ML20244A804
| ML20244A804 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/20/1984 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| Shared Package | |
| ML20097F079 | List:
|
| References | |
| FOIA-84-487 NUDOCS 8906120151 | |
| Download: ML20244A804 (33) | |
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\/ hi-l,*NITED STATES OF AMERICA j.j
) NLcLEAR RIct LATORY COMMISSION ff'd u .c j, i *s a V h.n [bs et
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l In the matter of: 1 TEXAS UTILITIES ELECTRIC COMPANY, et al Docket No. 5 0-445 50-446 (Comanche Peak Steam Electric Station, Units 1 & 2) I 1
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IN CAMERA SESSION - l Ceposition of: Location: Glen Rose ,- Texas Pages: 100 - 130 Date: Friday, July 20, 1984 Information in this record was deleted in tc:ordance r::b the Freedom of Iriferraatica Act, exemptions F0iA. _ TAtLot ASSOCIATES Coun Reponers 8906120151 890607 ten I sitwi. N w. Seu taas EB B7 PDR * *** * ** 0 C "
. 1202mm
100-fc/mn-1 1 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 2 3' BEFORE THE' ATOMIC SAFETY & LICENSING BOARD i- 1 4 5 ---------x In the. matter of: : 6 7 TEXAS UTILITIES ELECTRIC : COMPANY, et al.
- Docket Nos. 50-445 e : 50-446 (Comanche Peak Steam Electric :
, Station, Units 1.and 2) : ;
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'I Glen Rose Motor Inn 12 Glen Rose, Texas 13 July 20, 1984 i
) 14 15 D e p o"s i t i"o nY of:
( (IN CAMERA)
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called by examination by counsel f or the NRC staf f. 37 taken before J. F. Couglin, Court Reporter, 18 beginning a t 12:55 5.m., pursuant to agreement. . J 19 I f , 20 ! 21 l F L 22 . g Staff's Discovery Deposition: Volume II. 24 : 4 25 1[ . 4 I
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~l 1 APPEARANCES:
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On behalf of the Applicants, Texas Utilities Electric 3 Company, et al. ' 4 MARK L. DAVIDSON, Esquire i Bishop, Liberman, Coo, Purcell & Reynolds ! 5 1200 Seventeenth Street, N. W.
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Washington, D. C. 20036 ' 6 j On behalf of the Witness, Danny Walter: 7 i MICHAEL L. SPEKTER, Esquire ; 8 Suite 1102 1717 "K" Street, N. W. t 9 Washington, D. C. 20006 ! l 10 On behalf of the Nuclear Regulatory Commission Staff: I 11 GEARY S. MIZUNO, Esquire GREGORY A. EERRY, Esquire 12 Office of the Executive Legal Director i U. S. Nuclear Regulatory Commission 13 Washington, D. C. 20555 l l I 14 l 15 16
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@/mn 102 D 1 I ND EX 2 3 WITNESS: . EXAMINATION 4 ;. . _.- .- L .:. -w-S By Mr. Mizuno 103 6 7 8 9 10 11 12 EXHIBITS 13 D 14 (NONE)
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16 17 18 19 ! 20 21 22 23 24 25 w_--___-____________-_----.____---_.--- -_ -
1nt -11 /mn-1 1 P R0 C E E D 1 N C S 2 Whereupon, j j 1 3 - i : SJ' {
, a witness, was called for examination and, having been !
5 previously duly sworn, was examined and testified further j 6 as follows: i 7 EXAMINATION 1 i t B BY MR. MIZUNO: q l 9 Q Do you know who Larry Howard is? i 10 A Yes, I do. 3; Q Do you know what his position is? 12 A Now? 13 Q At the beginning of 1984. ja A Yes. He was an electrical test group craft 15 personnel. 13 Q Was he the person who observed you being told 37 by Mr. London that you were walking on thin ice? 18 A 1 do not believe that the walking on thin ice 39 was by Mr. London. I believe it was by Fred Powers. 73 Q Fred Powers, all right. So it was Fred Powers 21 who told y ou that you were walking on thin ice? 22 A Correct. ~ 23 l Q Did Art London join you at some later time? 24 A Join me and Fred Powers? 25 Q Yes. -s ~_.Y
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nm.i y d J I ! A Yes, he did. 2 Was Mr. Howard Frill there? Q q j 3 A I do not r e n4e mb e r . Q You do not remember. During your conversation 5 or your argument with Mr. Powers was there anyone else besided j 6l -y o.u and Mr. Powers and Mr. Howard? 7 A I do not remember. It was in the chart-up I B trailer offices. There could 1. ave been other people walk'ing j throtsh and around.- 10 1 Q No one who was waiting alang with Mr. Howard? !
'I I believe there possibly r.ould'have been i
A i 12 because with Mr. howard I had additional" craft' personnel. 33 They usually run in pair.. so he very well could have had I# somebody with him. 15 Q But you don't recall? i 16 A 1 don't recall. 17 Q Do you recall anyone accompanying Mr. Powers? 18 A Yes, I do. 19 Q Do you know how that person was? i 20 A I do not remember who that was. 21 Q Do you recall whether he was a supervisor? -'
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A I do not remember. I do not recall what his s 23 i positten was or who be was. i 24 Q Do you recall him being as part of the start-up ; 25 grcup? , i 1 i i i f-. l
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1 1 i 1 A I do not. 2 Q On page nine of your affidavit, let ma read'you 3 a sentence which states, "I am further concerned because 4 the test instruction provides no guidelines that assist an 5, STE in determining when energired functional testing is i 6 impractical." Do you see that portion of that sentence? 7 A (Revtewing documents.) 8 Correct. 9 Q When you refer to test instruction, you are 10 referring to the prerequisite test instruction XCP-EE-8?' 11 ' A Yes. 12 Q Do you recall our discussion yesterday about 13 the sentences prior to the sentence I have just read you 14 referring to the fact that since tests performed during 15 prerequisite are not necessarily repeated during preop, this 16 means that it is possible that a component can pass through 17 those stages of testing? 18 A 'les. 19 Fine. Q I assume that the' fact that you are 1 20 concerned thct test instruction provides no. guidelines 21 that assist an STE in determining when energized functional 1 22 testing is impractical is separate from the concern that ' l 23 you were discussing last night? I 24 A Correct. I believe so. 25 Q All right. Did you ever make your concern that-I l ______.-_--_--J
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'there are no guidelines'to assist an'STE in determining 2-whether energized functional testing is impractical:to your 3
supervisors? d A -Yes, I did.- 5l Q How did you d'o'that?- 6 A I.' brought up the procedure,in the note that there 7 should'be no reas.on possible that can be given to where a 8 deenergized functional-est would suffice as-a form of. functional testing. 10 Q This~ note that you wrote -- II A I am not sure'if I wrote a note or not'but'I _l 12 ~! did bring the' concern'up to TomI M111er ide.nti4ying.that the d I3 ( note was inside the s t a t enaen t and the note, I believe..'is-in Id quotes. I indicated to him that there should never be an 15 occasion - you see, they were informing me,that this' note 16 was put in there that in case -
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A 1 am leading off again, I will' stay to-the. ; l' :i question. 20 Q Let's start again. You indicated that.you ) 21 i brought this 2oncern about the lack of. guidelines for- -l 22 determining when energized. functional testing is impractical- ^! 23 .! to the attention of your supervisors? <
'4 A Correct. l 25 Q You also 1ndtcated that you didn't know whether D
107 1-5 1 you did it orally or whether you did it in written form. 2 ( Is that true? 3 A True. 4 Q Could you have done.both? 5 A Possibly. 6{ Q But you do not recall whether it was both or 7 one or the other? 8 A I know it was at least orally and I am not 9 positive as far as the. written. 10 Q So you were certain that you did it orally i i but you are not sure whether you also did it'in written 12 form? 13 A Correct. 14 Q If there was such a note, would it possibly be 15 contained within the notes that you brought with you? } 16 A No. it is not. 17 - Q Would it be contained within the documents that 18 you have at home? 19 A 1 don't believe I would have-a note associated 20 with that. 21 Q All right. Would you have made a log or a note 2 that memorializes your telephone call with Mr. Miller on.this 23 matter? , 24 A I don't believe I called him. I believe I went 25 to his office and I don't believe I had a log of that. i j s . I
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i 1 Q All right. Can you check your records for e' note i i 2 which may have memorialized your oral conversation with Mr. -l l 1 3 Miller and also any written notes or memos that you sent to- ! i 4 Mr. Miller? ,' l 4 1 5 A I will. ' l 6 Q Or any other person on site regarding this f
- i 7 problem?
l 8 A I will. l l i. nd#1 9 5 10
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/mn >l f 1 (Discussion of f the record ) 2 SY MR. BARRY: , [
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3 Q L. if a record were made would you be '
- _.y 4 in possession of it?
I 5l A I would believe that I would be in possession 6 of a record involving these incidences here. 7 0 So consequently if you don't come with the 8 record, is it f ir to say that there was not a record made? 4 A No. I left large amounts of records in my desk to even at the site. There were notes written all over those 11 ' records. I don't remember exactly what records I took out, 12 which records I left, which ones were handwritten person notes 13 either way. I have also as indicated earlier that I have 14 given GAP documentation and I do not recollect or remember 15 what documentation I have given them. 16 BY MR. MIZUNO: 17 Q
}{ 'the documentation that you g e v e ...t o .
1B GAP nr CASE, were those documents derived from your files 19 at home or from the documents which are contained in your 20 briefcase? 21 ! A I may have possibly even given them my documents 22 that I had but I do not remember which documents I gave to ! i 23 them. 24 Q Perhaps you misunderstand me. I am asking 25 whether all the documents that you gave GAP or CASE, whatever
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) I they may be, were derived entirely from your own files.
I your own documentation?
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A 3 Yes, they were derived entirely from my own 4 files. i 5, All right. Q Now you indicated that you brought 6 this to the attent 4 '> n of your supervisor, Tom Miller, in 1 7 some fashion. 8 A Yes. I { o s Q But you don't necessarily recall in what fntm? j l 10 A Yes. t'
;! i Q Did Mr. Miller pursue your concern tu ycur I
'2 knowledge? i
{ 13 A I believe so. 3 y 14 i Q k'h a t wat that? i 15 MR. BERPY: May we go off the record f or a j lo second? i 1 17 (Counsel conferring off the record.) 18 BY MR. MIZUNO: i -~= { y. to Q p ,I believe the question was what was - A c 2 20 , your knowlcdge of what Mr. Miller did to follow up your 21 concern? ' 22 A I know that he had listened to me during my 1 23 concern. de may have spoken to Art London concerning it, 2A too. i 25 Q Did Mr. Killer ever tell you what he did?
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l 1 A I do.not believe he did.. 4 2} Q Did you ser rece?.ve any kind of response l' rom n i 2 any of your supervisors or from any.Other organization.whetle{ 4 1 j on-site or off-site regarding your concern involving , S 4;uidelines for determining.whether energized functional 6} testing is impracti6al or not? 7 A Tormel as in tylt!ch form or verbal?. B Q Uh -- 9 A
! I received no' formal form. 1 did receive verbal 10 f.orm. l 1
l 11 Q By t' o rm a l , y.au mean that you received no l 12 written? 13 A Correct. ' 14 Q But you did receive a verb'al response you IS indicated? (
-l 16 A Yes.
17 Q Where did that responscLcome from? 1 <B A Art London, i 19 Q Do you at what tire.Mr. -- - - 20 A I don't know bcw much rika frane had elap's'ed 21 from me bringing it up to Tom Miller-and Art London. i 22 Q Do you recall whethei you felt at the time 23 that it was an unduly long period? 24 A The problem that 1 addressed they felt had.no ( 25 immediate significance so it could have taken a st a r t e r. i 4-
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.perind of rima but yet I think I am'nct even sure if it took 2
& week but it did take a couple of severa] days, I believe.. i 3
Q Do you now believe that it took him an unduly long time for them to get back to you? [ i A No. I wil'1 not make that statement. They had- i 6 other workloads that were present at the time. 7 My original questie'a to you though was a'little I Q 8 differant althongh the information that you did give me 4 l was also information that I wanted. My original question 50 was in what time period did you inceive a' response? In i II ! other words, a date, a month? i i 12 A I I don't remember the exact date or month on th.at. u 1, I .1 Q Plight. It was in 198(? I I' A I believe so.
"' C Was it towards the end of youi employment I
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period? 17 A I don't remember. It was not towards the tail IB end. I do not think t. h a t I had already given notice. Q All right. What did Mr. London tell you in his
'c cral respo'ase to you?
l ! i Ul A That it was their feeling that it.y eliminating l 22 i the note it put too stringent of restiietions or left the 23 I possibility that they would have problems in doing that. ! 2# He could not identify the p rci> I em e but he did not vs.n t to 25 remove that note. I
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1 Q Let me return'back to your.--
! .1 THE WITNESS: Can we break.just for one qui; . !
3 ! minute so L can talk to counsel? j. j MR. MIZUK0: Fine. ' l ' 5 I (Witness and counsel conferiing.) {d 6 2ncl# 2 I a l' 7 8 ! I. i 9
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114 ge/mn 3-1 1 BY MR. M12UNO: (Resuming)
-s 2 g .when you first made your concern l
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3 known to Mr. Miller, what precisely did you tell hin? d A The exact words I cannot remember right now. l 5 j The inf orma tion t hat I was relating to hi.a was that I felt l 6 that there was no reason to have that note in the procedure s 7 in the fact that there was never a circumstance that could j a arise that would require deenergized functional testing to be perfctmed. N Q Sc you did not tell him that your concern f 11 i was that th9re were no guidelines to assist an SIE in i 1 12 determining whether energized functional testJng is 1 l i 13 ! impractical? Rather you told Mr. Miller that you could not Di 'd 1 foresee any reason why deenergized functionci tecting i 15 i will suffice? Is that the case? I to A I may have brought that up, also. Part 6f the 17 argument is that there As never any reason to do deenergized ' M functional and even with your note implemented in here, I you don't define under whar conditions you can do deenergized 20 functional testing. It just leaves it dp to the discretion 21 of the ST2 which eculd be anything or a number of things. 22 I believe I related that question to him 23 possibly in th e examples or scmething. Maybe I am not 24 answering your question. I 25 Q No. You answered my question. If you believe 94 es - .- i-W 1 l
I 115 1 i that deenergized functional testing'is never'ressonable 2 then why are you concerned about guidelines'to determine. j, 3 whether an STE should perform the energized functional t.esting? 1 :i 5t j A It was used as an example or a phrasing t o a tr ,. 6 example. .i . ( 7 Q Why don't you describe the example? l-A the example being that a compo;aent -- cabl'es a r.e 9 liftsd and by lifting the cables the cables are reterminated-10 ' again. The subsequent retesting for that should be an~ l 11 1 ' energized functional check but under this procedrue and the I 12 I notat. ion there, it was allowing STE's to not perform an j 13 14 energized functional test, to perform a deenergized functional 15 test which as indicated in this statement cannot be documented o r j u .s t i f i e d on the test records because th6ra.was no
\b -l "was it deenergized or was it energized <"
17 My concern to him was that that is a problem 18 in itself. 10 Q Did you tell Mr. Miller th.ts? 20 A Mr. Miller did know that there was deenergized 71 functional testing.
'22 Q Did you tell him the substance of what you are 23 saying now to Mr. Miller?
24 ' A Yes, in one or note conversations or in one .o r 25 more different words. 6
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'l Q So you had more than one' conversation with Mr.
2 i Miller where you expressed your concern? . 4 A Yes. A Q Did you tell Mr. Miller or indicate to him that i 5 i you also had a separate concern that there were . 3 6 nofguldelinesj- ! s to assist an STE .in determining whether energized functional ! 7 l testing is impractical? \
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8 i A J. believe so. I believe that came up during the j o I conversation. ' 10 l Q All right. Now Mr. London's response to you 11 1 indicated that they could not drop note one to secti.on.'7.8 l 12 I l of this prerequisite test instruction? 1 j
;3 A Correct.
14 Q Did he indicate to you why? 15 A Yes. 16 Q What did he say? i 17 ! A He indicated in words to the effect that he 3 1 F 'l felt that it locked him in to always performing energized -)' 19 functional testing and he felt like it would put a hamper
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j 20 ! i cr slow down on the testing procedures to the extent that 21 it would require functional testing on al.1 circuits instr.ad I of being able to do deenergized functional testing and would further slow dovn the start-up process. 24 Q Did Mr. London tell you anything else .in this i i conversation? ' i
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j l 1 I A 1 don't remember at this time. 2 Q Did he say'anvthing else with regard to your i J 1 3 concern in this conversation? l
# 1 A During this time' period it may have been --
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5 now 1.am saying "may have been" because i have already j a o indicated that I don't remember the exact dates and. times ; l 7 but this time period may have been the fact that he was ' i 4 8 i J going to if I could find all these problems that'I maybe could do additional workload ca the site. i 10 Q Apart from that, the statement involving j
!. i Il finding p r o b l e n.s and doing additional work, did he further l l
;- 4 12 discuss with you the technical merits of your concern ! l 13 :
regarding the fact that there are no guidelines? i Id A 1 do not remember if he did or not. Id#3 15 1 16 17 10 19 - l i 20 21 22 23 l 2A l 25 l l
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I 118 . 6 e/mn (
, BY MR. MIZUNO: (Resuming) 2 0 I am going to read you the remainder of your l
3 last sentence in that paragraph which beings, "And there 3 is no notation on test documentation that indicates the ! 5 i functional testing was deenergized." Am I correct in 1 1 6 assuming that that is a separate concern of yours? '
, A Yes. j i
g MR. MIZUNO: May we have just a short break? q g MR. SPEKTER: Surely. (
,g (Discussion off the record.) j 33 MR. MIZUNO: I would like to thank both counsel 12 and the witness for indulging the staff in the short break.
13 MR. SPEKTER: It is our pleesure, Mr. Mizuno. g BY MR. MIZUNO: (Resubing) < c 0 l you indicate here that one of your 15 v y concerns is that there is no notation on test documentation. g Which test documentation are you referring to? A The EE-8 test procedure documentation such that
'. 8 39 they take a print and stamp it with an SCP-EE-8 stamp 20 and thst automatically becomes the test documentation.
21 Q I see. In other worda, there are many copies 22 1 f this test instruction with blanks to be filled out? 23 A No. The SCP-EE-8 test procedure has no blanks 3 in it to speak of and that test procedure is not actually 3 turned in. It gives instruction on how the test and l I\ J
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1 1 tells you what acceptance eriteria you will specific and l
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2 in the documentation that that test-was performed will be on j L 3 a print such as a termination print or a control circuit t
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print thac has been yellow highlighted indicating that those 3
! i 5 components h a ra been tested. ,
i 6 Q What do you mean by a print? Do you mean a. 7 computer printout? h, 8 A No. I mean a print such as 2.3, 2.3-E-1-100 or t { 9 something. I :
'J e are talking about physical plant prints. I !
10 If you would like to see one, . I believe.Mr. Davidson had ! 1 i 11 one in his information that he had brought-to the hearing j
!. 1 12 earlier. '
13 Q Are you referring to' drawings? I l 14 A Yes. 1
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15 Q You are now indicating that there are spaces on .! ] i 16 the drawings for you to indicate that systeus have been i 17 tested? ; 18 A The way this procedure vould go would be tha: i 19 you would take a control circuit drawing aut with you 20 and a termination print out with you. You would verify- ' 21 termination from point "A" to point "B" and you_would elso j 22 have a control circuit printout there with you and thle 23 would have light indications and relays and all. As you j 24 tested the system, you would highlight these terminsfion 25 points from point "A" to point "B" indicating r. hat you_had !
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I verified they were terminated correctly and that they 6 2 I functioned correctly and then you would go to the system ! 3 '1 l print which identified the components and you would yellow- ;
'd line through that' indicating-that you had performed,a 5
functional test there. 6 The reasoning for this last s"atement is.that 7 i there is a stamp -- l 8 Q Stop there. 9 A Okay, 10 l Q When you say " highlighting 3" you meant using a i 1 11 highlight pen where you can see through'-- I 12 A A yellow highlight pen, yes. 1 k 13 i Q On these prints, I believe you mentioned'two 14 different types of prints. i 15 A Yes. 16 Q Is there any space or designated area for you.to 17 sign your name or indicate your initials? IB A They have a rubber stamp which is red ink and you ! 19 will take that rubber stamp and stamp it in the-red ink and 20 then stamp an imprint onto the document or the drawing and. 21 by signing that block, you are indicating that you perfcrmed 22 the highlighted sections indicated above. : I 23 Q What are the words on the rubber stamp? ! 24 A Test record and then it will require, I believe, 25 test proceaure and then you will place in there 'XCP-EE-8 and l 1
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12r i system number across the top and that would be about the information without going into the signature block.. l 3 Q There is a signature block there? s A Yes. [ S Q How is the signature block identified?- ( 1 6 A Performed by, reviewed?by and that is;it. 7 , Q All right. What signature block would you l' I 8 sign, the performed by signature area or the reviewed ~by 9 signature area? 10 A i I could sign both bloc.ks.
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11 Q All right. What is the difference between 12 performinh a. test and reviewing the test? 13
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A They 'nad craft personnel signing the performed by J! , 14 li block, 1 i 1 15 Q All right. l e 16 A The reviewed by block even though it says j I
" review," was defined L+y upper level management to be s
18 a actual -- when you sign that, you are taking responsibility that that circuitry is correct.
^0 Q This is y.our concern that la related on-pages I 21 four through five of your affidavit?
22 A (Reviewing document.) i 23 It does identify another concern in.pages four 2# through five, f
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' i Q Now let us suppose that a craft person _does the t
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122 1 test and he signs the " performed by" area signature block, 2 what does the craftsman do assuming that you were the person 3 who provides that particular test? 4 A If I was the person -- I ran my testing not ) necessarily in line with the rest of the 'other syetem test 6 engineers. They felt 1.4ke I always spent too much of my 7 time out in the field. I would collect the documentation, 8 grab the craft, we would go into the field, I would direct 9 them as to place jumpers here or lift.this wire right 10 through communications throughout the plant and I would be 11 marking up the drawings and indic.7 ting what was being te s ted- i l and what had been adequately functioning. 13 Q This occurs after the craftsman has signed 1 14 i '
" performed" the test?
l 15 A No. l; lo Q If that is not the case, I want you to confine I 17 yourself to the situation where a craftsman performs the , l 18 1 test and then sign? the signature block indicating that he 19 performed the test. 20 A Okay. Q At that point, what does he do? 22 A He would bring it back over to the engineer 23 that he received the document from and give it to him.
'4 Q Suppose that person was you,'what would you do at that point?
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1 123 1 i 1 l A On an ICP-EE-8 I cannot' remember inscances 2 where 1 did not go out into the field with them. Wit'a t 3 other STE's, they sat in their office and the documentation 4 was brought back to them and he looked at it to make sure i 5 all the information that they expecte.d to be highlighted j 6 was highlighted and that was it. They signed uit. i l 7 ! Q In your mind-by signing the " reviewed by" 8 {i signature block, what does that indicate? ! A It indicates and it was told to me several times 10 I that you are responsible to the fact that that circuit ! II would function the way the print showed'when you sign it. >nd#4 I2 ! There may be a more clarified answer. l 13 14 is 16 , i 17 18 19 20 21 , 22 22 2A 25 i r .. s ,
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124L , c/mn l d i 5' ' j; 1 Q No. Just_end is right there, please. 2 1 1 Now these two types of prints that you were 1 3 ' talking about, those prints sre what you considered to be R d the . test documentation that you were referring to in the . I I 4 i 5 l last sentence in your affidavit, the lest. sentence in'the j. 6 para 6raph on page nine? 7 A (Perusing document.) [ i-B Correct. I 9 Q Your concern is that -~
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10 A You said that thesa~ documentation, the reason {
\ ib 11 that there is no comment on there I will submit that on my 12 test documentation I made handwritten notes that I'was only ] :)
i i 13 performing phoning of cables not actual energized functional 14 testing as a general rule. 15 Q l guess by the fact th'at you say that you hand 16 wrote in some potes that this was above and beyond the 17 requirements of the test procedure? 18 A Correct. 19 Q Your concern was that the test procedure did not 20 havte a requirement for the crafts person or the engineer, 21 the STE, .the reviewing engineer to indicate whether the test ~ 22 was done in an energized or a deenergized state? 23 A Correct. 24 i Q These prerequisite testing, the documentation j 25 that you generated as a result of performing these i
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h 125 l-1 prerequisite tests and in particular, I am referring to the-2 test procedure-that we: have been talking about' theJ XCP-EE-8. 3 A Yes. 4 Q Were the test documentation reviewed.by a QC- ~ 5 inspector? 6 A No. l 7 Q What happened to these prints,-to this test B documentation once you had. completed your. signature? ! 9 A Once I had completed my signature', once the 10
" performed by." and the " reviewed by" blocks'were signed, 11 the test document in question went over to a computer-12 system for them to log down that ~this test had been 13 performed and then it was seht over'for filing'to the h
w- 14 best of my knowledge is how~the system ran. 15 Q What computer system was that?' 16 A 1 don't know exactly which' computer system. 17 About halfway through the process they decided to start IB trying to note what procedures were performed'so.that;they 10 could have easy recall on documentation. The - computer 20 system basically listed that an SCP-EE-8.was performed on 21 this system on this date. .That is the information that it i 22 gave. 23 Q fth'roughout'this three days of . 24 deposition you have been' spending time talking about the ! { I 25 fact that there were several instances where you felt you
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l 126 i I l l I were intimidated or. harassed. As a result of these actions I 2 ) did you ever during your time at Comance Peak fail to j ) 3 ! properly perform what you believe was necessary because l d of this intimidation or' harassment? - i 5 A 1 believe I may have dropped some-issues due to- -i 6 the harassment instead of pursuing them.. Accordingly, I 7 may have just dropped them. 8 3 9 Q When you say " dropped them."'you mean'not ! i l 1 bring them to the attention of your supervisors? { 10 t' A Correct. .) II l Q Can you recall any of them at this time? 12 A I d o no t remember at this time. - 13 Q Wete these issues that you cannot remember at j Id' -1 this time, do you recall whether any other engineers in the 15 i start-up group had concerns that were the ones that you ! 16 dropped? 17 A 1 am aware that several others -- well, this
'8 is going to lead into your asking me where and why -- several I'
other start-up engineers had the same concerns that I did : 20 !' and additional concerns but did not voice their opinions I 21 due to the problem. 22 i l Q I don't want to hear why they didn't voice their . 23 concerns. l 24 A Okay. 25 Q But you are telling me though that these
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_ : .- n . - _ -w TM " 127 1 inspectors or engineers that had concerns similar to yours 2 were not brought up with their supervisors? 3
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A Correct. s Q What is the basis -- 5 MR. DAVIDSON: Excuse me, Mr. Mizuno, but I_ 6 l could swear that[ ] testified that he didn't 7 remember what concerns they were and now he is saying that 8 he remembers though that other people shared those concerns 9 and I am wondering how he could possibly make that Connection. II MR. MIZUNO: That is right. That is far someone 12 else to decide how he can do that..
-. 13 MR. SPEKTER: I think that is arguing and I
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Id would like him to answer the questirnt, please. 15 BY MR. MILUNO: (. Resuming) 16 Q I would like to know vhat is the basis for 17 your believing that other engineers had the same concerns
'8 that you did vbich you did not pursue?
Io A I would sp.eak to other engineers with problems
'O that I had brought up such as butt splicing and --
21 Q Excuse me. You are now talking about problems 22 which you brought up. I want to limit your discussion to 23 those problems where you said you can't remember what they
'4 were but you definitely remember that you dropped them because of intimidation and harassment.
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I want to focus just
7 i 128 i 1 1 i 1 on those. A All right. l 3 ' Q However nebulous they may be, j 4 A If I don't remember whet the problems I might ! I s 5 have dropped for intimidation and harassment, then therefore 6 i I cculdn't.possibly remember if they were brought up:by' 'l i 1 7 ,
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1 other fellow workers. I 1 8 i MR. MIZUNO: That might be a point. All right. 4
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9 I I think we can end there. That ends my discovery deposition. l MR. SPEKTER: Thank'you, Mr. Mizuno, and you have 11 had complete opportunity to finish your discovery deposition j q 12 and we are done prior to two o' clock, is'that correct? I l 1 13 1 MR. MIZUNO: Yes.
'# I MR. SPEKTER: Therefore, we will not,have to 15 meet on August 4 as we had previously agreed to continue i
16 the discovery deposition. ~ 17 MR, MIZUNO: To continue a discovery deposition, 18 that is true, but the staff does reserve its right to i' 19 conduct a cross-examination deposition to develcp the {
,0 evidentiary record in this case.
21 MR. SPEKTER: That is inderstood. I believe 22 that it is my understanding at this point that cross-23 examination is going to be held at the hearing, itself. MR. DAVIDSON: That is, Mr. Spekter, one of the . I 25 ' roposals that has been put on the table. I unfortunately
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1 , can't tell.you.what.has-been decided'so I am limited ~in what .- 2 I can contribute'. However, . I obviously-can't'take.any 3 obj ec tion to the reservation of any-of Mr. Mizuno's rights. g a He is fully entitled to.do s o .'a n d ' I . t h i n k . h'e stated'his
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'S position yesterdayfand he.has renewed his position-here 6
today. 7 As for your understanding, I believe ~it is'also: 8 mine that there was one suggestion on-the table now that 9 A- 9 rather than havec- . come back for'a cross
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evidentiary deposition-that he may appear at the hearing. 11 I think at some point in the future we ought to resolve 12 the issue. -' 13 ' MR. SPEKTER: Yes. I' agree it should.be 14 resolved in the future and I just wanted to make it-perfectly 15 clear that it is, of course, the intervenor's. position ! 16 that certainly in such an evidentiary deposition that both 0 ' 17 1 the applicant and the NRC are certainly entitled'to cross ; 18 U this witness at some particular time,in the future wherever 19 that is decided. 20 MR. MIZUNO: The St'aff just wanted to make < 91 clear that when it said," evidentiary deposition,".that'it l 22 was not aware of these pending proposals as to how to d 23 develop the record and hil the staff was doing was'trying- -l 2A to reserve its right to develop the record in the .; 25 evidentiary proceeding.
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130 1 Thank you very much. 2 MR. SPEKTER: Thank you. 3 (Whereupon, the instant deposition was a concluded at 1: 44 o' clock p.m.) 6
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8 _L .--_ ) 9 10 11 12 13 14 15 16 17 18 to 20 21 22 , 23 24 25
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l CERTIFICATE OF PROCEEDINGS l' 1
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This is to certify that the attached proceedings before the. " NRC COMMISSION 3 4 In the matter-of: Texas-Utilities ~ Electric Company, et al- ! 4 , i Date of Proceeding: Friday, July 20, 1984 , 5 Place o'f Proceeding: Glen Rose, Texas ~I 6! 7 were held as'herein appears, and that this is the original transcript for the file of the Commission. , 8 9
'J. F._Coughlin '
10 t Official Reporter Typed; Il 12 h 13 Official Reporter - Signaturej 14 l ( 15 i i t 1 i 17 ' 18 ' l i 19 20 ' l-6. 21 22 l'
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mmmmmmm--- TAYLOE ASSOCIATES
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