ML20237L431
| ML20237L431 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/24/1986 |
| From: | Hale C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20237F760 | List:
|
| References | |
| NUDOCS 8708200219 | |
| Download: ML20237L431 (86) | |
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3 Uh11tv STATES l l
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NUCLEAR REGULATORY COMMISSION 1 i
IN THE MATTER OF: DOCKET NO: .
1 INVESTIGATIVE INTERVIEW
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LOCATION: GLEN ROSE, TEXAS PAGES: 1 - 84 l
l DATE: THURSDAY, JULY 24, 1986
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ACE-FEDERAL REPORTERS, INC.
I Repor*rs 4u captoiseme
'/Mm iuu, D.C. 20001 870B200219 B70819 g 3c m DR ADOCK0500g5 NATIONWIDE CC Attachment N 4
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l SWORN STATEMENT 9E CLIFF HALE July 24, 1986 1
i NRC Region IV Trailer Comanche Peak Steam Electric Station Glen Rose, Texas 9:30 a.m., C.D.T.
c TAKEN BY: George Mulley
{ REPORTED BY: R. Patrick Tate TATE REPORTING SERVICE, (713) 222-7177
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l 1 CLIFF HALE 2 called as a witness, having been first duly cautioned and 3 sworn, testified upon his oath as follows.':
4 EXAMINATION 1
5 By Mr. Mulley: !
l 6 Q The time is 9:30 a.m. The date is July 24th, i 7 1986. We are at the NRC trailer at the Comanche Peak Steam l l
8 Electric Station in Glen Rose, Texas. Present are l 9 Mr. Cliff Hale who's a project inspector with Region IV, 10 Nuclear Regulatory Commission; myself, George Mulley, and 1
11 I'm the Assistant Director for Investigations, Office of l 12 I'nspector and Auditor, Nuclear Regulatory Commission; Steve 13 Goldberg, who's a technical advis'or to the Office of 14 Inspector and Auditor, and Mr. Pat Tate who's the court 15 reporter.
16 We're here today to discuss with Mr. Hale, his 17 involvement with several NRC inspections done by Region IV 18 at the Comanche Peak Steam Electrical Station, and also to 19 obtain from Mr. Hale information concerning Region IV's 20 regulation of Comanche Peak project.
21 Mr. Hale, before we begin, could you give us a 22 resume of your background here at Region IV?
23 A At Region IV?
! 24 0 Yes.
25 A I joined Region IV in 1974 as chief of the TATE REPORTING SERVICE, (713) 222-7177
. I 1 section in the vendor inspection branch that dealt with 2 inspections of NSSS and A/E organizations.
3 I stayed in that capacity until June of '84, and 4 transferred into the Division of Reactor Projects in Region 1
5 IV and was detailed to the technical review team on site at 1
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6 Comanche Peak, and was assigned to the QA/QC group, working l 7 under the lead of Tom Conlan and then Herb Livermore.
8 I served in that capacity until about June of 9 1985, then was assigned to the Comanche Peak task force to j r
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10 evaluate the implementation'of the CPRT program plan which i i
11 was being performed by the utility as a third party effort !
12 to address the issues raised by the TRT, and other 13 organizations. Since that time, I have been charged with 14 the responsibility of QA/QC issues and have acted in that 15 capacity.since about July, June or July, of 1985. And 16 that's been my activity in Region IV to date.
17 Q In this capacity, have you worked closely with 18 Tom Westerman?
19 A To the extent that he was the , chief of this task 20 force for a period of time, I have, yes.
- l 21 Q Okay. Has Tom ever asked you to review 22 inspection reports to get input from you concerning the 23 validity of the findings and to make sure that the findings 24 were accurate?
25 A If there was a QA/QC issue of that sort, he's TATE REPORTING SERVICE, (713) 222-7177
l 1 asked me to comment on reports, yes.
2 Q okay. When he asked you to comment, is this done 3 without prompting or just a straight objective --
4 A He would hand me a report and ask me to look over 5 the findings and see if I nad any comments on the findings.
6 Q Do you recall inspection report No. 85-07/057
- 1 7 A Not by the number. j 8 MR. MULLEY: Let's go off the record for just a 9 minute.
10 (Discussion off the record) 11 MR. MULLEY: Steve, would you please review the 12 issues on this inspection report for Mr. Hale.
l 13 Q (By Mr. Goldberg) Yes. There were several 14 issues and I will just enumerate what they are. First one 15 involves the reactor pressure vessel.. And there were two i 16 issues involved there. One was the_ audit of the reactor I 17 vessel installation issue, and related to that is thu l l
18 traveler written or travelers written associated with the 19 changes in the instp11ation of the reactor vessel. Were ;
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20 you involved in any of that? '
21 A I was not asked to review that report with those 22 issues.
23 Q An issue involving the identification of the 24 spool piece?
25 A No.
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1 Q An issue involving the CMTR report for the piping 2 sub-assembly?
l 3 A Not from a review of the report. I have heard L 1 j 4 some discussion, but I wasn't asked to participate in that. J 5 Q okay, and the last one is the audit or a QC j 6 report associated with the concrete mixer blades? f
- I 7 A No.
8 Q okay.
9 Q (By Mr. Mulley) What issues did you overhear 10 concerning the --
l l 11 A It was.in the context of a meeting and I don't 12 recall who was present at the meeting now, but it was 13 discussing the issue on the spool pieces being, as I l
14 recall, being tested -- testing being required by the 1 15 vendor prior to shipment to the site.
16 And what I recall from that conversation was that i 17 Ian Barnes had stated that this is not normally a j l
18 requirement of a vendor, and certainly was not a 19 requirement of the code. And it seemed foreign to him. ;
20 And someone else had said - .then we talked with Bosnick, 21 in NRC headquarters and he had confirmed that statement 22 that Ian had made. And that's just what I over heard.
23 I was just in the meeting, overheard that 24 conversation, and that's the only reason I would be 25 ' familiar with that even, but was not involved in any way or TATE REPORTING SERVICE, (713) 222-7177
I 1 asked to comment in any way on that.
2 Q Also as*part of that inspection report was a 1
3 trind analysis that had been completed by Mr. Phillips
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. 4 under the direction of Mr./ and Mrl- !.
h *: : h :r l *, ;;._. l'.:{! Are you i
5 familiar with that at all?
. 6 A shannon had asked -- well, he had showed it to 7 me, I guess, is probably a better characterization of it, i 3 at one time. Therewas\ someone from headquarters on site 9 and I don't even - I don't know how the discussion came to l 10 it, but anyway, he had givon it to me to look'at'and I
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11 looked at it and that was a ut theLextent'of_.-thiitt. .;. 3 12 Q As to the inclusi n or taking the trend analysis 8
13 out of the inspection repor$, you hav\
e knowedget.. ,
14 A 350, huh-uh. c~
15 Q Let',s then.go on.to inspection report _ ,.._..
16 85-14/11. onbe$iik$h,l Steve,wouldyoureadthoseisSees?lo#
17 nr. sale.
18 MR. GOLDBERO: Yes, let me just give him a copy 19 of one of the - oes of the. w.. .,es of the' report.
copi.
20 okay, let me read the areas that you would'be 21 looking'at. There's several of them, so you want me to do 22 it all at'once George, or do it.1 individually?
23 MR. MULLEY: Yeah, do it --
(. 24 MR. GOLDBERG One by one.
25 MR. MULLEY: one by one. .
TATE REPORTING SERVICE, (713) 222-7177
7 1 Q (By Mr. Goldberg) Okay, the first one is the 2 FSAR does not describe TUGCO's record system. Mr. Hale, 3 are you familiar with that issue? T h i's - - m a n y m a n y i s s u e s 4 involving QA records.
5 A Yes, yes, I was involved in discussions with 6 respect to the QA record system on site. Yes.
7 Q Do you want to give us -- I think it would be 8 better to back up and give us the context of how you got 9 involved in this and what your involvement was.
10 A okay. It wasn't a review of the report, it was,
! 11 I think, discussions of the propriety of findings dealing l
12 with handling of records being shipped off site. As I 13 recall, it was records on pipe support, or pipe design i
14 analyses being shipped to Stone & Webster. And I don't 15 know if it's the same report or if it's a different
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16 subject, bu't there was also some discussion about CB&I 17 records being shipped off site for reproduction.
18 Some discussion also about the design of the 19 records facility, discussions about, you know, when a -
i 20 record becomees a record and when it is a record, and when 21 it's subject to the requirements of the standard. Yes, 22 quite a few discussions at different times concerning that 23 issue, but not the review of a report per se, but 24 discussions of findings, yes.
25 Q I think what we might do is go over each of these !
TATE REPORTING SERVICE, (713) 222-7177
8 1 issues and get some of your reaction to how you would --
2 how -- if I were presented with these issues, how would i
. 1 3 you -- how you reacted to those issues. !
4 A Sure.
-l 5 Q okay, one of them -- I'm going to jump down to l l
6 the first one you mentioned, TUGCO failed to have or use j l
7 procedures to control shipment of original records to Stone j i
8 & Webster which at the time was interpreted to be a i
9 violation of criteria 5.
10 And related to that issue is: The original 1
11 design records shipped in cardboard boxes without making a l 12 backup copy, and that could have been a violation of 13 criteria 17. Why don't we start with that one? Did you 14 get presented with that issue at all?
15 A I was asked my opinion on that. And I suppose 16 that you would like my opinion or what kind of'information 17 I gave back --
18 Q Yeah.
19 A -- so I'm going to give it to you. First off, I I l
20 was not -- wasn't involved in nor did I know the absolute 21 facts associated with this issue. So all I could take was 22 what was presented to me. These were' original design 23 records.
( 24 Well, to me, that has a very definite and precise 25 ' meaning which I do not think applied to these records, to TATE REPORTING SERVICE, (713) 222-7177
9 1 these documents, anyway. Original design records would be
'2 something that was in the vault, subject to the controls of 3 ANSI N45.2.9. That would have had to have been removed 4 from the vault and shipped off site. Being removed from 5 the vault, there should be -- and I don't know if there is 6 but there should be -- procedures in place on site to 7 control the removal of records from the vault.
8 But my interpretation of ANSI N45.2.9 is that 9 when records are removed from the vault without that l 10 control, they're no longer records; they become in-process 11 documents, and are not subject to the same kinds of 12 controls that were required by 2.9 or Crit'eria 17, either.
13 So they would be design re" cords that are just 14 being moved from one location to another. And if something' 15 occurred to those records, that they were lost, destroyed 16 or in some other manner misplaced, they would have to be 17 regenerated at some point in time.
18 So my feelings with respect to that finding is 19 that there was not a violation. It was yery poor judgment 20 and a very risky thing on the part of the utility to do 21 that.
22 'But I could see no violation based on information 23 I had of either -- certainly of Criterion 17, and perhaps 24 there may have been a violat' ion of Criterion 5 if some 25 procedure, site procedure, would have prohibited that sort TATE REPORTING SERVICE, (713) 222-7177
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10 l 1 of handling of the records.
2 Q Now, in' terms of putting them in cardboard-boxes i
3 and shipping them oft site, in terms of accounting for that 4 by TUGCO, if there were no procedures, are you saying.that 5 they would be proceeding at their own risk, they would be.
6 in-process records and now everyone's.at their own risk.
'7 A That's the way I would perceive that, based on 8 what I understood with respect to this issue. It's not 9 unlike a document that would be in Gibbs.& Hill's hands-on 10 site that was a developing design'that had to be shipped 11 back to New York, their New York office, for some review or
, 12 some additional work. It's not a record. It's an ]
l l 13 in-process document. I l
14 And in the absence of a violation of a procedure 15 that would say you must process this document in this' )
16 manner, there would be no violation with respect to a l
l 17 Criterion 17 which deals with records, t
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18 Q In other words, something that was stored in the 19 permanent, in the records center or the, permanent. records 20 vault, whatever we call it, and is removed, you know, in 21 your interpretation is no longer a permanent record but 22 becomes an in-process record? 1 i 0.
gs 23 A Depends on how it's removed. Now, there are 3
( 24 provisions, procedural provisions that are required-for the t n 25 removal of records from a permanent vau'lt. These vill vary _ 1 '"
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11 1 in many different ways, and I do not know what they have 2 in place at the si~te. But it could be that.they can only 3 remove a copy; could be that they've got to sign in blood, 4 as it were, when they take that out and that document must 5 be then reevaluated, reassessed and reprocessed when it 6 goes back into the vault, otherwise it's not a record when 7 we take it out. It's a document that they have said, " Wait 8 a minute; we put the this in prematurely, we've got to take 9 it back out, we're not through with it," so it's an 10 in-process document now. l 11 Q Based on what it was used for at Stone & Webster, 12 you are interpreting they're going to do more work on these 13 design cales, for example? ;
14 A As I understand the work that Stone & Webster is 15 going to do with those documents, to me, they classically 16 fall into the category of an in-process document. They're 17 either -- they're reanalyzing or performing the analysis l
l 38 over again on these pipe supports or they're verifying, 19 confirming, the analysis that exists. .
20 In either case, the document is, you know, it's l 21 an in-process document again. That document that was 1
L, 22 shf.pped to Stone & Webster may not be a plant document, a l
i' 23 plant record when it's completed and comes back; it may be
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24 an altogether different document.
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25 C And what will happen to it once it is changed; I
l TATE R.TPORTIMG SERVICE, (713) 222-7177 l
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. i 12 1 will the material that's shipped up will be -- could be !
2 destroyed if --
3 A It could be. It could be. There's n'o 4 requirement that a, you know, that a superseded document' 5 such as that, anyway, be retained. Most organizations, and j 1
6 I would imagine that this site is the same way, retains 7 revised versions of drawings and analyses and that sort of 8 stuff, while even though there's no -- there's no 9 regulatory requirement to retain those type of documents.
10 0 So interactions of design calculations are not 11 required in your way of --
i 12 A The way I interpret the appendix and the ANSI j i \
13 N45.2.9, revised analysis and drawings are not. As bu,ilt j 14 drawings, final analysis, are. The only thing I can think 15 right now that you retain as part of that Appendix A in 16 ANSI N45.2.9 are revisions of procedures. !
l 17 0 What about design inputs?
18 A The design inputs are retained. But if they are 19 revised, the same -- well, Appendix A is,.really silent on 20 those things. And certainly you could interpret it and it 21 would be very hard for a regulator to enforce someone to 22 retain prior versions of design inputs, or prior versions 23 of design drawings or analyses, either one.
i 24 Q So the-bottom line in this discussion with Stone :
25 & Webster is that because of the nature of the records and TATE REPORTING SERVICE, (713) 222-7177 l
13 1 its removal frem the storage area, the vault, the utility 2 was proceeding at'its own risk relative to the cardboard I 3 boxes issue, the inventory, maintair.ing duplicate copies, 4 that kind of thing, in your mind, it's sort of outside the 5 bounds of a regulatory requirement?
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6 A It 's i with respect to criterion 17. As I said 7 earlier, if there was a virlation of a procedure, then 8 there could still be a violation there with respect to 1
9 Cr.iterion 5.
But the procedure would -- now one would have 10 to find precisely where'a procedure had been violated. But 11 Criterion 17, I do not see that these are records.
12 They are now documents. And that's probably --
13 you referred to them as records a minute ago. And I think l 14 of records as those documents subject to Criterion 17 or as 15 industry has adopted and the NRC has sanctioned the ANSI 1
16 N45.2.9 requirements. All other items are documents that 17 are not records, is the way I have divided them in my own i
18 mind anyway. I 1
1 19 Q If these were records, we'll get to the next set l l i
- 20 of records, but if these were records that were not design ]
1 21 cales but they were procurement, procurement records, i J
4 22 records that would not be changed, and they were removed I 23 from the storage area, would it have been -- would you have 24 viewed in differently? ,
i 25 A As in the case of CB&I? I l
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14f e 1 Q_ Maybe,the CB&I would be a better example of this.
2 A -There are procurement. documents on site right'nowL
,3 that are in a myriad of places and locations. .I do not' 4 view these as QA records. They are QA documents subject to 5 controls, say of criterion 6, and subject to procedural 6 control.s that would preserve and protect these during this .
7 processing.
8 But until they are a part of the records system 9 that has been established.by the utility, and they have a 10 " records administrator and a records custodian, once-that 11 document becomes a responsibility of those individuals, 12 then 2.9 applies. Untii'that time, 2.9 just doesn't apply.
13 Q In the state of the plant, do they have records i
t 14 custodians and records managers right now that control 15 records?
16 A They certainly should have. Now, I have not 17 looked at the records systems personally, myself, on. site.
18 So I-can't say absolutely that they do. But the 19 regulations require that they do, so I would say yes, they 20 have. .
21 Q Maybe we'll go on to the Chicago' Bridge & Iron.
22 If you have any questions, Goerge --
23 MR. MULLEY: I just.have a general sorts of L i 24 question.
25 Q (By Mr. Mulley) These in-process records, are TATE REPORTING SERVICE, (713) 222-7177 l .
15 1 they protected while on the site in temporary s'torages or 2 is there any requi'rement to protect them?
3 A No. The requirements are to control them. Now, 4 to the extent that this control protects them, th'y're e 5 protected. But I think the philosophp of both the NRC and 6 perhaps the standards committees, was that these type 7 documents, while they're important and they're necessary 8 and are eventually going to become recoeds for the plant, 9 one should take, you know, take prudent care of these. But- 1 10 there's -- they're just not records at this point in time.
11 I guess their philosophy is that if something I
12 happens to them, they can regenerate this record. And to 13 prevent that, that's why they have the control that is 14 designed, certainly to preserve and protect these records.
15 'But it's a system that's established,'I feel usually, under 16 Criterion 6 of Appendix B.
17 Q okay. So if these records, until they become, as 18 you say, documents at the very end --
19 A No, the other way around.
20 Q These documents, until they become records --
21 A At the end.
22 Q -- at the end, while they're here on site, 23 there's no requirement to keep them in a building that's 24 fireproof or anything like that?
25 A There's no regulatory requirement.
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16
! 1 Q You say there is requirements towards controlling 2 the records?
3 A Yes.
I 4 Q When you say " control," do you mean access to 'he 5 records by people?
l 6 A In some cases, that's true. In some cases you l
l l 7 have a whole set of design calculations that are in 8 looseleaf binders in a book case in a bullpen area where l 9 the engineers are, accessible to anyone in the engineering
! l'0 organization and anyone walking in. ;
I 11 There have been occasions that we have obtained l l
12 documents from the utility that will ultimately be records l 1
13 and brought them over here to the trail'er unescorted or 14 anything else, that we have used and then returned to them.
15 If we had not returned them and we had lost them over here, 16 the utility would have had to regenerate that record.
17 0 What about the temporary storage of these 18 records; is that -- is that done here on site?
19 A Are you talking about records,,. temporary-- you 20 said " temporary storage of records."
21 Q Of documents.
22 A' Of the' documents? There's -- well, I don't think 23 you'd call it temporary storage.
- 24 There are places, there are places that 25 accumulate these documents that have these documents TATE REPORTING SERVICE, (713) 222-7177
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i 1 accessible, like the docus.ents control center is a place 2 that you can obtain a. copy of just about any document on I l
3 site, 4 There are other areas that you can pick up
- 5 procedures and revisions to procedures of any procedure on 6 site.
7 There are other places where you can find 8 travelers, inspection reports, all kinds of documents
! 9 dealing with those activities and they accumulate. But 10 this is a part of, you know, th'e document control system 11 that controls these kinds of documents that will ultimately I i
12 be records.
13 Q I guess what I'm driving at, in any area.where 14 these records -- these documents --
a -
15 A Thank you.
16 Q Any area where at least documents are, you know, 17 gathered together as a' group, for example the document 18 control area, are there any requirements towards there 19 physical protection of these dt- ts while they're 20 together? -
21 I can understand -- and I don't know the answer 22 to this, but I can understand where you're' talking about 23 taking an isolated document away that there's no 24 requirement because they might not be that difficult. But 25 when you're talking about boxes of these documents TATE REPORTING SERVICE, (713) 222-7177
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i together, are there any requirements as to the physical s
2 protection, when they're put together?
3 A I'll give you an example. The document control l l
4 center, which is,'I guess ,the repository of all documents i l
5 on site, and even documents that are records, copies of !
6 these documents have now become records and are in the
- 7 permanent vault. They have access controls to that -- to 8 the area where they're stored. If someone needs copies of
- 9 some of these documents, they fill out forms and all they ;
1 i
10 get is a copy, they don't get the' original record, and 11 that's probably something else that is not uncommon at this i
12 site.
I 13 For example, drawings, the originals are not kept 14 in the document control center. The velums as they revise l 15 and approved and issued, come to the document control 16 center, they make copies of these velums; that becomes the 17 working revisien of that document, the velum goes back to 18 engineering then. And so copies of these are provided.
19 But the original document or the effective 20 document is preserved as well as revisions, those are 21 preserved in the document control center.
22 Two years ago, I could have told you the kinds of 23 controls that one would -- that they had with respect to
{ 24* removing dccuments from the document control center. I 25 can't do that now. But as I recall, there are controls l
TATE REPORTING SERVICE, (713) 222-7177
19 1 deal with the removal of documents. For example, like the i
2 Stone & Webster calculations may have been taken out of the 3 document control center and shipped. But I think'in the 4 case of the calculations, even, they were probably not in I 5 the document control center in the first place. They were 6 more likely in a book case in engineering. )
7 Q But as far as the document control center, 5
1 d itself, is there any requirement that this document control j 9 l center be in a fireproof building -- !
10 A No.
11 0 -- that the records be in fireproof boxes, 12 anything like that? 1 13 A None that I'm aware of.
I 14 Q (By Mr. Goldberg) Okay, let me go on to the 15 Chicago Bridge & Iron issue and I'll go back to an issue 16 you had raised just a few minutes ago.
17 The Chicago Bridge & Iron records were not design 18 cales, as we understand it, and the issues here is: Site 19 records of Chicago Bridge & Iron were shipped to Houston in 20 cardboard boxes, the original subjected to little 21 protection without retaining backup copy, and also TUGCO 22 failed to inventory the Chicago Bridge & Iron records sent 23 to Houston therefore they cannot determine what are the 24 records that must be returned, and TUGCO -- let's 25 see -- okay, that's that one.
l That's the issue with I
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20 l Chicago Bridge & Iron. Can you give us some comments on 2 that?
3- A To the best of my understanding'on 'this issue, 4 here, this subject or this condition is further removed 5 from question and regulatory requirements than the' Stone &
6 Webster records were. 1 7 As I understand, these documents were CB&I -
8 documents, controlled by CB&I site personnel, that CB&I was 9 turning'over or in the process of turning over to the 10 utility in accordance with the terms of their contract or 11 the procurement documents, and were being shipped back to 12 their -- to their Houston office, as I. recall, for
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13 reproduction, inventory and transmittal to the utility. So ;
I 14 they certainly would'not be classed as a site record, !
i 15 subject to 2.9. It even more classically an in-process )
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16 document. l 17 Q What about CB&I's QA program, could it that their i 18 problem might be the compliance with CB&I's QA program for 19 records control?
20 A Well, document control, not records control. It 21 could have been, but I doubt that that would be the case 22 either because this is an -- they have to have provisions 23 to do exactly what they did. There's some code
( 24 requirements that certain documents be retained by the 25 ' vendor,.while the procurement document may also require TATE REPORTING SERVICE, (713) 222-7177
. 21 1 that they provide these same documents to the utility.
2 So that'would mean the code requires the vendor 3 to retain certain documents and the procurement documents 4 said, "We want copies of those documents as well."
5 Q Well, the other aspect to it is going back to 6 Criteria 1, which is that the utility retains 7 responsibility for all work that goes on site; for example 8 work done by CB&I and consultants.
9 How do you view that, the retention of 10 responsibility by the utility? Does that include their 1
I l 11 establishing procedures for control of records, control of 12 documentation as generated on site'?
13 A Well, CB&I would have been a contractor or a l 14 vendor of the utility. And certainly, Criterion 1 permits 15 the delegation of certain of these kinds of 16 responsibilities. And in the case of CB&I or any other 17 vendor, they have delegated the document control and all 18 other QA requirements to these organizations.
19 But with audits and surveillanges and that sort i 20 of thing, assurances that a program is in place by this 21 vendor prior to placing a contract with them and periodic 22 audits and surveillance during the course of that <
23 contract. So it's not a -- it's not a relinquishing of 24 responsibility, because they do retain the responsibility.
25 But they have delegated this under their surveillance.
TATE REPORTING SERVICE, (713) 222-7177
22 1 Q So you interpret the retention of responsibility 2 to be the periodic audits, the surveillance that go on, as 3 opposed to TUGCO establishing procedures for control of 4 CB&I records?
5 A well, even more than that. The retention of the 6 responsibility is, when CB&I has finished the, the utility 7 is responsible for the work CB&I did. And the records that 8 the utility ends up with has got to. support and provide an 9 auditable trail of the work that'CB&I did based on the 10 records that are turned over to them, and the records that 11 the utility may have had in their interfacing with the 12 vendor.
13 Q Should TUGC0 be interested at all that the site 14 records of CB&I may have been shipped in boxes, cardboard 15 boxes with little protection? .
A 16 A That's kind of a two-fold concern there. First 17 of all, no, they need not be controlled. Their contract 18 would not have been completed had these records not been 19 provided if something had happened to them. ,
So it's a CB&I l 20 problem. If something happens to those records, CB&I is 21 going to have to regenerate those records. It becomes a 22 utility problem, if they have violated some of their own 23 procedures in the way they handled the records. And that l
i 24 could or could not have been picked up by the utility in an l 25 " audit of them but CB&I also has a QA program which provides TATE REPORTING SERVICE, (713) 222-7177
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-1 internal audits themselves.
2 Q Isn't CB&I's problem TUGCO's problem ultimately?
3 A If you ended up without records,' it.would be a 4 problem for TUGCO, true. But the problem I feel like is 5 probably more CB&I's than it would be TUGCO's, because CB&I 6 is the one that now has violated their centract with the 7 utility.
8 I'll give-you an example of some things that we 9 observed during the TRT review that we had down here.
10 There were some allegations, and they turned out to be 11 factual,.that .the records did not exist for certain pipe
. 12 supports. And some of these allegations were found to have 13 merit to them. Some of the records were found and properly 14 protected. Others were not found.
15 In the case -- and I recall of two instances were 16 two pipe supports, the records supporting the construction _
l 17 and inspection of those pipe supports could not be found.
18 Those pipe supports had to be removed and reinstalled. So I 19 that's the risk that one ends up with. ,.
j 20 If CB&I indeed could not support with their i
21 documents the material and the work that they had provided, 22 then the consequences could be as bad as removing all the 23 work that they had done and doing it over again and 24 developing the records over again.
25 So in that sense, yeah, it's a concern of the TATE REPORTING SERVICE, (713) 222-7177
24 1 ut: . ity, but the concern is in time and CB&I is going to be 2 out the money unless there's some kind of recoverable means j 3 'which CB&I could reclaim some of their losses because of
( 4 their carelessness or violation of their procedures. ;
l I
l 5 Q Why don't we go back to the Stone & Webster l
6 issue, couple of things you said earlier. One was that They 7 these records were not in the permanent facility.
8 were out in the plant, they never became records. y i
9 Where were the records; where were these I 10 documents?
I 11 A I don't know.
]
l 12 Q Were they QA documents? !
(
i 13 A Yes, they were. We were talking about the,DCC, 14 the document control center. I do not believe that those 15 type documents are captured in the document control center.
16 Q Where would they be, then?
17 A More than likely where I have seen them in the 18 past, would be in the discipline areas, in the engineering l 19 areas where these analyses were performed.,
And I have seen j 20 numerous ways in which those documents are controlled in 21 those kinds of areas. I've seen where you check out 22 documents out of a controlled area, but that's more the 23 exception than the rule.
3 24 Normally you f.ind them in the mechanical lead's 25 ' area, he's got a bookcase with all the calculations and TATE REPORTING SERVICE, (713) 222-7177
25 l 1 they're just in looseleaf binders in those book cases.
2 That-is where the analyses are. When they finish, the 3 thing is sold off, then.those documents are moved over, 4 microfilmed or copied and become a record.
5 Q So you don't think the records we're talking 6 about with Stone & Webster have been yet moved into the 1
7 so-called records control area?
8 A I don't think they were. 1 9 Q okay. That's a fairly significant point, because 10 the other point you made was if they were and then removed 11 from that controlled area, then you said, I think earlier, 12 then 45.2.9 applies? /
Is that waht you said earlier? -
i 13 A When they're in the control of that records 1 14 center, 2.9 applies. When they're removed from that I 15 center, then either 2.9 doesn't apply if they.have ]
1 16 relinqui'shed responsibility for-them from the records '
17 center, they have taken them back out and they become 18 documents again; or if they have checked them out of the 19 recordscenter,thenprocedureswouldstjllhavetobe 20 complied with that controls these records when tbry're j 21 outside the control of the center.
22 Q But I point out to you the version I believe of 23 the plant is that under which is the 1973 version of J 24 45.2.9, there's a statement made there, I don't have it in 25 ' front of me, the control of records when removed from the TATE REPORTING SERVICE, (713) 222-7177
1 4 <
26 1 permanent storage facility. Now what'does that mean?
2 A' Well, that's what I tried to explain. earlier. I 3 Q What does that mean, " control," in your mind what 4 does " control" mean when you remove material from the 5 permanent' records facility? .!
6 A I've seen various ways in which-they control 7 these documents as they come out. The preferred way -- and-8 of course that doesn't buy much of anything.-- is that.the 9 documents are-not removed themselves, but a copy of the 10 document is released.
11 But when it's necessary to remove that' record.
~
12 from the facility, from the storage facility, then there 13 are signouts, there are means in( which that record is 14 verified that when it comes back into the' records center,-
) 1 15 it is the same record that went out or,'if'any changes have 16 been made, they have been authorized, they're authorized 17 changes; and in some cases, and these pipe supports may t
l 18 fall into that category, these documents have'to be 19 verified again by the code inspector. ,
l 20 Q What about the, just where,they were in fireproof 21 cabinets, when they're taken out of permanent records 22 storage to put them back in fireproof cabinets in these ,
23 areas where the work is going on in the plant? Would that
- - 24 be your concept of control?
25 A I don't know if -- I don't know if any of'the TATE REPORTING SERVICE, (713) 222-7177 l
- ~
27 1 procedures would get that detailed on what you do with them 2 while you have them out. There's usually the controls of 3 how.you get them out and how you get them'back fn.
4 Now, there are probably some procedures that deal 5 with how you handle these records when they are checked out 6 of the records center. I don't think that's a very common 7 thing that occurs. Usually most records centers will not 1
8 permit the record to be taken any further than the room l 9 next to them. .
10 This records center over here, any time that I 11 want to look at something over there, I've got to stay in 12 the record center to look at it. They won't let me take it 13 outside the records center, i
I 14 Now, there's probably provisions from remove them j j
15 from that and still maintain their designation as a j i
16 records. But I think more often than not when they take {
17 them out for something like that, certainly for a change, j 1
18 they relinquish the responsibility and they've got to go 19 through the same. process that they put into the storage a
l 20 facility in the first place when they bring it.back to go
]
21 into the storage facilities: A legibility review, a 22 completeness review, the whole --
23 Q But in terms, we're going -- this leads into the .
I l
24 next issue which is the comingling of permanant and 25 ' temporary. records. When it's removed from the storage l
TATE REPORTING SERVICE, (713) 222-7177
28 1 facilities which has it's'own environmental control, when 2 it's removed and taken out of that control and moved into 3 another area, are you saying that the utility can or cannot 4 or should or shoyuld not try to safeguard that record by 5 putting in it a fireproof fire cabinet or what kind of 6 - control are you saying? I'm trying to define your term 7 " control" that's N45.2.9?
8 A Well, I'd. almost have to get involved in f. hat 9 process, you know, to make a judgment on the. thing. I 10 think, first, I would question the removal of the record 11 from the facility in the first place; that as soon as it 12 leaves that facility, it cannot have the same kinds of l 13 contro'. that 2.9 requires. You can't have it. And so I
1.4 therefore, it's no longer a record.
15 But if the organization has a process by which 16 one can take a record out of the facility, do something to -
17 it and bring it back, then there's got to be an
- 18 accountability, there's got to be procedures to control the 19 removal of these records and the return of the records.
20 But in any case, it would seem like when that 21 record comes back, that they'd have to have controls that 22 did to that record the same thing it did to th0t document 23 when it came in initially to assure that everytning was 24 there.
25 Q The real question is the preservation of that TATE REPORTING SERVICE, (713) 222-7177
29 1 record. Does the control include making sure that t' hat 2
record is not going to be put in a position where a fire --
3 A It certainly should.
4 Q -- or a flood or some other thing might occur 5
which would cause a problem in preserving the record?
6 A It certainly should.
7 0 Which is one of the things called out in 8 Criterion 17, a preservation of a record?
9 A Yeah.
10 Okay.
Q Which leads into the next --
11 MR. MULLEY: I want to make sure I got this 12 straight.
13 MR. GOLDBERG: Okay.
14 Q (By Mr. Mulley) Going back to the Stone &
15 Webster records, they were in the permanent record -- I 16 mean the records storage center. Is that correct?
17 A I don't know.
18 Q Where were they -- where were they stored before 19 they were shipped?
20 A That's some of the details I do not know.
21 Do you know where they came from?
22 MR. GOLDBERG: The source of the record?
23 THE WITNESS: Yeah.
24 MR. GOLDBERG: We're going to have to go off the 25 ' record.
TATE REPORTING SERVICE, (713) 222-7177
'~ ,
30 1 (Discussion off the record.)
2 MR. GOLDBERG: Okay, the inspection report does 3 not.give us the indication where the records came from in i
4 the plant.
5 Q (By Mr. Mulley) So then to my understanding, if 6 we don't know exactly where the records came from, then we 1
7 cannot make a determination as to whether or not they 1
8 should have been controlled. Is that correct? In fact, 9 these records could have come from various departments and 10 various sections within the plant?
11 A Yes, they could have. But controlled in the ]
i 12 sense of 2.9, I think is what you meant when you said j 1
I 13 " controlled." -
l .
I 14 Q Yes, right.
l l 15 A But if even if they were in the records center, l
l 16 removing those documents for the purposes for which they 17 were removed, in my view would have made them in-process 18 documents again, because each one of these were being sent 19 to Stone & Webster for the reanalysis, revision, and 20 certainly at least confirmation of the analysis that was 21 there, which makes them amended, revised, documents.
22 Q If these documents were in fact in the document 23 control center and were then removed for the purpose that i 24 you were just talking about, would there have been some 25 sort of procedure or formality which would document the TATE REPORTING SERVICE, (713) 222-7177
31 1 fact that these records are now back out being worked on? l 2 A Okay, you meant the records center, not the 4
3 document control center.
4 Q I'm sorry, the record center, yes.
5 A If they were removed from the records center, 6 there would have to be something noted in the records i
I 7 center that these are no longer a part of the inventory of 8 the records that they're responsible for.
9 Q "They" being --
10 A "They" being the records center personnel. ]
11 Q And they're part of TUGCO?
12 A Yes.
13 Q So then basically TUGCO would relinquish control l
14 of those records back to Stone & Webster for further l 15 modifications? j 16 A That's correct.
1 17 Q And then when Stone & Webster returned these 18 records to the site -- and when Stone & Webster returned 19 these documents and decided now to make ,them records, what 20 would TUGCO have to do?
21 A Re-enter then in the same manner in which they 22 would have been entered in the fir-t place, a review of the 23 records for legibility and inventory of the records, all l
, 24 those things that the recor.ds center personnel do when 25 they're installing a record into their system.
TATE REPORTING SERVICE, (713) 222-7177 Lh-
32 1 0 So when these records were removed, if they were 2 removed from the records storage center, then it would be 3 up to Stone & Webster to protect their property and make 4 sure that they got their property back into TUGCO's 5 responsibility in the same condition as it left or with the 6 modifications.
7 A It's one of those delegated responsibilities we-8 were talking about earlier, that they now have given over 9 to Stone & Webster to handle.
10 Q I understand.
11 MR. GOLDBERG: Okay.
12 Q (By Mr. Goldberg) What I want to do is go right 13 into the issue of in-process records because we've been 14 involved in that and we'll save the last one which would be 15 the condition of the storage area, itself, because I think 16 it would fit in better to jump into the in-process records.
17 There was an issue involving, I guess you're going to get I 18 into the TRT finding in this one, involves the -- let's see 19 if it have it here, it involves comingling of records. Let 20 me give you the words here. -
21 '
" Failure to provide temporary or permanent 22 storage facility for records comingled with in-process 23 records in the paper flow group." Okay, I'm sure you're 24 familiar with that one. Why don't you give us your version 25 of this thing.
TATE REPORTING SERVICE, (713) 222-7177 '
33 1 A The paper flow group is a work station in 2 essence, and the contents of that work station is paper.
3 They have a paper' flow group.for Unit 1, and one-for 4 Unit 2. And this is where work packages are compiled, and l 5- these work packages are travelers and all things attendant
- 6 to craft installing something; inspection reports,-QC l
7 documents; in some cases, they'll have controlled documents l
8 such as drawings, design change documents.
9 -But it's not'a record center in any sense of the 10 word. It's a document control center, well, it's a pseudo 11 document control center, it's not even really a document 12 control center.
13 There's.the main document control center on this 14 site, which is the place where all the documents are 1
15 controlled, are controlled. There's satelltes which are 16 extensions of the document control center which exist at 17 locations on site that are more accessible to the craft and 18 inspection personnel than the document control center is, 19 and they're set up to issue packages that relate to -- that 20 relate to an activity. . -
21 And then a paper flow group is more a craft, not 22 a document control center organization, but a craft 23 organization which functions pretty much like a document 24 control center, where they develop packages for craft 25 'mainly to do -- to accomplish things, i
TATE REPORTING SERVICE, (713) 222-7177
34 1 And they have.a multitude of files and records 2 out there in those -- in those paper flow groups. But they 3 don't even, they don't even come as close -- they're not -- .
4 they're not even similar to or subject to the same kind of 5 requirements that the document control center is. And the 6 document control center is long way removed from a storage, 7 a records storage center. So that puts PFG even further 8 away from a records type organization. !
9 Q Let me tell you what issue is here that I think !
10 is central. As we understand it, there were a large number 11 of mechanical and electrical records that were removed from 12 the permanent storage area and they were in fireproof >
13 cabinets; when they went into the paper flow group, for 14 work or to check the records or put the them in all in one 15 place in some way, they were removed from the fireproof 16 cabinets into the nonfireproof cabinets and when the !
17 insoector was asked why such records were not in fireproof 18 cabinets, the response was that it cost too much. I 19 i So the issue here is the contro1 of so-called 20 permanent records that were in the permanent storage area 1 I 21 and taken out of the permanent storage area, put in the l l
22 paper flow group storage facilities and the problems 23 associated with that area.
24 A Let me understand this. This dealt with records 25 ' removed from the records center?
TATE REPORTING SERVICE, (713) 222-7177 i I
35 1 O From the permanent storage area, that's what it 2 says here.
3 A Permanent storage area?
4 0 Yes.
5 A And you interpret that to mean the permanent 6 records center?
7 0 I would interpret it to be the permanent 8
record -- I would interpret it to be a records center, yes, 9 where it was actually signed out from the records center?
10 A You wouldn't know why they were removed? For 11 additional work, for modifications?
12 l
Q We heard from Mr. Westerman, I believe, that they 13 l
were put in the paper flow group to get the packages put 14 together. There were various things that were finished 15 early on that were determined to be re' cords, they came back 16 because they were working on a large system and they wanted 17 to have everything in one place.
18 So the paper flow group had in-process work going 19 on, so they took material out of the permanent facilities, 20 or "the permanent storage area," it says here,'they brought j 21 l
it back into the paper flow group so that there was a pl' ace 22 that they could organize all their materi'al.
23 Now, the question is: In your mind, if records 24 are removed from the permanent storage area that were in l
i 25 fireproof cabinets, should they continue to be stored in TATE REPORTING SERVICE, (713) 222-7177 i
. ~
36' j 1 fireproof cabinets when they're put in the plant?
2 A Well, again it sounds like that the records 3 center or whatever this permanent storage'is, has 4 relinquished their responsibility back to the paper flow 5 group. Most likely whatever this permanent storage thing 6 is got these records at some point in time earlier from the
! 7 paper flow group as being, " Hey, we're through with this j 8 package, and ready to tutn it over to the records group." l l
9 Now, sometime subsequent to that, they decide, 10 " Hey, we want to make this a part of a package that we've 11 got already started here in the paper flow group, so give l
12 those documents back to us."
13 It would seem-to me like that would be the l 14 removal of the record from the storage facility and it 15 would become a part of this document ' package which.wouldn't l 16 be a record.
17 Q So the removal, your interpretation is, the 18 removal of the record from the permanent storage facility 19 and bringing it back in to put it into a larger package
! 20 takes it from the realm of a record back into an in-process 21 document?
l 22 A That's the way I approach the r'ecords system.
23 And when they come out of that records system, they're not 24 records anymore subject to 2.9. And when the bottom line 25 comes down, they have to have those records. If they don't TATE REPORTING SERVICE, (713) 222-7177
. s
~
37 1 have those records, they're like these two' supports I gave i
2 you a while ago, they don't have the reco'rds for those supports, they've got to tear those suppor'ts down, put the
~
3 4- supports up there and generate the records they've got to i i
5 have for them.
6 Q It goes back to 45.2. which and statement I made 7 earlier of the control and accountability of records 8 removed from the permanent storage facility. And if 9 " control"'means " preservation," wouldn't one, if they're 10 taking records from the permanent storage facility back 11 into the plant, try to have the same preservation that's in I
12 the permanent storage facility? j I
13 A No. Can't see that. The reason is the .
( 14 preservation, the storage requirements, the security and' l 1
15 all those requirements apply to the storage center, itself. l t
J 1
Once that storage center turns loose of them, they can no 16 l 17 longer meet the requirements for which that storage. center 18 was maintained.
I 19 That's why -- I guess that's the position I come j 20 from. When they turn loose of it, it is no longer in 21 compliance with 2.9, 2.9 can't apply to it there. So any q I
l 22 time that, any time that booger goes out, it's, you know, 23 it's not accountable to them, they mark it off their l
- 24 accountability list and now it's a document for which they -
.i
. I 25 do not have. At some. point in time they're going to have-TATE REPORTING SERVICE, (713) 222-7177 j
_ ____ _ Q
y 38
. w 1 y 1 to have it and if they don't have it, then they'rd!?oing to s -
2 have to generate that docume3t! . \[ i y\ ,
3 Q Okay, there's a related issue and I don't know if
).
, I
'4 this has any_ bearing on your conclusion here, accoroing to .
1 1
i<
l 5 to the report, this inspector's inspection, report, he says,- '
r w
,a "An NRC special review them report dated July'13th, 1984, *\;
6 A. ., . s 1
n,4 y l 7 identified a potential enforcement issue because N1 2tlal
. 4
~
'q 3
4 l 8 ASME records such as moment restraintpackagesweres,h. ,
enfed y i
g i
i 9 in trailers in nonfireproof cabinets without a backup copy ,
. .r I
i 10 in a separate and remote locations." Are gou familiar with b ./ 4-11 that issue at all? This issue of origina.'1 ASME recoEdt9 '
t .
.3..- 3-12 that were taken out in nonfireproof cabinetr? ' [. ,
13 A It has a~ familiar ring and I may have^even$
e 14 evaluated that situacion back in '84. And I know dey-15 came -- this was JunU, of '84, SRT7. 5 16 Q July of '84, SRT. Right. (
17 A
(. if <
I think that SRT came in and did a two Wek
- f 4 18 inspection with guys from Region II and headqdart'e.js. And 19 with all due respect'to the caliber of personn.1 on there,,
3 20 they were not inspectors in the large part. . ,,
21 I mean like Tom Epalito was ed ihat" tee.m.
(
And \\ i t.j t s
- i , 4 ,.
22 they saw something which tn,oy perceivd,d pet %&ps as a
, t 23 record, and may be laborino'onder thd same dind of y.
24 impression that it seems tiils report is lahN2ing that if 1 25 'someone calls something a record, it's subject to 2.9.
2, _.
TATE REPORTING SERVICE, (713) 222-7177 -
'\
+ .
. _ _ - - n &'
- ~ . .
-N g
39.
's e 1 And the words " record" and " document" are tossed 2 around rather casually as we've done here today. And you k
3 say " record," you think 2.9.
t But not a11' documents are i
\
4 records. I s
!5 Q (By Mr. Mulley) Let me ask a question. There !
s 6 are certain projections thatnapply to the permanent records s
i A :7 storage center, k E' ' A Yes.'
! s ,
l , '
- A 0 Tc ne, very stringent protection requirements. l v
10
,The reason they're there is to protect the records. Why is l ,
l 11~ it then if somebody tal:es the record away from that center i
L 12 and decides to take it someplace'else and maybe store it' b
L 4
13 ,
temporarily, why are there no requirements to protect the 14 records in the same fashion.
~
j 15 A Records center was really, or the ANSI standard 16 for records.wps developed for the storage of records,
- 17, completed records.
t 'N l .
18 N k, The implementation of that standard by the
< 19 industry has been assdiverse I guess as the interpretations 20 of that has been. ,2.9 could almost be interpreted that you u
21 <do not have to call any document a record until you finish 22 the plant.
23 c, And I think what has occurred in this situation '
k a\ .( 24 is similar to what's occurred in many other places, they !
~ 25 ' dent something to the center before they should have. If s-c s> f Q., .'. h 1 s
>s i 3 ,, , ' TATE REPORTING SERVICE, (713b 222-7177 t ,o s ..
- 1:
+.} .,
1 40 1 they hadn't sent that document to the records center and i
2- just kept it over here,.that would not have been a record, 3 it would never have been considered a record. What they ;
4 did was send it over to the center, they said, " cops, we 5 need that back," we shouldn't have sent it, now we've got i 4
6 it back, it's not a record anymore.
7 It shouldn't have'been sent over there in the l
i 8 first place, you know, if one had the ability to see ahead 9 to those situations. So, you know, we're talking about 10 preservation and the preservation of those documents, of 11 .this record, and it's really not even a record yet. It's 12 still a document.
'l i 13 Documents need to be preserved because documents 14 become records which are going to have to be preserved from 15 one year to 40 years or in some. cases even longer than 16 that, perhaps. l i
17 But that was what 2.9 is talking about. The l l 18 preservation of a document on site, and even if it were in 19 a records center, is a very large task. ,.Some of the 20 records in the vault over here right now are beginning to 21 be dogeared just by taking them out and them being looked
- 22 at and handled, because they were probably turned into the 23 center too soon.
24 When a record goes into a center, it should be 25 ' referred to probably very infrequently, if ever. This is TATE REPORTING SERVICE, (713) 222-7177 l
._ _._-_____-A
L .
l
- 4
- .. 1 l '
41 1 almost -- the records-center in many cases looks like a 2 documents control center because they're so much traffic of 3 documents handling of documents in that ar'ea. So the 4 preservation of documents that come.back out that were put 5 in, and I'll say prematurely and I think probably the i
6 evidence that appears evident from that, there would be --
l 7 no violation other than perhaps a technical violation with 8 respect to the preservation that might be applied to the !
9 control of those documents when they were back out in the 10 area.
11 Q If,the record, the document is entered into the 12 control center prematurely --
13 A Records center.
14 Q -- records center, as you say, prematurely, once 15 it is entered into the center, though, is it then a record?
i
! 16 A It's a record as far as the center is concerned.
17 Q Right. But --
18 A But they can remove and it cannot be a record. I 1
19 If we take it back out, they can remove it from the index '
20 of records in the records center and it's no longer 21 considered by that center as a record.
22 Q Going through the formality of removing it from 23 the index of records?
24 A Sure.
25 Q Now, talking about the records that were TATE REPORTING SERVICE, (713) 222-7177
42 l' intermingled back into the paper flow group, that 2 presumably was done then.
3 A He said they came from a records management or 4 something, I didn't say the records center, but I'm 5 assuming that it came from the records storage location on 6 site back to the paper flow group. l
\
7 Q So if in fact this record was then removed from )
1 8 the index of records and if the records control center 9 relinquished control of this, it became a document?
10 A Yeah.
11 Q okay.
12 A They would have had to have done that. 4 l
i i
i 13 Q okay, if they had not done that , then the records i 14 would still come under ANSI, because it is still a record 15 that the record control room was responsible for? j i
16 A That's the way I would view it. j 17 Q So if the records control group goes through the 18 formality of taking this record off their index, it then it 19 becomes a document, then it's treated just as any other i r
20 document?
21 A Sure.
i 22 Q If in fact it is not deleted from their index of 23 records and is taken out, then it is still a. record that 24 they're responsible for and should be protected as a 25 ' record?
TATE REPORTING SERVICE, (713) 222-7177 1
43 !
1 A That's correct. 1 2 Q Do I understand that correctly?
3 A And they would be in violation of the ANSI j
)
4 N45.2.9. One would -- and I would write a violation for 5 that. Their correction would be to remove it from the
! 6 records. I mean, remove it from the records index.
7 It's -- that's why I said it's almost a technicality. I l
l 8 don't like to write violations that correct something by "
l i 9 just changing it, changing whatever it was and you haven't
}
1C really changed or affected any change in the condition.
11 For example, you write a violation against a l
12 procedure, not following a procedure. And they just change i 13 the procedure so the way they're doing it is in compliance.
14 I don't like to write that kind of violation. That kind of 15 violation would been the same k'ind of violation. Write 16 them a violation because these documents out there in the 17 the paper flow group are not controlled in accordance with 18 ANSI 2.9, and they're still in the index of the ANSI 2.9 19 records center, they'll just say, " Corrective action, 20 remove them from the ANSI 2.9 records index and we',re not .
21 going to do that anymore." I'll write them like that but I 22 don't get much, I don't get any satisfaction if that's what 23: you call it, in writing a violation that would be like
. 24 that.
25 MR. MULLEY: I understand.
TATE REPORTING SERVICE, (713) 222-7177
f - -
l 1
i 44 4
i 1 Q (By Mr. Goldberg) Okay. There was reference 2 made in the tr"nscript to an SSER involving this issue.
3 A Transcript?
4 Q In the transcript that we have accumulated over .
l L 5 the last few weeks, not in your work. I think that one of 6 the -- I think Mr. Westerman spoke about SSER, I' don't know L
7 the number of this SSER.
8 A Eleven.
9 Q Eleven, it's 0103, and it pertains I believe to l 10 some degree to the issue we've been discussing, the { '
l l 11 characterization.of the allegation, it is alleged that 12 between May '82 and July '84, permanent records were not i 13 stored in a fireproof vault.
14 And it talks about the in-process records, and it ,
I 15 also talks about the paper flow group. But reading this, 16 let me see if I interpret this correctly,'this only 17 pertains to records, I'm sorry, to documents that have not 18 been designated as records as yet; they're still in work.
19 Is that correct, in this interpretation?
20 In other words, they haven't really taken stuff 21 out of the permanent records and moved them back in, but 22 rather material that has moved through the process and has 23 not -- and has not reached the permanent records *: enter i 24 yet.
25 A This is on page --
TATE REPORTING SERVICE, (713) 222-7177
45 1 0 0103 and 0104.
2 A Yes, that's what I've got here. As 1 recall 3 this, this dealt with the documents in the paper flow group l 4 control, not of documents that had been removed from the 5 permanent storage back into the paper flow group.
l
)
l 6 Q Okay. I want to go on.to the next issue, which 7 is the storage facil'ity, itself. and I'll read you what i
8 was -- )
9 MR. MULLEY: Before we do that, let me ask one
~10 more question.
11 Q (By Mr. Mulley) Did you discuss with l
12 Mr. Westerman, you know, the things that we're talking l
13 about today?
14 A My views on this subject?
15 Q Yes.
16 A Yes.
17 Q Okay. At what point did these discussions take 18 place, during the review of the report, subsequent to the 19 review of the report?
20 A Oh, well, I don't know when the report was 21 issued; it has not been recently. It's been back in -- the 22 report -- the report was issued in --
23 0 I think the report was issued on --
24 A As I recall, it was somewhere around January 25 Q Right.
TATE REPORTING SERVICE, (713) 222-7177
46 A
1 -- or something like that that we were discussing P
2 that. And I don't know when the report was issued. I 3 Q. Let me ask you this.
4 A It's been awhile back.
. 5 Q When you were discussing this with Tom Westerman, 6 was it in the context -- did he bring out the fact that he 7 was reviewing a. draft report and had some questions about 8 some findings?
9 A He said, "I don't like the way this looks or. k 10 something," and he came to this thing. "What do you think 11 about this? This doesn't look right to me.*
12 I looked at it, or he described it to me or I s 13 looked at it, one, I don't recall which, and I gave him my i
14 views on it.
15 I don't recall that our views differed very much.
16 There may have been a few, you know, a few small things. I 17 don't know. But he didn't change my mind about what I 18 thought about it anyway. I don't know if I changed his or 19 not.
20 Q Okay. .
21 Q (By Mr. Goldberg) Okay. This next area involves 22 the condition of the storage facilities. The first one is 23 failure to preclude rain from entering the QA records vault 24 over several years time and the second related issue is'the 25 ' failure to preclude food, coffee, and other types of TATE REPORTING SERVICE, (713) 222-7177
47 1 problems from the QA records vault; in other words, there 2 were problems associated with cleanliness of the area.
3 Were you involved in these issues at all,'the condition of 4 the vault?
5 ~A I remember it being discussed. But I wasn't -- I 6 didn't go and check the vault or anything else. I think it 7 was more like is there a requirement for this or a 8 requirement for that sort of question asked of me.
9 And I just played back to Tom or Ian or whoever 10 it was that asked, that, you know, what my recollection was 11 of the standard. I might have even referred back to the 12 standard to be sure that what he was telling him was 13 corrects.
14 Q Let me try these one at a time. One of them was 15 to preclude rain from entering the QA records vault, 16 safeguarding of flooding, for example, and the question 17 there is whether there was sufficient slope on the floor 18 for drainage of the water, if water came into the vault 19 area. Did you go back to 45.2.9 and che,ck the language on 20 that issue? .
21 A Yes, I did. I don't recall now what -- seemed to 22 me like what I was looking at -- what I recall anyway, that
{ 23 2.9 says, is that if drains are required, there's not to be l 24 a slope in the floor but it doesn't say that drains are 25 ' required.
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48 i
1 Rain entering, of course it doesn't say anything 2 about rain entering, just says that you'll protect them.
3 And I guess if rain comes in, you have a problem with 4 . humidity control if you're storing records subject to 5 humidity deterioration.
6 The thing that occurred to me was that, you know, 7 it's one thing if you've got a leakey roof and you haven't 8 done anything about it for three years or you've got a roof 9 that's been leaking form three years in spite of your 10 efforts to fix it.
11 We've been here for nearly a year and they've 12 came out and fixed a leak we got' in the roof of this thing i 13 here three times and we've still got a leak. So there's 14 mitigation even to that sort of thing.
15 But slope on the floor, I don't recall, I don't 16 recall that the standard speaks to a slope on the floor in 17 the the absence of a drain. Now perhaps it does. But I l 18 don't recall that.
19 Now, as far as food in there, and coffee and that 20 sort of thing, it speaks to activities unrelated to the 21 storage of documents. So one could interpret from that 22 that eating and drinking in that area is not an activity 23 associated with the storage of records. And it's certainly i 24 something that you wouldn't want to permit. But your 25 pushing a point if you write somebody a violation for that.
TATE REPORTING SERVICE, (713) 222-7177 4
49-1 Q Okay. Here's what the water issue is. I'm 2 reading on here. " Water had been leaking through the 3 forced air system and beside a support girder, and a second 4 location approximately,two to three gallons of water had 5- leaked.in through the forced air duct' ventilation duct and l 6 was caught by a container placed under the duct. The 7 temperature / humidity control chart indicated high humidity 8 from October 14th through October 20th,.1985.
l 9 " Interviews with vault and other site personnel 10 revealed that the roof and vent system had been-leaking for 1
11 approximately,two years or perhaps longer. Radiographs, 12 photographs, microfilm and other sensitive records were l 13 stored in the PPRV and the IRV until approximately December 14 26, 1984, when they were transferred.to the QA records 15 center."
16 I guess the question is: Is this the kind of 17 condition that should continue in a records center like 18 this?
19 A No, it's not the kind of condition that should be 20 permitted to continue. But you are also presenting some 21 information there that would cause me to question it..
22 First you're talking about six days where the j 23 humidity was out of back over a, I don't know, a year's 1
i 24 period? If they had a leak in the roof, yeah, you're going 25 'to have some humidity problems back then.
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50 1 The leak that was observed was a leak that was l 2 observed at a point in time, and all the other information l
3 is based on what someone else said was th'e situation. And 4 I've come to learn that -- myself, included -- you can't l 5 take as a hundred percent accurate things that are said.
I 6 People tend to embelish upon things and exaggerate perhaps 7 just a little bit. And it could have been a condition, i 8 that existed, that same condition, for four or five years.
9 That could not be the case as well. .
10 Q It gets back to a general indication of the l .
11 control of those records in the records storage area, and 12 whether, you know, this kind of practice is indicative of 13 things could get more serious.
14 A It's a situation that needs -- that needed to be 15 corrected and should have been corrected, and it's 16 something that one should not be ignoring, that's for sure.
17 Q How does the NRC get the utility to correct the 18 problem if it doesn't issue a noncompliance?
19 A Well, that's certainly one mec,hanism, but you 20 know of other mechanisms, too. There is the mechanism used 21 by licensing, who do not issue noncompliance but they get 22 things corrected and get things changed.
23 The NRC inspectors use those same mechanisms at 24 times. And they've put backfit rules and those kinds of 25 rules out to provide, or ratchet rules to prevent those TATE REPORTING SERVICE, (713) 222-7177
51 1 kinds of actions but I think they still occur. You can get 2 things accomplished apart from writing a violation, 3 certainly.
l 4 Q But isn't the violation -- a " violation" is a i o
5 poor word, I think. " Noncompliance" would probably be more i
! 6 aprapos because it could involve a deviation of a i I
7 commitment. Wouldn't a noncompliance, though, get more 8 effective, more timely collective action than waiting until l 9 the end of the line and --
{
10 A Let me put it this way. The issuanc6 of a j 11 deviation or a violation is the p. roper means by which the 12 NRC should affect corrective action for conditions adverse 13 to commitments and requirements. But we all recognize 14 there are other ways to correct items than those. And I 15 know of not very many inspectors that do not get things 16 corrected apart from that vehicle.
17 Q But still, this is a viable option to go and 18 write a noncompliance, if one finds a deviation, for 19 example, from a commitment that was made,.by the utility --
20 A Sure.
21 Q -- to the NRC7 22 A Sure.
23 0 The other issue, let me read you the other issue 24 and then George might want to follow this up. The NRC 25 inspector observed, "A coffee pot, sugar and crumbs, on an TATE REPORTING SERVICE, (713) 222-7177
~~'
52 1 adjacent. table where food had been brought into the vault 2 area. Coffee pots are real fire hazards and should not.be 3 allowed inside the vault." Have any comment on that?
4 A Well, I would have approached it, were I l
5 inspecting that, and that to me would be the -- well, the 6 trigger for a violation, just as soon as I saw that.
7 But I would also find out if that was a condition 1
8 that was constant or if someone had a birthday party and
.J l 9 they moved it in there and was doing it that day or .
l 10 something like that.
11 I would temper the action I took based on the 12 circumstances associated with it. Now, that would be a l .
i i 13 condition where I may or may not write a violation. If 14 that had been a one time occurrence and if I had been there 15 last week and that was not there, I was there this week and
! 16 they moved in in there because the little girl that had to 17 stay in there all the time had a birthday or something like 18 that and they were having a little thing, I'd say, " Buddy, l 19 that's no good, out." i 20 And if that corrected it, then that's where I'd 21 drop it. But if it was set up in there and that was where 22 everybody paraded in and out of there for the coffee and 23 that sort of stuff,'and if it was, if it was in the area ;
24 that the, records were stored, yeah.
25 Now, the record -- the PPRV and the IRV ar? not TATE REPORTING SERVICE, (713) 222-7177
53 1 the classical records storage areas, and that kind of 2 condition is going to exist in those areas. There are 3 areas there that would not be acceptable in a permanent 4 storage facility.
5 Now, it could be that that is the areas that 6 these things were observed in. And in a situation like 7 that, I would temper, I'd temper my action to it in ,
8 accordance with that.
9 The PPRV is a large area with controlled access, 10 but it has a half dozen personal desks in there, it has a 11 place off to the side were people can take documents, stay 12 inside the controlled area and review them; and it's 13 arranged not like a permanent plant, permanent records 14 storage would be arranged.
15 And I see where this kind of thing could exist in 16 some of their interim storege, I guess, for want of a l
1 17 better word, that they've got here. Now the permanent 18 storage thing, that's something different. I really feel 19 like that -- wel'1, you don't want that. ,
20 Q (By Mr. Mulley) Going back to the Stone &
21 Webster records, where they for unit one?
22 A I'm sure they included Unit 1, and there may have !
l 23 been some Unit 2 things in there, too. But I'm sure they !
. 24 included Unit 1 but there could have been some Unit 2.
25 Q And Unit 1 is complete, a hundred percent TATE REPORTING SERVICE, (713) 222-7177
4 54 1 complete?
2 A For all' intents and purposes, except for the 3 rework and modifications that are going on. I think the 4 claimed percent complete is 99.3 or something like that.
5 But there's considerable amount of modification and rework 6 going on. So that's probably not too accurate a statement.
7 Q But even if that unit is so close to being 8 complete, the Stone & Webster papers could still be 9 considered documents and not records if they're taken out 10 of the document room. Is that correct?
11 A Sure. Sure.
12 0 Okay. And theres no requirement under ANSI to l 13 protect these records on site, to protect these documents 14 on site until they tetually become records, do I understand 15 that correct.
16 A With respect to Criterion 17, that's true.
17 Criterion 17 applies to records, not to documents.
18 Q What about criterion 3 or Criterion 10, any of j 19 those criteria apply? ,
l 20 A 10, inspection? -
l 21 MR. GOLDBERG: Must be 3, which would be design.
22 And it does have records in it.
i 23 THE WITNESS: It talks about design records but I 24 i
don't think it talks about the -- it talks more about the 25 control of documents, I think, as opposed to records.
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1 Q (By Mr. Mulley) The control of documents?
2 A Yeah, design documents. Talks about the manner 3 in which -- like designs must reviewed and' approved by 4 someone independent of the person that originated the 5 design, the design changes must go through the same process 6 that the original design, so it talks about the process of j 1
7 design and about the documents that are documenting the 8 design. j i
9 But as far as records are concerned, 3 I don't 10 think says anything about records. It talks about the, you l
11 know, what will be generated with respect to. records.
12 Talking about documents, you know, the documents that will 13 eventually in many cases become records. )
l 14 Q Aren't we talking about that now, that these i 15 leave the records center and are now documents?
16 A Yeah, design documents. Yeah, they're design i
17 dopcuments, certainly. '
18 Q So is there anything in that criterion that 19 addresses these design documents and how to protect them 20 and protect them? -
21 A Not in Criterion 3. So as far as design 22 documents? Not really.
23 Q (By Mr. Goldberg) Cliff, what about the ANSI 24 standard 45.2.11, design control aspects of design 25 ' documents?
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1 A I think it talks about those things which will 2 become documents. I'm sorry, those things which will
.3 become records. But as far as.the preservation of them, l 4 you know, it says 2.9, these kinds of things will be 5 controlled, these things will be controlled in accordance l
! 6 with 2.9.
7 0 So the manner of preservation would be in 45.2.9.
8 A Sure.
l 9 Q The actual controlling of documents is in l 10 45.2.117 11 A Sure. Yes. The processing, I guess, 12 0 Yeah.
13 A And of course the control of the documents as 14 well. And control, to some degree as we talked about J
. J 15 earlier, provides a measure of preservation.
l 16 Q (By Mr. Mulley) Let me understand what you just i 17 said. You said that the ANSI 2.11 says the records will be l
18 controlled by ANSI 2.9. Is that what was just said? l 19 A Were you asking me? I'm sorry, you were looking i 20 at him and I thought you were talking to him.
21 Q I'm trying to make sure I understand. There's an 22 awful lot of ANSI standards going around here and I'm not 23 familiar with them all. But is that what it says, that i 24 2.11 says that the control of these records will be in 25 'accordance with ANSI 2.9? Did I understand what you just TATE REPORTING SERVICE, (713) 222-7177
57 1 said?
2 A Yeah, more than likely, I think there is a 3 reference in 2.11 to the records generated will be subject 4 to the control of 2.9 or controlled in a manner consistent 5 with 2.9.
1 6 Q So the records inat are eventually generated will 7 be controlled under ANSI 45.2.9, r.at that these documents 8 will be controlled the same as required by ANSI 2.9?
i l
9 A As these documents are being generated, now
( 10 that -- 2.9 would not apply to that.
11 Q 2.9 applies once these documents become records?
1 12 A ANSI N45.2.11 would identify the kinds of l 13 documents that would become records, but 2.9 does not 14 control the generation of these documents that 2.11 is 15 really established to do, controlling the generation of the ;
i l 16 documents. It's really controlling the generation of the
! 17 design which manifests itself in documents.
18 Q So there's nothing in 2.11 talking about original 19 design documents that speaks to how these documents are 20 protected?
21 MR. GOLDBERG: Well --
22 A If we want to, I can get 2.11 just like that, 23 it's right out there on the table. If this is a test, I 24 don't know if --
25 O It's not, as a matter of fact.
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1 A Let me get 2.11.
l 2 Q Sure. Sure.
3 (Discussion off the record.)
4 Q (By Mr. Mulley) Okay, after looking at ANSI 5 45.2.11, I guess it's paragraph 10, records, it says:
l 6 " Design documentation and records which provide evidence 7 that the design and review process was performed in 8 accordance with-the requirements of this standard shall be 9 collected, stored and maintained in accordance with the 10 requirements of ANSI N45.2.9. The documentation shall 11 include not only the final design documents such as '
12 drawings and specifications, but revisions thereto, but 13 also records of the important steps including sources of 14 the design inputs which support the final design. The 15 record shall be Iegible, identifiable and retrievable.
16 Documentation of records will be either of the lifetime or 17 nonpermanent category as defined in ANSI 45.2.9."
18 In your opinion, would this ANSI standard apply 19 to the records that were shipped to Stone & Webster, CB&I 20 or later put into the in-process flow group again?
21 A ANSI in 45.2.117 22 0 Yes. .
i 23 A Yes, it applies to the activities that Stone & j 24 Webster will be doing with respect to those documents.
25 Q (By Mr. Goldberg) George's question, though, is ,
l i
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1 the section 10, called records. Would that section apply 2 to the Stone & Webster documents?
3 A The documents that Stone & Webster will be 4 generating will be records subject to 2.9. They are not 5 subject to 2.9 at this point in time.
1 6 Q okay.. That's the key. Were they subject at that 7 point in time --
8 A No.
9 Q -- when the records were removed from the 10 utility. That's the key.
11 A When they were -- again, it's going to depend on 12 where they were removed from. But I believe whether they 13 were in the records storage center on site or in the' 14 engineer's desk, once they were taken out of that, moved i 15 back to Stone & Webster for further work, they are not, i
16 they're no longer records. They're documents that'are 17 being or that are continuing to be processed. That does 18 not fit the definition of a record.
19 Q. (By Mr. Mulley) One other que,stion concerning j 20 the CB&I records or documents.
- If these documents were
'~
21 destroyed, could they be replaced?
22 A I would say they probably could. But if they 23 could not, they would have to be regenerated, if it meant '
24 rebuilding something, remanufacturing.something. The 25 ' records are required. If they are required records, and.
TATE REPORTING SERVICE, (713) 222-7177
i 60 1 I'm sure we are talking about required records, then they i'
2 would have to be produced. If they could not be 3 regenerated based on the evidence of the work that was 4 done, then the work would have to be repeated and the 5 records regenerated. l l 6 Q Now, they did work, as I understand, on the liner 7 plate.
1 8 A Containment liner and I imagine probably tanks as '
9 well, yeah.
l
! 10 Q Which is all buried in concrete?
l I
l 11 A Well, yeah, in some cases it's buried. Many j l
12 cases it's lined, you know, lined on one side with i
13 concrete. Yeah.
14 0 okay. Like'in the base mat and stuff like that? I l
i 15 A The base mat and probably the floor of }
16 containment is probably buried. And around the walls of 17 the containment, it's just painted.
18 Q So if the truck that was taken these CB&I records 19 to Houston went down --
l 20 A Blew up -- '
21 Q Right.
22 A -- burned?
23 Q What position would this plant be in?
( 24 A Geez, don't know. They'd be in trouble because 25 they're going to have to come up with some records to TATE REPORTING SERVICE, (713) 222-7177
. I 61 1 substantiate the quality and everything else with respect 2 to that liner.
i 3 They may be in fairly deep trouble. Now I. don't 4 think it would to be the point where they'd have to rip the 5 liner out and put the liner back in, but they have may have 6 to chip some concrete, take a awful lot of paint off, do an
, 7 awful lot of work on the work that's been done, and it j 8 would not be -- might not be a small task.
l 9 But then again, I don't know if you're talking 10 about every record that was ever generated or if you're 11 talking about some records that they've got that they may l
l 12 have duplicates of or preliminaries of back in their home 13 office, or what.
14 But I guess the key thing.here that I based my 15 judgment on was the fact that they're vendor records, and 3 16 they were not documents -- see, I'm doing it now. Vendor 17 documents as opposed to being TUGCO documents, that CB&I 18 was more than likely producing in order to fulfill the 19 requirements of their contract, that when you finish this 20 contract, you will produce these' records and provide us one 21 copy, eight and-a-half by eleven SEPA of all drawings, all 22 those details spelled out and until they get all of those ;
23 documents, the utility gets all those documents, they don't 24 get their final check.
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25 Q (By Mr. Goldberg) And that fulfills Criterion 1, TATE REPORTING SERVICE, (713) 222-7177
62 ,
l 1 in your opinion; that's sufficient to fulfill Criterion 17 2 A That is.the responsibility. The' utility.has the 3 responsibility to produce the documents attesting to the 4 design and quality of that liner. They,have said, "CB&I, 5 we're going to give you 'X' dollars to do this and produce 6 the documents we've got to have to attest to that."
l 7 -
And when CB&I gives that to them, that's got to 8 comply with what the utility told them they had to give 9 them.
10 And then this utility says, "Okay, these are our
)
. 1 I
11 documents now and here you are NRC," and they've got to 12 comply with what the requirements are. And we don't knock l
l .
13 CB&I if we find something wrong with those documents, we 14 knock the utility. It's his responsibility.
l 15 Q 'T,UGCO is responsible for --
16 A That's true. And --
l 17 Q -- its vendor?
l l 18 A And that's why any problem, if we had -- well, 19 this violation was not going to CB&I or whatever the thing l l
20 is, the deviation or whatever it is now, not going to CB&I, 21 it's going to the utility.
22 CB&I, if any action is required, will most likely 23 have to take it; the utility is going to have to track
, 24 that, the utility is going to respond back to us. So in 25 'that sense, of course, or Criteria 1 and the responsibility TATE REPORTING SERVICE, (713) 222-7177 l
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63 l' of the plant rests with the utility.
i 2 Q (By Mr. Goldberg) I , guess that's it -- do you.
3 have anymore comments that you want to mak'e on that 4 inspection report we've just about coveted?-
5 There'was one last' issue which we understood you-6 were not involved with. That was weld' rod control. Did 7 you want to get into that one? We understand it's another--
8 party' involved in that:ene.
9 A I don't know. I have been involved in weld rod :I
.i 10 control from.the standpoint of allegations but I don't know 11 if that --
12 Q Let me read it to you and see if it's valid.
4 13 'Says we're weld rod was not identified at the main q l
14 distribution or distribution station. 1 15 A Does it deal with labels on the weld. rod cans'and q l
16 that sort of stuff?
i 17 Q I believe it was.
18 A Okay, you're right. I don't think that I was.
I 19 Q Okay. I was going to ask you whether anyone had 20 gone to the weld rod log book to see if what was done, ,
21 because the log, as I understand it, would tell you a great' 22 deal about the material control.
23 A I wasn't involved in that item anyway. I have~
i 24 been involved.
l
- l. H25 Q Did you want to add anymore to what we've been i
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e 64 1 discussing in the records area, because we're going to go l 2 on to another issue?
3 A In the r.ecords area?
! 4 Q The issues that we've --
l 5 A I don't think so. I've pretty well expressed my l l
6 views on the regulatory requirements, whi'ch basically is 7 the endorsed standard. And I think the most difficult i
l 8 thing with respect to records is determining when a record ]
I 9 is a record, and the control required by ANSI 2.9 is one l
10 that deals with that facility that's been designed to {
11 preserve and protect these records.,
Ii 12 And once you're outside that facility, you have ,
j 13 got to start looking for a different way or means of ,
j 14 control. And procedures that control those things have to 15 account or have to provide for those kinds of conditions I
16 for removing records from the facility. And if they don't, 17 they should. i I
18 Q The next few issues, we're going to ask you l j
19 whether you got involved with them,.we're not sure. The l q
20 next is inspection report 85-16/13. .
I i
21 The issues in that report involve actions on !
,( 22 50.55(e) reporting, actions on bulletins, and BISCO seals, l
23 the BISCO fire seals. Did you get into any discussion I 24 involving those issues with Mr. Westerman? i
' i 25 A No. '
, i TATE REPORTING SERVICE, (713) 222-7177-
65 1 0 The last one is the coverage of the inspection 2 program. There's some concern in terms of some holes or 3 problems in frequency of coverage in the past on the 4 inspection program at Comanche. You want to give us some 5 comment on that?
6 A Well, as I said earlier, Shannon stopped me one 7 day when I was walking through the trailer and was 8 c discussing this issue, about things that hadn't been done 9 in the past.
10 To the extent -- to that extent, he developed a t
11 rather comprehensive list of ills of prior -- of his l 12 predecessors, which to me seemed to be somewhat of a 13 self-ser' ring document so I didn't pay too much goes to it.
14 I have been involved to some extent in going back l
15 and covering some of the deficient modules, at the request 16 of Shannon through Tom. Shannon and I have gotten into 17 some discussions about how what we are doing in the task 18 group could satisfy some of these omissions that exist in 19 the module program. .
20 But I don't think that anything has ever been 21 formalized. The thhngs that Shannon was suggesting I felt 22 was not the proper way to approach the thing, and that was 23 when one of the people over here go out to do an inspection 24 in the plant, check with him and see if there's some 25 ' modules that covers that inspection and they can take h
f TATE REPORTING SERVICE, (713) 222-7177 a
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lh, il! 66' t es-t r-y 1 credit for that module. 3 2 It would seems to me -- I didn'.t agree u that that 3 was the proper approach.to doing somethincj like that; that
+ y 4 it would be best that if ae would review the reports of our 5 inspections and then decide if those were covering some' of
. 4 d 6 those those holes. But anyway that's just discussion %.,,,\"% ~ <; p. l 9
7 between Shannon and I.s l
1 l
j 8 And as far as.l.lknow,-I think everyone recogniz.es l
)
9 that the work we're doing out here is probably more than )
3 N' I 10 satisfying all-the inspectied requirements that the IE 5 l j
11 manual requires and even in\., ex c e s s o f a t.,3 ha t . But no one has w
ghg'< j f, t ,
P l
12 sat down and tried to on a one-td-t.ne ' bas.Ls' shew wiiere =,
al
% i e. k ]'y 1 13 we're covered all these things,; " ,
l" ,QK[! tR l 1 '
- l. g 14 Q Doyouthinkthathoeldbe'thesomethingthat*
15 someone should do is sit down and do a little road map or s 4 3
ts a
- j. 16 some kind of a sketch of where things were,done? i r 3 f +1
! 17 A Well, I think it would pint, to' : test any concern NJ 1 t s,
18 that anyone might have with respect to whether the L
19 inspection program, whether befute or after the fact, was l 20 completed on Comanche Peak. And I think before we finish.s
( 21 here, it's going to have bien completed ten times over; h 22 We're putting in at the rate probably of 2,000 to 3,000 23 manhours a. month easily here on almost direct inspection on 24 acontinuingbasis,andintothtkdetailthatP.heIEmanual 25 ' rarely asks you to go into. Andhit's/its) covering all '
j t;
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)n p
7, 1 areas, all disciplines 2 0 One last question in this area. When you fill 3L - out youi)156 for the work you've been doing the last 4
+,.
several weeks, do you fill it out based on your review of a
, b; particular area or look at the IE manual, based on your
)t' .,
6 2
l%: completed number of requirements that you went through and 7 how many the percent completion of that module, or do you 8
base it on dse percent ecmpletion of the utility's activity
, 4 4, ,,
(.
a 9 , , in that >% ,
aria; or;do you use some other scheme?
h4 10 '4 ? ' fpf use of the 766 has been rather limited and 11 that thinhchangesjustaabout as quickly as it seems like i s 12 the stages of the moon.
l $
13 '
l But up until just recently, have I been doing '
h 14 inspections that even fit the 766 program or the IE manual 15 program. When we do one of these, and I think.the first 16 one that I have done that's directly relatable to the IE 17 manual is back in the January / February time frame.
That I s
18 based on the'pordent cenplate of the module.
l '
,i r 19 Lult it s c.ot one that's subject to, you know, the i
- i.
- d 20 percent corplete of the plant necessarily. It's a 4
\ 21
\ programmatic module done with QA. I did that about 80 22 percent complete. '
23 I got to about 20 percent left to do in the 1
(
I 24 . design area. l 25 But I did tne udit it program and a bunch of
~
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68 q l
1 attendant programs, procurement, vendor control, that sort i
2 of thing, which fi-lied in all the gaps in that module with j I
3 the exception of design. ]
1 4 Now, 766 will reflect an 80 percent complete of
{
j 5 that module. The other 20 I haven't done specifically but j 6 I would venture to say that in going through s'eme of the 7 work that we have done in a totally unrelated area wouldn't
)
8 apply specifically to that. But I haven't taken the time l I
9 to try to figure out where that would be and it might be .
10 word while to do that.
11 Q (By Mr. Mulley) Let me ask some more general 12 questions. Since you've been out here at Comanche Peak, do l 13 you feel that you've had the freedom to identify, document i i 14 and report deficiencies that you find?
l l 15 A Absolutely. I've never in my time with the l l
16 Commission, which is approaching 18 years, have ever
- 17 encountered any difficulty presenting the facts that I feel I 18 are proper.
19 Now, I have not been so bu11 headed that I would
- ~
l 20 not listen to a challenge to one of them. When I feel like 21 that I*ve been right, I've stayed with it and that's not to l 22 say that I haven't been questioned on findings, I have 23 been. But I've been in a position more of questioning 24 people on their findings than I have been having my 25 ' findings questioned. But no, in no way restricted in l
TATE REPORTING SERVICE, (713) 222-7177 l
l
69 1 findings that I make but, you know, managed certainly.
i 2 Q Have you.ever been encourged by anybody at Region '
3 IV to try to handle findings in an informsl manner? ]
4 A No, just the opposite, just the opposite. I was 3
l 5 talking about a moment ago in this records area how that, u 6 you know, t.here are other ways to affect action. This is i
7 something that I'm sure whoever reads the transcript would !
8 not be pleased to hear me say. But I think everyone does 9 it, but they're certainly not encouraged to do it. They're 10 encouraged to write findings down when you have a finding, l
11 that's the proper and the appropriate ways of affecting 1
12 enforcement, is the mechanisms that are available to you 13 through the IE manual.
14 So just the converse, really. l 15 Q So there's been no effort to contac't the 16 licensee, discuss potential findings with them and have l l
17 them handle the matter without going into writing?
18 A Not apart from the normal way in which an 19 inspection is properly conducted. ,
)
20 Now, that involves discussing your finding with j 21 the people that you find it with. And when the people I 22 got reporting to me do not do that, I send them back out to ;
23 do that. 4 24 And what it amounts to is when you identify what 25 'you feel is a deviation or a violation, you advise the .;
TATE REPORTING SERVICE, (713) 222-7177 j
70 1 person that that is what you -- that's what your 2 conclusions are based at this time and do they have any l
3 information that would alter that. And that's the i
4 individual you're interfacing with. !
5 I always try to go at least one step higher than i
6 that and advise that person also of the potential violation u
7 that's been identified when it's done. This gives the !
l 8 organization an opportunity to develop any kind of !
9 information that I may have overlooked or the person that 10 you're interfacing with may not have known.
11 I've been bitten too many times in the past of 12 talking to this individual and he's, "No, we don't have 13 that.
14 "Well, it's required.
l 15 "Well, you got us."
16 And you write it down, say he admitted that it 17 was a violation.
18 Well, his supervisor says, "Well, the idiot 19 didn't flow where it was, it's right over here and it's
! 20 been over here for 20 years. And I'll tell that guy and ,
! 21 he'll know where it is next time somebody asks him."
22 But that's an individual giving an answer to a 23 question for which he didn't know the answer. That is why 24 I try to go at least another level up and advise that group 25 and this is all before the exit.
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1- In the exit meeting, you go into'the exit 2 meeting, you present your findings as they presently exist.
3' And the exit meeting provides yet'another' opportunity for i 4 the utility to come back with any additional information.
5 But by the time it gets to the exit meeting, the 6 people should know full well what the findings are' going to 7 be that you're presenting. And if they have some 1 \
l 8 information, they should have already provided it to you -i l
1 9 even then. So the exit meeting shoUld'go just 10 rick-tick-tick-tick-tick, i
11 Q How far into this process are you willing to 12 accept additional information from the utility? Let's say, 13 as you just said, okay, you go to the exit briefing; by )
( 14 that time, they'll be given an opportunity to provide i 15 information back to you. At the exit briefing, they 16 provide information. Okay, after the exit briefing, you go ,
1 17 into the stage of writing draft reports and getting out the. '
18 final report.
19 A Uh-huh.
20 Q How far into this process do you feel it's 21 appropriate for you to accept input from the licensee?
22 A well, certainly you don't accept anything that ,
23 might change your ultimate report after the report is' ,
24 issued.
25 But I have in the past' issued reports that I've TATE REPORTING SERVICE, (713) 222-7177 i
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1 amended because of information or errors in the report.
2 Errors work the same way. You may have been given 3 erroneous information, you put that in the report, it gets 4 issued or you make a mistake take and you amend a report 5 after it goes out. That's rather infrequent but that does 1
6 occur.
[
7 But I think you should consider information as 8 long as there's an opportunity to -- if it has an impact on l 9 the information you're putting in the report, you ought to 10 consider it until that report is issued.
l 11 I don't think that it would be proper to, continue 12 the inspection after the. exit meeting. But if during the 13 exit meeting they say, "Well, I don't think that's right,"
14 and they generate some paper and bring it to me, yeah, I'm 15 going do consider that.
I 16 And in the normal course of things, when 17 inspection reports are issued like 20 to 30 days after the 18 exit meeting, not very inuch happens during that period' of 19 time that you don't already know about. I 20 But if you identify something like the day before 21 the exit or the morning before the exit and that afternoon, 22 they haven't had an opportunity to really look at it so 23 they could generate some information in the interim that
. 24 could make the finding that you're presenting wrong, 25 ' incorrect.
TATE REPORTING SERVICE, (713) 222-7177
1 And certainly I don't want to put out an 2 c t roneous document, or document that's going to elicit a 3 response from the utility that says, "Well, the guy wasn't i 4 talking to the right individual. Of course this 5 information is here," or "Of course that drawing was l
revised, it was in the so and so and so and so and he was 6
7 looking over here."
8 The utility has a, you know, has a very good way l
9 and a very nice way of making you look like an idiot when l
10 you do something like that. And I don't particularly like !
11 that. I like to be right when I go out with a report, and i 12 so I'm going to modify it if information is provided to me 13 that says that something is different from my understanding 14 of the thing when it was identified.
i 15 That's why, that's why I like to get that 16 information as high in the organization as I can as quick 17 as I can so thhat I can get that kind of feedback; even 18 when I'm, even when I'm certain that the item that I found l 19 is a violation, I get that information up there.
20 0 Has there been any effort on the part of the Region to steer you away from QA issues and try to make you
~
21 22 emphasize more the hardware?
23 A Hardly. I never get to look at hardware anymore.
24 All I do is OA issues. They don't let me look at hardware, 25 'I'm telling you. You get that QA hat, and you're sunk. So TATE REPORTING SERVICE, (713) 222-7177
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) ,
74 1 ju.st about the only thing I have the opportunity to do is I i 2 QA/QC issues.
l l
'3 Q Have your inspections been confi'ned to the old.
l 4 issues, or have you been allowed to, if you find something l
5 knew, a knew problem, have you been allowed to go and 6 develop --
l
! 7 A Of course this task group was set up to verify 8 the implementation of the Comanche Peak response, CPRT l
9 plan. But in the context of that, we've been involved in 10 an ongoing activities out here. I also had the 11 responsibility to assess a number of allegations in the 12 QA/QC area. These have led me into areas of current 13 organizations and current programs which I have inspected l
14 with respect to the ongoing activities right here now.
15 So there's been, there's been nothing to restrict 16 us only to the antique stuff. In fact, we get into current 17 programs more and more.
18 Every time we look at something that's ongoing 19 right now, with respect to the CPRT, we're involving 20 ourselves in current programs.
21 An allegation that I followed up on not to long 22 ago was an assessment of a program that was being done away 23 with and another program replacing it. And I assessed both 24 the program and that was existing and the program that was 25 coming in, and had several violations with respect to the TATE REPORTING SERVICE, (713) 222-7177
75 1 previous program and the existing pro, gram. But it had 2, nothing to do with CPRT' effort, but.it was an extention of 3 the allegation assessment.
4 And just this past week, in assessing an 5 . allegation, I'm out looking at the warehouse and I find a l .
l 6 violation with two examples, of poorly stored material l 7 which was a condition that was alleged to have existed two 8 years ago. Another violation, current conditions.
9 Q Okay. That's all I have. Do you have anything 10 .you would like to add?
11 A Do you want to go off the record and bounce it i
! 12 around to see if you want to talk about some of these?
13 MR. MULLEY: Okay.
l 14 (Discussion off the record.) l l 15 THE WITNESS: Okay, 84-32, in'spection. November 16 the 7th, the date on this document here says '83 but I 17 believe it should have been '85.
18 Phillips sent Westerman a memo asking that a 19 number of open items that had been identified in previous 20 inspection reports, since they were in the general area 21 that the CPRT task group in Region IV was working on, if we 22 would take these open items and close them out.
23 In this area was a number of reports. The ones 24 that I particularly was involved with was a report 84-32, 25 'There were a couple of violations, an unresolved item, and TATE REPORTING SERVICE, (713) 222-7177 L
76 1 about, let's see -- there were eight items in that 84-32 2 that were open.
3 And Shannon in his memo to Tom suggested that I 4 work on these because they were in the QA/QC area.
5 Tom stuck a little note on the top of this and 6 sent it,to me and says, "Your guys should cover the audit I 7 issues; we'll need to reference them in your report." j 8 That says to me that we've got these findings !
1 9 that are open, we've got a response to them, close them out !
l 10 or status them in a future report.
11 Most of them dealt with areas surrounding the j I
12 audit program of TUGCO, both internal and external.
I 13 Internal audits being those audits they do of their I i
14 internal operation, external audits being of vendors and 1 j
15 those type of o' organizations; the qualifications of this 16 personnel, the schedules, those kinds of things that --
17 really 84-32 was based on in essence the findings that came 18 out of the TRT effort and, I feel, was the product of the 19 QA/QC function and during the TRT.
20 And the reason I say that is that about September
- 21 of '84, maybe October, Herb Livermore, the lead QA/QC on 22 TRT, we were gettinIg to the end of wrapping up all of our 23 QA/QC allegations and we were coming out with generic
. 24 findings with respect to what all of the collective 25 evaluation, if you will, of the -- allegations were saying TATE REPORTING SERVICE, (713) 222-7177 e
~
1
> - , 0 l
77
-1 certain things about the QA program at TUGCO and we were- i I
2 coming out with some generic assessments or findings with j
(
- ~
3 respect to the total program.
l 4 And these impressions were that management >was '
5 not involved in the past as they should have been in the 6 assessment of the quality assurance program; that the 7 quality assurance program, while it was being implemented 8 through audits of site activities, it was understaffed and 9 that it was not looking at the effectiveness of the program 10 but only looking at the procedural structure and the I 11 procedural implementation; and that there wasn't enough 12 hands on type effectiveness assessments being made; and a 13 number of other issues along the audit line.
l 14 Herb said, " Cliff, you need to go over and talk 15 to Shannon," who was working miscellaneous or testing 16 issues or some other issues in the TRT. And he said, "I l
17 understand that he's doing some work in the audit area or 18 in the TUGCO QA area, and be sure that our findings are not 19 inconsistent with his findings." ,
20 So I came to Shannon's trailer and said -- and 21 Shannon had two contractors working with him at the time, 22 and one of them was present, maybe both of them were 23 present at the time that I was there. And I said, 24 "Shannon, what are you finding in the area of TUGCO's QA 25 ' program?"
TATE REPORTING SERVICE, (713) 222-7177 C ______ _ _ ___ _ - - -
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78 1 'And Shannon said, "Well, I've been over in Dallas 2 for a week and my contractor has been over in Dallas for a 3 week and they're coming out looking pretty good." .
4 And I said, "Well, have you looked at the vendor 5 program?
6 "Well, no. I was going to look at that." j l
7 To me that said hasn't looked at it.
[
8 So I said, "Well, I don't know if you're aware of 9 it or not, but in 1978, TUGCO relieved Gibbs & Hill of all 10 vendor responsibilities, and assumed the vendor -- the 11 responsibility for the control of their vendors back in 12 '78. So they would have had to have some program in place I
i 13 all through that time."
14 And I said, "I don't know how well that's been 15 developed but it's certainly worth a look if you're looking l
l 16 in that area. ?
l 17 " Yeah. Yeah."
18 I asked him about the management inspection; he l
l 19 hadn't really found any findings to speak of.
)"
20 And he said, "Well, we still got some more work 21 to do in there."
22 I interfaced with him; I went back and I told :
23 Herb basically what the discussions had been. He said,
, 24 "Well, he doesn't disagree with anything we found but then 25 'lue hasn't looked in these areas either and hasn't found TATE REPORTING SERVICE, (713) 222-7177 l
9
. 4
, 79
~1 anything in these areas so it's not going to disagree with 2 what he's saying unless he comes out with some' statement 3 that everything's okay and we're saying, " Bey, gleon and 4 doom in a few areas here."
5 But I said, "I told him what we're finding and if.
'6 . he's got a probles, he's going to get back with'us." , ,
7 se never got back with us.
l 8 Then in about I guess November or something like
- +, .: ,1 9 that, we had a meeting down here and with .1,,'
- . . ~ ..'g.l'and 10 Gay 1Tudo,' serb, myself, and shannon, to discuss a draft of
~ "'
.. . .7. .":
11' this'84-32. ' w:. .
- .v -
12 ' 'Well, it looked just like the'1etter we had been i 13 working on that's in this ssER-11 that was dated January 44 the 9th that we .sent.w A lot of the findings looked like l 15 the same findingQiat,; we. we,rg identifying .and we. made,that 16 statenest that a meetish j. sNid,' 'Looks Io' melike'
! 17 that you're preempti.ng information'..that we're providing in l 'f.
l 18 SSER'-11; you're making violationsfout g ,
of the things that Y ^
' we had already identified, that we' vie"identif'ied here." ' ~~
20 "Well,.there's nothing wrong with that, that's ,
21~ okay." That was management's approach to that.
22 Well', that's.true. There's nothing wrong with 23 that. This is going to hit the street long before this 24 will precipitate any kind of action. And se it went ahead 25 "like that. That report that we discussed in draft was .
TATE REPORTING SERVICE, (713) 222-7177
e .
l 80 -
1 changed drastically from the way we saw it in draft and the
,2 way that it was finally issued.
3, Q (By Mr. Mulley) who changed. it,' do you know?
4 A Don't know. ' UIS., ._ and Shannon were the ones 4x 2:L -n : ;.7 ;
5 working on it. I would assume that, [.~;e4 change'dit.
, j
- - ,4- r Probably in concert with Shannen; I, don't know. But 6
- 7 anywdy, the thing case out like.this.
8 And of course I went to D.C. and was up there for
~
9 six months working on the ssER-11, and we saw'the report 10 when it 'came out and noted thai., " Hey, it's dra's'tically .
diffe.ren i l1 than it was-when we..
.w re
- dis
..e ,
ssing'iti In ~draf t,"
12 but we j st put it aside, we ha'd.our or work to do..
13 .
- I get back down here and in.the summer.of '85,
+ :p .. , ,.,, ,
14 and this comes to me later on. 84-32, I remember seeing 15 the NRC
'theresponseandthe.responsethat.was.ayg 16 said basically that it invited this respo ~nse ..n....~ e .
.z.
17 utility opted for the _ response, that if you would'like you
%5i.L . ,
18 .
- maywaithfortheresultsoftheCFRTprogran,to.providethe
- m. . .s .... .
j l .*I -
- g. .
'19 action and that sort of thing for this. -
+
e .
. ..w . .
l
. .. .a ,.
20- Well, they opted'to accepti'tiha't, which does not- i i ~21 give you any basis to close out something.. A restilts 7- .
22 report issued by the CFRT.is.not. going to'respondi ,
, g.y ,
23 specifically to these violations, perhaps, in'a way that we 24 can follow them up.
25 so when I got this meno saying go out, check the i
TATE REPORTING SERVICE, (713) 222-7177
P 81 1 status, and do something with these, the only thing I was I i' 2 left to do is go out and try,to close them on the basis of 3 the information or the program that existed then and what 4 the finding was then; I couldn't base it on the final 5 product of the CPRT because it's not out yet and won't be i 1 6 out for who knows when.
7 So I went to Dallas, I did an ' audit of this as 8 though I were doing a re-audit of these same areas looking 9 at these same things, and made the statement in the report, 10 which hasn't been issued yet, by the way, that they had not !
11 responded to these things but here are the actions they've 12 taken in response to these violations that were identified 13 and on the basis of these actions and on the basis that the i
44 NRC is' tracking and will track the resolution of these i
15 ISAPs that have been generated in response to these things,
]
- l 16 we will be tracking those on an ongoing basis, but we're 17 going to close this item as far as an open item because 18 we're covering these same issues in our coverage of the 19 ISAPs. , ,
20 That's the way I proposed to close out each one 1
21 of these violations that were identified. As I say, it has 22 not been issued yet. I spoke one time to Ian about it and 23 Ian said, "I don't like the idea of closing them," and I 24 can understand why he said he doesn't like the idea of 25 " closing them and that's because the response has never TATE REPORTING SERVICE, (713) 222-7177
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82 1 really come back to them so how can we close a violation if 2 we haven't really gotten the response.
3 And it,'s got merit there. But we're tracking the 4 same thing in two different systems, and all I'm saying is 5 let's get rid of one of them we're tracking on here and 6 they have properly responded to these things, they've 7 l already taken action to correct these things. s 8 Q These things being --
l 9 A The violations identified in 84-32. So why don't 10 we document, while we are doing that, say that satisfies 11 our concern and in addition, that the long term effects or 12 the preventative actions effects, those things are being, 13 those kinds of actions are being, are going.to fall out of I
14 the CPRT program.
15 But I don't know what the status of that is going 16 to be. In any event, I'm for closing this out.
17 I'll look at this 86-06, 86-08, and Shannon who 18 turned this thing over to Tom and said that I should take 19 care of it, he's given a status in there and he's got the * )
y 20 things open in his reports and even got another violation i
21 stuck underneath one of them as a further example, j 22 And I became a little bit insensed when, you 23 know, when I saw that. I mean, if he wants to do it, he j i
24 should have kept it. If he wanted me to do it, then he 25 'should keep his hands off it. And that's basically what I TATE REPORTING SERVICE, (713) 222-7177 I
4 83 1 told Tom.
2 And I hadn't told Shannon that but I haven't had 3 an opportunity. . I'd tell him -- if he wou'1d like to. hear 4 it, I'll tell him that.
l 5 So any way, that's what that is. I don't know 6 what's going to happend there. If that thing-is going to 7 stay in there open. If it's going to stay in this one. '
-8 open -- this is an April /May report -- then I'm going have l
9 to change my January report because I closed it in January.
10 Q (By Mr. Mulley) And for the record, when we're 11 talking about -- you did a lot of pointing -- these things, .
. 12 you're talking about the findings in 84-32/11- as closing 13 that out.
14 A I don't know if the 446 docket is 84-11 or not.
15 '84 -- I just wrote down the -- the 445 docket number on 16 that thing. It's 84-32.
I 17 0 84-32 is slash eleven. l 1
18 A And it deals with TUGCO audits of -- oh, no,. l 1
19 that's not one. That was one that he'put down here as an 20 open item which had been closed two years prior and he had l i
21 open down here but it has to do with failure to review the 22 QA program, failure to develop audit prccedures, failure to 23 verify compliance with.the QA program, failure co audit 24 Westinghouse; failure to audit vendors annually, failure to 25 certify vendor inspector, and then two unresolved items, l l
j TATE REPORTING SERVICE, (713) 222-7177 I
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i 84 1 the number of audits slash auditors, inconsistency there; 2 and the other unresolved item is weak on site vendor 3 surveillance.
- 4 Q So the first citations you read are --
l 5 A Violations. The last two were --
1 6 Q Unresolved items?
l l
7 A -- unresolved items, in the 84-32 report.
8 Q And some of these, again, appear in --
- 9 A This draft that I looked at.
10 Q 86-06?
i 11 A 86-06/08, and the section under status of 12 previous inspection findings.or action on previous 13 inspection findings. Here's one that he has open, and it's 14 one of the violations; another one, one of the violations 15 still open; just trying to see which one generated another 16 violation. I don't'see that right now.
17 Well, anyway, we don't want to get into this I 18 guess into this report, because it's is still in draft. I 19 guess that's -- I don't know what other kind of information 20 you gentleman might be after but I can't think.of anything 21 else that might be, that might be pertinent to the record 22 you're attempting to develop.
23 MR. MULLEY: Okay.
24 (Statement recessed at 11:55 a.m., C.D.T.)
25 TATE REPORTING SERVICE, (713) 222-7177
I s 85 1 THE STATE OF TEXAS:
2 COUNTY OF HARRIS:
- 3 l 4 I, R. Patrick Tate, CSR #1730 and Notary Public 5 in and for the State of Texas, certify that the facts as 6 stated in the caption hereto are true; that the proceedings i
! l 7 indicated were had before me, and the same were thereafter 8 reduced to typewriting by me or under my direction. i 1
l 9 I further certify that the above and foregoing i
10 transcript as set forth in typewriting is a full, true and j 11 correct transcript of the proceedings had at the time 12 indicated.
13 In testimony whereof, witness my hand, this 26th day of June, 1986. l 1.4 j 15 !
/ /
16 My Business address is: /
w- (. A --
1712 Esperson Buildings R. @atr'ick Tate, CSR #1730 17 Houston, Texas 77002 Notary Public in and for My current certification the State of Texas 18 expires: 12-31-86 My Commission Expires: 10-27-89 19 20 -
21 22 23 24 25 TATE REPORTING SERVICE, (713) 222-7177
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