ML20215J923
| ML20215J923 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/04/1984 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML20215J867 | List: |
| References | |
| FOIA-84-779, FOIA-86-A-219 NUDOCS 8705080332 | |
| Download: ML20215J923 (71) | |
Text
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N N NT BEFORE THE UNITED STATES I
i NUCLEAR REGULATORY COMMISSION a.
IN RE:
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TRIP REPORT OBC b
JOB NO. H8301
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COMANCHE PEAK UNIT 1
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GLEN ROSE, TX
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1 THE SWORN STATEMENT OF MR. JOSEPH J. LIPINSKY, taken by Mr. Frank Hawkins, Reactor Inspector for the United States Nuclear Regulatory Cosuaission, before GLORIA APOSTOLOS, C.S.R.,
Notary Public, held on Wednesday, the 4th day of January, A.D.1984, at the hour of 11:00 o' clock A.M.,
at the O' Hare Hilton, Room 2076, Chicago, Illinois.
4 PRESENT:
l Mr. Frank Hawkins, Reactor Inspector Region III Mr. Claude E. Johnson, Reactor Inspector Region.
4 IV MESSRS. BISHOP, LIBERMAN, COOK, PURCELL &
REYNOLDS, by MR. MC NEILL WATKINS II, appeared on behalf of Mr. Lipinsky.
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MR. HAWKINS:
Do you want to swear in Mr. Lipinsky?
2 THE COURT REPORTER:
Raise your right hand, 3
please.
4 (The oath was thereupon duly 5
administered to the witness 6
by the Notary.)
7 MR. HAWKINS:
Okay.
We are going to mark the 8
transcript confidential.
And would you like a copy 9
provided to either one of you all?
10 A.
I would like a copy to myself and if possible, 11 if it's not going to be too much of a problem, to Mr.
12 Watkins.
13 MR. HAWKINS:
Okay.
Why don't you put your 14 address into the record, both of you, so we can make 15 sure we get it to you.
16 i You have it.
Okay.
17 BY MR. HAWKINS:
18 0.
Let's first also introduce everybody.
19 My name is Frank Hawkins.
I am a 20 Reactor Inspector from Region 3 in Glen Ellyn, 21 Illinois.
To my left is Claude Johnson, a Reactor 22 Inspector out of the Region 4 office in Arlington, COUNTY COURT REPORTERS, INC.
3 1
And we have got Mr. Joe Lipinsky whom we are 2
here to talk to today.
He is a Q.A.
Manager; is that 3
correct?
4 A.
Q.A.
Director.
~
5 Q.
Q.A.
Director for O.
B.
Cannon in 6
And representing him is Mr. McNeill 7
Watkins, an attorney from Washington, D.C.
s 8
Let me get into the purpose of the 9
interview and that's to clearly define each technical 10 concern which you have, Joe.
We want to see each 11 issue from your perspective.
To accomplish that, we 12 are going to go through the trip report that you 13 furnished as a result of your visit to the Comanche 14 Peak site.
15 We will read each issue to you to 1
16 refresh your memory, and then we will discuss each one 17 in detail.
l 18 Now, I want to establish also for the 19 record that Mr. Watkins~is here to represent you; is 20 that correct?
21 A.
Yes, that's correct.
22 Q.
Mr. Watkins, can I ask you, are you or your COUNTY COURT REPORTERS, INC.
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1 organization in any way associated with the Comanche 2
Peak ASOB proceedings that are presently under way?
3-MR. WATKINS:
My firm represents the applicants of 4
the N.R.C.
for the proceedings.
5 MR. HAWKINS:
And that would be Texas Utilities 6
Generating Company?
7 MR. WATKINS:
Yes.
8 MR. HAWKINS:
Are you personally involved in any 9
way as far as developing defense for contentions, that q
10 sort of thing, anything at all?
11 MR. WATKINS:
I have not been in the past.
12 MR. HAWKINS:
All right.
13 BY MR. HAWKINS:
14 0.
I need to ask you anyway, Joe, will Mr.
15 Watkins' presence here in any way inhibit you from 16 answering our questions fully and honestly, I guess?
17 A.
No.
18 0
All right.
19 So if you don't have any objections, 1 20 guess we will just continue.
21 A.
Can I interrupt here a second?
22 0.
Sure.
COUNTY COURT REPORTERS, INC.
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1 A.
You indicated that I furnished a copy of the 2
trip report.
3 Q.
To?
4 A.
That's what I am leading into.
5 Q.
Okay.
6 It's my understanding that you gave that 7
trip report to people at the site, whether it was i
8 Texas Utilities or it was some person there at the 9
site that we 10 MR. WATKINS:
Perhaps you could explain the 11 circumstances under.which the' trip report and by 12 trip report, we are referring to the August 8th trip 13 report.
The circumstances under which that report saw 14 the light of day, Joe.
15 THE WITNESS:
Well, from what I understand from,,
1 16 the N.R.C.
report, and th'is is a question I have later, 17 but that trip report was surreptitiously taken, either 18 from the site or from.the spec on the site somewhere 19 along those lines.
And I have been asked by people in 20 my company how this report got out.
21 In that N.R.C.
memo from 1
22 guess it's an in-house memo, he names the individual 1
COUNTY COURT REPORTERS, INC.
6 1
who has surreptitiously taken this report.
And I 2
guess what I need to find out is can I discuss that 3
individual's name?
I have not.
4 MR. HAWKINS:
Sure.
I that's what we are here for.
5 A.
Well, I understand that from the N.R.C.
point 6
of view, that that's how this report surfaced.
7 Q.
All right.
Why don't we get into that as we i
8 go through things?
I think it will be a more 9
opportune time as we proceed.
Do either one of you 10 want to make any opening remarks?
11 MR. WATKINS:
I don't.
12 MR. HAWKINS:
All right.
I want to enter as 13 Exhibit No. 1 your August 8th, 1983 trip report.
It's 14 entitled Departmental Correspondence.
15 As far as a little background *, ilso,
,I 16 want to -- could you tell me again for the record who 17 you are employed by and what your responsibilities are?
18 MR. WATKINS:
Ftcuse me.
19 MR. HAWKINS:
Yes.
20 MR. WATKINS:
Is that entered into the record?
21 Could you show a copy of that to Mr. Lipinsky?
22 MR. HAWKINS:
Yes.
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THE WITNESS:
I may need to refer to this, being I 2
don't have a copy with me.
3 BY MR. HAWKINS:
4 0.
All right.
5 A.
I can use Mr. Johnson's as a reference.
6 0.
Okay.
That's fine.
7-Okay.
Again, to establish some 8
background, would you tell us again who you are 9
employed by and what your basic responsibilities are?
10 A.
I am employed by Oliver B.
Cannon and Son the 11 Philadelphia base.
Coating American indicator 12 painting company.
Specialists.
My position with the 13 company is Corporate Quality Assurance Director.
In 14 that position in a nutshell, I'm essentially 15 responsible for the activities of Cannon on nuclear..
16 projects throughout the United States.
17 0.
What's your relationship to the Comanche Peak 18 facility?
19 A.
Mine personally, or the company's?
20 0.
Well, we can do both.
Let's do yours first.
21 A.
All right.
I was brought down on-site at the 22 request of
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8 1
out of Houston, to evaluate certain aspects of the 2
Comanche Peak coating operation.
3 As a result of that request, I was 4
on-site initially on, I believe it was July 26th, 27th, S
28th, which precipitated that August 8th trip report.
6 Q.,
Okay.
7 Now, you just gave me your company 8
relation to Comanche Peak, or was that the personal 9
one?
10 A.
That was about it.
11 0.
That was the whole thing?
12 A.
Yes.
13 Q.
Okay.
14 So there is not really any difference 15 between the two?
16 A.
I wouldn't think so, no.
17 0.
All right.
18 What was the purpose of your visit?
I 19 didn't believe or I don't know that O.
B.
Cannon is 20 involved to any degree at all at Comanche Peak a rid I 21 was surprised to hear that they had asked you to come 22 down, or anybody from O.
B.
Cannon to come down to COUNTY COURT REPORTERS, INC.
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take a look at what was going on.
2 A.
I'm not sure what precipitated our 3
involvement.
Evidentally, it was something through 4
and Comanche Peak that precipitated o s
5 real.
Our role is stri,ctly as a consultant.
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A purchase order was issued to Cann'on by 7
Comanche Peak and there were four or five items or 8
areas that they wanted us to look at and give them our 9
opinion of how they were performing.
Off the top of 10 my head, I don't know what those areas were. I would 11 have to look at the purchase order.
And that's 12 essentially our role on-site.
13 Q.
So you would say, I guess, let me understand 14 then what you just said.
Basically your role when you 15 went to Comanche Peak was as a consultant to look into 16 certain areas, maybe problem areas that they had, to 17 see what you thought of and if they were headed in the 18 right direction to get things corrected, or maybe you 19 would suggest things to help them get out of what they r
20 perceived to be a difficult situation in respect to 21 the codings work?'
22 A.
I don't know that they were problem areas.
COUNTY COURT REPORTERS, INC.
219 Nacerville Rd.,
Wheaton, IL 60187 (312) 653-1622
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These were just areas, major topics, as I recall, that 2
for some reason Comanche Peak management asked us, us 3
meaning Cannon, to look at.
4 Q.
But you were not privy to why Comanche Peak 5
management requested O.
B.
Cannon to come down?
6 A.
No.
I am not really sure of the background 7
on that.
8 0
Okay.
9 Could you give us an abbreviated summary 10 of your activities on-site during the two and-a-half 11 days that you were there?
12 A.
It's pretty much summarized in my trip report.
i 13 Essentially on the 26th, I initially met 14 who in turn introduced me to 15 At that time I walked around unit one containment with 16 17 Also, I met who was employed what g 18 by cannon to look at I'm not really sure 19 jrole was.
I believe he was looking more at J
20 the practical end of it; the actual limitation.
21 When I was with we discussed 22 things in general.
It was more of an introductory COUNTY COURT REPORTERS, INC.
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type thing.
We looked through the specification that i
2 day.
I met 3
Sometime during the course of the
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I got badged.
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5 Also, on the 26th,.I believe I walked 6
around on-site with who was 7
then employed I guess b W That's really it, to J
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tell you the truth.
9 O.
Okay.
10 What's your relationship to 11 l
l 12 A.
Short of seeing the gentleman's name in a i
13 previously mentioned memo, I never heard of him before 14 that.
Before reading his name in the N.R.C.
- memo, 15 that is.
16 Q.
He is the man ue were talking about earlier 17 that you weren't sure you should bring up his name?
18 You don't have any relationship at all with him?
You.
19 don't even know him?
20 A.
I never talked to the man.
If he was sitting 21 where Mr. Johnson is, I wouldn't be able to recognize 22 him.
You know, I never talked to him, never met him, I
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that I know of.
2 Q.
You must be pretty curious though, weren't 3
you, why he would it's my understanding that he is i
4 the one that supplied us with the trip report.
5 A.
Yes.
l 6
Q.
Is it your understanding, also?
7 A.
Yes, that's my understanding, also, based on 8
memo, whatever date it was.
I don't 9
know the date of the memo.
10 Q.
Okay.
11 A.
Now, this is where my question comes in.
Am 12 I any liability or problem if I divulged that(gg 13 JEEEEEE supplied the N.R.C.
with that memo?
14 Q.
You are asking me?
15 A.
Yes.
16 Q.
What was the question again now?
17 A.
The N.R.C.
memo that I read, I guess it was 18 November 10th, is when I read the memo.
I don't know.'
1 fromdRE 19 when the memo is dated.
But that memo 20 indicated that supplied the N.R.C.
21 with a copy of my trip report.
22 I have been asked by people'within my l
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company about how this trip report serviced.
2 My concern is Fevidentally 3
supplied the N.R.C.
with the report.
To date I have 4
not said that has supplied a copy of the 5
report.
If I did, would there be a problem with that?
6 Q.
If that's your belief, I don't see that there 7
wbuld be a problem on it?
8 A.
Well, the only way I could base that on is 9
the N.R.C.
memo.
From what I understand from h.
10 your investigator, that memo wan not 11 sanitized, was not sensored and if it ever were i
12 released, it would be sensored because has 13 confidentiality.
You see where I'm leading into?
14 Q.
Sure, I understand.
Well, what we are doing 15 here, at least, is confident.
what we talk about ip.
16 confident ial.
As far as saying it publicly or in a 17 form that isn't controlled, I can't really speak to 18 that.
I'm sure Mr. Watkins can help you out on that 19 more than I could.
20 MR. WATKINS:
Well, I think Mr. Lipinsky wants to 21 know whether he is going to get into trouble with you 22 guys, with the N.R.C.,
if he repeats what he's been COUNTY COURT REPORTERS, INC.
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told by the N.R.C.
2 MR. HAWKINS:
I don't care.
Like I said, it's in 3
writing, so and the other gentlemen, that's their understanding of what happened, 4
i 5
so I don't see any problem with you restating what 6
they said, as long as you qualify it in that light.
7 MR. LIPINSKY:
Well, what I am leading into with 8
that report is, when I initially had my conversation wit (
9 he indicated that that report would 10 be sanitized prior to its release and l
11 name would be removed.
There would be no reference.
12 BY MR. HAWKINS:
13 Q.
I seu.
But you saw it before that happened?
14 A.
Right.
15 Q.
Well, I don't know.
I guess I would just 16 walk around on egg shells a little longer and see what 17 happens.
18 A.
All right.
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19 0.
Have you inquired at all as to how llll got
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20 ahold of the thing and gave it to us?
d' 21 A.
I tried to, but it's one of those things at 22 this point in time, I can't track it down.
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1 0.
Who typically gets distribution on this 2
departmental correspondence of this sort?
3 A.
That report was given to the I,
6 Additionally, I did allow to 7
read the report when I was on-site, I believe August 8
8th or 9th.
I am not really sure of the date.
9 Q.
Who is I'm sorry.
10 A.
He was the I believe was his l
11 title, at Comanche Peak site.
i 12 Q.
Okay.
You allowed him to read it,-but did 13 not give him a copy of it?
i 14 A.
Yes, that's correct.
I J
15 Q.
So it's a mystery to you how the thing got,,
i 16 out?
17 A.
Yes.
I can't the common link is 4
18 but I can't believe that I gave him a copy.
I don't 19 recall doing it.
So for me, it's 20 0.
Who did you say the common link was?
21 A.
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22 Q.
All right.
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So as you recall, you gave one to your 2
one to your
/you retaihed 3
one, of course, and let read it and that's 4
as far as it went, to your knowledge?
5 A.
Right.
6 Q.
All right.
7 Why don't we move into some specific 8
issues here?
9 Let me read from your trip report and 10 then we will discuss the i s s u ers.
11 Item one reads, "To some extent, 12 parallel can be drawn with Comanche Peak and Zimmer.
13 Comanche Peak is doing inspections to the degree that 14 they (Comanche Peak) are comfortable with or will 15 tolerate.
However, in the real world there are 16 requirements that have to be satisfied, and in at 17 least the areas of material storage, painter 18 qualification / indoctrination, documentation and 19 traceability, indications are that Comanche Peak falls 20 short in adequately satisfying these requirements.".
21 I'm real curious in what the parallel is 22 between Comanche Peak and Zimmer that you referred to.
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1 A.
Well, initially I based that conclusion on 2
the results of that trip; conversations I had wi~th 3
individuals on the site, site management.
4 Essentially, it was a one-sided opinion i
5 at that time, since subsequent to my original t r i'p,
6 project management on-site has gone to great lengths i
7 to explain how they are satisfying each of the 8
requirements that I had concerns with.
9 As a result of that, I would not at this 10 time draw a parallel between Zimmer and Comanche Peak.
11 Q.
Okay.
12 So presently, you would not draw that 13 parallel?
14 A.
That's correct.
15 Q.
But having the information you had at the 16 time, which in your own words was not an entire 17 picture but one-sided, you would have drawn that 18 conclusion?
19 A.
That's correct.
20 Q.
All right.
21 What were the specific problems that you 22 were aware of relative to material storage?
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A.
All right.
2 I was looking, I guess essentially for 3
status tags; you know, accept tags, reject tags, that 4
sort of thing.
Reject areas, hold areas.
Some way 5
that the mix material was controlled; traceability of 6
the mix material.
7 When I was there on-site, I did not see 8
any status tags whatsoever on the material in storage.
9 I didn't see any reject area or hold area.
And 10 Q.
This is in the paint warehouse now you are 11 referring to?
12 A.
It's out near the blast shop.
I believe 13 that's the paint warehouse, yes.
14 Q.
All right.
15 A.
Additionally, it was not explained to me at 16 the time how they control mix material from the point 17 of where it's mixed until it actually is surfaced.
18 Those were the areas I was concerned about.
19 Q.
Have all those concerns been addressed in 20 subsequent meetings between you and representatives of 21 Texas Utilities?
22 A.
I believe it was November 10th and lith.
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not sure of those dates.
That's the ballpark.
I had 2
a pretty extended meeting with the people on-sit'e, and 3
they went ahead and went in detail as to how they 4
control this stuff; the material that is, and they 5
pretty much addressed my concerns at the time, yes.
6 Q.
When you say they pretty much addressed them, 7
did they address them totally, or did you have some 8
concerns?
9 A.
Yes, they did address them.
10 I cannot I want to emphasize at this 11 point that from what they described to me, if in fact 12 they are doing that, then I would not have a concern 13 with the material storage.
14 But I was not given the opportunity, or 15 I can't prove it one way or the other, is what I am,,
16 leading into, I guess.
17 Q.
Okay.
18 But as far as credibility, I guess, 19 would you say that their discussions with you were as 20 credible as what you heard or saw before?
21 A.
I think at my second meeting, the site 22 management people were more concerned what opinion l
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that would have on the left site.
That is, the first 2
time I was on-site, the time given to me while I' w a s 3
on-site was less than adequate, or I would have 4
presented other views.
5 Q.
That's the first trip?
6 A.
My first one in July, right.
7 The second trip, they made sure that I 8
had complete access and they pretty much satisfied my 9
concerns.
10 Q.
What about painter qualifications and 11 indoctrination?
t 12 A.
Okay.
13 When I was on-site in July, I was 14 concerned that painters were being allowed to apply 15 materials in class one areas without any actual 16 hands-on testing other application or technique.
17 And subsequent to that, when I was 18 on-site I believe August 9th, painters were actually 19 being qualified physically with zinc.
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20 witnessed the application.
21 Q.
Was that as a result of your concern, or was 22 that something that you just didn't see the first time COUNTY COURT REPORTERS, INC.
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you were there?
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I was told that was something I didn't see 3
the first time I was there.
4 Q.
What do you believe?
5 A.
I would assume that they in fact were doing 6
painter qualifications throughout the course of the 7
project and I just did not witness it the first time 8
out.
I mean, I have no reason not to believe that.
9 Q.
Okay.
10 You also referred to a problem with 11 documentation?
12 A.
Yes.
13 Q.
In what respect?
14 A.
There were two things with that.
One was the 15 documentation of the painter qualifications, was one 16 of them.
17 The other concern I had was I had looked 18 at some documentation.
I don't recall what it was.
19 Specifically, the surface preparation for coating 20 application was a check list type format and I felt at 21 the time, or I had the impression, that that was not 22 adequate.
COUNTY COURT REPORTERS, INC.
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I don't remember the specifics.
I just 2
thought that the documentation used to document 3
coating activity for surface preparation did not 4
contain sufficient data to satisfy the forms, the 5
sample forms and 101.4.
Not that it had to be the 6
same format as the 101.4 forms.
It's just that the 7
data had to be there.
8 0
You didn't see as much detail on their 9
documentation of in-process work as you were used to 10 seeing on sample forms or typical forms used at other 11 utility sites as required by NCN 101.~47 Is that.a 12 fair summary of what you just said?
13 A.
That's a summary, yes.
14 Again, I don't recall the specifics.
15 But just looking at the format of the forms, I felt 16 that at least I had the impression, anyway, that it 17 was not sufficient.
18 0.
In your mind, did they resolve those problems 19 for you during your meetings in November?
20 A.
Yes.
One of the things that came up during 21 the meetings in November, or meeting in November was 22 that there had been numerous audits, both internally COUNTY COURT REPORTERS, INC.
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and external audits, I assumed, by the N.R.C.
2 I felt and I still do -- I have not 3
reviewed the audits, but if the audits were of 4
sufficient scope and depth, they would have uncovered 5
any problems that would have at least the audits we 6
have been exposed to should have uncovered any 7
problems in documentation.
And from what I understand, 8
they haven't had any significant findings in that a r ea.-l 9
Q.
All right.
10 Now, your original concerns that you 11 wrote in your trip report were as a result of your 12 visit in July of '837 13 A.
That's correct.
14 Q.
Could you be more specif-ic now and tell me 15 exactly what the basis for those concerns were?
You 16 said interviews with people and some observational 17 work, but could you be more specific for me in both 18 those areas?
19 A.
Essentially when I first came on-site, I met 20 with various individuals in the coating section.
21 Primarily Everett Mazzer.
I had worked with 22 COUNTY COURT REPORTERS, INC.
219 Naperville Rd.,
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2 I would ask how is materia'l 3
storage being handled and he would respond as to how 4
it was being handled and I would ask additional 5
questions.
It was a give and take type thing.
6 Additionally, 7
0.
But you didn't like the answers though at 8
that point?
9 A.
That's correct.
There were areas that were 10 areas of concern, for lack of a better word.
Areas 11 that I am not used -- that if it was being handled 12 that way, I would have a problem with it.
13 As a result of my conversations withll[
m 14 I tried to confirm this through observations 15 and through conversations with other people *on-site,in 16 the codings area.
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17 We had, we Cannon had approximately 18 eight or nine former employees working at the Comanche 19 Peak site at one time or another.
Those people were 20 qualified by Cannon as inspectors, and I tried to 21 confirm what I was told b in separate 22 conversations with those individuals and through COUNTY COURT REPORTERS, INC.
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observations if I could.
2 Q.
Could you give me the names of the 3
individuals that you knew personally on the site?
4 A.
As best as I recall, it was 5
I'm not sure of the spelling on these.
6 7
There were a couple more, but I don't have 8
a list with me.
I have my notes at the office.
9 Q.
Okay.
10 But they confirmed your concerns 11 basically at the time you talked to them?
i 12 A.
They either confirmed them, or they did not 13 give me enough not to confirm them.
l 14 Q.
In other words, they still left some areas 15 that in your mind were gray and that you were 16 uncomfortable with?
17 A.
Yes.
18 Q.
Would they have been in a position to know 19 the answers to all the questions you were asking?
20 A.
In a lot of cases I would think they would just the fact that they were involved in the 21 be 22 day-to-day activities, they would have to know how
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26 1
much material is controlled, mix material is 2
controlled, I would think, if they document how'it's 3
applied, as an example.
4 Q.
Did you go out in the field at all very much 5
and really look at any work that was in process?
6 A.
On the 26th?
7 Q.
In July, right.
8 A.
Yes.
On July 26th I was in containment unit 9
one for a good part of the time.
I didn't keep track 10 of my time exactly.
11 On the 27th, again I was in containment 12 unit one it was primarily the uppermost elevation.
13 I'm not sure of the floor elevation.
It's the one 14 where if you look up you can see the polar crane.
I'm 15 not sure of what the number was.
There were people 16 performing work on the dome and on the polar crane at 17 the time.
18 Additionally on the 27th, I did go out 19 to the blast shop briefly, but I didn't observe any 20 work up there.
21 Q.
Did you come away with any results as to what 22 your observations were?
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A.
There were just two items which I think I 2
addressed, including integrity.
One was the amount of 3
sanding on the C.Z.ll.
The other one was the 4
preparation of the Phenoline 305 that's already on the -
5 surface, and any additional coating that's applied on 6
top of that.
,7 Q.
Okay.
We will discuss those in more detail' 8
as we go through this thing.
9 That's really all I have on one.
Do you 10 have any questions on one, Claude.
11 MR. JOHNSON:
Yes.
I have one question.
12 BY MR. JOHNSON:
l 13 Q.
When you made your findings, did you present 14 them to the 0.A.
Management there at Comanche Peak and 15 define the specific areas that you had found problems 16 to give them a chance to either explain or identify 17 some of their program?
18 A.
Well, on the 26th I had a brief meeting, very 19 brief, it was about five or ten minutes, but a brief 20 meeting with and I believe 21 it's referenced in my trip report on page two -- I'm 22 sorry.
It's on page one where I indicated I talked COUNTY COURT REPORTERS, INC.
l l
28 1
t where I said that there might be some 2
problems in the areas of material storage, workmanship 3
ANSI requirements, possible coating integrity.
All 4
the above can affect N.R.C.
licensing.
5 At the time when replied 6
that's not my job or concern, I took it to mean that 7
he didn't care about those quality items.
8 Subsequent to that, has 9
explained that he heard the word licensing and 10 essentially tuned me out; didn't pay any attention to 11 what else I had to say.
And so I came away with.the 12 feeling tha wasn't concerned about those 13 quality items.
14 Additionally, on the 28th, we had an 15 exit meeting where I again mentioned those areas of 16 concerns, and at that time did ask for 17 specifies and I pointed out that I could not give him 18 specific areas or items, except in generalities, 19 without a more thorough review.
20 BY MR. HAWKINS:
21 0.
At that time did you propose that O.
B.
22 Cannon come on-site and be contracted to Texas i
COUNTY COURT REPORTERR. '""
29 1
Utilities to do that work?
2 A.
No.
I said that we would not be able to do 3
or give specifics without a more thorough review or l
4 audit at that time.
And since that time 5
has stated that he does not want their audit from the 6,
standpoint that he's gone through numerous audits and 7
he just felt that an audit would be redundant.
And I 8
wasn't ready to push for Cannon to do ab. audit,- no.
9 0.
One thing I did forget to ask was you 10 referred to a meeting in November that went for two 11 days and it was in regard to your concerns that you 12 expressed here in the trip report?
13 A.
That's correct.
O 14 0.
That was the only time that you met with them 15 on the issues that you expressed as concerns?
16 A.
The only time I met with them, yes.
We have 17 had telephone conversations, but nothing in great 18 detail.
The meeting in November, I believe it was e
19 10th and lith was fairly detailed.
20 Q.
So the basis, would it be fair to say then 21 that the basis for the resolution of your concerns was 22 this two-day meeting at the site?
e COUNTY COURT REPORTERS. TWr.
30 1
A.
That's correct.
2 0.
Okay.
3 Do you recall who was there?
Did you 4
document that meeting anywhere?
I guess I have never 5
seen it.
6 A.
There is a transcript of that.
7-O.
Is there?
8 A.
That meeting was I don't know what the 9
correct word is recorded and transcribed.
10 Q.
Oh, it was?
11 A.
Yes.
And I believe has the 12 transcript I would assume, the final edition of it.
13 Q.
Okay.
14 A.
I don't know if that answers your question or 15 not.
16 Q.
Yes, it does.
It sure does.
17 okay.
Let's go on to number two then, 18 Claude.
19 BY MR. JOHNSON:
20 0.
Okay.
This is again from the transcript.
I 21 "The writer's opinion is that management and Comanche 22 Peak has deluded itself into thinking everything is i
l COUNTY COURT REPORTERS, INC.
{
31 1
1 all right, or it will all come out in the wash.
2 The fact that management attempts'to 3
squash any efforts to point out quality problems (No 4
NCR's Q.C.
reporting to production etc.) to some 5
extent confirms the above, and has led to a morale 6
problem with the inspection staff.".
7 What do you mean when you say that 8
Comanche Peak management has deluded itself?
9 A.
Again, at the time, I felt based on that July 10 26th, 27 and 28 trip, that Comanche Peak management 11 was not concerned with the quality, overall quality of 12 coating work.
13 Subsequent to that, and again primarily 14 based on the November 10th meeting, the Comanche Peak 15 management people on-site have expressed that they are 16 quality oriented.
That they are concerned with any 17 issue that might affect the quality coatings.
18 Q.
Do you know of any instances where managarent 19 has stopped the identification of quality problems at 20 Comanche Peak such as NCR's or Q.C.
reporting?
21 A.
The only thing I would say on that is that I 22 had been told when I was on-site by the people I COUNTY COURT REPORTERS, INC.
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1 mentioned that rather than write NCR's, that I believe 2
it's called on-site reports or inspection reports were 3
to be generated in lieu of the NCR.
4 At the time I was under the impression 5
that a non-sat report or an NIR would not adequately 6
document the nonconformance report.
1 l
7 I don't want to get hung up on terms, 8
but you don't necessarily have to close the 9
nonconformance as long as it identifies l
10 insufficiencies.
A un-sat or NIR, from what's been 11 described by management, a un-sat or NIR would 12 adequately document deficiency.
13 Q.
You are saying at the time it was explained 14 to you and it's clear in your mind what's all been 15 taken place since that time?
16 A.
That's correct, yes.
17 Q.
What is your basis for concluding that there 18 is a morale problem on the O.C.
inspection staff?
l 19 A.
Pretty much that was something that came up 20 during the course of my visit and during the exit 21 meeting on the 28th.
The site management people 22 acknowledged that they had a morale problem and they i
1 i
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were taking steps to rectify that.
2 From what I understand, a barbeque or a 3
get-together or something along those lines was 4
planned and held.
From what I got out, evidentally 5
0.C.
did not participate to an extent.
I believe jlll partook and another individual, but I don't 6
7 know that person's name.
8 I don't think the problems of morale 9
were any secrets, or was a secret or a surprise to the 10 people on-site, management.
They realized there was a 11 morale problem and they were working on it to correct 12 it.
13 Q.
One other thing, 14 I guess since this last meeting with 15 Comanche Peak management, in your opinion, management 16 still has deluded itself into thinking that everything 17 has come out in the wash, or do you change or have you 18 changed your opinion on that since this last meeting 19 that you had?
20 A.
I think that I was given more background l
21 information.
And if in fact they are doing -- by they 22 I mean the people on the Comanche Peak site.
If they 1
COUNTY COURT REPORTERS, INC.
34 1
are in fact implementing everything they told me they 2
are implementing, that I would not have expressed the 3
concerns I expressed on that trip report.
l 4
BY MR. HAWKINS:
5 Q.
Who were the management personnel you're 6
referring to in that statement?
7 A.
and 8
Q.
Those two specifically?
9 A.
Yes.
10 Q.
Were there any others?
11 A.
No.
In my trip report?
Is that the 12 statement you are talking about?
13 Q.
Right.
14 Did I understand you correctly when you 15 said that you don't have any problem with the program 16 as it's structured today, as you understand it, as far 17 as reporting a nonconforming condition?
18 A.
From what I understand, they are using, it's 19 either a un-sat or an inspection report to identify 20 deficiencies.
And from what I understand, it goes 21 through a review.
Essentially it does everything' a
)
22 nonconformance report would do.
They call it
)
i II W
COUNTY COURT REPORTERS, INC.
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35 1
something other than a nonconformance report.
2 BY MR.
JOHNSON:
3 Q.
Were you satisfied with that?
l 4
A.
From their explanation, yes.
j 5
BY MR. HAWKINS:
i 6
Q.
One of the things you mentioned was Q.C.
I 7
reporting to production.
That was based on your i
I 8
conversation with some of the O.C.
Inspectors; right?
i 9
A.
Yes.
That was more, I believe, along the I
i 10 lines of painter qualification, as I recall.
I'm kind l
I 11 of hazy on that one.
I know at the time it was an 12 item, but I don't really recall the specifics.
l 13 0.
All right.
But in general, you would say 1
14 that your concerns in this area were resolved by the i
l 15 November meetings?
l l
16 A.
That's correct.
j i
17 Q.
All right.
l 18 This morale problem, did it have any 19 impact on work that you are aware of?
f 20 A.
Not that I am aware of, no.
I 21 MR. HAWKINS:
All right.
i i
1 22 I don't have any more, Claude.
I COUNTY COURT REPORTERS, INC.
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BY MR. JOHNSON:
1 2
Q.
Okay.
Statement number three, and this is 3
again from your letter dated August 8th.
i 4
"Almost everyone in the inspection staff 5
is looking to get out of Comanche Peak.
The 6
inspection staff works 60 to 70 hours8.101852e-4 days <br />0.0194 hours <br />1.157407e-4 weeks <br />2.6635e-5 months <br /> a week.
You 7
can't work people on an extended basis even with high 8
salaries.
(Apparently only a few stay a whole year.).
9 In addition to the long hours, the 10 Inspectors contacted by the writer (other disciplines 11 included) all have a low opinion of the quality of
.ork put in place, and in effect are keeping quiet 12 w
13 until they can find another job.".
14 What work were they referring to as far 15 as disciplines?
16 A.
During the course of my site tour, I guess 17 would be for lack of a better word, I was introduced 18 on a casual basis to other Inspectors.
And during the 19 course of the conversations, which I wasn't really a 20 large part of, these other Inspectors, the two topics 21 that came up were essentially other jobs with who is 22 hiring, where they are being hired, that type of thing.
COUNTY COURT REPORTERS, INC.
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37 1
So I didn't really get into any in-depth 2
discussion with these individuals; however, from~what 3
I gathered from the conversations, it was more of 4
these individuals were talking about possible places 5
of employment other than Comanche Peak.
6 Q.
Were these Coatings Inspectors?
7 A.
Some of them were, some of them were not.
8 The other people, I didn't even get the names.
We 9
were inside a building.
I was introduced.
Background
10 noise and all that other type thing.
It was a hi, how 11 are you doing type thing.
12 Q.
So your discussion was just not on' coating?
13 It was in other areas then?
Is what you are telling 14 me?
15 A.
I would assume it's other areas.
I know 16 these people aren't in coatings, but I don't know what 17 area they are in.
That's why I said other disciplines 18 included.
19 Q.
Who were the inspectors which have a low 20 opinion of the work put in place?
You don't know?
21 A.
If I could recall the names, I would be able 22 to tell you that.
COUNTY COURT REPORTERS, INC.
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Like I said, it was a casual meeting.
2 It couldn't have lasted meeting is a bad term.
It 3
was an introduction.
4 Q.
Okay.
5
' Were they responsible for the work that 6
was unacceptable, these particular Inspectors that you 7
told us about?
8 A.
I wouldn't know.
9 O.
And were they criticizing their own work or 10 the work that they were responsible for?
11 A.
Again, it wasn't a meeting.
We were walking 12 through the building.
I was either with or 13 another Inspector.
I went by myself because I didn't 14 know any of the individuals on-site.
15 The person who was guiding me through, 16 the plant recognized the individual and said hi, how 17 are you doing?
This i 18 this is whoever, you know, Joe Blow.
I don't know.
I 19 didn't catch the person's name.
20 The person then that was guiding me 21 through the plant proceeded to have a conversation
]
22 with whoever it was we encountered.
I was on the l
i i
COUNTY COURT REPORTERS, INC.
i
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39 d
1 fringe of that conversation at best.
2 Q.
Would you say it would you characterize 3
it's for me, I guess?
Was it the kind of thing you 4
would hear -- I'm sure you have experienced this 5
sitting arou'nd a bar one night having a couple of i
6 drinks and start bad-mouthing in a hate session?
Was 7
it that kind of morale or was it truly a I am 8
asking you to speculate.
9 MR. WATKINS:
Are you inferring that 10 sits around at bars?
11 MR. HAWKINS:
Not at all.
It's more of a human 12 BY MR. HAWKINS:
13 Q.
Was it that the sort of thing, or would it be 14 more that I truly have some concerns in that area 15 because I know that the plate has been installed wrong, 16 the stud welding on the anchors has been installed 17 wrong.
Was it specific, or was it something more 18 innocuous than that?
19 A.
No, it was not specific.
It was a casual 20 conversation.
Using your classification, it was the 21 type that people would kick around in a bar somewhere 22 after work.
COUNTY COURT REPORTERS, INC.
40 1
I wouldn't, in retrospect, place a great 2
deal of weight on what was said.
3 0.
Okay.
4 MR. HAWKINS:
Claude, do you have anything?
5 MR. JOHN' SON:
No.
6 BY MR. HAWKINS:
7 Let's go on to number four.
"The writer waydll presented 8
did not feel comfortable with the 9
the ANSI requirements.
This has been discussed with l
10 and to a certain extent the writer feels that at 11 least the manner of presentation was counter 12 productive to Cannon's efforts.
The writer would like 13 to state for the record that O.
B.
Cannon does satisfy 14 all applicable ANSI requirements and has done so on 15 numerous nuclear projects."
16 Just for my own education, jlll 17 18 A.
That's correct.
19 0.
And he represents O.
B.
Cannon?
20 A.
That's correct.
21 0.
He accompanied you on your site tour?
22 A.
He was on the site on the 28th.
The 26th and COUNTY COURT REPORTERS, INC.
41
)
1 27th I was on-site.
2 0.
Is he from your office in Philadelphia, or'is 3
he from Houston?
4 A.
He is from 5
O.
And your concern in this regard just was 6
relative to his effectiveness during his presentation 7
to utility personnel on what you all could do for them 8
or what concerns you had?
9 A.
I don't know if that characterizes it.
10 It.
opinions of the N.C.
11 requirements and mine differ.
It's an internal thing i
12 in Cannon.
It really has no effect on the Comanche 13 Peak site.
It was just something I wanted to praise 14 on the superior of it.
15 O.
So he is a peer of yours?
16 A.
He is I am not.
17
'O.
Okay.
18 Is there anything in this issue that we 19 should be --
20 A.
There is nothing that deals with Comanche 21 Peak.
22 0.
All right.
COUNTY COURT REPORTERS, INC.
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1 There is nothing that we should be i
2 concerned about in this area then?
3 A.
No.
4 Q.
All right.
Why don't we go onto five then?
6 A.
That's me.
7 Q.
discussed the problem of O.
B.
8 Cannon performing an in-depth audit.
The writer 9
cannot perform an audit at this time because Brown and 10 Root is hostile to the idea and no action would be 11 taken by Brown and Root on problems and concerns taken 12 during the audit."
13 A.
Before you ask any questions, I would like to 14 correct myself there.
Where I refer to Brown and Root, 15 I was referring to TUGCO.
i 16 Q.
Okay.
So that should be Texas Utilities 17 Generating Company instead of Brown and Root?
18 A.
I believe tha orks for th~m.
e 19 Q.
Right.
And specif 20 What type of audit were you proposing?
21 A.
Audit is a bad term.
I was thinking more a j
22 review type situation.
Just an audit that would allow
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43 1
me to provide specifics.
2 0.
In other words, to provide you the 3
opportunity to get in --
4 A.
To either confirm or allay my concerns.
5 O.
Why was that necessary in your mind?
Because 6
you had unresolved questions at that point?
7 A.
Well, the whole trip, like we said at the 8
onset here, was three days, two and-a-half.
Something 9
along those lines.
And that's not a sufficient amount 10 of time to do an in-depth evaluation.
11 Q.
Okay.
12 So I think I understand then when you 13 said that Brown and Root was hostile to an audit, you thathllllfbasicallywas 14 meant then hostile to an 15 audit; is that correct?
16 A.
Yes.
Hostile.
Not receptive to having 17 another audit perform.
18 At the time I was not used to lhg 19 demeanor.
He has a way of -- kind of an 20 abrasive personality at times, I guess.
21 And again, based on the fact that they 22 have gone through numerous audits, internal and l
COUNTY COURT REPORTERS, INC.
44 1
1 external, my understanding is they have gone through 2
those audits.
felt that shother audi't
{
3 would be redundant.
4 Q.
You stated that in your mind, that no action
{
l 5
would be taken on any audit findings that you would 6
have had, had you been allowed to do the audit.
7 Now, what was the basis for that concern?
8 How did that statement 9
A.
At the time, it was based on what led up to 1
i 10 this trip report.
I essentially had what I thought 11 were legitimate areas that should be pursued, and 12 mentioned it twice to what I thought was the 13 management on-site, which in fact they were the 5
14 management on-site; And at 15 best, it was glanced over.
Not a greet deal of 16 conversation or time was spent on what I thought was 17 concerns.
18 I felt that they were brought down there.
19 I had identified what I thought could be potential
}
20 areas of problems, concerns, and the management people 1
21 on-site really didn't dwell on it to any extent.
So I 22 felt that if we did an audit, we had findings, I would COUNTY COURT REPORTERS, INC.
i 45 l
l l
1 think that 2
Q.
So that was basically just your intuiti~on on 3
how you felt, based on how they treated you while you 4
were there?
5 A.
At that time, yes.
subsequently changed your opinion of 6
Q.
And you and everybody 7
everybody, and now you love 8
on the site; is that correct?
would invite me to 9
A.
I don't think if that's what we are leading into, 10 his 11 no.
12 MR. HAWKINS:
Okay.
I don't have any more on that.
How j
13 Claude?
14 about you, 15 MR. JOHNSON:
No.
16 MR. HAWKINS:
Okay.
Let's move on to number six.
17 BY MR. JOHNSON:
18 Q.
"High dry f ',1 -
tt
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19 ground to an 20 polish the zine and possibly result in poor adhesion 21 of the top coat."
Have you observed, or did you observe 22 annuev 000RT REPORTERS, INC.
c3 scon
46 1
CZ 811 being power ground to an acceptable DFT?
2 A.
When I was in the containment building, I 3
don't recall power grindings specifically; however, I 4
was told or given the impression that power grinding 5
was utilized by 0.B.
Cannon.
6 Q.
Who told you this, Q.C.
Inspectors, or what?
7 A.
I don't recall.
Again, I had that impression 8
that it was an option.
Either hand-sanded or power 9
tooled.
10 Q.
I guess what I am trying to get at is who 11 gave you that impression?
12 A.
I don't recall.
13 Q.
Do you recall I know you went through the 14 procedures, whether the procedures allowed it or 15 A.
Again, I couldn't help you out with that.
16 I'm sorry.
17 Q.
To your knowledge, has any system 18 qualification testing been performed, on primer 19 prepared for top coat application using that method?
20 A.
Not during July, my July trip.
i 21 Subsequently, I understand that the site 22 is preparing D.B.A.
panels for various combinations or COUNTY COURT REPORTERS, INC.
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47 1
systems that are encountered in the field.
2 I would -- again, this is an assumption 3
on my part, but I would assume that that condition is i
4 one of the panels that is being prepared.
5 Q.
Okay.
6 In your experience, what is an accepted 7
method of preparing high primer for a subsequent top 8
coat application?
9 A.
Wit 1 zinc, Cannon traditionally has removed 10 any large areas of high dry film thickness, either 11 blast or mechanical m e a n s ', to the substrate, and 12 reapplied the coating.
13 Q.
What about in, say, real tight areas?
Say 14 pipe supports that need repair work?
I mean you know, 15 they are kind of small.
16 A.
We normally use something scotch bright pad, 17 something like that, for three square feet or less.
18 Anything above three square feet, we take off.
19 Q.
You say anything above three square feet.
20 You mean the whole area of the particular item that we 21 are talking about here?
22 A.
Yes.
We handle pieces of steel something COUNTY COURT REPORTERS, INC.
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along those lines.
2 Q.
What would you do in case a pipe is c o a't e d 3
with this material?
How would you repair that?
4 A.
In place, or in the field?
5 Q.
In place in the field?
6 A.
Well, you have eliminated the various 7
blasting, essentially, from what I understand.
We 8
power wire brush.
Excuse me.
Wire brush is a mistake.
9 We would power tool using a scotch type pad.
10 Q.
That's basically the same thing that you are 11 saying here, I guess.
What I am trying to get at here 12
.i s you made these observations, but did you determine 13 whether it was a repair type work on small items like 14 that, or for say a large square area.
15 A.
No, I did not.
16 Q.
Okay.
17 A.
I would indicate that there is a difference 18 between scotch bright pad preparation and sanding in 19 the type of surface profile they can get, the finished i
20 product.
21 Q.
Are you saying you get a better profile, or 22 what?
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A.
With the scotch bright pad.
2 Q.
Did you determine from the applicant on what 3
they were using?
4 A.
No.
5 Q.
Okay.
So really you knew they were using 6
that or some other method; right?
7 A.
That's correct.
8 Q.
What do you feel about this now, after the 9
last meeting that you discussed?
Did you bring this 10 up again?
11 A.
On November 10th we brought it up, and from 12 what I understand, they are sanding with sandpaper;-
j 13 from what I understand, a very fine sandpaper.
From 14 what I understand, they are getting an automobile 15 finish almost on the surface.
16 Q.
What do you feel about this method?
Is that 17 acceptable as far as 0.
B.
Cannon is concerned?
i 18 A.
I don't think O.
B.
Cannon's concern deals 19 with the Comanche Peak site.
l 20 From what I understand, they have 21 addressed this with the coating manufacturer and they 22 have a written response from the coating manufacturer COUNTY COURT REPORTERS, INC.
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1 saying that that's an acceptable method.
As far as I 2
am concerned, as long as the coating manufacturer 3
stands behind their product, that's sufficient, I 4
would think.
5 Q.
Okay.
6 BY MR. HAWKINS:
7 Q.
What's been your experience, though?
I am 8
asking you to speak as a coatings expert, Q.A.
9 Director for O.
B.
Cannon.
10 A.
Traditionally people pay for that.
11-Q.
No, I want you to tell me what your 12 experience has been.
13 A.
I really don't want to get into speculations.
14 From what I understand, they have a 15 letter from the coating manufacturer saying that 16 that's sufficient.
I don't want to get into any more 17 speculation.
18 Q.
You mentioned DBA panels that are being put 19 together at the site presently.
What do you know 20 about those?
21 A.
Other than I believe the meeting when I was 22 on-site for August 9th, I went out to the blast shop COUNTY COURT REPORTERS, INC.
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at that time where I saw the people being qualified, 2
the painters.
3 During that time there was a small 4
building off to the side where evidentally all the 5
panels were being prepared.
I recall the standard 6
three-by-five panels.
Some of them had angles cut 7
into them, that type of thing.
But I didn't really 8
get into any specifics.
Just that the panels were 9
there.
I don't know what systems were being applied.
10 Q.
This is the qualification in accordance with 11 NCN 101.2 that you are referring to now?
12 A.
I don't know if it's the original 13 qualification. It's something supplemental, I guess.
14 I'm not really sure.
I don't know what these panels 15 were being prepared for.
16 0.
Let me explain to you why I am asking you 17 that.
We are having you do some lockups for us on the 18 six panels at the site.
And that started how long ago, 19 Claude?
About a month ago.
And I am curious if the 20 panels you're referring to are the same panels that we 21 requested.
That's all I am asking.
22 A.
I don't know.
There were more than six.
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know that.
2 Q.
Oh, there were?
It must have been some' thing 3
different.
4 Who did you speak to that told you about 5
these panels in the DBA and the DBA testing that was 6
being done?
7 A.
I would assume it was and-8 MR. WATKINS:
Could we take a two-minute break 9
here?
10 (Whereupon, there was a short break 11 taken, after which the Statement 12 was resumed as follows:)
13 BY MR. HAWKINS:
14 Q.
Okay let's start up with statement 7.
15 "Old Phenoline 305 (between one and two 16 years old) is being topcoated with new Phenoline 305 17 with little or no surface preparation (solvent wipe).
18 Did you personally observe the 305 being 19 topcoated with new 3057 20 A.
No.
Not that I know of anyway.
21 Q.
So that was again based on conversations with 22 Q.C.
Inspectors?
COUNTY COURT REPORTERS, INC.
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1 A.
That's correct.
2 Q.
To your knowledge, do the site procedures 1
3 allow it?
4 A.
I would assume they do, but I can't recall 5
offhand.
6 Q.
Do you know if any system qualification 7
testing has been done at Comanche Peak or anywhere 8
else to your knowledge, with a resulting system like 9
that?
10 A.
I'm sure there was DBA testing for the 305, 11 over 305.
My concern at that time was the surface 12 prep between the coats.
13 Again, I point out that Comanche Peak 14 people told me that they have a letter on file saying 15 that that was inadequate.
I 16 Q.
Okay.
17 So, what did they tell you in November?
]
18 Did they tell you they were having some solvent wipe i
19 down for surface prep, or what exactly did they tell j
20 you?
i 21 A.
I had asked them what type of surface 22 preparation was performed between the old coating 1
i COUNTY COURT REPORTERS, INC.
714 Nanervi11e Dd..
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that's on the dome and the new coating that's applied 1
2 and that's what their response was.
3 Q.
What?
4 A.
Well, that evidentally what their response 5
was that the old coating was solvent wiped.
The new 6
coating is applied.
7 Q.
All right.
8 Was it a full -- was the dry film on 9
that original coat bf 305, was it up to snuff, or was 10 it 11 A.
Something I didn't pursue.
12 Q.
You don't know if it was a repair area or 13 something that had been 14 A.
No.
15 Q.
Okay.
16 And you kind of dropped it after they 17 told you that say, look man, we've we got this letter; 18 and you didn't really pursue it any further?
19 A.
I wasn't aware of the letter until November 20 10th.
21 Again, I did not see the letter.
I have 22 just been told it's a file and it addresses this area.
COUNTY COURT REPORTERS, INC.
219 Nacervillo Rd..
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Q.
But you did not pursue it any further than 2
that?
3 A.
No.
4 Q.
Would you care to tell me what your past 5
experience has been in that type of application with 6
the old Phenoline?
7 A.
The same situation with the CZ #11.
8 I really don't want to get into any more 9
speculation than I have.
10 MR. HAWKINS:
All right I don't have any more.
I 11 Claude?
l 12 MR. JOHNSON:
No.
- i 13 MR. HAWKINS:
Why don't we go onto eight?
14 BY MR. JOHNSON:
15 Q.
Okay.
Statement of eight.
16 "This trip was not as productive as the 17 writer had hoped.
Often the writer felt that B & R 18 wanted to buy the "right" answer --
19 Let me ask you this, is that TUGCO or 20 Brown and Root?
21 A.
That is TUGCO.
I was mistaken.
22 Q.
Okay.
Correction.
Often the writer felt COUNTY COURT REPORTERS, INC.
714 Nanarv411. na wk..*an er snio7 is19s cas scos
56 1
that TUGCO wanted to buy the "right" answer.
2 This is substantiated to some extent by 3
the fact that they did not try to utilize the 4
expertise and/or experience of the writer with regard 5
to Quality Assurance / Quality Control, and the attitude 6
of TUGCO management (especially Quality Assurance)"
7 What do you mean when you say TUGC0 8
wanted to buy the right answer?
i 9
A.
I come back to what I said earlier, in that I 10 had expressed some concerns and very little time was 11 spent on what I thought were at the time significant 1
12 concerns.
13 I at the time was under the impression 14 that Cannon and myself were brought into identify 15 areas.
I identified those areas, and little time was 16 spent discussing them or following up on it.
17 Therefore, I felt that again, at the 18 time, I have since subsequently changed my mind to 19 some degree; that when we pointed out these concerns, 20 people don't want to hear it and did not pursue it.
21 Q.
So you are saying since that time, your 22 opinion has somewhat changed about this, since this i
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last meeting with TUGCo?
2 A.
Yes.
I again repeat that on November : loth, 3j and did make it very clear.that 4
they are concerned with the quality of the work 5
on-site, not only in coatings, but any area, and that 6
they seemed sincere about it when they talked about it 7
own November 10th.
8 MR. JOHNSON:
Do you have anything, Frank?
9 MR. HAWKINS:
No, I don't have anything.
10 BY MR. HAWKINS:
11 Q.
We will move on to 9.
I am reading from the 12 August 8th trip report again.
13 "If O.
B.
Cannon tries to obtain a 14 contract on this site the writer would suggest that it 15 be a rework contract because it will be impossible to 16 salvage what work is currently in place."
17 That's a pretty strong statement.
What 18 did you mean by you feel that rework would be 19 necessary?
20 Do you believe or did you believe at one 21 time that all the coatings work,that's been done there 22 to date is unacceptable, and if so, why?
COUNTY COURT REPORTERS, INC.
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1 A.
Once I had written that trip report, I based 2
that statement on what I thought were legitimate 3
concerns at that time.
4 0.
Which is what we have discussed here earlier?
5 A.
That's correct.
6 Based on that, if you had new tracing of 7
the coating material, if the documentation was not 8
adequate, that type of thing, the coating on the 9
surface would not be acceptable.
And as a result of 10 that, you would get into a situation where you would 11 try to backfit or somehow make the coating on the 12 surface acceptable through destructive testing.
13 And some areas may be acceptable, some 14 areas may not be acceptable.
That type of thing.
15 It's easier from a production standpoint 16 to go in and rework a whole area sometimes, rather 17 than go in and try to save spots; a couple square feet 18 here, a couple square feet there.
19 Also from a documentation standpoint, 20 it's easier just from the documentation that you 21 remove it all and just reapplied it as rework.
What 22 were the records on the did he coating that you saved.
COUNTY COURT REPORTERS, INC.
714 Nanprvillo Rd..
Wheaton. T T.
601R7 (117) 6%3-1622
59 1
That type of thing.
It's just easier to do the rework.
2 Again, that's not Cannon's opinion.
3 It's my opinion and not Cannon's, necessarily.
4 Q.
Are you familiar with any of the l
5 re-inspection that they are doing on-site now with 6
regard to coatings work, completed coatings work?
7 A.
From what I understand from the November 10th 8
meeting, the retrofit program was instituted.
It has 9
since stopped because of statistical analysis of the 10 results of that program.
But nothing I could fit into 11 the retrofit program, no.
12 0.
I get the feeling from this that you guys 13 were down there trying to solicit work on the site.
14 Is that 15 A.
No, that was not the case.
As a matter of, 16 fact, we are kind of booked up through next year.
17 At the time, one of the reasons why we j
18 did not put more people out of the Philadelphia office i
19 was the fact that we are extremely busy.
the only 20 Personally, I haven't spent
]
21 time I spend on Comanche Peak was a case like today, 22 where I have to.
Other than that, my time is pretty i
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well devoted to other areas of activity.
2 Now, I'm sure Cannon would'like to' do 3
work.
You know, we are in business to do work.
But 4
right now, we don't have the people, the manpower to 5
spare.
6 And that's something that I am not 7
really qualified to address.
You would have to 8
discuss that with or somebody else in that 9
area.
But our intention was not to solicit work.
10 Q.
We spoke about rework and under what 11 conditions it would be necessary.
Are the types of 12 problems that we discussed, we have discussed in the 13 last hour and-a-half or so, are those the type of 14 problems that you would feel would render the 15 acceptability of completed coatings work unacceptable 16 or indeterminate?
17 A.
What you are saying is that those problems 18 exist.
I don't know that they do from what 19 Q.
We are assuming now.
This is only 20 hypothetical, but I want to get some idea of your 21 perception of the importance of these things.
Had 22 they been correct, is it true that you would have felt COUNTY COURT REPORTERS, INC.
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that they would have represented something that would 2
have been so bad as to render the acceptability?
3 A.
You are ar, king a hypothetical question.
4 Q.
Exactly.
5 Hypothetically speaking The easy 6
way to ask that question is how important do you think 7
the problems were that you 8
A.
Well, what I am saying is I don't know that 9
they are problems any more.
From the explanation I 10 received, I don't know that they are problems.
11 Hypothetically speaking, if you had no 12 traceability of the coating material that was applied, 13 if the personnel applying the paint were not qualified, 14 if deficiencies were not documented, it would be real 15 hard to make the coating acceptable.
I mean I don't 16 know what else to tell you.
17 Q.
Okay.
That's fine.
l 18 But you don't have any indica' tion that 1
l 19 you don't what is your belief right now as of today?
20 I guess that's what I want to know.
What is your 21 belief today?
Are the coatings acceptable?
Is the 22 program acceptable?
Where are they there on-site, COUNTY COURT REPORTERS, INC.
219 Naperville Rd.,
Wheaton, IL 60187 (312) 653-1622
62 1
from what you know?
2 A.
Okay.
You are asking for a conclusion.
3 I would say that when I went down there 4
in July, I identified some concerns.
I listed those 5
in my trip report.
Subsequent meetings on-site, I got 6
the other side of the story.
7 People have seen, you know, you had a 8
problem here.
Here is how we are handling it.
If i
9 they are handling it the way they said they are 10 handling it, the problem or concern, then I would not 11 have a concern in that area.
I cannot prove 12 Q.
So what do you want us to do?
13 A.
I cannot prove one way or the other that they
~
14 are actually implementing what they
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15 Q.
So I am trying to decide where that leaves us.
i 16 Everything you say, you qualify if they l
17 are doing it or and then I have got to make a q
18 decision here on whether or not we need to go and look 19 at some of these things or not.
l 20 You say well, I hear this on one side, 21 but then they tell me they are doing that over here.
22 So you know, are you satisfied or aren't you?
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what I need to know.
Yes or no?
Don't qualify it.
2 A.
I can't qualify it.
It's not a yes or'no 3
question, or an answer, at least in my opinion.
4 I had one set of opinions.
I had 5
another set of opinions.
6 If they are doing what they told me they 7
are doing, my concerns are no longer valid.
I cannot 8
prove they are doing it; however, I would condition 9
that by saying that if they had the numerous audits, 10 both internal and external, and those audits were of 11 sufficient scope and depth; those audits did not 12 result in any significant findings, those would 13 substantiate what I was told.
14 0.
But you said you couldn't prove that they 15 were doing what they told you in November.
Can you,,
16 prove that they weren't doing what you saw in July and 17 heard in July?
I mean you have the same basis for 18 both conclusions.
That's where I guess my concern is.
19 A.
Well, I guess my concern here isn't carved in 20 stone.
21 Q.
Well, black and white anyway?
22 A.
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in November, you would have had two sets of opinions 2
there.
I would have said I was told by these 3
individuals that, and the list of concerns.
4 However, I was told by the site 5
management that these concerns are being handled in 6
this manner.
Essentially, I am not there to draw a 7
conclusion.
I made a trip report and other people 8
draw the conclusions.
9 This trip report was not meant to be 10 circulated.
It was meant for the President of t e 11 company and the Vice-President in Houston.
12 0.
Let me understand then.
13 You had concerns in July based on your 14 interviews and discussions with 0.C.
Inspectors and 15 the other personnel on-site.
Subsequently in Novembe.r,*)
you. >
16 you went back and the utility people sat down with 17 You discussed all those concerns in detail, and if 7
18 they are doing what they said they were doing, you 19 don't have problems any more?
20 A.
In a nutshell, that's correct, yes.
g 21 BY MR. JOHNSON:
2 22 Q.
I have got about two questions.
COUNTY COURT REPORTERS, INC.
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One is that were you aware that they had 2
a backfit program going on at the time of your 3
inspection?
They have had this backfit program going 4
on ever since you identified the problem.
Were you 5
aware of all this?
I 6
A.
I don't believe I was, no.
7 Q.
The next question I have is when you go out 8
and make a surveillance on a trip report, wouldn't you 9
substantiate most of your opinions here before you go 10 out and write that down like that?
11 It seems to me it would have been 12 substantiated right there before you left..With all
)
j 13 these problems identified, you could have 14 substantiated most of this without the November 15 meeting?
16 A.
Two things.
First, on that previous question 17 as far as the retrofit program, I may have been aware 18 of it.
If I was, I didn't go into any detail.
19 The other thing, as far as the trip
{
20 report, the trip report is essentially my observations i
21 and opinions as a result of that trip.
It was a j
22 three-day trip.
It's very hard, as I stated in there, I
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to come up with specifics in three days, two 2
and-a-half days, whatever it was.
3 That was a summary of my opinion of the 4
observations as to the President of my company for him 5
to make decisions or for what avenues Cannon should i
i 6
pursue; whether or not we should recommend to go down 7
there and do more work on a consulting basis or 8
whether it should drop.
9 Essentially, my observation was the trip, 10 and I wrote it and that was the end of it.
11 Q.
So let me get a good understanding.
So your 12 trip reports really are your opinions-and none of 13 these opinions are substantiated before you leave the
~
14 site?
15 A.
In some cases that's the case, yes,.
In'this 16 case it was.
J 17 On other sites and other projects, we 18 spend more time, or it's easy.
Easy is a bad term, 19 but you can substantiate comments before you put it in i
20 the trip report.
21 Q.
Okay.
22 So most of these comments were not l
i i
COUNTY COURT REPORTERS, INC.
219 Naperville Rd.,
Wheaton, IL 60187 (312) 653-1622
67 I
substantiated, is what you are telling me?
I 2
A.
Most of them were based on conversations, yes.
3 0.
All right.
4 BY MR. HAWKINS:
5 0.
Do you expect anything of us in regards to 6
these concerns that you have expressed?
7 A.
Well, other than from what I understand from 8
and that I will be getting a J
9 copy of your report when it becomes public knowledge 10 and a copy of the sanitized memo of if 11 and when that becomes public knowledge or public 12 record, no.
13 0.
How did you get a copy of that?
~
14 A.
met me, I believe the afternoon 15 of November loth, to discuss the confidentiality.
And i
16 during the course of that conversation, I was allowed 17 to read that memo.
18 0.
All right.
19 But you don't have a copy of it?
20 A.
No.
I was not given a copy of that memo, no.
21 0.
So you really don't expect anything specific 22 of us in regard to these concerns, other than just
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68 I
when we are finished with our investigation.or our 2
inspection down at Comanche Peak, you want to see the 3
results of that?
4 A.
With regards to the coating ' aspect, yes.
(
5 Q.
You don't have any expectations at all of us
>(
6 lo'oking into each item that you have flagged out here?(
7, A.
No.
That was not my intent to begin with.
8 0.
That was not your intent?
9 A.
No.
10 MR. HAWKINS:
Well, I don't have a. thing more to 11 talk about, really.
12 Do you all have anything you want to say 13 in conclusion?
14 MR. WATKINS:
Do you have anything to add?
15 THE WITNESS:
No, other than I am still a little 16 bit I guess in a gray area as far as 17 You are saying that ! should not discuss-5 18 that released a copy of my trip report, 19 regardless of how he obtained it?
20 MR. HAWKINS:
I don't really know what to tell you 21 on that.
I really don't.
22 THE WITNESS:
See, I don't want to^get into any l
COUNTY CO,URT REPORTERS, INC.
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kind of a conflict with the N.R.C.
as a result of this.
2 MR. HAWKINS:
I don't believe you will have'any Oh 3
problem with me.
You'll probably have to talk t o AdQf-4 and get some.
From them.
5 THE WITNESS:
So until I get some kind of an 6
opinion from you guys, I should not discuss how my 7
trip report got in the N.R.C.'s hands, or at least the 8
individual that delivered it?
9 MR. HAWKINS:
I will just leave it up to you.
I 10 have no idea what to tell you.
11 Logic tells me that if you want to go 12 ahead and discuss it, discuss it.
13 THE WITNESS:
One thing, the legal aspect I don't 14 want to get into.
15 MR. HAWKINS:
I guess the safest way is to not i
~
16 discuss it.
And I would say that I guess that's 17 probably the best thing to do.
But I will leave the 18 decision to you.
19 THE WITNESS:
Again, the other thing with this 20 trip report, just in summary.
I guess I didn't really 21 tell you people this, but that was based on a very 22 short trip, without any time to substantiate what my 1
l l
COUNTY COURT REPORTERS, INC.
219 Naoerville Rd..
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70 1
concerns were.
2 If I was able to substantiate it, I 3
would be more definitive in that report.
If you read 4
the wording, it's not a definitive report.
5 MR. WATKINS:
Would it be fair to say that had you 6
spent a lot longer period of time on the site, your 7
conclusions might well have been different?
8 THE WITNESS:
That's correct, yes.
Had I gone 4
9 through an in-depth review, I would have been able to 10 write a completely different report than what I have 11 written.
12 MR. HAWKINS:
All right.
Ready to conclude?
Okay.
13 We are off the record.
That's it.
14 (Which were all of the j
15 proceedings had and testimony 16 taken at the Sworn Statement 17 of the above-entitled cause.)
18 19 20 21 22 COUNTY COURT REPORTERS, INC.
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71 STATE OF ILLINOIS
)
)
SS.
COUNTY OF DU PAGE
)
I, GLORIA APOSTOLOS, C. S.R., No tary Public duly qualified and commissioned for the State of Illinois', County of DuPage, do hereby certify that I reported in shorthand the proceedings had and testimony taken at the statement of the above-entitled cause, and that the foregoing transcript is a true, correct and complete report of the entire testimony so taken at the time and place hereinabove set forth.
! I' l
l lbtr OdCP):d.l CERTIFIED SHORTHAND REPORTER NOTARY PUBLIC My Commission expires March 30th, 1987.
.. _ _ _