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Transcript of Comanche Peak Technical Review Team 860509 Discussion W/C Welch in Glen Rose,Tx.Pp 1-23
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Issue date: 05/09/1985
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COMANCHE PEAK i

TECHNICAL REVIEW TEAM l

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DISCUSSION WITH CHUCK WELCH

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i GODFREY & AMES COURT REPORTING CERTIFIED SHORTHAND REPORTERS 1106 W. PIONEER PARKWAY SUITE 400 ARLINGTON. TX 76013 (817) 460 2048. METRO 469 6100 COMPUTER AIDED TRANSCRIPTION VIDEO TAPE SPECIAUST OAILY COPY May 9, 1985 8607100400 860624 PDR FOIA ~b (J ,

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2 e e e e e e e e e e e e e e a e a e e a e e , e e e a e 3 TECHNICAL REVIEW TEAM DISCUSSION 4 e e e e e e e e e e e a e a e e e ae ee eee ee ee 5 APPEARANCES:

6 TECHNICAL REVIEW TEAM:

Chet Poslusny 7 Cliff Hale Charlie Richards 8

9 e a e * * * *

  • a a e e e e e e ee o e e e e e e . . .

10 DISCUSSION WITH CHUCK WELCH, called on behalf of 11 the Technical Review Team, taken before Jayne Ames a 12 CSR, and Notary Public for the State of Texas, on the i  !

t i 13 9th day of May, 1985, beginning at 9:15 a.m., at the 14 trailer of Nuclear Regulatory Commission, Comanche Peak 15 Power Plant, Glen Rose, Texas.

16 17 18 .

19 20 21 22 23

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, 25 .

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__- 1 PROCCEEDINGS, 2 MR. POSLUSNY: This is Chet Poslusny. We're in a 3 discussion with Mr. Chuck Welch. Also present are Cliff 4

Hale and Charlie Richards of the Tech Review Team. And 5 if you could, state your name and your position?

6 MR. WELCH: I'm Chuck Welch, QA supervisor for 7 TUGCo.

8 MR. POSLUSNY: Okay. What we'd like to know, if 9 you can tell us a little bit about your organization and 10 its activities, as it stands today, before it changes?

11 MR. WELCH: Okay. Right now in the QA surveillance 12 group, we have four people. And we survey construction, i I L a 13 engineering, startup activities. I have it broken down 14 into one individual that looks at primarily engineering 15 in the startup, and another guy looks at primarily 16 mechanical.

17 Another guy looks at electrical. Another guy looks 18 -at instrumentation. We are in the process now of 19 setting procedures out for unit two testing. And we'll 20 be soon starting them to review those.

21 We review them before they're issued for -- well, 22 we say it's QA review, but we also provide a technical 23 review of sorts, b(cause the individuals that I have, 24 have had considerable background in nuclear and testing I'~}

25 a'etivities.

GODFREY & AMES COURT REPORTING Metro.469-6100n (817) 460-2048

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_ _ - 1 After the procedures are issued, well, then they go

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2 to do the testing. ,

We'll have people out there 3 surveying the testing activities to see if they're in 4 compliance. We insert witness or hold points in the 5 procedures where we feel they're appropriatu to your --

6 to the complexity of the operation, that we would like 7 to be there and make certain it's valid. We do not 8 watch the entire test.

9 MR. POELUSWY: Okay. It's a random sampling?

10 MR. WELCH: Pretty random, yeah. There may be 10, 11 maybe 15 hold points in a given preoperational test.

l 12 There may be as few as two or three.

I I L J 13 Right now they're doing a test in unit one on the 14 ERF computer. The test procedure has something like 425 15 pages, and we're doing a random sampling of that 16 activity, i

17 In some cases, the operation may require two j 18 people to witness. We have instructions as to how and j

19 what is required for them to come up with a -- justify 20 their sign off.

l 21 We do about somewhere in the range of 90, 80 to 90 l

22 surveillances a year.

l 23 So far this year, we have done 36. This number r~] 24 will vary, depending on how much testing we look at l

25 besides doing surveillances.

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_ _ , 1 MR. HALE: Having been an auditor and inspector in

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2 the past myself, I can go into an area and start looking 3 at something. And as soon as I start looking at 4 something in an area. I'll find something in a related' 5 area. It seems like that there's always something wrong 6 someplace else, more than it is where I'm looking. And 7 I'm sure most inspectors do that.

8 How do you interface with these other groups when 9 you find problems that cross. I guess, boundaries of 10 responsibility? I know you have an interface with the 11 Dallas office. And probably with the ops QA. How do

! 12 you handle those kinds of interfaces?

L 1 13 MR. WELCH: Okay. When we -- we're out coing 14 surveillance and we find a problem with ops, David 15 Devini and I have agreed a long time ago, if it's ops 16 messing up with ops procedures, it's ops problem. And 17 ops should handle it. So we pass the problem on to Dave 16 Devini and let him take care of it in-house.

! 19 If it's startup screwing up against the operation j 20 procedures, well, then we'll take care or it. But at 21 one time we had operations people working to startup 22 test procedures. And it was the instrumentation 23 people. We issued several procedures over here for Il

. J 24 doing initial calibrations.

25 -

And the operations people were not following the GODFREY & AMES COURT REPORTING CJe_t r_o__Q_6_9-61B&. ( 8 97 D OGh9(D0Q _ , _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _

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__- 1 procedures. And so we wrote them up, and in fact we put

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2 a stop work on them until they got totally squared away 3 and knew how to follow procedures.

4 But that's the way Dave Devini and I agreed to a 5 long time ago, that if it's operations not following 6 operations procedures, that they would handle it.

7 And the way we have done that is, we have seat, oh, 8 like three part menos to them. We have sent just a memo 9 -- memo, okay, without three parts, and let them take 10 care of them.

11 MR. POSLUSNY: So you ship it off to them, you 12 don't really follow-up after you give it to them?

I I L J 13 MR. WELCH: I feel that Dave Devini has --

14 HR. POSLUSNY: His own responsibility?

15 MR. WELCH: -- his own responsibility to follow-up 16 on it. We have checked on them to see that things have l 17 in fact been taken care of.

18 -

If the auditing people, we -- well, I talk to the 19 auditors when they come in, any time they do an 20 entrance, I will let them know what we have found in 21 that area while doing surveillances. And that way they l

22 can use that information as part of their audit.

23 or I will point them to something that I think

[l] 24 needs to be looked at as part of that audit. I send 25 c'opies of my surveillance reports to Dave McAfee. Who GODFREY & AMES COURT REPORTING

_ _ _ Metro 469-6.100.__(817) _460-?n48_,__ _ ____________.

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_ _ - 1 then can follow to'Debra Anderson who has the audit

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2 group.

3 MR. HALE: Does the audit group audit your 4 activity?

5 MR. WELCH: Yeah, they have. Yeah, they audited 6 us, well, a couple times that I can remember. And one 7 case they found that my guys weren't certified to the 8 latest revision of the procedure. The procedure that 9 talks of certification.

10 As far as them being certified 4526, they are not.

11 There's no requirement for them to be that. But there 12 was some requirements that we imposed locally that says P

t a 13 you have to fill out this sheet of paper to be 14 certified. And we hadn't done that.

15 hR. HALE: You mentioned a moment ago about a memo 16 to Devini or a three part memo to identify problems or 17 potential problems in his area of responsibility.

18 .

Does that get documented in a fashion auch that, 19 say Dallas QA could come down and they could track to 20 see if, hey, this was identified as a problem, and see 21 if Devini actually did take care of the things 22 appropriately?

23 It's a, you know, mechanism of tracking the thing 24 or maybe even possibly trending the item?

25 MR. WELCH: I believe that we have sufficient files GODFREY & AMES COURT REPORTING Metro 469-6100 (817) 460-2048

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.-- 1 to support sending stuff over to him, you know. You

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2 know, we have -- I have a file of operations problems.

3 And that's where you will find these menos.

4 MR. HALE: Sometimes you can get into a buddy 5 system arrangement such that, "You take care of me and I 6 will look out for you, and no one outside the two of us 1

7 need to know about it." And I just wonder if you have 8 got that kind of rapport with Mr. Devini?

MR. WELCH:

9 No, I don't have that kind of rapport i

10 with Mr. Devini. He's in charge over there and I'm in j 11 charge over here. And he doesn't like me over there, 12 and I don't care if he comes over here, if he wants to, i

l!L J 13 or not. No, we're not buddy-buddies.

14 MR. HALE: Your organization is about to change, I t

! 15 understand?

16 MR. WELCH: Yeah. And I think it's going to be for 17 the good. Because we have Paul Lydecker, who is the 18 -IPC supervisor, and underneath him there is -- he has 19 some people that kind of an overview type inspection.

20 And then we have another group that does QC 21 surveillance, and they're under another individual. And 22 then there's a group that does the startup turnover 23 surveillance -- well, actually does construction, too,

{'} 24 but primarily startup oriented.

25 And what we're going to do is put them all under GODFREY & AMES COURT REPORTING Metro 469-6100n (817) 460-2048

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__, 1 one roof. And so there will be a, underneath Paul 2 Lydecker, there will be a surveillance supervisor. And

3 underneath him will be the QA group that does 4

4 construction surveillance, and the other group that does 5 startup turnover surveillance.

6 Also we'll be increasing the sizes of those groups, 7 because the startup activities and turnover activities

8 vant to look heavily at the turnovers from construction i

9 of startup, so that we know we have got a good package i 10 from the time it comes from construction to startup, and 11 it's not just the system is done enough so it will hold 12 water, and you can test it with all this construction

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't  ;

13 activity yet to come.

14 So we're going to concentrate heavily on turnovers i

{ 15 this time for unit two.

4 16 On unit one we looked at turnovers. We looked at 1

j 17 the turnover, 41 rooms, which was a pretty good sample, 18 but we want do look more towards like 90 to a 100 19 percent of the turnovers.

20 HR. HALE: What are you looking at when you look at 21 some of these rooms, type things?

22 MR. WELCH: You're looking for elephants, the 23 obvious that shouldn't be there, the thing that's wrong, 24

~] the paperwork sesociated with the turnover, is it --

25 does it -- the paperwork agree with what's out there?

GODFREY & AMES COURT REPORTING Metro 469-6100n (817) 06A-a@08

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.-- 1 But primarily it's a walkthrough and you look at

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2 everything. ,

3 MR. POSLUSNY: How long will he spend at a given, 4 say, on an average?

5 MR. WELCHs I keep track of all the hours spent in 6 the: field, in their inspection of this -- during the 7 surveillance and how much hours -- how many man hours 8 are used in writing it up.

9 And I would say that during the walkdowns, we put 10 somewhere close to 80 to a 100 man hours on a given 11 walkdown. We have one surveillance that we did, which 12 is not on turnovers, but it used 562 man hours.

O t a 13 MR. HALE: I don't know what an elephant is, if 14 your terminology --

15 MR. WELCH: Oh, okay. The obvious. The obvious 16 that shouldn't be there. Like if you walk there and you 17 look in the reactor cavity, and there's a garbage can 18 -lying in there, it's pretty obvious it shouldn't be

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19 there.

So as you look at things, there's obvious things 20 that jump right out and get you and say, "That's wrong."

21 MR. HALE: What about a hanger mialocated or 22 oriented improperly? Would that be an elephant?

23 MR. WELCH: Yeah, okay. Here would be an r~l 24 elephant. We found that there was two hangers that are

. 2 25 supposed to be up on this large vertical piece or GODFREY & AMES COURT REPORTING Q

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. _.. 1 equipment. They weren't there, period.

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2 MR. HALE: This is something QC had already bought 3 off?

4 MR. WELCH: Teah.

5 MR. HALE: Does that tell you anything about QC7 6 I mean --

7 MR. WELCH: Well, I mean, this was obvious. I 8 sean, we're talking a good size hanger.

9 MR. HALE: What does this tell you about QC7 What 10 does this do to you when you run into something like 11 that?

12 MR. WELCH: Well, you have got to wonder how could iI L a 13 they miss such an obvious thing, you know. Just how can 14 they miss it. And that.happens. People make mistakes.

15 M9. HALE: What's not an elephant? Give me an 16 example of what an elephant isn't.

l 17 MR. WELCH: Oh, if you're looking at a weld, and 18 you find that it is undersized. That's not obvious.

19 You have to take your equipment and measure it. That I 20 would not consider an elephant. That's something you 21 have to get down there and finitely look at it.

22 MR. HALE: Okay.

23 MR. POSLUSNY: How many people are going to be in 24 new groups while he's looking at that?

I'~}

25 .- MR. WELCH: We plan on increasing the start up GODFREY & AMES COURT REPORTING

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'.-- 1 turnover group by about two or three. And the other QC

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2 surveillance group, I think about three more in that.

3 So there will be a lead in the startup turnover.

4 and about seven people.

5 And in the construction surveillance there will be 6 a lead in six, yeah, six or seven.

7 MR. POSLUSNY: It looks like it's quite a jump, 8 just right based on what you said. You have got four 9 people now doing construction, plus start up turnover.

10 Now you're going to have 13, 15 people, roughly?

11 MR. WELCH: Yeah. Yeah. There's, when we did unit 12 one, I guess I was up to about ten people besides

.I  !

L .i 13 myself.

14 And when we got heavy into testing, I needed two 15 guys on each shift. So there's six people right there, 16 just looking at testing activities. And with the

17 emphasis that we're going to put on the turnover, you l

18 -could keep a guy or two busy doing that also. So they 19 need about six people. Seven people.

i 20 MR. HALE: When is this organization going to go i

21 into effect, and what's involved in getting it into I

22 effect7

! 23 MR. WELCH: We tried to come up with a lead for the l{~}

l 24 group. We have interviewed people on that. And we 25 think we'll probably make a decision, probably GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048

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.__. 1 tomorrow. And on the 20th, that's when the group will 1

2 shift over. They already have a building or trailer for 3 them over there. So it will be all centrally located in 4 one spot. So should happen the 20th.

5 I had some contract people people working for me 6 when we were doing unit one. And then when the testing i

j 7 activities concluded. I let the contract people go and 8 kept the TUGC0 people.

9 MR. POSLUSNY: How are the work assignments j 10 generated to the group?

11 MR. WELCH: When we have got down to four people, I 12 thought that probably the best way we could do it is Il L , 13 make experts. So that's why I came up with the four 14 areas.

15 And that was pretty much left to their discretion, i

16 "what would you like to look at". That and coupled l 17 with, "What is your background?" Turned out to be their 18 background does fit what they like to look at, and 19 that's understandable. You're not going to go out and 20 look at something you don't know anything about.

21 So that's how it came to be that we have four j 22 areas. And the people's background fit the areas they 23 selected.

l 24 MR. HALE: Looks like about the time that you 1

I}

! 25 touble the responsibilities in the group, you have the GODFREY & AMES COURT REPORTING Metro _469_-6100_g_(817) __4_60-2048

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' _ _ - 1 personnel in the group. Looked like you picked up

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2 construction turnover all into one bunch, and you had 3 like eight or ten people in there. And then right after 4 that, you went down to four people.

5 MR. WELCH: I think.

6 MR. HALE: Kind of a strange way of working a 7 system. You double the work effort and half the 8 personnel to do the work and it gives one a feeling of, 9 " Gee, are you really accomplishing what your purposes 10 were?"

11 MR. WELCH: Well, I guess you would have to look at 12 the surveillances that have been completed with the nine I I L ; 13 people. We did about 89 surveillances in a year. With 14 four people, we did 92. I haven't counted the number of 15 findings, but as far as coverage, I feel we have covered 16 what needed to be covered.

17 There was -- I did have this other group that 18 folded into mine, which is site surveillance. I really 19 don't think that they were very effective before they i .

20 came over in my group, based on the write-ups that they 21 came up with.

22 We have a pretty good system. We document it as 23 though it was an audit. We do everything as though it's

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24 an audit. Our entrance might be high. I'm here to look

{~]

j 25 st this. We do have an exit. So they're really l

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- - , 1 auditors. And I think they're~ pretty good.

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2 MR. POSLUSNY: What happened --

3 MR.. HALE: Sounds like they're pretty busy?

4 MR. WELCH: Oh, yeah, yeah, I like to keep then 5 busy. I. don't like to see them standing around shooting 6 the breeze. Occasionally I get a chance to see them do i

7 that. But I have asked them to do like two 8 surveillances a month, and they have pretty much stuck 9 to that. In some cases, they have done more than two a I 10 month. In a few cases, they haven't followed the 11 schedule.

12 MR. POSLUSNY: When they do a surveillance, each 13 one generates a r2 port, whether there's positive or

! 14 negative findings? How does the system work if there i

15 are negative findings, the follow-up?

1 16 MR. WELCH: Okay. They have a checklist that they 17 use when they do their surveillance, has all the I

18 attributes on there. I approve that.

19 They go out and do the monitoring or surveying.

20 They have some findings. If the surveillance that 21 they're doing is going to take a long time, I say more 22 than a week, then I have asked them, and we have a paper 23 that requires that they issue deficiency reports.

24 A deficiency report is just a quick way of getting

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25 the problem on paper so somebody can get some action GODFREY & AMES COURT REPORTING Metro 469-6100,. _ (8

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. . - - 1 going.

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2 If they run across a problem that, it's a 3 nonconforming condition, they write a nonconformance 4 report. 1 l

5 If they haven't run across a pro'olen, it's a 6 nonconforming condition, but it is a deficiency and' 7 they're not going to spend on it, never getting the i

8 report out, they would issue it as just a deficiency as

9 part of the surveillance report. They may have a 10 deficiency or may have a concern or comment. If it
11 violates a procedure, it's a deficiency.

i 12 And if it's something that looks wrong or perhaps I

6 i 13 you could do it another way, it's a comment or a i

14 concern. And then that report is issued. Usually it 15 goes to John Merritt, and given about 30 days to respond 16 to it.

! 17 And they need to provide what action they're 18 talking won't let it happen again, if they're fixing it

- 19 and provide a completion date as to when the action is 20 going to be done.

21 MR. HALE: Do they verify the action taken 22 subsequently?

23 MR. WELCH: After I get their response, I give that 24

~] to my surveillance guy, whoever did the surveillance, 25 and it's his job to go verify that the action was in GODFREY & AMES COURT REPORTING Metro 469-6100n (817) 460-2048

, 17 1 fact completed.

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2 MR. POSLUSNY: Okay.

3 MR. WELCH: When that's done, he sends me a sheet 4 of paper, fills in the blanks, and says, "I verified 5 this," and represents whatever.

1 1 6 If it's incomplete, well, then we.may write then 7 another letter.

8 MR. POSLUSNY: So you go back to them again?

9 MR. WELCH: Or we might write a corrective action i 10 request on that.

11 MR. HALE: How many times do you disagree with the 2

12 findings of your surveillance personnel?

f l L a 13 MR. WELCH: Not too often any more. I did have a 14 guy they wanted to write-up some, not shall's, but 15 should's. It says here, "It should be this."

16 And I says, "Okay. It should, but it doesn't have 17 to be."

18 - And he was quite insistent on it. He wanted to l

19 write it up as a deficiency. I said, "It can't be a l 20 deficiency. You can have it as a concern, but not as a 21 deficiency." But that guy left. He's going up to New 22 York.

23 Recently Gerald Sigler and I had a discussion on a 1l .. ;

I~l 24 surveillance that he had done on rigging, in the rigging j 25 tres. There's a lot of should's. And he wanted to 1

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__.- 1 pursue that "should", and squeeze it into a shall. So

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2 we talked about that a little bit.

3 MR. HALE: Who wins?

4 MR. WELCH: I do. But, no, I haven't had any real 5 arguements about them. Quite sometime ago I had one guy 6 wanted to write a thing as a deficiency, and it was such 7 a minuscule problem, I could have solved the problem by I 8 just asking the guy a question and getting the right 9 answer. And I didn't feel that it warranted the paper 10 necessary to do it.

11 But that's very infrequent. I can only think of 12 one time that I actually did not like the deficiency 13 report. But we get good responses. We set good 14 action. It gets high visibility. Most of the reports 15 go to Dave McAfee. Previously they went to Bill 16 Clemmons, Dave Chapman.

17 One of the problems I had when we were doing l 18 walkdowns, is they would have a grocery list of I

! 19 deficiencies or problems that they have sighted, like a I

l 20 screw was missing from a cover or something like that.

21 That would be mixed in with the fact that the dimensions l 22 are wrong on a hanger.

23 So we would issue a report, and maybe have 120

l 24 problems. And it didn't jump out and get you that, 6 4 25 hired in, there are nonconforming conditions.

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'._- 1 So I issued a directive that they would pull out

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2 those nonconformin;g conditions and issue a 3 nonconformance report on it.

4 MR. POSLUSNY: Separately?

5 MR. WELCH: Yeah, separately.

6 MR. HALE: Would this be an example of mixing up 7 elephants and non-elephants?

8 MR. WELCH: The manager doesn't want to read 120 9 items to find out the last one is, the one that's 10 causing the containment to crack. So you have got to 11 get that out so you can work on it.

12 MR. HALE: But not at the expense of not getting i . 13 out the others?

14 MR. WELCH: Oh, no, no. But to get that out, get 15 that out on the table as a nonconforming condition, pull 16 it out from all the other chaff that's in there.

17 MR. HALE: I have had individuals disagree with me 18 and my judgment with respect to a finding that they have 19 had before.

20 MR. WELCH: Oh, yeah.

21 MR. HALE: And use the prerogative that you have 22 used. If that individual has had a -- did not like my 23 decision, he had another avenue to which he could F 24 appeal that decision. They didn't use it very often 25 Vith me. Do they use it with you, and is there such a GODFREY & AMES COURT REPORTING l

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. . - - 1 mechanism that one could have, your auditors might have

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2 if they disagree with one of your oppositions of their i 3 findings?

4 MR. WELCH: Sure is. There's a memo out that says, 5 "If you have got a problem with a decision that your 6 supervisor has made, that the correct approach to the 7 problem is to bring it up with his supervisor."

8 MR. HALE: So in this case it would be your 9 supervisor?

10 MR. WELCH: Right. So if one of my guys had a 11 problem with a decision I made, that he should then 12 inform ma of that, and, "Let's go talk to my boss."

I i i 13 MR. HALE: That's Mr. Halstead in your case?

14 MR. WELCH: Yes. That's the normal. That's what's 15 supposed to happen.

16 MR. HALE: You say that as though that isn't 17 always what happens.

18 -

Mr. WELCH: That's true. That's what's supposed to 19 happen. And they do have now, they do have the other 20 avenue of the SAFE team. They can go to them.

21 MR. POSLUSNY: Well, apparently there was some 22 problem, I guess last August or September, and Shannon 23 Phillips, our resident here, was asked to go to a I

24 meeting with Mr. Clemmons.

, } .

25 And apparently Mr. Clemmons was going to look into GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048_ _ _ - - - -

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_ _ _ 1 some previous inspection and concerns of your people, 2 and there was supposed to be some written report or 3 investigation. And this is what I was told by Shannon I ,

4 would like to find out, was that ever done or anything 5 come out of it?

6 MR. WELCH: Last August or September? I would have 7 to pick a subject.

8 MR. HALE: It would have to have been when we were 9 out here, about the time the TRT was out here. We were 10 going to as-built inspections, if you could relate it to 11 that time frame.

12 MR. WELCH: I can't think of a problem when Shannon

! .I L a 13 Phillips and "lemmons were in discussions.

14 MR. HALE: Shannon didn't meet with them, did he?

15 MR. POSLUSNY: He set in on the meeting.

16 MR. HALE: Or -- oh, did he?

l 17 MR. POSLUSNY: Well, we can talk to Clemmons.

18 -

MR. WELCH: No, I don't remember that.

19 MR. POSLUSNY: I guess we have addressed what was 20 included in this inspection report.

21 MR. HALE: I guess.

22 MR. POSLUSNY: Anything else? Anything you have 23 got, Charlie?

l' 24

[ ,

MR. RICHARDS: I don't suppose so. How long you 25 3'ay you have been the supervisor of the surveillance GODFREY & AMES COURT REPORTING C3GRFPs 065)-6 9 00 u(_8_J172J) O(661. J & Q_8

, . 22 1 group?

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2 MR. WELCH: It will be three years in. July.

3 MR. RICHARDS: Three years? I might address the 4 one question that I'm concerned about, if you have 5 noticed, during the operations testing, hydrotesting, 6 and if you were aware of any weld repairs of 7 hydrotested pressure boundary items after hydrotest?

8 MR. WELCH: Weld repairs after hydro? I don't know 9 of any. I have -- also have the section 11 NIS-2 form 10 generation underneath me now, which I just picked up a 11 few months ago. But I don't recall any on systems that 12 have already been hydro, any repairs that were done.

l  !

t . 13 They should be documented on those NIS.2's, if it had 14 been done. But I don't recall any.

15 MR. RICHARDS: Okay.

16 MR. POSLUSNY: Okay. Anything else? Thank you 17 for your time.

18 _

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'..__ 1 STATE OF TEXAS (

2 COUNTY OF TARRANT (

3 I, Jayne Ames, a Certified Shorthand Reporter for l

4 the State of Texas, do hereby certify that the above and 5 foregoing contains a true and correct transcription of 6 the answers in response to the interrogatories as 7 indicated, and were made before me by CHUCK WELCH, 8 hereinbefore named, and were thereafter reduced to 9 typewriting under my supervision.

10 I further certify that the above and foregoing as 11 set forth in typewriting is a full, true, correct, and 12 complete transcript of the proceedings had at the time i- I t . 13 of taking.

14 k

Certified to on this the s

,- _______ day of C '

15 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _- _ _ _ _ _ _ _ , 1985.

16 I' 17 '

JAY E A $ ,' C'SR, WR-CP 18 Ceptiri at on Number: 1902 ErAirat o Date: January 1, 1986 19 1106 W. Pioneer Parkway, Suite 400 Arlington, Texas 76013 20 Metro 469-6100 (817) 460-2048 21 22 23 l'~l 24 25 -

GODFREY & AMES COURT REPORTING Metro 469-6100, (817) 460-2048

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