ML19345B259

Statement of 790508 Appearance in Madison,In Re Const Deficiences.Pp 1-23

ML19345B259
Person / Time
Site:	Marble Hill
Issue date:	05/08/1979
From:	Cutshell C AFFILIATION NOT ASSIGNED
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ML19345B245	List: ML19345B259
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NUDOCS 8011260429
Download: ML19345B259 (23)

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{{#Wiki_filter:,, .- U.- D mm0 0' V b eg e3 Se => S'v,'ODN ST,*.TEMENT OF CIIARITS EDWI.PD C11TSTIAT.T, DATE: May 8, 1979. PIACE: Law office of Thornas M. Dattilo, Mr dison, Tuddana. TIriE: 4: 30 P.M. PRESENT: Thoman M. Dnttilo, Attorney for Save The Va31oy. Mr. Robert Gray, Chairman of Board of Directors, Save The Va31ey. Mr. Paul R$ chnrd Hill , accompanying Charlcv Edward Cutahall. Mr. Charino Edward Cntnhall, the witnecn. Mrc.. Patri cia 3. Toriine , the reporter. The wi tnens, Charlen Eduard Cutnhall , hav int been duly nworn by the reporter to tell the truth, the whol. troth and nothing but the truth, gave the following utntomont, to-wiL: PATRICIA S. TORLINE Exhibit I SHORTHAND REPORTER Page 1 of 23 RT. 6, BOX 2A MADISON, INDIANA 47250

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• 2 2 QU}ETTONS BY MR. ROBERT GRAY:

3 MR. GRAY: This is Bob Gray, and we're going to talk briefly 4 to Charles Cutsha13 ; and we understand he's em-5 ployed at the Marble Hill construction site. 6 Q. Might I ask your full name, Mr. Cutshall; what you - 7 do for a living; your Enrital Status, and your age, e please? 9 - A.  % name is Charles Edward Cutcha31; I am a laborer 10 for Newberg Construction Company; my a6e is 22. 11 Q. Are you married, sir? 12 A. I am single. 13 Q. Could you tell us brief]y what you do at the New-14 berg construction site at Mnrble Hill; just tell 15 us briefly what you do there and how long you've 16 been employed with them? 17 - A. I am a concrete finishcr's helper, a laborer. I 18 help concrete fininhors by houling their noconnary 10 ; materials to them and building their scaffoldn and 20 just Smeral handyman for them. 21 Q. How long have you been employed in this position? 22 A. Two (2) months. 23 Q. Where were you employed hofore thin? 24 A. I was employed by Wackenhut Security for P.S.I. 25, 4 On the Marble Hill nite? 26 A. On the Marble Hill construction site. 27 Q. And how long had you been employed in that capacity, 2a then, Mr. Cutshall? Exhibit I page 2 of 23  ;

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2 A. I was employed from June - I mean Jsnuary of '79 un-3 til my employment as.a laborer. 4 Q. Okay. In pre-conversation you indicated that you 5 were going to leave this type of employment as a 6 cement finisher and go somewhere else? 7 A. Yes sir. I'm Going to stay on as a laborer, not for 8 the Newberg Company. I am moving to Teyns. 9 Q. Can you tell us, Mr. Cutshall, then essentially, 10 why you re here? Just make it informal and tell us 11 what you know about cement, and juct take off and 12 do your own thing nc you youngsters say. 13 A. Okay. T live in the area of the Marb]e Hill con-14 struction site. I live - 15 Q. (Interrupting) Can you be specific where? 16 A. Approximately 5 miles southeast of Austin, Indiana. 17 Q. Okay, go ahead. That would be in Scott County? 18 A. Scott County. 19 Q. Go ahend. 20 g, 7.vc been around concrete work all my life; my 21 father's been a finisher for clone to 50 years. 22 I'm familiar with concrete work. 23 Q. Have you worked previously with your Dad, in con-24 crete? 25 A. Yes sir. 26 Q. , What time frames; like how long? 27 A. Just small pours - patios and sidewa3ku and things, 3 for instance. Exhibit I page 3 of 23

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< 2 Q. Go ahead, please. 3 - A. I'm concerned about the conditions of the concrete I d and things I have seen on the Marble Hill constructic n 5 site, pertainin6 to honeycomb patches. 6 Q. Please explain each now. Honeycomb is what in 7 cement? 8 ~ A. Honeycomb patches are air pockets that form long 9 forms, when the concrete forms, that leave air pock-10 ets in the concrete where you can - the material's 11 real loose ar,d just falls out. 12 Q. You mean more narrow perhaps; less concrete in thick-13 ness, or what happens with a honeycomb? Id ' A. If a form is, soy for instance, four (4) feet thich-- 15 a or the concrete would be/four (4) feet thick wall 16 and has a honeycomb on the side, it might go in hs 17 much as two (2) or three (3) feet into it and have 18 the Fir pocket to where the concrete is loose. You 19 can just boat it out with a hammer, and in some 20 cases it'll fall out on its own - just breaking it 21 with your hand. 22 Q. Thus leaving it much more narrow than the specifi-23 cations would en11 for? 24 A. Yes sir. 25 Q. Okay, and you've seen this at Marble Hill? 26 ,. A . Yes sir. It is one of my jobs to patch these -- 2/ to supply materials for the finishers to patch these 20 Ereas. Exhibit I page 4 of 23 6

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    .-                                                                        5 2       Q. Okay, what structures have you been working on down 3              there?

6 e-4 A. Steam tunnels, just... (pauses) 5 Q. Containment building? Have you ever been on the 6 containment? 7 A. Containment side of the containment -- inside of the 8 containment. 9 Q. The contai.1 ment room itself? 10 A. Yes sir. 11 Q. Both inside and outside? 12 A. Yes sir. 13 - Q. And you've seen honeycoabs in the containment struct-14 ure, itsel f? 15 -A. Yes sir. 16 Q. As I understand then, it's part of your job to go 17 around and patch these honeycombs as they occur? 18 A. It is my job to supply the materials for the finish-19 era to patch. 20 Q. To do thin? 21 A. Yes cir. 22 Q. I sec. Okay, what was the next item, boulde honey-23 combn, that you tn] ked about? 24 - A. In one nteam tunnel, along the -- where the wall 25 meets the floor on the perpendicular corners, I've 26 seen water leaking through these nrens at n pretty 27 fact rate. I'd shy approximately anywhere from 28 4 five (5) to twenty (20) gallons an hour; and water Exhibit I l page 5 of 23 l j, ,

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comes from the lower levels and outside levels, out-3 side of the walls, just where the water's backed up, 4 and places I don't even know. 5 Q. Explain the steam tunnel; what do you know about - 6 that? 7 A. Well, all I know on the steam tunnel is that that's 8 where the excess stnam, and the steam after it's 9 run through the turbines, fo310ws these steam tunnel: 10 to where they're released through the cooling bins. 11 Q. Okay, what -- have you observed why this is so? 12 Why is it leaking through from ground water, or whtt-13 ever? 14 A. The -- just poor concrete work, just poor forms. 15 Q. Like poor forming that causes the scam not to be 16 sealed, or what? What exactly? 17 A. Just where the air pocketc will run all the uey 18 through to where the water will be on these seams, 19 in corners. 20 Q. Would thic have to do with the honeycomb uituation 21 that you talked nbout? 22 A. Yec cir, more than -- it's my iden that there's 23 honeycomhn on in the wall to where the water can run 24 on through. There's -- the water han to be flowing  ! 25 from soacplace to be coming out of there, and I'm 26 not sure where it's coming from; but it is coming 27 through. Exhibit I Page 6 of 23 28 Q. What other cement defects, besides honeycombing, do l 1 l

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you know about; and have you seen it at Marble Hil]? 3 'A. On patches, I have seen five (5) cases within the 4 last two (2) weeks where the supervision -- Newberg'c 5 supervicion, their supervisor or superintendent, and 6 other P.G.I. officials will say patch them before 7 the inspectora can come by on patchen that should a have been air-hammered out and - 9 Q. (Interrupting) Does this go back to the honeycomb 10 situation you talked about? 11 A. Yes sir. 12 Q. Okay, you're talking now about a patching situation? 13 A. Y.es sir. Well, you have to patch the honeycombc. 14 Q. And this then was ' patch it bercro the NRC people 15 could see it', did you say? 16 A. Yes sir, on numerous counta. NRC is not there all 17 the time and they cannot kocp up with what'c going 18 on. 19 Q. Is it supposed to be the procedure thnt the NDC sco 20 all honeycombn thn t appear, or what? the 21 - A. No cir; it's /brocedure for Quality Control , or Q. A. , i 22 incpectorn to coc. 23 Q. That's Newborg inspectors? 24 A. Newberg inspectorn, to patch theco -- to see theco 25 areas, and tley put n tag on it; and that's where I 26 was explaining to you, earlicr. 27 Q. What kind of tag; what does it look like? 48 A. Non -- not serviceabic, poor material tags where Exhibit I page 7 of 23

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2 they have to -- after they put a tag on a honeycomb 3 that hasn't been beat out, or air-bnmmered out, they 4 have to air-hammer it out; and then the inspector 5 huc to come and look at it before they patch it, to 6 make sure it's donc right. And on the occasions I 7 was talking about, the supervitorn will have them a cover up just the outside and not worry about the 9 inside of the patches. Before the inspectors can 10 set around, they'll have them jttst more or less mack 11 over, cover up, the areas before the inspector can 12 see it. 13 Q. So that somebody could understand, would it be fair 14 to equate this with like plastering over an uren is rather than filling it up completely? 16 A. Yes sir, that would be a good -way to put it. 17 Q. Thus leaving -- 18 A. Areas in-between. 19 Q. -- an air bubble? 20 A. Right. 21 Q. Inside the -- although it would look solid? 22 A. night. It'll just have an inch or no outer covering. 23 where they've slapped a patch on this honnycomb, 24 and duct made it look good from the outnide. l You 25 can't tell the difference until you get in there 26 and start beating it out. 27 Q. You said two or three times about beating it out; 28 how do you do that? Exhibit I page 8 of 23

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1 9 2 A. With an air hammer, that's what I meant; pneumatic 3 air hammers. They're just Jack hammers is what they 4 are, with chisel' bits. ' 5 Q. You mentioned something about the reinforcement and 6 the fact that the concrete sometimes doesn't shake 7 down through. Would you explain that situa.. n? 8 A. Well, the reinforcement rod is placed close together 9 . u areas, to where the concrete cannot get in-betwee r, 10 the reinforcement rod and the forms, to where it 11 doesn't fill in the forms completely and leaves pntch 12 holes in it and honeycomb holes. It's not vibrated 13 down right and it's poor concrete. 14 Q. Poor concrete? 15 A. That's what it would have to be. It'd be too rocky 16 in places. 17 Q. In other words, the mix is wrong or something? 18 - A. Right. When they start pouring the concrete, they'l' 19 have a real high rock content in it, right at the 20 beginnin6, and then it'll ccme out to the right 21 mixture after the bccinning; but they'll pour this 22 on in the be6 inning of the forms to start out with. 23 Q. Who's reponsible for seeing that this is not done -- 24 or to see that it's donc properly; and evidently 25 it's not then. Who's responsible? 26 A. I would say the concrete superintendent, the finish-27 er superintendent, and the concrete pouring crcWS 28 foremans and superintendent. Exhibit I page 9 of 23

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i e sf- _, 10 2 Q. Are they supposed to be there when au concrete is 3 poured? , 4 A. They are; they're in pouring the concrete, so they'r c 5 there. Dee. you -- when they pour concrete, you 6 have pneumatic vibrators, electric vibrators, that 7 vibrate the concrete on down into thece, or into a the honeycomb -- 7 menn into the rebarb; and that's 9 the reason for the vibrations, so you won't have 10 boneycomb. But they're not doing it ce nectly, or 11 the rebarb's too close to pernit the concrete to 12' fill in these areas. 13 Q. Please explain that?

• 14 A. -

Steel rebarb is just reinforcement steel that's in 15 concrete, so it can ho.Ld a heavier stress and -- l 16 well that would just be the main problem for them -- 17 heavier stress. 18 Q. Have you known any occasionc when the shakedown 19 mechanism wasn't workinC at nll? 20 A. I cannot honentl'f nny that I've never seen them not 21 vibrate concreto; they've a] ways vibrated them, but 22 they're not doing it right. 23 Q. Well, not doing it right in fnirly General. Can you 24 be more specific? Iike do you know why it'= not 25 working properly? 26 A, They e re not letting the concrete vibrate down into 27 the holes into the pl ces where the honeycomb de-28 velopes, and that's what causes the honeycomb. Exhibit I page 10 of 23

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2 They're... (puuses) 3 A matter of timc? Q. , d -A. Yes, they're pushin6 it and they're trying to make 5 it as fast as pcccible. 6 Q. In other wordo, if they'd let it vibrate longer it 7 wouldn't develop honeycombc? 8 A. In my opinion, yes sir. V Q. Okay. You mentioned the pocaibility that an NRC 10 inspector had seen thic crack cituation nt: one of 11 the tunnels? 12 - A. I was in a steam tunnel working with finishers that 13 were putching a steam tunnel, and an NRC innpector j 14 Now, T cannot nay that ho didn't came to the nren. 15 write somethinC down, but he, in my opinion, never 16 took notice of the situation - of the cracks in the 17 seams or the water coming throuch. Is Q. How often doc: nn NRC inspector come to inspect the 19 cement cituation? 20 A. I've noen, in my period or working t.here chmn to 21 two (2) monthn, I'vn noen him I'd any thre.c (3) 22 times. 23 4 Thron (3) timen? 24 A. Yes cir. 25 How much coment would have been poured then in this Q. 26 period, in your judgment; could you tell? 27 A. Hundredo and thouannds of yards of concrete. 2e Is it a fair statement then to say that the quality, Q. Exhibit I . page 11 of 23

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             ,                                 a                        y 2         the Q.A. as you referred to, has to be done by New-3         berg, and the NRC really has no effective wny.      Is d

that fair to say? 5 A. That would be fair, because NRC cannot be on the 6 site, or they're not on the site; I guess they conid 7 be on the site all the time, but they're not on the 8 site all the time; and when they are there my super-9 -- visors, and the people I work with, have notice be-10 fore they can even como on the site. It's my ex-11 perience, because T worked au a cuard on the securit; , 12 for P.S.I. , that they're not allr;we 1 on the nite 13 without a P.S.I escort. 14 Not allowed? Q. 15 A. No sir, they will not let ther como into the site 16 without having n P.S.I. CScurt; nnd this was what 17 I was instructed to do if -- when T was working as 18 o guard, and I'd be on the cate and nn NPC man l 19 came in, I was to hold him there until P.S.I. was 20 notified nnd como to encort him. 21 Q. In other wordn, i f I came -- if you were a guard 22 there and I came there and identified mynnir nu nn 23 NBC innpoctor, T couldn't entor the preminna until l 24 a P.S.I. person came to encort me? l 25 A. Yes sir; unless it's changed in the last two weeks, 26 that's the way it was. 27 Do you know any of the Newberg inspectorn, Q. I see. 28 personally? Exhibit I page 12 of 23 .___m

r D*O D #3 M'} @' I 6 sf a a J hl5L , 13 2 A. Not personally; I know them by cight. 3 Q. And these -- is this,their only job, to inspect d cement,ordot)$cyhavejust6cncralinspectors? 5 What is n Newherg inspector? 6 A. A Newborg inapector, the only ono I'm oscociated 7 with .is the concrete inupcctorms, and T think their 8 only job is to incpect concrete. I thin 1< , and I'm 9 pretty sure, they have other in:tpectors for their 10 carpentry work and iron works and this sort of thing. 11 Q. You told us something then about the appar<>nt de-12 fccts that are indard in the structuren right now; 13 you know that they're there, is that right? 14 A. Yen cir. 15 ,Q. Back to the particular structures, you say the i_n-16 side and the outcide of the containment.. room, itself,  ; 17 is affected; that you know that these things are la covered up there? 19 A. Yes cir. 20 Q. The contninmont room, itnolr? 21 A. The containment walls sir, when I firnt ntarted, was 22

                  -- one of my first. Jobs was to hc1p patch these 23          holen on thp cide cont,ninment, innido ant) outnide.

24 They, majority-wdce, they patch most of the hoinc 25 according to qualifications, or according tc. the 26 way it's supposed to be; but they have so many de-27 facts and holes that need to be patched that they  ; 1 28 can't get them all; and that's the reason, one reason , l Exhibit I page 13 of 23 , _ y- , - - . _

.-- O j $ --' 2 they're pushing the job so hard to try and get it 3 done - that they're putching over these defects be-4 fore the inspect' ors can see them. ' 5 Q. And this is donc purpoucly'then, as you have pointed 6 out? 7 A. Yes sir, it's the only way it could be. The super-a visors say ' patch it over'. 9 Q. And they say that in so many werda - a Newberg 10 supervior sa;rs that? 11 _. A . I've heard statenents where, from the cupervior 12 personnel, to say fill in certnin holes or hencycomb 13 in the side of a wall before the inspector can sco 14 it. I, myself, have hciped with this by hauling 15 the material and drypack to these holes and patchen. 16 q, ye:VC anked you about the containment room, itnc3T, 17 and you also have talked about a utcam tunnel; any la other structures involved in this honeycombing and 19 the cover-over, that you know of? 20 A. Your turbine room walln, your flourn; there's a31 21 kinds of walls, concretc walls and floors that, non, 22 are necoccary, besides just the containment. You 23 have placcc where your heat pumps or nome generators 24 are coing to be, and just pipoworks and ductworks 25 and thingn like thic that the patches aren't riCht, 26 too. 27 Q. In other words, the same situation in the thinCD 28 you've just mentioned then; those kind of rooms? Exhibit I page 14 of 23

i g ..' 2 A. I would say the majority is on other, the turbine 3 rooms and things, instead of the containment. It 4 is on the containment, too, but it sEems there wuc 5 more on the other areas. 6 Q. Can you tell us, Mr. Cutshal], about porosity of 7 cement. We're all wc]1 aware of the Three-Milo a Island situation and porocity ceu:nnt, where radiatior 9 apparently can get through three and a half (3%) to 10 four (4) feet of concreto. Is there any npecifi-11 cations you're aware of au to porosity of coment 12 being poured at Marb3e Hill on various structures; 13 or do you know anything about that? 14 A. I'm not raol familiar with the torn porosity; I've 15 heard it mentioned by the NRC inspector. The in-16 formation I have in through an NRC inspector, where 17 he was te13ing ne that radiation will 3cak through f 18 scamn and honeycomb patchen at a lot Inrger rato 19 than if it wac solid concretc and donc right. 20 Q. But you're not fnmiliar with concrete poronity no 21 such? 22 A. I can't honestly nay I am. 23 Do you know who's furninhing this concrete? Q. 24 A. Newbor6 Construction Company. They have their own 25 batch plant and they mix their own concretc. 26 Their own batch plant right on - ? Q. 27 A. Right on the site. 28 In other words, this is not a sublet proposition? Q. Exhibit I page 15 of 23

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.- 2 A. No sir, they mix their own concreto. 3 Q. They're totally responsible, I see. So whatever mix 4 they make, it's'their responsibility all the way? 5 A. Yen cir. There's a testing, U.S. Testing Corporatior, 6 is the one that's responsibic fur testinC the con-7 crete for the proper slump and the proper mixtures - - 8 slump is a Water content, nomehow to do with the 9 concrete, and the right rntios of cement and cand 10 and rock mixed together. Il Q. And thic in United States Tenting Company, did you 12 say? 13 A. Yec sir, U.S. Testing. 14 Q. Well, how are they involved? Do they just - 15 A. (Interrupting) That is their only job is to test 16 the metal bars and tent concreto and tent henting 17 points of different materials and so on. 18 Q. What'c their reintionship as inspectorn or tectors? 19 A. They're a sub-contractor to P.C.T., for NewberC. 20 Q. They're not the incpectorn that you've talked about 21 here? 22 A. No cir; this in different. 23 Q. What, exactly, do they do? I snonn, do they not do 24 it at the -- where it's poured -- or what? 25 A. , Yeah, they -- the U.S. Testing right at the pour, 26 right out of the concrete trucks, they take samples 27 of concreto to tect; right on the pours, before the 28 -- they take just, you know, samples out of the Exhibit I page 16 of 23 "or' F

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  -             2 concrete tru^-s as it's Soing to a pour.

3 Q. And they wo ud know, then, whether it was accurate 4 and to sracifications by these samples? 5 A. Yes sir. 6 Q. Do you have any reason to question their work? 7 A. No sir, because I'm not associated with them; all I 8 know is I see them out there takinC samples all the 9 time. 10 Q. Are you aware of any of the training necessary, for 11 either United States Testin6 people or the Newberg 12 inspectors? What do they have to do to be what they 13 are? 14 A. When I was loohng for a job this winter, and I was 15 hired on at the Wackenhut -- for Wackenhut Security, 16 that's the security corporation that takes care of 17 P.S.I. and job site security -- I ncquired an appli-18 cation from U.S. Teating for work for them too, at 19 the name time; T was trying, you know, trying to 20 fill in two chances nt one time. And they told me 21 T could have got hired, you know, would have been 22 hired if I'd wanted to go ahead and do it, and I had 23 no prior training. They wou'Id train you as you went, 24 Q. Train you on the job;is that accurate? 25 A. They wanted people that had experience, but they 26 told me that since I'd been arcund concrete and knew 27 how, you know, what concrete is made up of and a 1 28 little familiar with the slu'ap tests, and things l Exhibit I l page 17 of 23 l l l

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2 like this, that they would go ahead and train me. 3 Q. Train you as they we,re pouring; is that what they 4 had in mind? 5 A. Yes sir. You have to understand that the job ca-6 pacity that I wouM oc fulfilling was more or less 7 just taking the samples and things like this. 8 Q. What happens to the sample then? 9 A. They take it to their shop and they test it for the 10 slump and numcrous other testa, numerous other in-Il spections I'm not familiar with. 12 Q. Have you ever had a bad batch? 13 A. I can't say that they have, because I'm not told; Id I'm just a laborer. 15 Q. Have you ever known a case where they've taken some 16 Cement out because it wasn't any good? 17 A. No sir. 18 Q. To try to get some perspectivo about this patching 19 of air pockets and 1,oneycombing; whnt arc we talk-20 ing about? The reference that T grew up with was 21 like bigger than a hrend basket. How big are we 22 talking about? 23 3, 7 vc seen patches as large as five (5) -- four (4) j 24 to five (5) feet in square, or honeycombs four (4) l 25 and five (5) foot squaro, that are patched in. 26 Q. Pour to five feet in diameter -- 27 A. Yes. 2a Q. -- like, would it come out like a hole? Exhibit I page 16 of 23

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  -     1                                                            19 2    A. Yeah; in diameter, you know, they're irregular shapes .

3 They're not necessarily a hole or rectangle; they're 4 just irregular s'hapcc. 5 .Q. And sometimoc quite deep, like a four foot wall clear - 6 ing to throc feet of it, or morc, or lens, or what? 7 , A. A foot or -- l've seen patcher or honeycombs that's a went in a foot, and better. 9 Q. add do you see those as the form is removed? 10 A. Yes sir. 11 Q. Is that when you see them? 12 A. After the form is removed. You can't see them, be-13 cause of the forms, you know, blockinE the sight 14 of them, until they're taken off. 15 Q. Would this be the average, or would they be much 16 smaller? 17 A. They're on the average -- well there really isn't is at, average. Like I soy, they're irregular shapes 19 and they might be anywhere from a couple of inchec 20 to four (4) feet in diameter. 21 Q. Okay, if i,itere was an irregularity of a couple of 22 inches, what would happen; you'd just go up and hit 23 it with a hammer and see if the cement gave, or l 24 what? 15 A. Well, you could see it. It's just little holes, looks Le like honeycomb; that's the reason it's got the name. 27 Q. It'd be an area then, would it? 28 A. Tes sir, that would be boneycombed. Exhibit I page 19 of 23

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CI 1 20 2 It could be then all the way from two inches to some-Q. 3 thing like five (5) feet in diameter -- d A. Yes sir. 5 -- the honeycombed areas that you're speaking of? Q. 6 A. Yes sir. ) 7 Have you ever known a case when an NRC inspector Q. 8 was on the site and knew of a honeycomb, and knew 9 that it was being covered up? 10 A. No sir. My impression of the NRC inspectors was, 11 that they were pretty sharp men; they caught stuff 12 that the supervisors would try to pull their log l 13 on, try to - excuse the term - of bullshit on them, 1d and they'd usually catch them on such thinCs. But, 15 a6ain, the NRC inspectors, as I said, in a two-month 16 period I'Vo only seen him threc (3) times. That's 17 not saying he's not there more; but for where I'm at. l 18 and I'm dealing with the concretc work cycry day, 19 I've only seen him approximately threc (3) timcc. 20 4 What survey view would you have of the concrete, 21 personally? Would you see five percent of it, twent;>- 22 five percent of it; how much are you involved in the 23 total concreto picture? 24 - A. A hundred (100) percent. 25 Q. You soo it all then? 26 A. Tes sir. That Coos back to what I said before. 27 - Ion a concrete fini 3her's helper, I'm a laborer work-28 ing as a . finisher's helper. My job is to stay with Exhibit I page 20 of 23

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..' l j ' 1 21 2 the finishers and keep them supplied, so I'm wherever 3 the finishers are, pouring concrete or patching holet . d Q. In other words,'if somebody would question this at 5 some later time, they couldn't say well he only saw 6 just five percent of the whole thing. You saw the 7 entire -- you surveyed all of it then; you survey - 8 A. (Interrupting) Yes sir, I'm walking around the 9 area cvery day, just gathering up materials,and 10 there isn't five (5) percent of the areas that they'v e 11 poured that I haven't seen. 12 Okay. Is there anything else that you want to add Q. 13 here; anything that I haven't answered or asked you? Id Anything at all you'd want to say in a general state-15 ment here? 16 A. My main concern over the Marble TIill Nuclear Power 17 Plant is that it's within a fairly c. lose range of 18 my homo. I'm not againut nuclenr encrey; in fact, 19 I'm in favor of it. But I want to see it done right . 20 I don't want to see thincn that I've explained prior 21 in this tape go on and not be corrected, bo nuse I 22 believe that such things that I've explaince will 23 definitely affect the workability of the nuclear 24 power plant. , 25 Would it be reasonable to sum up then that you l Q. 26 think that the quality is below standards at 27 Marble Ilill? Exhibit 1 28 , nage 21 of 23 A. Yes sir.

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1 22 else 2 Q. Is there anything/you want to say here, Mr. Cutshall? 3 A. No sir. . d Q. Okay, this would continue the recorded interview; 5 and you understand that this hac been roem'ded and 6 that you're under oath to tell the truth? 7 A. Yes sir. 8 151. GRAY: This concludes the recorded interview. 9 10 11 CONCLUSION OF STATHENT. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Exhibit I

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   -           2 3     STATE OF INDIANA                     ~

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4 COUNTY OF JEFFECON l 5 I, Patricl > 3. Torline, do hereby certify that I j 6 am a Notary Public it. . 1 for the County of Jefferacn, State 7 of Indiana, duly authorized and qualified to administer oaths; j e That the foregoing sworn statement of Mr. Charlen Edward Citt-9 shall was taken by me in shorthand and on a tape recorder on l

10 May 8,1978, in the law office of Thomas M. Datti3 o, 311 East l 11 Main Street, Madison, Indiana; That the witness was duly sw'orn l - i l 15 by me to tell the truth, the whole truth and nothing blit the '

              .3    truth prior to E i ving said statement;         That this statement has 14    been reduced to typewriting by no and contnins a cuniplete and 15    accurate transcript of the said statement.                                            I 16                  I do further certify that I am o dininterusted party 17    in this matter.

18 WITNESS my hand and notarial coal thin 26th day 19 of May, 1979 20 21 22 itY t l 23 Pntricin S. Torline, Notary Publie Jefferson County, Utate of Indiana. 24 l 25  % Commission Expiren: l 26 May 30, 1980. 27 28 Exhibit I page 23 of 23 I

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SUBJECT:

MARBLE HILL NUCLEAR GENERATING STATION To Whom It May Concern: , I,. Steve Gayso, at no point in time authorized any of the fol-i lowing individuals to patch or cover up any defective surfaces, honeycomb, voids, or rock pockets without prior approval from N-Mll Q.C. or PSI Representative at above job site: d Stanley Mortensen Michael L. Walston Jule Rogers I, Steve Gayso, am a supervisor and all my orders and directions 90 directly to the Foreman, however, I will indicate when men are loafing to get back to work. 61,2 i Steve payso [ July 10, 1979

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i MUBJECT: MARBLE HILL NUCLEAR GE!'ERATING STATION To Whom It May Concern: I, James Cutshall, at no poir t in time authorized any of the fol-lowing individual to patch or cover up any defective surfaces, honeycomb, voids or rock pockets without prior approval from supervision, N-MH Q.C. or PSI Representative at above job site: Michael E. Walston -

                                                               /

aw J/mes Cutshall J. LY Aly 10, 1979 i. l Exhibit VI page 1 of 1

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.' Exhibit VII ERRORS MAY EXIST IN THIS TRANSCRIPT DUE TO TRANSCRIPTION DII7ICULTIES. IT HAS BEEN REVIEWED FOR MAJOR ERRORS. This is a tape recording of a conversation with Individual "J" of Newberg Construction Company at the Marble Hill site. James Foster and Cordell Williams participating. July 18, 1979 Q. Individual "J", you and I were discussing the problems that we'd seen in some of the patches out at the plant, both the patching waterial in some cases being weak, and we indicated that we had found in other discussions that in some cases the cement material had bees stored in 55 gallon drums and ist some cases apparently gotten wet and resulted in some dead cement when the patches were done. A. That's true and I know myself "on some occasions when the helper was going. . . . . . . . . .first of a morning, I have dumped just a full bucket of........ simple fact that it was dead. Q. The other problem that seems to be prevalent through the plant, and I don't have exact numbers, it seems like, looked at over 500 patches during the review and found 170 I think approximately, give or take a few, that had problems or questionable to some extent. We found a number of areas where the patch is somewhat of a thin layer over honeycombed areas where the rock has not been chipped out. The exact number of those I can't tell you but producing a good number of them. That's one of the areas that we're very concerned about, trying to understand how we got to where we are now and finding out whether anyone in a supervisory position who has knowledgeable knew that this was going on, and didn't gec flushed up through the system, and hoped that you would be able to tell us a little bit in your own view point how this particular situation came about. A. 1 only know some of this. Our finishers, we worked short handed always as far as fully qualified people are concerned. We've got some young people that come in that are not fully qualified and they are trying to teach them and with this type of thing, a young man can't be everyplace at the same time. And I think as far as your

              ............       journeyman finishers are concerned, they were doing the very best they could, the way they were told to do it.

Exhibit VII Page 1 of 12

  .'    Q. How were they told to do it, Individual "J"?

A. We were told that your honeycomb would oe tagged. 0.K., after you go through process in removing the tag, then chipp ag takes place. After your chipping takes place then it is inspected again by Newberg and PSI. Then, if they sign it off we patch it back.

Q. Considering the number of patches, I wish I had an exact number to give you, but I don't, where a thin layer of material has been put i on or all the honeycomb has not been chipped out, I guess.it is somewhat of a concern to us that the foreman or somebody else, or the superintendent here, Mr. Steve Gayso has been named ;; several people as knowledgable that this was going out in the field, and you i indicated to me a little earlier that you might be able to shed some light on these comments. j A. Pertaining to Bud Cutshall, Bud Cutshall worked in the same period I do for Joe and he and Steve had a personal plan going between theu. Bud is not a good worker by any means. He'll goof off every chance he gets and Steve was on his butt and one morning we was down on 391' 50, this was just before Bud left the job. He made the remark i to me that "I'll get Steve Gayso's butt any way I can" and you hear this kind of chatter on the job all the time and I never gave another .i thought to it, because you hear that kind of thing, but then after this whole thing come out, it was pretty plain to me that the man 4 meant what he said. 2 Q. I believe that Charles Cutshall left site on May 11. Would this be a couple of days before then? A. Somewhere in that .eighborhood. If Bud wants to challenge this I'd I

;

be very happy to point it out to him the very time and place this conversation took place. Q. I understand from previous discussions, before we got the tape recorder working, that you have worked on Joseph Cutshall's crew since coming on site and still are a member of his crew. We spoke with Joe yesterday and among other things we asked him the question, had he ever directed any member of his crews to cosmetically patch over an area with honeycomb had not been removed. A. To my knowledge he has not. Exhibit VII Page 2 of 12 l l i

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Q. Have you personally been aware of anv other foremen or the Newberg Superintendent giving orders that such cosmetic patches be made? A. Not to my knowledge, no. Now let me clarify something here. I have done this myself. Now where there was an air pocket, you know what I am talking about, from the vibrator, and you will get a whole series in the face of the wall. Now I'm guilty of taking my hand and dry patch mix and slip and sliding over it to dress up the wall. Q. These are mostly surface defects? A. These are surface air pockets, what's caused by the vibrator. It is not a honeycomb. Q. I believe I've seen these things. We have people who have told me that these are normal surface defects with no structural importance. A. There is no structural value whatsoever. Q. O.K. You mentioned that in your knowledge, neither the superintendent at Newberg nor the foreman were knowledgeable of the coometic repairs of the honeycombed areas. A. Not to my kn vledge. Q. Would any of the quality control personnel of either Newberg or PSI be knowledgeable, to your information? A. This is my honest opinion. If this has took place, if PSI and quality control had been on the damn ball and been doing their job, then this would have been tagged when we got there. Let me go just a little bit further here. I was on this job for around five months before I ever saw an NRC inspector. Q. We are at the site irregularly, especially during the earlier stages of construction, our inspections pick up in the later construction effort. A. ify feeling is this: if we had had the people that was supposed to be doing their job were out there doing it, then the whole thing, if Exhibit VII Page 3 of 12

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                                                                                                                                     \
 ,-               there is any' fault, it would have been caught before we got there.                                                !

Honestly, what I think everybody is saying, we're getting the blame because somebody else didn't do his dann job. Q. We in the NRC understand that the workman on site generally does whatever he's told to and we don't hold the workman personally liable for any defect at the plant. The utility, who has a license from the NRC, is charged with making sure that the work is done properly; they are supposed to oversee the quality control efforts of your own company. They are the people who ultimately have to answer for the quality of the plant. That's very true. Since Bud Cutshall's statement has come out, we received three other statements from other people and I have been in contact wit'a one gentleman in addition to them. A. Would you like me to name the one ......you been in contact with? Q. If you can, I'd be interested. A. Individual."A". Q. I've talked to Individual "A" on the telephone. A. Do you know what his personal vendetta is? Q. No sir, I don't. A. His father-in-law and Steve have a personal thing going - there's a personal dislike there. Now I worked on the job with the father-in-law and he continually cussed Steve up from the time he got here to theso I think he quit. The whole difficulty was that he wanted the foreman's job and he didn't get it. Q. I see. A. So I think that's more than likely Individual "A's" big gripe. I don't agree with Steve's methods 100%. You know yourself that you can make a man miserable. l Exhibit VII Page 4 of 12

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.- Q. I think we realize that. We also have a statement from a Stanley ' Mortensen. A. Stanley Mortensen, yes sir, I can tell you exactly. He and Bud were like two peas in a pod from the day he hit the job. (Deleted to protect the privacy of the individual.) Q. I understand (Deleted to protect the privacy of the individual). A. That's my understanding. I don't know if it's reliable and I don't know what was put on his layoff slip or anything about it but (deleted to protect the privacy of the individual) I know Mortensen hated to lose his job and I think every man hated it because he did lose his job, but nevertheless there's a personal vendetta that comes back to..... Q. We also have statements from two other, these people approached Mr. Dattilo who's the lawyer for SAVE THE VALLEY. Jewel Rogers. A. Jewel - this is the typ of man and the type of supervisor he is. You can go out there anu can go to work and if you try to work as it falls, you get in there and do your part. He'll stay off your butt and leave you alone. But if you walk out there on his job and you go to work and you go hunting for the easy stuff you're going to make........... There's another vendetta. Q. One more man who has provided an affidavit to us through SAVE THE VALLEY. His name is Michael Walston. A. Mike - that one there, I never worked enough with that man to know. Q. Can you tell me which of these, any of these people work on your crew or were they on another crew? A. That Mortensen, he worked on our crew, and as far as I know the man is unexperienced and I never did see the man put in a patch. The only thing I ever saw him do was break nails, cleaning the imbeds and patch tie holes. Exhibit VII Page 5 of 12 , 1 i

4 .- Q. From what you told me, it seems that you feel there was a conspiracy of several people to get Mr. Gayso out. A. I do. I think that is exactly it. These guys, for one reason or another, they're ticked off at him and if you get it in for a super-visor with all the other crap that's going on the project out here, what would be a better way to settle it? Q. And again, from what we were talking about just a few minutes ago, and I don't want to put any words in your mouth, especially in a case like this, is it your belief that the inexperienced people that were hired as finishers, were doing the repair work, were responsible for those areas where the honeycomb has not been removed? A. They could have been responsible for quite a bit of the chipping, anything where there was a major patch to go in, I think the biggest majority was done by us old journeymen. And here is something else. As far as your chipping is concerned, we were not given any depth as far es the chiping is concerned. We were told that you go back to some solid stuff regardless of where it may be. Q. That's the way it should be. I guess that there are areas that I could understand how you might chip back and think you were at solid concrete and sometimes miss it, a patch of honeycomb that didn't get removed and had to be put in. A. I've done some of the chipping myself and every patch that I.....every patch that I chipped after I finished with the enipping, then it has been inspected by QC and he has signed and approved it before we patch it back. Q. How did QC and PSI know that you were finished and ready? A. Whenever we finished a patch with the honeycomb, chipping, we notified our foreman. He in turn gets hold of QC or get hold of PSI then they come down and inspect it, then after they inspect it, sign, and then we are released to re patch. Q. Did you have much hold up in getting QC and PSI down in instances where they didn't have time to come and see? A Exhibit VII Page 6 of 12

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 .-    A. We have had this happen and at no time did we proceed until it was done.

Q. Individual "J" let me tell you what really causes us some problem at this point and hopefully you will be able to enlighten ut We do need to know the true story. The areas we've seen, and a aata we've seen a reasonable number of them, where there is a cosmetic atch over some just plain pure and simple honeycomb. To Cordel.. and myself and other people who have looked through, there seems to be a large enough number of these areas that we find it difficult to understand how it could have been made without a foreman or somebody else in a responsible position knowing that this was happening on the job. It is really a fundamental difficulty that we have, because we need to understand, if we can accept that people didn't know what was going on, how this could happen. A. What areas are you talking about? Q. I am essentially talking about the lower levels of the auxiliary building. A. Your lower levels on that probably were done last summer and last fall, and that would be efore I came on the job. Q. By lower levels, you mean elevation 364"? A. 364" is about the time that I went to work. Q. I guess that there was one that I personally have seen, and I have

not seen all of them, where it is on the bottom of a slab and where there is a very thin coating of patch material underneath this really very loose honeycomb and I guess that if there were only one or two, I think it would be very easy for you to believe, well a couple of men didn't know what they were doing and knocked off early one day anu wanted to hurry and rather than call in QC and get busy with the chipping hammers, they patched this right over. There's enough of those areas that are similar, some what similar, perhaps not as thin a coating or had honeycomb behind them, that I really need to understand how that happended. Were there times when the foreman would not be present for long times while your people were working? Finishers like yourself were doing patches?

Exhibit VII Page 7 of 12

 .'    A. No I don't think so. I can't explain it. I don't know. Our foreman was there and I'm sure that I put in as many patches down there as most any in my crew.

Q. What would happen if you were down there, I take it you people would be down there when the forms were stripped, when the stripping crews were down there. A. On some occasions yes, but most occasions no. Q. 0.K. If they came upon a patch of honeycomb and they didn't call it to anybody's attention, QC, or pointed it out to the foreman, and started patching it, would someone know about this other than the finisher himself? A. I don't think it could be done because you got enough qualified people on the floor to know definite. Q. In those cases where you have tagged, in your personal opinion in the areas where you observed, what is your opinion of the evaluations that Newberg QC or PSI QC has made? Are they good opinions? In my conversations with the QC people, I find that my personal evaluation is evidence of them not being fully qualified. Have you had any experiences like that? A. Yes. I've seen and heard enough that if I had been in their position I wouldn't have approved. i Q. We have some other comments along much the same line and at least in one occasion our own inspector found areas apparently been approved for patching that he had some real problems with. When circumstances like that occur, have the foreman, or you made a complaint? A. No, because as far as we was concerned, they were the final word. l l Q. Another question on our part - most of those who made allegations of the helpers and your perspective, I understand, each had some personal difficulty....... Were any of these people these laborers who were essentially untrained,-trainable in your view? Exhibit VII Page 8 of 12

A. Yes, we've got a man out there right now from labor and they're being trsined. Q. Is that going well? A. That't going real well, but here's the thing about it. You take a man that's willing to work and his head's not a yard thick you can train that man but if that man don't want to work I don't give a damn how much time you spend with him you're not going to teach him anything. Q. Let me ask you another question here. In several instances we found what would normally amount to a good patch, except that it had been patched with dead concrete, something you pointed out to us that you'd pointed out to us previously. In one instance that was dug out, that we saw, and one that we knocked out ourselves, the concrete upset like putty. Did someone do what you did, come to the conclusion that this was dead concrete before it was put in? And from the way you've described conditions down there, I would conclude, maybe not accurately, have no proof that there was some qualified people, maybe some helpers, more than likely foremen, that were in the area when this was done. Do you have any opinion as to why we're finding quite a number of patches that show evidence of dead concrete? A. Yes, I've got one idea of my own and I don't know exactly where I got the idea from, I was told when I come on the job. When I make dry pack, the way I was taught to make it years ago, you take sand and cement and mix it together. You mix it to where you can squeeze it in your hand and make a ball and when you open your hand up, that ball will stay 6 -r- mod not fall apart. Alright, you can squeeze it as hard as ye out you can't squeeze it. Alright, when you open your hand yua'li hold that ball toward the sun, you can see water crystals. Then you've got a good dry pack. Alright, I don't know where I got the idea, I couldn't tell you who told me, but anyway the pack we were using was dry and in my opinion it was too dry, and my honest opinion is that in a lot of cases you've got dead cement, plus you don't have enough moisture that will set your material. Then when you take your wet mud on the outside to face it, your wet mud will penetrate so far, when your moisture runs out and from there on its powder. Q. -When talking earlier to a couple of people, especially in management, they told us that on some days when you had bad weather, a rainy day and there was no work being done in other areas at the plant, that l t Exhibit VII Page 9 of 12

T \ i (* 1 i .- often the finishers would be kept on site and would be asked to go into areas in the auxiliary building for example, and do patching and those days also the stripping crews, in order to keep them employed they would also be sent down in that area to strip forms. People that we talked to appeared to believe that this might have been the days in the time frame when some of the honeycomb areas have been patched over improperly, because the quality control people were perhaps catching up on their paperwork on a rainy day, that stripping crews were down there moving forms and finishers had been generally instructed to go down and do patching. Does this appear accurate? A. We were clear back from the wrecking crew; they would be working on one area and we would be workirg on another. This has happended numerous times. I'll tell you something else. I don't know, it is just an idea. Q. I am interested in opinions. A. I've seen this happen. Where wreckers will be backing out. At the time they pull those forms, and it is raining. Alright, you can take and patch material over top of something. Q. Yes you could. A. Now I don't know that it happened, but it is an idea. Q. That this might be done by a stripper? A. It could be. I don't say it's so, I say it is a possibility. Q. O.K. It is a possibility that hadn't been mentioned to us earlier. A. But I know myself because I owned and operated a business for 10 years and if you want to fix something where it is up, an outside job where you don't have any danger or water problems or something like that, you've got a honeycomb that's above ground level by the time you take and strip that form, take and wet it you can place it and go on. I l Exhibit VII ) Page 10 of 12 1

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Q. This would be normal for a, say supermarket, parking lot, apartment building?

A. That's right - that's just what we're talking about. Q. Another question: In those instances where one has dug out a honeycomb area to one extent or the other, say I/ve got a honeycomb that has pretty regular dimensions - I'll look into it, it's six inches deep all the way around it and I get into a place where it squirrels off and gets eight inches deep and builds up and the guys dug it out in that configuration. A. You'll never hit it like that. You'll be running by a 1/2" down to 2" and then it will go up to say 4" and then you've got to dry pack all the way back and there's no way in hell you are going to pack it back like that. Q. What do they do then? i A. They went ahead and wrote it off. These are some of the chippings that I said that I would personally not approve. Q. The shape of the patch was such that you couldn't even make a good patch, no matter how good you were. To this extent PSI and Newberg QC didn't make a good judgement, they didn't give you a good shape to try to fill back on? A. Their orders was this: Go back to solid material, at that point you } stop. 1 Q. Who gave that order? A. I couldn't tell you where the order come from, it was just the way we got it and this is something that is improper and there is no man alive that can put that patch back and make a good patch out of it. Q. Some of the stuff I saw falling off, I'd have to agree with you. Anything else you want.to tell us while we're here? Exhibit VII Page 11 of 12

r 1 e A. Just what I told you, that if you have any more names you want to throw at me, the people that I think griped and squawking the most, I think it was strictly personal and not business. END OF TAPED PORTION OF INTERVIEW i i i i a a J l

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Exhibit VII Page 12 of 12

c' I, Individual "K" make the following written statement freely and voluntarity to Mr. James E. Foster, who has identified himself to me as an Investigation Specialist of the U.S. Nuclear Regulatory Commission. Mr. Foster has advised me that I do not have to make a statement, and any _ statement I do make may be used in a judicial proceeding. I am a finisher for the Newberg Construction company at the Marble Hill site. Individual "L" told me that on July 18, 1979, sometime in the morning, Individual "M", known to me as a Newberg concrete placement foreman, asked Individual "L" to cover up a honeycomb area on cooling tower I. The pour for the concrete had just been stripped, and he stated he wanted it covered up "before they see it". We both reft..a to do this. This was the caly ocassion when I have been asked or ordered to patch improperly repaired ccacrete. I have done little concrete patching myself, except for tie holes and seams. I have been given " dead" or deretiorated cement for patching, but did not use it, and observed some " dead" cement on Turbine b1dg II yesterday. I I have read this statement, consisting of one page, and it is accurate to the best i of my knowledge and belief. Witness James E. Fcster 7/19/79 Individual "K" 7/19/79 Cordell Williams 7/19/79 7 Exhibit VIII typed transcript of statement page 1 of 1 gyn 4 ~q e-m-- em- g- <w- + - w w . - w

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o' w I, Individual "G", make the following statement freely and voluntarily to Mr. James E. Foster, who has identified himself to me as an Investigator, U.S, Nuclear Regulatory Commission. Mr. Foster has informed me that I d'o not have to make a stateuent.and that any statement I do make may later be used in a judicial proceeding. I have been a finisher foreman for Newberg Marble Hill since mid-November,1978, and have worked at the construction site several times previously. I have never ordered finishers in my crew to patch areas where honeycomb was evident and had not been tagged. No member of my crew has 'been ordered to " cover-up" areas which were not chipped.I feel that some areas were not chipped out to the extent that all uncound material was removed. I believe that these ' areas were approved for patching by honest mistakes in judgement.

• Concrete has been stored in barrels and has deteriorated prior to being used for patches. This was brought to the attention of Newberg and PSI in March of 1979 l approximate. l l

I have not received any training in Quality Control from Newberg, and do not believe that the other foremen received such training. I I I do not believe that PSI QC inspectors were aware of patches being made improperly. l Mr. Stanley Mortansen worked on my crew, and did no patching to my knowledge. I do not recall any date on which he worked for Individual "F". On Inclement days such as -rainy days, finishers would of ten be kept an at the planc to do patching. In some cases they may have patched surface conditions which hid l honeycomb pockets they were not aware of. Two problems on this job have been the level of experience of some personnel, and the configuration + procedure used to perform patches. Deep pockets may not have Exhibit IX typed transcript of statement page 1 of 2

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o been filled by the " ram pack" method utilized. Mr. Foster has read the above statement to me and it is true and correct to the best l of my knowledge and belief. Witness: James E. Foster 7/17/79 Individual "G" July 17-79 Cordell C. Willicms 7/17/79 f i typed transcript of statement Exhibit IX page 2 of 2

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     'b 1, Individual  "N",     make the following statement freely and voluntarily to Mr.

eP * - James E. Foster, who has-identified himself to me as an Investigator, U.S. Nuclear Regulatory Commission. Mr. Foster has informed me that I do not have to make a statement and that any statement I do make may be later used in a judicial proceeding. I an a steward for the finisher's Union, and have worked at the Marble Hill site for approximately one year and seven months.

      , I have been physically present when Mr. Steve Gayso, Superintendent for the Newberg Construction Company, has ordered Individual "G"       to cosmetically patch over honeycombed areas of concrete. These have been small areas of approximately one-half foot square. This happened only ocassionally.

Individual "G" passed on the orders from Mr. Gayso to the crew members. I personally hr7e not been ordered to cover vp any honeycombed area, t Improperly repaired areas (such as ordered above) were located in the Auxiliary building, fuel handling building and other areas. j I have read the above statement, and it is true and correct to the best of my knowledge and belief. Witness: James E. Foster 7/18/79 Individual "N" 18 Exhibit X typed transcript of statement page 1 of 1

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