is it?
22 MS. KEZELIS: $42, for the record.
23 (Whereupon the hearing of the 24 above-entitled matter was recessed to 25 June 13, at 9:00 o' clock A. M. )
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CERTIFICATE OF OFFICIAL REPORTER O
This is to certify that the attached proceedings before the UNITED STATES NUCLEAR REGULATORY COMMISSION in the matter of:
NAME OF PROCEEDING: COMMONWEALTH EDISON COMPANY (Braidwood Station, Units 1 & 2)
DOCKET NO.: 50-456 OL; 50-457 OL PLACE: WAS!!INGTON, D. C.
DATE: THURSDAY, JUNE 12, 1986 were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission.
(sigt) B#L b (TYPED)
G. ALLEN SONNTAG Official Reporter ACE-FEDERAL REPORTERS, INC.
Reporter's Affiliation O
v
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