ML20214F141

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Applicant Exhibit A-186,consisting of 861203 Ltr Forwarding Depositions of C Biskey on 860915,C Noble on 860916, D Schlichter on 860916,J Thomas on 860915,D Schirmer on 860916 & D Box on 860915
ML20214F141
Person / Time
Site: Braidwood  Constellation icon.png
Issue date: 11/26/1986
From: Fogelberg B
ISHAM, LINCOLN & BEALE
To:
SONTAG REPORTING
References
OL-A-186, NUDOCS 8705220428
Download: ML20214F141 (385)


Text

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. cain sse 7551 December 3, 1986 Sontag Reporting 227 W. State Street Geneva, IL 60134

Dear Sontag(s):

Enclosed please find a copy of Applicant's exhibit 186 that was transcript identified and received into the record at 18296.

Sincerely,  !

Brian Fogelberg Legal Assistant BTF:sgg .

Enclosure 9

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4 Interview of:  :

5 CARL BISKEY  :

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8 9 Braidwood Generating Station 10 Braidwood, Illinois 11 Monday, September 15, 1986

  • 12 13 The interview commenced at 3:59 o' clock, p.m.,

14 examination by JOSEPH GALLO, ESQUIRE, Isham, Lincoln & Beale,

15 Chicago, Illinois.

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-- 1 PROCEEDINGS 2 (3:59 P.M.]

3 DR. HULIN: ,Mr. Biskey, let me explain the purpose

  • 4 of this meeting. Let me explain it to you. If you are not' 5 happy with my explanation, fesl free to ask me some

,6 _guestions. .

e 7 What we are trying to determine, if we can, is the 8 type of relationship that exists between management and QC 9 personnel for Comstock. We are trying to determine if 1

10 production foremen have freedom to report concerns and we are 11 trying to determine if QC inspectors have freedom to report i: .

i 12 concerns, and to determine if any quality concerns exist at 13 all on the sites, in the work Comstock is doing.

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i 14 I also will stress that we are not here 15 investigating you. That is not our purpose. We want to find 16 out what is going on out there. We are asking you to 17 cooperate and give us your frank answers to the questions that i

18 we have. You should feel free to leave, if you don't want to 19 cooperate. Let me stress that at the start.

20 Joe Gallo represents a different interest, so I will 21 let him explain what his purpose is.

22 MR. GALLO: Basically, our interests are the same.

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3 1 You probably know that Greg Archambeault testified 2 at the NRC hearings last week, and managed to get written up 3 in the newspapers as well. In that connaction, I as one of .

4 the lawyers for commonwealth Edison, was interested in some of 5 the remarks he made in terms of statements and 6 characterizations that he attributed to other inspectors.

7 Certainly, an important purpose of this interview is' 8 to get your perspective with respect to such things as whether 9 or not you have any hesitation to come forward to identify 10 a concern, if you have one. As chuck said, how you get along 11 with -- what your feeling is with respect to management at

  • 12 Comstock, those kinds of things.

i 13 Basically, the main purpose of this interview, as I 14 have said, is to really kind of inquire into these areas. We l

15 got the Archambeault perspective. We would like to get the 16 perspective of the other inspectors that he worked with on the i 17 second shift, to see if his characterization of how they felt l

l 18 is indeed how they felt.

j 19 Chuck is working as a consultant to me. He is very 20 helpful in these kinds of interviews.

21 I don't know if you know George Marcus here.

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! 22 MR. MARCUS: Hello.

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,f' 1 MR. BISKEY: We shook hands at the beginning of the

, 2 meeting.

', 3 MR. MARCUS: I an Assistant to the Manager of QA for -

4 Edison.

5 MR. GALLO: He is Ceco QA. I an one of the lawyers 6 for Commonwealth Edison. He's my client, or at least he is a 7 representative of my client. Chuck is helping us in this 8 respect as a consultant.

9 This fellow is manipulating these wires and machines 10 so that we have a transcript of everything that is said.

',' 11 That's basically the situation. I know you are kind

  • l 12 of surprised. I would be, too, in your position.

13 MR. MARCUS: Carl, if any quality issues come up, I 14 want to hear them firsthand. I want to be able to hear any of 15 the issues that may exist or concerns you might have, like 16 Dr. Hulin asked about. If there are any problems in getting 17 these issues out on the table, we think we have a system to do 18 that, and if it doesn't work, I have to know about it. I am 19 participating in that regard.

20 DR. NULIN: With that long introduction out of the 21 way, I will again say that we are only in a position of being 22 able to ask you to cooperate with us.

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. 1 MR. BISKEY: Okay.

2 BY DR. HULIN:

3 Q Your name is Carl Biskey?

  • 4 A Yes.

5 Q Do you prefer to be called Carl?

6 A Carl.

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7 Q' How long have you been employed by Comstock?

8 A I started the first part of February; February 3rd, 9 1986.

10 Q In what capacity did you start, as an inspector?

11 I stated in welding and configuration inspections.

A 12 After I was certified in welding and configuration, I moved on 13 to cable pulling, second shift.

14 Q You are qualified in those two areas, cable pulling 15 and terminations?

16 A No. I'm qualified in welding and config, and also 17 cable pulling.

18 BY MR. GALLO:

19 Q Is welding and configuration two separate 20 certifications?

21 A Yes.

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. 1 BY DR. HULIN: 1 2 Q Do you feel that you have adequate access to 3 supervision to obtain answers to either technical or -

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, 4 administrative questions that come up?

5 A Yes. I feel that I'm relatively new, as far as

  • 6 inspections. I haven't worked any other plants. This is the 7 only plant I've ever worked. This is my second job as an 8 inspector. Myself, I don't feel there is a problem. If I 9 have a problem with if it should be wrote up or not, I do ask 10 my lead. I don't take the initiative to go ahead and write.it 11 up.
  • 12 Q You think you have adequate access to supervision 13 and you sort of go through a chain, and you talk to your lead 14 first?

15 A Yes.

16 Q Have you ever not gotten an answer when you have 17 talked to the lead? ,

18 A No. It has taken some time before. My lead has had 19 to go through Engineering, Engineering has had to check into 20 it, and it has taken three or four days to get an answer back, 21 but I have gotten answers back.

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- 1 BY MR. MARCUS:

2 Q The lead is always on the shift with you?

3 A Yes. -

4 BY DR. KULIN:

5 Q Let me ask you a hypothetical question. If you 6 didn't get an answer from your la'ad or from your supervisor on

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7 the fi'rst shift, would you feel free to talk to say Mr. DeWald l 8 or seltmann or simile?

i 9 A Well, if I felt it was that serious of a problem, I 10 would. I believe that anything with a serious problem has 11 already been taken care of at this stage of the game, this '

12 stage of construction. I believe most of the serious 13 construction is done.

14 BY MR. GALLO:

15 Q You say this was your second inspector job?

16 A Yes.

17 Q What was your first?

18 A I first broke in over with PTL. Prior to that, I 19 was a boilermaker.

20 Q You were inspecting at PTL7

~21 A Yes. I was there approximately eight months.

2 22 Q Did you do any overview inspections?

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, , 1 A No. I didn't work any overview.

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, 2 Q What kind of inspections did you do?

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. 3 A I followed up on field correction reports and .'

l' 4 checked after engineering change notices, ECN's. I followed b

i 5 through hold tag verifications, stuff like this. I was in 6 Special Projects. '

7 Which one of the contractors were you inspecting?

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8 A I was following basically Pullman, checking on their *

. 9 hangers and their fit-ups.

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Q You say that you would talk to your lead initially..

11 How many leads have you had since February? '

. 12 A Well, when I first started -- I would say I an on my i 13 third lead. When I first started, they changed. There were i, 14 some concerns from day shift and night shift, who was getting

. 15 the work done, who wasn't. They changed leads there for a I

16 couple of weeks. They changed lead and supers both for l

17 approximately two to three weeks. They changed back. Out of 1

18 that situation, we got a new lead on the second shift.

19 Q Was your first supervisor Mr. Revels?

20 A Yes.

21 Q Was your lead, Mr. Frey?

22 A Yes.

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,- 1 Q They went on first shift?

2 A Yes. They switched shifts; first shift came on ,

second shift, just to understand if there was a shake up or 3 -

4 not, what the problem was. The craft was saying they had a 5 QC hold up and there was argument there. They came on to t  ;

6 determine exactly what was going on.

7 Q ,

hhowasthenewsupervisor?

8 A Bob Tuite and Mike Lechner.

9 Q. Who is the lead now?

10 A Doug Schirmer.

I 11 Q Is Revels back?

j} 12 A Revels is back.

13 Q When you said you asked the lead questiond, which

14 one of those three did you have reference to?

s 15 A Right now, I would reference Don Schirmer, if I have

{ 16 any problems at all. I would contact him.

17 BY DR. HULIN:

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18 Q Were there any easily noticeable differences between 19 ,those three leads in terms of how easy they were to bring 20 problems to, how helpful they were?

f 21 A I would say Harry has a tendency to get you an 22 answer and go out of his way for you.

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. 1 Q Harry?

2 A Revels.

3 BY MR. GALLO:

  • 4 Q He is a supervisor, not a lead?

5 A Right. When I was in training, I trained under Bob 6 Tuite and Mike Iachner. They had more of a well, we don't 7 worry about it, we are not concerned in that area any way, 8 type of an attitude. It was a little rough at first, 9 realizing that you have a 4.8.8 inspection criteria to inspect 10 to, and you have a 4.3.8 to hold the craft to, and which one 11 are you going to enforce.

12 BY MR. MARCUS:

13 Q How do you feel about that now, between those two 14 procedures? That question has been up for some time. What is 15 your feeling now? Do you feel your questions have been 16 answered?

17 A Yes.

18 Q Do you think it is clear, that you have a clear 19 understanding about the application of the procedures?

20 A Yes; I do.

21 Q It was confusing at first?

22 A To begin with, because you don't know if the craft e

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. 1 does something wrong, you know, what do you press them to.

2 BY MR. GALLO:

3 Q You indicated that under Tuite and Revels, that it -

4 wasn't as easy to get information. I don't want to put words 5 in your mouth.

6 A No, I wouldn't say that. They were there. At that 7 point in time, like I said, I was in training. I feel now 8 that I have been with the leads that we have now, more

9 relaxed, non-certified -- I'm gaining some experience and 10 everything else seems to be smoother in a sense.

11 Q This is under Schirmer and Revels? "

12 A Yes.

13 BY DR. KULIN:'

14 Q Do you have any reluctance to bring any questions or 15 concerns up to your supervision, and not just about quality 16 issues but any concerns you have about the job?

17 A I would say I wouldn't be afraid to talk to him. On 18 occasions when Harry does come out to the office, everyone 19 talks.

t I mean there is no when he walks in, everybody quiets 20 down or anything like that. He fits in, I believe, as part of 21 the gang.

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, 1 BY MR. GALLO:

2 Q Can you give me an example of the kind of questions

3 you might have asked in the past? -

4 A Yes; I sure can. In procedures, part of the cable 5 pulling stage, it references free air and clearance separation 6 criteria. I had a question on that just last week. There was -

7 a question brought up. 4.8.8 references a log that if there ,

8 is a problem, you should check this log and make sure that 9 Engineering is aware of it.

10 In the past, I have always asked for my lead to 11 check on it and he has checked on it and got back with me. '

, 12 Last week, we had a problem. We pulled in some cables and 13 they are not referenced in the log. He's checking with 14 Engineering. He showed me the log; showed me how it works.

, 15 In the future, if we should pu'll and there is ever any 16 separation problems, I can go ahead and look them up.

17 -

Q The cables that you are referring to, didn't they have a segregation code on them?

18 19 A Yes; they do. In some instances, inside of 20 equipment, I don't know if it is Engineering or just these two 21 cables, it's not going to bother those two particular cables, a

22 They are in conflict. When they are in conflict, that's when l

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. 1 you have to check on the log and make sure they are aware of 2 it.

. 3 Q You are referring to the Comstock log, to see if the 4 problem had been flagged previously?

5 A Right. -

. 6 -Q You found out it had been flagged previously?

7 A In one case, it hadn't. They are still working on 8 it in Engineering. In another case, it has been logged. In 9 another case, it wasn't logged. I logged it in.

10 Q Did you write a CSCR in that case, when you logged 11 it in? '

8 12 A Yes.

13 Q Can you think of another one that may go back a

14. little further than a week ago?

15 A Problem-wise?

16 Q A question that you might have asked your lead or 17 supervisor.

18 A Before that, I would say the last problem I had a 19 question with was in the breaking of the seals. They have 20 Unit I pretty wel3, sealed up, as far as penetrations, room 21 barriers. In Unit II, in sealing up Unit II conduits, they 22 are still pulling cable into them. A question came up if they t

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14 1 were going to have PBI's barrier paperwork, if we had to have 2 that before we went through or if we didn't. Word came down d' 3 that we didn't have to have them. We popped a couple of seals -

4 and pulled in. The following week, they said that would be a 5 problem, that we can't do it that way, that we have to have 6 the paperwork in hand at the time we break the seals.

7 BY DR. HULIN:

8 Q You really had no trouble getting -- that

. 9 information came to you fairly readily?

h 10 A Yes.

11 Q Did anybody explain why there was a difference? '

12 A Evidently, they were talking about changing some of 13 the paperwork due to the fact that there are no other cables 14 in some of the conduits, that they really don't need an 15 inspection. The only thing we had to do was swab out and make 16 sure the conduits were clean, free of debris.

17 Q They did explain to you what was going on with the 18 change?

19 A Yes.

20 BY MR. GALLO:

21 Q Who did you get the advice from in the first 22 instance that said you didn't need to do the paperwork?

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15 1 A That would have came at a meeting, a. Monday morning 2

i meeting.- I believe Don Schirmer was doing the talking that 3 week. Harry Revels was on vacation. The following Monday, we

  • 4 had a meeting and everything was straightened out, make sure 5 you have the paperwork in hand.
6. Q Who was doing the talking at the second meeting?  !

7 A Harry. -

8 Q Was it essentially Don schirmer was mistaken the 9 week before?

10 A No. I believe there was going to be a change, due.

q 11 to the fact that there was no other cables. Normally when 12 they break a barrier, you have to inspect the other cables for

.- 13 any damage, due to the fact there are no cables in there, you 14 just pull them. They thought that would be allowed, which 1 15 evidently it wasn't. They couldn't evidently change the l

16 procedures to make it read --

17 Q The inspection procedure required the inspection and 18 from a practical standpoint, there weren't any cables in there 19 and there wasn't nothing to inspect, right?

20 A Correct.

21 Q Because there was no change in the procedure 22 process, no formal change, what did you do, just inspect an 9

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, 1 empty tray or conduit?

2 A Conduit. Yes. I had to verify that the conduit was 3 clean and there is no debris in it. There is a standing -

4 argument, and I don't know what is going to happen out of this 5 one, Engineering and QC, do you have to inspect it. There are 6 no other cables in the conduit. The procedure, it is a

. 7 different procedure. It is 4.3.1* procedure that the PBI is 8 written up on and we inspect to 4.3.8 and 4.8.8. There seems 9 to be a question there.

d 10 Personally, I have been signing them.off any way, j 11 indicating that due to the fact that it is a safety related

  • l 12 cable that would be involved with, I would sign it off behind 13 my foreman, indicating that the paperwork is in order.

14 BY DR. HULIN:

15 Q Basically, you inspect it by running a swab through 16 the conduit?

17 A Yes, after the seals have been broken. You have to 18 . verify that the conduit is open.

19 BY MR. GALIO:

20 Q Did you have to re-inspect the conduit for the cable 21 that was pulled the week before, when the inspection wasn't 22 done, I take it, or the paperwork at least wasn't done?

.- . . . . .. . . . . ... . - - - - . - a 17 1 A That paperwork, I'didn't sign off.

My foreman said i 2 he got one through. I'm still not sure whether the other one 3 came through or not, due to the fact that I haven't signed '

4 it. They are not holding QC'to sign them. I can't tell if the j 5 paperwork has come through or not.

6 Q When you say " sign," you mean the checklist, sign 7 the checklist? .

8 A Sign the PBI itself indicating everything is in 9 order.

10 Q What does "PBI" stand for?.

11 A It's a barrier --

12 Q A barrier inspection?

13 A It's a break of seal barrier. I can't recall right

. 14 now. ,

! 15 MR. MARCUS: I'm not sure either.

16 BY DR. HULIN:

17 Q Let me change topics just a little bit.

18 MR. GALLO: Let me interrupt briefly. You have been 19 focusing primarily on the technical aspects. You might want 20 to focus on that aspect.

21 BY DR. HULIN:'

22 Q We have been focusing on the technical issues. How i .

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18 1 about if you have any administrative questions, not concerned 2 necessarily with the technical aspects of your job but with '

, 3 anything related to your job, time off, vacation time, _

4 different certifications, anything. Do you have any problem l

S talking to the supervisors or leads about that?

6 A No.

x 7 Q Do you usually get an answer?

8 A Well, I don't ask for time off. I'm not, should I 9 say, a prima donna inspector, that takes occasional three or 10 four day weekends or anything like that. I just put in my 11 time. At the and of the year, I'll take vacation.

At that 12 time, I'll request vacation. Otherwisa, as far as leaving 13 early or days off, I don't do it.

14 Q Anything that comes up, you would have no problems 15 in going to them to talk to them about? Health insurance, 16 anything?

17 A No; I wouldn't have any problem.

18 Q one of the issues that surfaced in the hearings was 19 the issue of a lay-off list. Do you have any reason to 20 believe there is a lay-off list at Comstock?

21 A No.

22 Q Have you heard it talked about in the plant?

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. . ._ _ _ _ _ . . _ . . . .. . . _ . _ _ . . . .a 19 1 A Well, that's -- you can't hardly say. lay-off list.

2 There are rumors around construction. Anybody that has been l' 3 around construction hears rumors constantly; there is going to '

4 be a lay-off next week. You can hear that for years.

5 Q I guess what we are concerned about is do you think 6 for some reason, some inspectors have been placed on a list 7 that would essentially say these people go first?

8 A I don't know if there is such a list or not. If 9 there is, I believe there are some that should go first before 10 others; yes.

11 Q For what reasons do you think inspectors would be 12 put on that list?

13 A Well, I would say if you take an inspector that 14 isn't working in-procesa, that is just bringing up paperwork, 15 let's say, for instance, hold tag verifications, pulling hold 16 tags. We are up to that point now where a lot of issues are 17 being closed and you have to go out and pull hold tags, or you 18 have to go over for re-inspection on something. Some 19 inspectors will go ahead and work, let's say up until lunch 20 time and quit for lunch and resure after. Again, some other 21 inspectors won't. They will just, well, craft is starting 22 work, I guess I better go back, too.

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20 1 .There isn't any pressure in that sense at all, as 2 far as being forced to work or what the quantity of work is.

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3 BY MR. GALLO:

  • 4 Q How would this distinction you make be pertinent to 5 who would be a candidate for a lay-off?

x 6 A' I would say somebody -- let me call somebody that is 7 fairly lazy -- I had a term there but it slipped my tongue --

8 a prima donna, you know. Just because he is QC and he can't 9 get pressure from either side, he thinks he can take as long 10 as he can. He can take one inspection for two hours and maybe 4 11 another inspector that will work for a living will only take 12 half an hour. There's no pressure from either side.

13 BY DR. HULIN:

14 Q Do you know of any QC inspectors that have been 15 terminated?

16 A No.

I 17 BY MR. GALLO:

i 18 Q Do you know R. D. Hunter?

I 19 A Yes; I do, now that you mention it. There was two 20 of them. There was him and another fellow that I went through 21 training with.

22 Q Mr. Arndt?

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1 A Yes. .

2 Q Were they terminated?

3 A I don't know if they were or if they were given a

  • 4 choice. I understand they were in violation of some  ;

l 5 procedures. They were called on it. Supervisors were brought 6 in. Union officials were brought in. -

7 Q That happened while you were working for Comstock?

8 A Yes.

9 Q I don't know if that is the kind of termination you

. 10 had in mind.

11 BY DR. HULIN:

i 12 Q What do you think of the relationship between QC 13 inspectors and QC supervision?

14 A I think it's okay. I don't see there is a problem.

15 If you have a question, you get an answer. In general, I 16 think it is okay.

17 BY MR. GALLO:

18 Q What did you understand him to mean by "QC 19 supervision?" Who did you have in mind?

20 A Don and Harry.

l 21 Q Don Schirmer and Harry Revels?

22 A Yes.

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1 Q Your lead and immediate supervisor?

2 A Yes.

3 BY DR. NULIN: -

4 Q My next question was going to be how about between 5 the QC inspectors and LKC middle management? DeWald, 6 Saltaann, Simile.

7 A I'm not aware of that. I don't know them.

8 Q You have had no reason to have any contact with 9 them?

l j- 10 A None.

11 Q Have other people complained about them? '

. 12 A I haven't heard any talk prior to the meetings about 1

13 any of the other management. Again, I'm fairly new. I don't 14 hear any feedback about the upper management at all.

15 Q How about relations between QC inspectors and LKC 4

16 production?

17 A We are not under any pressure at all from the 18 craft. On occasions, they will I say QC is holding us up. They 19 have to realize, too, that we do have research to do. When we 20 are handed a package, we have to research it and do a 21 walk-down. A lot of times, it will be a big package, 22 something that is going to take four or five days. There is 9

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23 1 no way you can walk through all of it. You just have to walk 2 through the paperwork and make sure the cables and everything 3 are ready to go. As far as the conduits or anything, pans, -

4 you just do that one day at a time; walk down whatever you are 5 going to get done in that day.

6 As far as actual holding up the craft, I'd say no.

7 Q Your main contact with the production people would 8 be through the craft foremen?

i 9 A Yes.

l 10 Q I guess what I am asking is in general or even be 11 specific, if you want, do you think what goes on out there "

[ 12 represents an acceptably good professional relationship 13 between these two?

i 14 A Yes; I would say it's professional.

l 15 Q The complaining that the craft foremen may do that 16 QC is holding them up'is warranted in some cases?

17 A Well, in some case's, they get in a hurry, they are 18 looking for their footage, but we still have procedures to do 19 and steps to follow. We can't break those. If sometimes they 20 do get held up, they should just realize that is the way it 21 has to be with a safety related pull.

22 1

1

24 l

. 1 BY MR. MARCUS:

2 Q Sometimes there are" crews that are ready and the 3 inspectors can't be everywhere at one time. Everybody -

4 understands that is the case; what are you going to do.

5 A Yes. They have to notify us in enough time so that 6 we can go ahead and research it. Most foremen do.

7 Occasionally, you will get a foreman that will get upset ,

8 because he will give you the package and want you right 9 there. We still have our steps to go through.

10 BY MR. GALIA:

11 Q From what you told us, your main supervisory '

12 relationship, I guess, is with your lead and with your 13- immediate supervisor, Harry Revels; right?

14 A Yes.

15 Q Do you have much contact with Simile at all?

16 A No. We haven't had any. He is starting to attend 17 our Monday meetings now, keep us posted meetings. He is 18 starting to attend those. Other than that, we have no contact 19 with him.

20 Q DeWald or Seltmann?

21 A No.

22 Q Is Harry Revels the senior supervisor on the second e

9

. 25 1 shift?

2 A Yes.

l 3 Q You mentioned something about craft complaining *'

4 about QC holding them up. Have you ever felt rushed in

, 5 working with the craft because they were probing you to move 6 faster? -

l 7 A Well, in a sense of saying A rushed," I would work at 8 a faster pace than what I would, if I know I have three or 9

four cards that we are going to be pulling for more than just 10 that day. I wouldn't say I would rush. I would try to move j 11 right along, not hold up the craft.-

h- 12 Q Move a little faster than you ordinarily might?

13 A Yes.

14 Q Would this be the case in connection with your 15 pre-pull walk-down?

16 A Yes. I would say in going through on a pre-pull l

i 17 walk-down, instead of -- after you have done the paperwork, 18 researched it, the cable and everything is ready to go, and i

19 there theoretically isn't any hold tags or anything, you can 20 move right along.

21 For-instance, let's say you are going through six 22 conduits. At the time of my walk-down, if the lids are on the

+ - - -+ s y--4m -,

,w- , ,- - , --

9 -,.,v--, wy .- , - -y-------e.---- - - - - - - - - - - , - - - - + - - , - . - - - - - - - - - - - . _ - - - - - -

. '. ~ l .. .~ . . - . . . - .~ -

~ ~

- ^ J --

. l 26

. 1 junction boxes, I wouldn't have the craft go back and open l 2 them up first. When they did open them up, when the cable 3 came through, I'd make sure the softeners were installed, ,

l l

4 stuff like that, at that time.

5 As far as my walk-down, I'd make sure the conduit 6 was there and no hold tags.

7 Q Did you ever have an occasi'on to complain to either 8 your lead or Harry Revels that you were rushed during any 9 aspect of your inspection, either pre-pull walk-down or the lo actual pull itself?

i 1 11 A No; none. I know of some inspectors that will -- QC-( 12 can get buried by production. They can move from one cable to 1

13 the next and essentially bury Qc in paperwork. I've known 14 times where I have seen inspectors sit down for two or three 15 days just to take care of paperwork, after a large pull or 16 something like this.

17 Q Did you ever have an occasion to complain to either 18 your lead or Harry Revels or your other supervisor, that craft j 19 was complaining you were holding up their work?

20 A No. I've seen in some cases where craft have been 21 skiddish on their work, instead of the procedure reads cable 22 pan, cable tray will be clean. I've seen some crews, instead o

9

. -- .=

=.u . . . . -

J ,

27 1 of going in let's say with a vacuum cleaner or something, they j 2 will just shake the cable.

-s 3 Q Are you supposed to vacuum clean those trays? -

4 A Well, that's up to craft. I can't determine that. l 5 -Q Is that their practice as you have observed it, that 6 most of them do that?

7 A Vacuum or sweep it. If it's full, they will have to 8 vacuum it.

i.* 9 BY MR. MARCUS:

10 Q You make the judgment whether the tray is clean or 11 not, however they get there? '

12 A Yes.

13 BY DR. HULIN:

14 Q Another change in topic. Have you ever attended a 15 Quality First orientation program?

16 A I'm not sure I know what you mean.

4 17 Q Are you familiar with the Quality First program at 18 the site?

19 A Yes .-

20 Q Have you ever been in a meeting that Quality First 21 called and sponsored to explain who they were or what they 22 were there for?

e

.- -- - -,_,y -.,,r,,-- , s.- ,--,.,c- . _ , - - , , ,., y. ,,m m,.- --- . . . - - - - - - - , - - , , . - - 4- .

. _ . ~

28 1 A No. - l l

2 BY MR. MARCUS: l i

3 Q How about a meeting called by your own management to 4 tell you about Quality First?

5 A Yes. We have those weekly on Monday mornings.

6 That's inside. As far as being somebody on the outside, no.

7 Q Does your own management make it aware to you that 8 there is a Quality First program for reporting concerns on the f

] 9 site?

10 A Yes.

11 Q You are aware of that?

12 A Yes. Like I said, I haven't been to a meeting or 13 anything. There is another branch. I realize that.

14 BY DR. HULIN:

15 Q 'How would you describe the Quality First program?

, 16 A Well --

17 , Q What do you think it is? If you had to tell

, 18 somebody what the Quality First program was.

19 A They are here to investigate any gripes or 20 complaints, allegations more or less. If somebody says t

21 something, somebody is doing something, they will go in and 22 check it out.

i I

I I ,

. 29

. 1 Q Do you feel free to bring any quality concerns that 2 you have to Quality First or the NRC?

3 A I wouldn't go to the NRC. I would bring them~first , ;

I to my immediate supervisors and then to Quality First.

~

4 5 Q If you didn't get satisfaction at that point, would 6 you feel any reluctance to go to the NRC?

7 A. No. If I knew there was a serious problem that -

a existed, a cable being pinched, severely cut, something like ti j 9 this, I would push it; yes.

10 Q What could keep you from going to the NRC?

11 A The only thing I would say is the knowledge of it,

} .

, 12 but in procedure, if there is a serious problem with any 13 cable, we are to notify COM ED. I haven't had to do that

14 either.

15 Q Do you think Quality First and the NRC are 16 responsive to the concerns that are brought to them?

17 A The only time I have ever known of the NRC, and that 18 was the last allegations -- I didn't talk with them.- It is my 19 understanding the man came out in a short sleeved shirt and a 20 pair of cutoffs. That's just hearsay. That could be job 21 rumors, too. I didn't see him. I didn't talk to him.

22 W

e 4

,7._ , - - - . - __ ., -

30 r - 1 BY MR. MARCUS:

2 Q You 'mean someone from the NRC?

1

.. ; 3 A Yes.

4 Q You didn't see him?

5 A No. That's job talk; rumors. .

6 BY DR. HULIN:

7 Q You really don't know if they are responsive or not 8 because you don't know of any problems that were taken to 9 them?

10 A No; correct.

11 Q Do you think it would be kept anonymous if you .

12 brought concerns to Quality First or the NRC?

13 A No.

. 14 Q You don't? Does that bother you?

15 A Well, I believe if there is that serious of.a 16 problem, that it shouldn't. If you want to take the 17 initiative to push the point, it shouldn't bother you.

18 Q Would it bother you?

19 A I really can't say.

20 BY MR. MARCUS:

21 Q  ?.re you saying that if you brought something to the 22 NRC, that you feel they would not keep your name confidential?

9 a

O 4

~

_. 31 1 A I don't believe they would.  !

2 Q You don't believe the NRC would? l l 3 A I don't believe it would be the NRC that would keep e

~

4 it confidential or not, but I believe by the time it got to 5 NRC, everybody would know any way what the problem was. If 6 you brought it to management first, and then if ycu brought it 7 to Quality First, they would know any way. -

8 Q You feel that reporting of problems, either to the 9 NRC or Quality First, somehow they would know you reported it?

10 A Yes.

11 Q People would know that you reported it? .

12 A Yes.

I e 13 Q Why do you feel that way?

14 'A Well, that's just hcw I feel. In Greg's case, 15 pushing the spreader rooms, everybody knew. Everybody heard 16 he was going to the NRC before he was even formally there.

17 Q That sounds like he is the only one who knew he was 18 going to the NRC. The thing that bothers me and the thing 19 that I'm concerned about is that what would be the -- I'm l

20 trying to get to the point, what would be the basis for you to l

21 feel that if you went to Quality First and you wanted to 22 remain confidential or if you went to the NRC, and you wanted i

D

  • ~ 32

^

1 to remain confidential, that in your own mind, you would feel 2 you wouldn't be able to remain confidential.

3 A That's correct. .

4 Q I'm trying to find out, other than maybe Greg's ,

5 case, why would you feel that way? What is the basis for 6 that?

7 BY MR. GALLO:

8 Q Let me help. If we take a hypothetical situation 9 where you did not go first to Comstock management, and you did 10 not go next to any kind of Ceco management, and went instead 11 directly to Quality First, do you think in that circumstance .

$ 12 if you asked for confidentiality, that people would find out 13 about it any how?

14 A Yes.

15 BY MR. MARCUS:

16 Q You think they would?

17 A Yes.

18 Q You don't know how or why, you just think they 19 would?

20 A Well, it's my understanding that if you go to 21 Quality First, if you want to keep it confidential, you don't 22 leave your name. They will give you a number or something.

e o

G

~

. 33

. 1 At that point, after Quality First checks your problem, they

+

are going to' contact you back.

2 When they contact you back by 3 phone or whatever, right away the question is going'to be, ,

4 what is Quality First calling you for.

5 Q So other people on the site would know that 6 Quality First was calling you; is that what you're saying?

7 A .Yes.

8 BY MR. MARCUS:

9 Q Carl, I'll take thisi opportunity to tell you 10 that, you know, you could ask Quality First, you know, you're 11 right, that they get back to you after they investigate your .

12 concern. But many calls from Quality First are done to 13 people's homes that night.

14 A Well, that's something that I don't understand, 15 and I don't --

16 Q And that probably tracks with the first question 17 that we're asking about the orientation, you know, when Chuck 18 asked the first question, have you ever had a meeting of 19 Quality First explaining all that.

20 A No.

21 Q So that's where your concern would come. You 22 feel that that would be one way that you would be identified e

b I -

e i

34 1 --

^

2 A Yes.'

3 Q -- if they called you back on the site?  ;

4 A Yes. I understand they're there, but I feel 5 that if anything was brought up, they'd contact me on the 6 site, and everybody -- if they called the office, the office

~

7 would know, and then right away there would be the question, 8 where did you go.

9 BY DR. HULIN:

10 Q okay. But you have still said that this lack 11 of confidentiality wouldn't stop you from going to them if you 12 thought there was a serious problem.

13 A No, I wouldn't. I would go ahead. If there was a 14 safety-related cable that was severed or a damaged panel or 15 something like that, a control' panel or something, I I

16 definitely -- I wouldn't be afraid.

17 Q Do you think that you would be terminated if you i, 18 brought concerns to Quality First or the NRC?

19 A Again, I can't say that. I dot think so. We 20 shouldn't. That's part of QC, to make people aware of it.

21 But again, we're here as QC to record and follow craft. We're 22 not here as complete outside inspection of the plant or l

l D

'., 35 1 anything like that.

2 BY MR. GALLO: -

3 Q Is your answer no? ,

4 A Pardon?

5 Q Is your answer no?

6 A Is my. answer no? ,

7 Q Yes.

8 BY DR. HULIN:

.: 9 Q The question was, do you think you would be 10 terminated if you brought, concerns to Quality First or the 11 NRC? .

12 A No. I feel I wouldn't.

13 BY MR. GALIO:

14 'Q How about -- not termination, but how about maybe 15 blackballed or something by the comstock supervision or higher 16' management?

17 A If I was to report a problem, would I be blackballed 18 against? No, not that I would --

19 Q How about denied overtime?

lg, 20 A No, definitely not.

21 Q How about made to feel like you were a fifth-wheel 22 on the car, kind of ostracized by the management or kind of l

e G

i

- - . . _ , _ _ _ _ . _ _ _ . . _ _ _ _ _ _ _ . . _ . _ _ . _ _ _ _ _ . _ _ _ . . _ _ , _ . _ _ . _ _ _ _ _ _ _ _ . . . _ . _ _ _ _ _ _ , - . _ , . . _ _ . - . _ , . ~ , . . . _ _ _ _ _ . _ . . _ - - . _ . _

- . . 36 ,

1 treated rudely, that sort of thing?

^

2 A I don't feel that way at all. I know in some 3 instances, you're trying to say that if you write up too many 4 ICRs or NCRs, they'll transfer you out or get laid off. I -

5 don't believe that.

6 Q Well, how about if you go to NRC or Quality First, ,

s 7 would that happen?

8 A I don't know how to answer that. If I had a problem 9 and Comstock couldn't handle it, and if I did notify Comed by 10 paperwork and,I still didn't get an answer, I would go to -

11 Quality First, and then if I didn't get an answer there, I'd ,

12 go to the NRC.

I 13 Q Do you think that if you followed this process, that 14 you'aight be in a position where maybe they'd transfer you

, 15 into another line of inspection activity?

16 A No.

17 -

BY DR. HULIN:

18 Q Have you at any time felt like you couldn't perform 19 a proper inspection because of pressure for production?

20 A No.

21 Q Have you ever approved or accepted an inspection 22 that maybe you thought should not have been accepted?

9 e

4

-,w,- w,_ - - , - -, - - - - - - - - - - ,__,__,--,,__4 e ,,_r_ .__y- ,,w, _ - - .m .~, , ..3-.m..e.__ . - , , _ , , , _ - , _ _ , , _ _ - . - , _ _ _ _ , - - _ . . - - . _ _ _ _ . - , - - - - . _

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.. e 37 i .

1 A No.

+

2 -

Q Do you know of any inspections, not necessarily that 1 3 you have done, that were improperly inspected? -

4 A No.

5 Q Do you ever get any feelings that cost and schedule 6 ovorride quality when you're out on the site? ,

7 .A No, none.

y If anything, it would beLRore lax.

8 People would have a tendency to take too much time to make p 9 sure it's right.

! 10 Q Are the inspection criteria and the proced'udes and 11 the instructions clea2 to you, so that you can do your job '

! 12 ,

properly?

r13 > A Yes. 1 14 '

MR. GALLO:

i Why don't you take them one at a time?

15 I suspect the answer is no on some of it.

16 BY DR. HULIN:

, 17 Q All right.

How about for the criteria for -- let's la l*

see, you're doing cable pulls, correct?

i 19 A Yes.

20 Q Okay.

There are critaria that are listed that would 21 mean that a cable pull was unacceptable.

22 A Yes. Such as debris in a --

l 0

w w ,-w- ,, - . - - a-----,r,-- -n.., , - - - - - . - , , , - ---,---,w-

. , . 38 l

9 1 Q Debris and no softeners. *

^

2 A Hold tags aren't listed'and stuff like this.

3 Q Those criteria are pretty well laid out for you?

4 A The stipulation that bothered me in training was how 5 clean does a pan have to be, what do they call clean. The 6 procedure doesn't specify the difference between fireproofing, 7 let's say, that's soft that won't hurt the cable or con' crete 8 that will hurt the cable or wire filings or anything like 9 that.. It says, "It must be clean."

10 There's a common-sense involvement there that, you 31 know, dust isn't debris. Fireproofing, if there's a crew ,

12 working on that area and it should get into the pan, it should

. 13 be clean.

14 I feel that one inspector might have his crew clean 15 out a pan more~than what another inspector might. Another 16 inspector might pull through, let's say minor debris or 17 something where another inspector will hold it right to the 18 procedure and say, "No, it has to be clean."

19 BY MR. GAILO:

20 Q But do you think that inspection attribute, then, is 21 unclecr because it allows too much room for judgment?

22 A No. It's just interpretation on the inspector. I e

O

39 1 mean, it's spelled out in the procedure that that's the way I

, 2 it's supposed to be. If an inspector doesn't do it that way, 1

3 I feel that's --

, j 4 BY DR. KULIN:

1 5 Q But you said there could be some question about what 6 constitutes debris in the tray.

7 A 'We did get an argument from the craft on it. See,  ;

8 craft, they'll contend that that's fireproofing; that doesn't

9 have to be cleaned. And we have a procedure that doesn't 10 stipulate what's good or what's bad. It just calls it debris, 11 and all debris must be removed. It doesn't say from one .
12 debris to the next.

13 So you tell them that they've got to get it out?

} Q 14 A Yes.

15 Q so basically even though they haven't stipulated

16 what is debris and what is not debris, you are willing to make 17 -- you have to make a judgment. So you're willing to make a 7

18 judgment on the basis of --

19 A Procedures.

20 Q Procedures.

21 A Yes.

l 22 Q okay. Are the procedures spelled out?

t e

S

- 40 1 A Yes, I believe they are.

2 Q Do they tell you, for instance, what you're supposed 3 to do when you come to a conduit that goes thrdugh the wall or ,

4 something?

5 A Yes. .

6 BY MR. GALLO:

7 Q Are you answering that' question generally to apply 8 to -- what procedures do you have in mind?

9 A Well, the procedure as far as embedded conduits.

10 488 references 438 on a lot of cases, and so basically we have 11 to follow 438 and 488. -

12 Q so you think basically that those two procedures are 13 sufficiently clear?

' 14 A I believe so, yes. It's just a matter of an 15 inspector enforcing them. One inspector might not enforce it 16 as hard as another inspector.

17 BY MR. MARCUS:

! 18 Q But you have to admit there is some judgment on it?

19 A Yes. There is common sense involved.

l l

20 BY DR. HULIN:

21 Q Have you ever been instructed or discouraged from ,

22 documenting nonconforming conditions on proper forms?

e e

, 41 1 *A No. The only -- as far as nonconforming items out 2 there at at this point of the game -- stage of construction 3 would be the safety-related and the non-safety-related .

4 criteria. I believe if it's not wrote up, I'll write it up-or 5 check the log to make sure that it has been wrote up. It's 6 just -- in a sense, it's not really writing it up. It's just 7 letting Engineering know that the problem is there, and in a 8 lot of cases, they know that it's there. They're waiting for 9 the cable to get there, so they can disposition it.

10 BY MR. GAILO:

11 Q Are you referring to the potential for separation "

. 12 conflicts between safety-related and non-safety-related cable?

13 A Yes.

14 BY DR. HULIN:

15 Q How do you handle quality concerns, safety-related

! 16 or non-safety-related, that are not directly related to the i

17 inspections that you are doing? Do you observe when you're 18 walking through the site?

19 A I'll ask Harry Revels, the night shift supervisor, 20 about it.

l l 21 Q Is this your understanding about what should be 22 done? I mean, have you been told what you should do if you l

l l

l

?

.- - . ._-- _ -- . . . . - - _ _ . = - . - . - . _ _ - --- ..

. 42' i I see a quality concern that is not directly related to something you are' inspecting?

2

. 3 A No. I can't recall. ,

4 Q so you would talk to Revels?

- . 5 A Yes. I have in the past, like we've -- well, there 6 was some vandalism going on, and we were told to be on the x 7 watch-out for that, people breaking panels, glass out of -

8 panels and stuff like that, and we were told to report it to 9 the Lead if we seen anybody, anything.

10 And, oh, a month ago, there was a glass broke out of 11 a panel, and I turned it in, and I got an answer back the next 12 day, so the day shift had turned it in, had done the paperwork i

13 . cn1 it, and it was being corrected.

. 14 BY MR. GALLO:

15 Q I have a few question's that I'd like to pursue.

16 These are more -- some of them are general, but these are more 17 directed to some of the concerns that Archambeault indicated.

18 Let me just ask you a general question first. Are 15 you aware of the problem that he discovered in the upper 20 cable-spreading room involving the cables being cut in some 21 instances and drooping and the saparation violations, minimum 22 band violations?

e S

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43 T

1 A Yes.

2 Q Were you with him on that inspection?

3 A No. .

4 Q Did you -- what's the source of your information on 5 that particular problem? -

6 A Well, it's obvious you can walk up any given riser 7 up in the spreading room and see the problem. But my question 8

,< is, this is a sister plant, and the criteria that's generated 9

on this plant has been generated on another plant, and if that 10 problem exists here, then it should also exist there.

+

11 Q Did you become aware of the problem in the upper ~

12 cable-spreading room before Archambeault did or after

. 13 Archambeault?

! 14 'A Everybody, I believe, was aware of it. Greg pursued 15 it, followed through. He wanted -- he wanted -- would you 16 call it an answer? It had been wrote up. Nothing had been 17 changed. And when he checked upon it, evidently nothing had 18 4

been changed, so he just, in a sense, just followed through.

19 Q So as I understand it, this nonconforming condition 20 up in the upper cable-spreading roon was one that the 21 ins.pectors generally were aware of?

22 A Yes.

d e

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44

. 1- Q Before Archambeault hit the scene?

2 A lit w'as commonly talked about.

3 Q It was commonly talked about. And then at some 4 point, Greg decided that he was going to write it up, and he 5 did?

. 6

( Well, to my understanding, he had it all written up 7 before I started in cable-pulling, and during training and 8 during pulls, I always questioned the crew why they put it 9 in. Why don't they put it up over the top of the hanger 10 instead of putting it in that way, and they just said, well,

\

11 they're following through the way the rest of the plant is. ,

l 12 I believe that Greg just never got an answer, a l 13 clear answer, and he just pursued it. He gave it sufficient 14 time for an answer, if there should have been an answer, and

. 15 he just kept on with it.

16 Q Let me pursue that a little bit. When these cables 17 were being installed out there, and there had to be a QC 18 inspector along at that time.

19 A Yes.

20 Q I would assume that the QC inspector would have 21 noticed these non-conforming conditions and would have written 22 them up in some fashion?

e O

. 45

~

1 A At the time of installation, you can be close to a 2 band radius violation and it will be one of those judgment 3 calls either way. With time, two or three years, on some of ,

4 those cables that are installed, they sag, thus, making an.

5 obvious band adius. With a year, two to three years, with 6 that many cables doing it, starting to sag altogether, comes 7 the question now, should it all be wrote up or not.

8 Q You don't know whether or not the inspection was 9 properly done at the time of the installation?

10 A Procedures change.. I'm sure they have changed from

, 11 the time the plant started back in the 1970's up until the -

12 1980's now. I'm sure there have been revisions and 13 clarifications. Things change.

14 Q At the time of the installation up there, the cables 15 that we are talking about, they may have been properly 16 installed, they may not have, and they may have been properly 17 accepted through QC inspection or they may not; you really ,

18 don't know? Is that correct? At the time of the 19 installation, now.

20 A At the time of the installation, I would say they 21 had to sign it off per procedure at that time, otherwise the 22 inspector would be in violation.

O

~

46 1 Q You are assuming they did it right?

2 A Yes.

3 Q Over time, the cables began to sag and these -

4 non-conforming conditions began to create themselves?

5 A Correct.

6 Q What I am trying to pin down is whether the QC 7 inspectors, the cable pull QC inspectors on the second shift, (

8 were aware of this sagging condition and there were some 9 non-conforming conditions before Archambeault went up and 10 noted the problem and wrote it up.

11 A Yes.

  • 12 Q How do you know that?

13 A It was talked about. Anybody that pulled through 14 there said, it seems funny that this hasn't been written up, 15 they are in violation. One answer was that -- one time I 16 asked about it, they would say, well, those get sealed off, 17 they are on the floor any way and there will be no weight on 18 the cable la>or.

19 Q You are essentially telling me, and I want you to 20 correct me if I am wrong, that some QC inspectors, including 21 yourself, prior to the time Archambeault wrote it up, had 22 noticed this situation?

e l

47 1 A Yes; we did. '

2 Q At least in your case, you brought it to the 3 attention of someone and they gave you the explanation you .

4 just told us about.

5 A Yes. They would be sealed off at the floor, there 6 would be no weight on the cables.

. 7' Q Who gave you that explanation?

8 A I don't recall.

9 Q Do you remember when this was?

10 A It would have been back when I was in training.

4 11 Q February / March? '

12 A April or May.

13 Q You were still in training in April or May?

14 'A Yes.

15 Q When you noticed this situation, you were in 16 training at the time?

17 A Yes. '

18 Q You didn't have any authority to write an NCR at 19 that time?

20 A Even after I finished training, I wouldn't have 21 written an'NCR, I don't believe, due to the fact that I would 22 be working in-process behind a crew and not in general e

e

- .- . . - - . ~ . - . . . -

j.

, 48 1 inspection over the other cables. I'm there to record and 2 document what my crew does. -

3 Q If you are doing that and you are assisting on a ,

4 pull, actually inspecting on a pull, and the route of the pull'

, 5 that you are on takes you through this area and you saw this 6 disarray, wouldn't you turn that in like Greg did?

7 A I would say yes. I would question it, which I did.

8 It was at that time that I was told it had already been 9 written up.

10 Q Did you see any hold tags on the cables in question? '

11 A No. .

12 Q Did you look for any?

13 A No. My understanding was the whole room was 14 underneath of an NCR and they didn't individualize it cable by 15 cable, they just took care of'that whole room.

16 Q That's the understanding that I have, after 17 Archambeault wrote his NCR, which was sometime in late March, 18 early April of 1986. Does that jog your memory any?

19 A- No. That was about the time I was in training.

20 Q Do you recall seeing this situation prior to the 21 time he wrote the NCR?

22 A Prior to that, I was in a different certification.

4

I '

49 1 I wouldn't have been in that area.

Q If k interpreted your prior remarks to suggest that 3 other inspectors had been up in that upper cable spreading ,

4 4 room, seen the disarray among these cables, and just igncred 5 their condition, would I be correct or incorrect?

6 A I would say you would be correct. .

7 Q Do you have any understanding as to why they would 8 ignore them a.1d not write up these non-conforming conditions 9 and put it or, an NCR?

l 10 A Chances ar- they would have relate it to craft, 11 question craft, why is it done this way, and the answer from F

12 craft would be, that's the way it is done at Byron. As far as 13 me saying what the rest of QC would do if they saw something 14 lik's that, I really can't say.

15 Q Did you look at these non-conforming conditions 16 yourself when you had the occezion to do so, whether it was 17 before or after the NCR7 18 A Yes; I looked at some of them, after.

19 Q The band radiuses were violated; weren't they?

20 A Yes.

21 Q Craft couldn't explain that one away; could they?

22 A No; that's correct. Per the procedures that we have 9

e

? -

1

50 1 now, you can look at the procedures now -- I don't know how

2 Unit I was built -- it is no given secret that you can walk 3 through Unit I, look down a tray and see violations, as far as ,

.4 on a corner or something. There will be cables hanging out of 5 the tray. Common-sense will tell you that it is not going to i

6 hurt the integrity of the cable, or it is not going to 7 interfere with operation or anything, but it is just --

8 Q When you see it hanging out like that, what kind of 9 non-conforming condition is that?

10 A It's in violation of the procedure. It should be an i 11 ICR situation. -

j, .12 Q What is the violation?

13 A I'd have to have my procedures here to pinpoint the 14 exact paragraph.

15 Q Is it that they are not properly trained?

Is that 16 the problem?

i 17 A They are not put in the trays in a workminship l

18 manner.

19 Q This is what I hear you telling me. Prior to the l

20 time Archambeault went up there, let's say he was up thera on 21 a pull, he observed this situation in early April, 1986, you l 22 are aware that other QC inspectors were up there some weeks i

r

. . . , -...___..._..,___...,___....,_.-_..._.,-_m.._..._..,.___-.._.._

w 51 1 1 prior to the time Archambeault was up there, and they saw the 2 same conditions, and the most they did was to question craft 3 or someone else and ask about it. .

4 A Correct. The exact same thing; Greg wrote up a big 5 separation problem down in the lower aux. There is <

, 6 approximately 60 to 70 cables in violation. They are all 7 safety related pulls. I would say how many QC pulled through 8 that sama separation without writing them up.

9 Q Why do you think they didn't do that, either in the 10 upper cable spreading room or the remote shutdown panels?

11 A I don't know. I wouldn't even speculate.

, I'd hate

  • 12 to say.

13 Q What would you do in that case?

14 A In that case, I'd question it to my lead. If my 15 lead said, that's the way it is supposed to be, I would let it 16 go at that.

! 17 Q Are you referring to the upper cable spreading room

18 or the remote shutdown panels?

l 19 A In either instance.

20 Q I can understand that in the remote shutdown panel, 21 a separation conflict is really a difficult call. In the

! 22 upper cable spreading room, you have bend radius violations.

i i

-. - .__ . - ~ . . _ . _ . _ _ , , . , .._ . ___._ _ _ _ , ,_ ._ ..._,__...._..,_._ _. _ ,. ,_. _ _ _ _ _ _ . _ _ _ . _ . . - . _ _ _ .

L -

52 1 You have Kellum grips digging into the insulation.

2 A I haven't seen any of that. I've seen the bend 3 radius. I haven't seen any of the grips digging in. ,

4 Q Let's stick with the band radius violation. What 5 are you supposed to do when you see one of those, on a pull 6 you are assigned to?

, 7 A Write them up.

8 Q What do you write up?

9 A Violation of the band radius.

10 Q Which document? ICR? NCR? ,

11 A ICR. ,

i i 12 Q You don't understand what you are supposed to do 13 when you see neighboring cables on a pull that is 14 disassociated with those neighboring cables?

15 A Yes; I understand what I'm supposed to do.

16 Q What is that?

17 A You are supposed to write them up via ICR. In some 18 instances, let's say you are coming down on a band violation 19 or something like that, it should be wrote up. That whole 20 room has been wrote up. There is no sense in pursuing that.

21 If it was inside the equipment or something, I would write it 22 up. Coming down to common-sense, the procedures say cables O

e mmmmm- imisii

. 53 1 have to be tagged entering or leaving an enclosure. If they 2 go in or out of a room, a lot of times cable is missing a tag, 3 an identification tag. That is supposed to be written up ,

4 also.

5 In ny. eyes, I don't believe something like that d

. 6 should be mandatory to be written up. When I run across ,

7 something like that, I just call and find out who the

  • 8 inspector was ar.d tell the inspector, hey, you overlooked

[I 9 something.

10 BY MR. MARCUS: .

i 11 Q on the upper cable spreading room, isn't it true -

12 that the problem there was common knowledge to everybody?

13 A Yes.

. 14 Q Writing it up would be like saying it's day light, t

15 Isn't it something like that? Everybody knew about it. It 16 wasn't like if you were writing.it up, you were writing up any l

17 big surprise to inform somebody of a problem. It was l

18 something that everybody knew about.

19 A Yes.

20 Q You write it up, it is almost like belaboring the 21 obvious, it is not like the Comstock people don't know about 22 it, or even the Edison people. Everybody knew about it.

e 1

. l 54 1 A Like I said, this is a sister plant. The same M 2 violation has to be elsewhere.

3 BY MR. GALLO: .

4 Q Everybody basically was aware of the separation 5 conflict down around the shutdown panel? -

i 6 A That's a control room. I wasn't aware of that. I 7 haven't been in there. I still haven't been in there to this 8 date.

, 9 Q How did you become aware of the problem?

10 A They put two inspectors o_n it, writing it up.

4

.i 11 Q You weren't one of them? '

4 1

12 A No.

i' 4; 13 Q I understand you were training with Archambeault 14 when he came across this footage marker problem. Is that 15 true?

16 A Yes.

17 i'

Q Did you observe the discrepancy on the footage

! 18 markers as well?

19 A That's common for a marker to be off. It's no big 20 surprise.

21 Q In this caso, you saw it?

22 A I was in training at that time. I can't say if I J

e 9

-v,-- w sw-- ,ye,-w--p-~-en- ,m_.+,-,--y-,- y,, ,,-u,ew--n--m-em,--,,-re-

--,m,p4-,,,w,-,-w- m -- - --m- - - - - - - -

Q -

55

, I went up and verified with him that the footage was off or if I 2 just stayed out of the way of the craft and l'et him do his 3 work.

4 -

Q Were you present when he discussed the issue with 5 Tuite?

6 A He asked the question (here. Bob said we work to 7 the ,4.8.8 procedure. . -

8 Q And did he say anything with respect to 4.3.8? ~

9 A Yes. He did say we inspect to 4.8.8 criteria and we 10 do not have to inspect t.o 4.3.8. '

11 Q What did you understand Tuite to mean when he said .

12 that?

13 ,

A Well, per procedure, if the footage marker 14 discrepancy should occur, we are to cease pulling from the 15 real. Now the procedure has been changed. We can go ahead 16 and just write on the actual footag chat we take off a reel.

17 At that point in time, we were to stop pulling. He let the 18 pull continue. He didn't stop them from reeling the cable.

19 Q What did you understand him to mean when he said "we 20 don't work to 4.3.8, we work to 4.8.8?"

21 A As far as inspections, we inspect to 4.8.8.

22 Q As I understand it, correct me, because I'm sure you e

8

+

56

~1 are more familiar, the procedure that covered this footage 2 marker problem was 4.3.8; right?

3 A Yes. ,

4 Q That is the installation procedure for cable?

5 A Yes.

6 Q Basically, there was nothing in 4.8.8 covering the 7 matter; was there?

8 A 4.8.8 references 4.3.8. It is a standing argument, 9 which do you train to, whoever comes through in training asks 10 that. Do we hold the craft to their procedure or are we just

,' 11 here to inspect to 4.8.8. -

12 Q What answer do you get to that question?

13 A You are here to inspect to 4.8.8, your 14 documentation, ar.d you are also to hold the craft and make 15 sure it is put in in a craftsmanship way to 4.3.8. We do have 16 authority to make sure and hold them to 4.3.8. A lot of times 17 they will skip a peg or try to cut a corner. They won't 18 re-train the cable in a tray.

19 Q Did that matter get clarified after the 20 Tuite/Archambeault discussion on that point?

21 A After; yes.

22 Q 1 east up to that time, there was some confusion O

e e

. . .. 57 1 in the relationship between the two procedures?

2 A Yes, as far as I'm concerned. I was in training and 3 I didn't know which one, what was what. After that, it was ,

4 cleared up.

5 Q The fact that you were in training is probably no 6 different. I think fully certified QC inspectors probably had 7 the same* question.

i 8 Do you know a man named Diederich?

9 JL Yes.

10 Q He's a second shift Ceco QA guy.

t 11 A Yes. -

12 Q Have you ever had an occasion to --

13 MR. MARCUS: PTL.

14 MR. GALLO: Yes, but apparently he works for Ceco as 15 well.

16 BY MR. GALLO:

17 Q Have you ever had an occasion to consult with him

,, 18 about questions you had on the application of procedures or l

19 any other aspect of your cable pull inspections?

r 20 A Yes. I talked to him. He audits second shift. If 21 I have any questions, I ask him. I feel free to talk to him, 22 because I had worked with him prior to working for

{.

9

-..,..,y..,we,- .- ,,-4

.y,,_..,.e w_ ,,_y7,--v--e----y--- , - - + .

.. 58

. 1 L. K. Comstock.

i 2 Q When'you were at PTL7 3 A Yes.

4 Q can you recall any questions you might have asked 5 him?

6 A The exact question we were talking about, do we 7

enforce 4.3.8, inspect-to 4.8.8, how much, how far do we push 8 it.

9 Q What did he tell you?

10 A

, He stated that 4.8.8 in more than one instance

, 11 refers you to 4.3.8 and therefore, you should hold them to .

12 4.3.8, document your paperwork to 4.8.8.

13 Q Was this conversation on this point after the 14 discussion between Tuite and Archambeault?

15 A Yes.

16 Q Was Greg present when you had this discussion?

17 A No. *

, 18 Q As you are probably aware, Archambeault circulated 19 some questionnaires. I am going to ask this question but if 20 you don't want to answer it, just say no.

21 Did you fill out one of his questionnaires?

22 A No.

e i

_]

~

59 1 Q Does that mean no, you did not, or no, you don't 2 want to answer the question? *

3 A I'd-just as soon not answer. ,

'I 4 Q one of the conversations that Archambeault had with 5 the NRC suggested that -- I am going to quote him -- really, I S am quoting the NRC, who in turn is quoting Archambeault. Greg

, 7 has said the quote is accurate.

8 He said "There is a general attitude among QC inspectors that quality problems are ignored."

9

', 10 Can you comment on that? Can you agree or disagree

'i 11 with that? -

12 A It depends on what the degree is, the quality 13 problem.

! 14 'Q Would that suggest that significant quality problems i

15 are not ignored but minor ones are?

2 Are you saying that?

16 A Yes. That's not common for me. As I said before, 17 when we do a cable pull, we have procedures to follow, there 18 is common-sense in there. It is nothing to find a violation i

l 19 at a given point.

i 20 If you go to a wall, you come through to cables.

21 You are going to find one with the tag off. You go through a 22 riser and you are going to find one that isn't properly l

{

l l

i

60 1 gripped.

i- 2 Q You kind of have to apply common-sense in the course 3 of your inspections? ,

l 4 A I'm saying some guys don't do a 100 percent 5 walk-down and again saying it is a difference in men there.

6 BY MR. MARCUS: .

7 Q Application of that judgment that you are talking ,

8 about, in your mind, when you apply that judgment, do you i 9 think tha* means quality problems are being ignored?

10 A No. I believe if there was a problem, separation 11 problem, any problem at all, I believe it would be taken care

  • 12 of. I'm nure that has been addressed at this stage of the 13 game. Obviously, there has been a lot of stuff that has come 14 up and has been addressed, changes have been made.

15 BY MR. GALLO:

16 Q What kind of minor problems do you have in mind that 17

  • simply are just overlooked? To use Archambeault's word, 18 " ignored?" >

19 A Training of cable through pans. The procedure says 20 they will be put in there in a craftsmanship way. A lot of 21 times, they are not. The procedure says any time cable i

22 changes direction, there is to be a man there. Common-sense l

l .

i.

l .

i

,.-.--..~--...,-_,~--,.,.-...--~..-,--n.,--.-,.-- , - - . . . . - , . , - . , , - - , , , - -

1-61 1 tells you that you don't have to, when you are pulling a

, 2 ' cable, but that is my argument, the cable should be 3 re-walked. Myself, as a QC person, I have to walk through -

4 that tray three times. Once prior, once during the pull, and 5 once after. The craft only comes through there once on a lot 6 of occasions. They should go through a second time, 7 re-training the cable in some instances.

8 Q That circumstance that you are describing, who is

'f 9 doing the ignoring? The craft or QC?

10 A I would say it would be QC. Some QC won't climb in -

11 a difficult place. They will just say, well, I'll depend on '

12 my crew, I know they did it right.

13 BY DR. HULIN:

14 Q Do you think that is ignoring a serious safety ,

15 problem?

16 A No, I wouldn't say it was a serious safety proLlam.

17 I would say that is again a procedure, some of the 18 common-sense lines. As far as being a serious problem, no.

19 That wouldn't be a serious problem.

20 BY MR. GALID:

21 Q I started off my question by asking you to identify 22 a minor problem.

e e

. 62 1 A That would be minor, through tray.

, 2 Q You are saying if they are not properly trained, 3 the QC inspector may not cause the craft to correct it? .

4 A Well, due to the fact that they don't re-train them,

5. put them in in a craftsmanship way, it causes overfill in the

., 6 tray, it causes extra work on Engineering, it causes extra 7 work on us. It provides extra work for the craft to have to 8 go back and put extensions on the tray.

9 BY MR. MARCUS:

10 Q Again, the training of cables in the cable tray,

, 11 what may be judged by one QC inspector as being adequately

  • 12 trained may be judged by another as being not adequately j 13 trained.

14 A correct.

15 Q That's why we have the lead inspectors out there and 16 the supervisors. If there was a question on it, like you said 17 before, you could bring your question up.

18 A Yes.

19 Q It's not always clear, there is judgment involved; 20 isn't that correct?

21 A Yes, in a sense. It has to be put in in a l

22 workmanship way. Common-sense should tell you that it should l .

_ _ _. . . . ~ -. . _ _ _

63 1 be trained in the direction of the pan.

. If that pan take~s a 2 dog leg, the cable takes a dog leg. The cable shouldn't be 3 run through there straight.

4 BY MR. GALLO:

5 Q The circumstance you were describing about the 6

cables drooping out, not being properly trained, which you 7

thought was a minor concern, quality concern, was there any 8 doubt in your mind they weren't properly trained?

9 A No. There's no doubt at all.

10 Q That's one example of a minor problem. Let me get 11 back to the words Archambeault used. "A minor quality problem 12 ignored." can you think of any others?

13 A In the re-working of a lot of the risers, they 14 re-worked the risers. I notice'd the riser I was pulling 15 through, a lot of the grips were improperly hung, in violation 16 of the procedure. Instead of writing it up, I phoned in to 17 the office and talked 91th my lead about it. They pulled the 18 package and said, no, they are re-working that riser. I 19 r

believe they should have left the tag somewhere letting QC I

l 20 know they were re-working it. There was re-work going on.

1 21 Q It wasn't ignored in that instance, but there was no l

l 22 l

tag to let you know that the matter had been flagged; right?

8 D

e 9

64 1 A Right.

2 Q Anything else?

i

, 3 A No, not as far as being ignored or swept under the .

4 carpet. I don't know of any.

5 Q Have you ever been in a situation where you were 6 writing your paperwork, your checklists, maybe a CSCR, with 9

7 respect to a pull that you had just completed, and you were 8 asked to stop doing your paperwork and participate in a 9 so-called hot pull?

10 A No. Hot pulls are common. I have been in the 11 middle of a pull before and we have pulled up and had to coil' 12 at a certain spot on a wall and he said, when you coil there, 13 flag it and tie it, we have another hot one here that we have to move on to.

14 15 Q How do you feel about that?

16 A Well, it puts QC in a hurry position. I just tell 17 the foreman that I have to do my research and I'll meet you.

18 In that sense, I can research it and come dow'. n Then I have 19 to do my paperwork, start my paperwork on this one, while I 20 still have open paperwork on the prior pull.

21 Q In your mind, is that an example of placing 22 production over quality?

I e

..-m _

. ~ . - - -

65 1 A As far as production over quality, that would be up

^

2 to QC. Your craft sometimes, in some instances like that,

{; 3 they do get in a hurry, as far as pushing cards. It's QC's ,

4 discretion if they want to hurry or not.

5 Q How about the act of interrupting one kind of work, 6 one pull, and putting you on a more important pull, at least 7 in the feelings of the production people, it is more i

8 important, do you feel being switched from one to the other is 9 any kind of conduct that indicates emphasizing production over 10 quality?

4 11 A No. -

12 Q You just don't?

13 A No, I don't believe it is production over quality.

14 If they get in a hurry, QC has that procedure to follow and 15 should hold them to it.

16 Q Did you ever have any difficulty returning to the 17 original job and finishing it?

18 A No. You have your paperwork. You have to keep your 19 paperwork on hand, should you do that. The procedure says you 20 are supposed to fill out your checklist as you are doing a 21 pull any way. Some inspectors do; some inspectors don't. The ,

22 prima donna's will just wait until after the pull is done and I

~e-+d -*mW -. - - -,-- w- i..g.,p.p..y+e,%_g%,,p m w mem-,, , ,,.,g,yyy m,y . yy9 , ...y%w pg- .y 9 -w -wy

66 1 then go back to the office and sit there for two hours filling 2 out paperwork.

J-3 Q You used that term a couple times during this .

4 interview, the prima donnas. What do you mean by that?

. 5 A Well, an inspector that will sit there and tell you 6 about his past, about his experience and how good of an N

7 inspector he is, and he will be'there sitting and talking 'and 8 doing his paperwork instead of being out in the field doing 9 his paperwork and being with the craft. A lot of inspectors 10 -- the procedure reads craft will notify QC in a sufficient 11 amount of time to do the research on a cable pull, and some *

, 12 inspectors will just sit there after they have completed their 13 research, sit in the office and wait for craft to come get 3

14 them and bring them out to the field to do their walkdown.

15 That's what I call a prima donna. Instead of going ahead and 16 doing his work, he will be waiting for craft to come and get 17 him.

d 18 Q Do you consider Greg to be a prima donna?

19 A No. I consider Greg to be an excellent inspector.

20 Q How about Rick Martin?

i l 21 A I don't know that much about Rick. He left the 22 office a short time after I was there.

1 5 .

i

. _ . - - - - - , . - , . . - , . . - . _ , _ - _ . - - . - _ - - . - _ - . - - - . . - . . - - - - - . - - - - - - - - - - - . - - - - . - ~ - - - - - - - - - -

  • 67 1

i Q This is another one of those permissive questions, 2

Do you care to identify anyone as a prima donna?

3 A No, I don't.

4 Q okay. At another point in the discussion with the  :

5 i

NRC, Greg is quoted as saying that because of Coastock's 6

emphasis on production over quality, he has heard other 7

inspectors make comments like this: It gets to the point where 1

8 all you want to do is pull the wire and that's that.

f, 9 i Do you ever recall anybody talking that way? I'm not

! 10 going to ask you who, but I just wanted to know if --

11 A Yes, there's an inspector I know of that pulled .

12

}

cable through dirty tray before. I've pointed it out. I

~

j, 13 I-brought QA in and I had him look at it, I pointed it out to my

14 lead,and had him look at it. Why he did it, I don't know. I i

15 don't know if he just overlooked it. It was in a difficult 16 spot to get to.

I coincidentally happened to be pulling 17 through the same area at the same time in a tray alongside of 18 his, and I had my men clean the tray, and in a case like that 19 where they just go ahead and pull through a dirty tray, then 20 that reflects back. My men ask me what's wrong with me, why 21 should they have to go through the work and the other crew 22 didn't because it obviously takes longer for a pull to go O

e O

+ 68 1 through that way. If they have to clean and the cther crew l

2 didn't, they got their footage in and documented where we 3 didn't. We stopped to clean tray. ,

I BY MR. MARCUS:

4 l 5 Q Did the tray eventually get cleaned?

6 A I don't know. I didn't go back and check.

7

  • BY MR. GALLO: -

8 Q But you turned the matter in to Comstock QA7 or 9 your lead, right?

10 A I turned it in. I had my lead look at it and I also 11 had overview QA look at it. -

12 Q This is somebody in soltaann's group?

13 A No, this is Ceco's QA.

14 'Q Diederich?

15 A Yes.

16 Q Do you know when it happened? I guess you don't, as 17 you indicated.

18 A Well, they took the scaffold out and I haven't 19 checked back.

l 20 Q Now, this quotation prompted that point, that it 21 gets to the point where all you want to do is pull the wire 22 and that's that. Are you aware that this particular inspector l

l l

l G

P S

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l .

  • 69 1 made a statement like that?

! 2 A There's general talk like that.

t 3 Q What do you understand that to mean?

5 4 A Pardon?

5 Q What do you understand that kind of statement to 6 mean?

7 A Well, I would say that somebody is obviously bored 8 with cable pulling due to the fact that the cable pulls from

'I 9 here to there, you check it at the walls for its tags, check 10 it in the riser for its grip and then you document it and away 11 you go to the next cable. Routinely, that's what you do. You 12 are there to pull cable. You walk tray and pull cable.

(

13 Whoever would make a statement like that is just, let's say, 14 bored.

15 Q Not n,ecessarily attempting to shortcut quality 16 concerns?

17 A I would say no because if somebody did shortcut 18 that, that talk would go around fast amongst craft and ha 19 would be pointed out.

20 Q Well, another statement was: All of these things

, 21 never get taken of. Did you ever hear anybody say anything j 22 like that?

r ,

i l .

t l

l '

l i

. l l l 70 1 1 A Pardon?

2 Q All of these things - " things" is never identified 3 -- all of these things never get taken of -- care of. I'm .

4 sorry. All of these things never get taken care of. Again, 5 that's a statement in the context, as Greg sees it, of 6 Coustock's emphasis on production over quality. l 7 A I would say that some situations -- like let's use, 8 for instance some risers, change floors. They have been 9 written up for years. You can look it up and verify it. The 10 NCR is there. You can verify the date on it. But yet .

11 production doesn't change it. Still some risers we have to

  • 12 use rope temporary supports on other risers that are written 13 up. It's been like that. Is that necessarily a QC problem or

, 14 is that in production?

15 Q The NCR has been written; it has just been open for 16 a long time and corrective action never taken. Or not never, 17 but hasn't been taken.

18 A Hasn't been taken.'

19 Q How about No one cares. Have you heard inspectors 20 talk that way?

21 A Well, no. I would say some inspectors feel that l 22 they are just here and maybe they are not getting the proper I I O

~

o 71 recognition out of being in cable pulling.

1 I don't know. As s

2 far as no one cares, I don't know if they are looking for 3 "That-a-boy" or what, but if you write up an ICR or anything ,

4 like its disposition, what's its disposition, it should no 5 longer be up to QC, it should be up to Engineering.

6 Q Finally: I'm just here for the money. As long as I

. 7' get paid, I'll sign the papers. Do you ever hear anybody say 8 that?

9 A No, but there's a degree. Again, I'll say that some l 10 inspectors are awful vague. Again I will bring up the point 11 of improperly hung grips, debris in pan, missing tags. One -

12 inspector might push it and go by the book, and the next 13 inspector will commonly overlook some things.

14 Q I have a couple of last questions. You mentioned a 15 discussion about a separation problem last week.

16 A Yes.

17 Q Can you recall a discussion among the second shift is inspectors, cable pull inspectors, that happened sometime 19 after September 5 -- let's see, that would be in about the 20 last ten days -- discussing the application of the separation 21 conflict criteria, and in particular, the one-inch criterion?

22 A Greg brought that conversation up on the separation 4

S

. 72 1

1 information questione, and it was discussed.

2 Q Did you have an understanding of the problem as Greg 3 discussed it? ,

4 A As a definition. You can have a cable running -- it 5 will be divided and it will curve over the top of the tray, 6 and that tray can be pretty full of cables. That one inch in 7 there --

8 Q What kind of clearance do you need in that 9 circumstance?

10 A In that situation there, one inch should be all that .

, 11 you need. And if you are looking at a terminated cable and -

12 that's the way it's hung, I would classify it as one inch.

13 Q Do you need a cable pan cover over the top of the 14 tray?

15 A The procedure says that the trays will be covered.

16 Q Yes, but in order to apply the one-inch separation 17 criterion, in the case where you describe where the cable are 18 passing over the top of the tray --

19 A' They had bins in that.

20 Q -- is that one inch with or without a cover?

i 21 A It should be one inch with a cover. Otherwise, your 22 12-inch free air criteria should be in effect.

i e

e

L 73 1 Q so if there is no cover, then the 12-inch criterion '

2 applies?

, I

) 3 A Yes. .

4 MR. GALLO: I have got many more questions, but I'm

, 5 going to quit.  !

6 BY DR. HULIN: .  !

P 7 Q Carl, you said that some inspectors are awfully , l t

S vague. What do you mean by that?

9 A Well, I made the statement before that instead of i 10 writing up an ICR over something simple that doesn't involve a 11 serious problem -- let's say missing tags or a grip improperly 12 hung -- I will check the cable number and call up the office 13 and verify what inspector did it, and it's developed to a 14 point now where I've got one particular inspector on five 15 different occasions. He is upset. He says it's none of my 16 business, which I guess would be true. I'm not a lead. I'm 17 not there to baby-sit him either; I'm there to do my job. But is on the same behalf, rather than writing up all his work, I 19 feel that he should go back with his crew and take care of the 20 matter.

I 21 Q so when you say you think he is vague, you think he l .

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22 is being a little sloppy with his inspections?

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. 1 A Yes. I feel that he is not performing his job 2 correctly.

3 Q so you essentially have to come along behind him and 4 help.

5 A If I was to write it up, I would have to come along 6 behind him. I don't. I call it to his attention.

7 Q But is it then your understanding that he corrects a it?

9 A Yes.

10 BY MR. GALLO:

11 Q Do you know Mike Dougherty?

  • 12 A No. -

1 13 Q You don't know the fellow that brought you here.

14 I guess I have one last request. If you wrote a 15 questionnaire, if you wrote one, I would like to have you 16 i

reconsider whether or not you want to volunteer that you did 17 because I would be interested in going over the answers 18 with you to explore them further. I don't know if you did or -

19 not, but all I'm asking at this point is that you think about 20 it.

If you did and if you decida you want to come forward, I 21 think I could speak for all of us here that it's going to be 22 no problem in terms of your work relationship or any of that 6

e 6

75 1 kind of thing. so I just leave it at that.

2 The reason I asked if you liked Dougherty -- or not 3

liked him, but knew Dougherty -- he would be a good contact to -

4 let us know. But instead, you could simply, I guess -- well, 5

I think it would be better to call Dougherty.

  • 6 BY MR. MARCUS:

7 Q I'm on the site on 2633 if you want to do that,

  • 8 Carl.

9 I think what you are saying, Joe, in light of 10 this conversation, to see what Carl is saying here, how it 11 came out on the survey, how do you read the two together? I

~

12 think if you choose to do that, that's your choice. .

t 13 A Well, I feel that this is the first site. I have no 14 problems here with QA/QC. As far as being able to say if 15 there is a problem in relation to another plant or not, I 16 couldn't say any of that because I haven't been on other 17 plants.

18 MR. GALLO: Okay. Well, that's all I have. I just 19 wanted you to think about that point. We appreciate the hour 20 and a half that you have been with us. You could have had two 21 cups of coffee.

22 (Whereupon, at 5:39 p.m.,

the interview was concluded.]

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[ CHARLES NOBLE)

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a THIS DOCUMENT IS SUBJECT TO ATTORNEY WORK PRODUCT PRIVILEGE

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2 3 __...____.................____._x 4 Interview of  :

4

. 5 CHARLES NOBLE  :

4 -

3 '.

, 1 ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~x -

8 9 Braidwood Generating station 10 , Braidwood, Illinois

  • 11 Tuesday, September 16, 1986 12

! 13 The interview commenced at 4:19 o' clock, p.m.,

14 examination by JOSEPH GALIo, ESQUIRE, Isham, Lincoln & Beale, 15 chicago, Illinois.

16 17 18 19 20

, 21 22 l .

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t 2

1 PR0CEEDING8 2 [6:19p.m.)

. 3 Whereupon, .

4 CHARLES NOBLE, 5 called for interview, was questioned and responded as a follows: -

7 DR. NULIN: I will explain the presence of all this ,

e equipment and all these people for you.

?

9 I an at the University of Illinois and I am working 10 as a consultant for Joe Gallo hora, and we are interviewing,-

11 talking to the QC inspectors from the second shift and, later

  • 12 on, some of them from the first shift.

13 The purpose of these interviews is to determine the i

14 type of relationship that exists with the management and QC 15 inspectors, and between the QC inspectors and the production 16 department, to determine if the QC inspectors feel that they 17 have the freedom to report any quality concerns they have, 18 and, in fact, to determine if any quality concerns exist in 19 their mind.

20 Now, all we can do is ask you to cooperate, and we 21 can ask you to answer the questions, and I should tell you now 22 that you are certainly free not to cooperate if you don't want e

4

4 .

3 1 to, not to answer the questions, and nobody is going to do 2 anything about it. We certainly appreciate your cooperation 3 because it's the only way we are going to be able to find out ,

4 what is going on out at the site, but feel free to exercise 5 your right to say no, you don't want to cooperate.

4 Now, those are our major concerns. I think Joe will 7 expand a little bit on some other areas that we are going to a get into.

9 MR. GALLO: Yes. The only other further 10, explanation, I think, that is needed is that I'm sure you are 11 aware that Greg Archambeault testified at the NRC in the last*

12 week, and during his testimony he indicated that there were 13 other inspectors that shared his views, and we are trying to i

14 determine by these interviews if that is the case, and if it 15 is, what steps could be taken to try to improve astters. That 16 is basically the extent of our objective here today.

17 MR. THORNTON: You might explain who the rest of us is are so he knows who he is talking to.

19 MR. GALLO: Oh, sure. You may recall that I'm Joe 20 Gallo. Peter and I are lawyers for Commonwealth Edison. We 21 are working on that NRC hearing. George is with connonwealth 22 Edison.

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. 1 MR. MARCUS: I'm assistant to the manager for QA, ,

i, .

2 but I'm here on site.

l 3 BY MR. GALLO: ,'

4 Q so, do you have any questions?

5 A well, I don't know what all Greg said. I don't 6 know. All I know is what little was said in the paper, and I j 7 can't rely on the paper, okay? So I don't know what Greg -

1 l, 8 said. Greg has talked to me about less than five minutes '

l

9 after that, and that was maybe Friday of last week. I

! f

, 10 BY DR. NULIN: I j 11 Q okay. We are not so concerned about what Greg said '

it I j-12 as we are about your perceptions, your experiences working out

[ 13 there on the site, and we will go through a list of questions

1.  !

!li 14 here. I think the best thing to do is when we get done, if we is haven't covered everything you wanted us to cover, then feel la free to say, hey, you missed this point.

l 17 A okay. Now, myself personally, there has only been >

1 i 18 one instance -- and again, no names, okay, because this is ,

19 only a one instance thing, what I'm getting ready to say. In -

l l 20 fact, I even went up there and showed Ceco QA the same thing, i 1 -

l 21 and they said that Ceco is going to come out with a memo to L

! 22 repair it.

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1 We have got a hanger out there right.at penetration,

2 4 by 4 by half-inch, I believe. Before it was painted, you could see daylight through four inches of metal, and we're 3

4 talking about this wide, an eighth to three-sixteenths wide.

5 I brought this up to the supervisor and the s supervisor says -- . .

7 BY NR. MARCUS: -

e Q To your supervisor? .

9 A Yes. This was some time ago. We are talking a .

10 while back.

11 Q okay. -

12 A And he told me that, look, these particular hangers 13 at the first penetrations have all been turned to Ceco, they 14 know about them, so don't do it, don't write nothing on it. I 15 .

had no reason to disbelieve the guy. But then about a month, la two months down the road, he says, no,s.othing has been turned 17 over to Ceco. So then --

le Q The same person?

19 A No.

20 Q A different person.

21 A Different one. So again, I just let it be. But 22 when Ceco QA case, I asked him. I said Has anything ever e

4 h

64

, 6 4; 1 been turned over? And he says no. I said: All right, I've i

2 got something to show you. So I went out there and I showed 3 him.

.(>

4 Q Who was that Ceco --

5 A Saentek. In fact, that was the first time I had  :

6 over seen smentek. This was about three or four weeks ago. ,

4

. 7 In fact, it had something to do with an NRC allegation, so ,

s smentok was out in our office talking to us. He said: If you -

t 9 have any quality concerns, I want to hear them. so that was 10 the only thing. Then he looked at it and he sayst Well, on i i 11 something like that, Ceco is going to be coming out with

  • l 12 something to cover these plate laminations. That's not plate l

.l 13 lamination; that's a defect. That's a material defoot. But

, 14 it's their plant.

v Can you describe the defect to me again?

l 15 Q There are 16 issues out there where plates are not laminated properly.

i l 17 A Right. okay. What it is, it's about three-quarters t l 18 of an inch wide, okay? It's anywhere from an eighth to i 19 three-eighths, an eighth to three-sixteenths wide, and it goes [

j 20 through four inches of steel, and the back side of it has got i 21 the same thing. Now, you could see, once upon a time before.

f 22 it was paintad, you could see daylight all the way through.

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El* 7 1 BY MR. GALLO:

2 0 You are describing a hole?

3 A Yes. It's just a defect on material. .

4 BY MR. MARCUS:

5 Q Is it where the eaterial pulled apart?

6 A There's nothing there.

7 Q Nothing there?

I

, 8 A Yeah. -

9 Q It was just never lined up?

10 A Well, it's just a defect, okay?

11 BY MR. GALLot '

12 Q Is the hole in the metal or is it between the edge 13 of the --

l 14 A Wo, it's the metal itself.

15 Q In the metal itself?

16 A Right. Right in the metal itself. And it's their 17 plant, so I just let it be. That was the only instance I had, 18 was just that one, and to me, that's not enough to go to 19 anybody, okay, because if they say Ceco is going to come out -

20 with a letter to examine it, then we don't have no recourse.

21 BY DR. HULIN:

22 Q okay. Let me get some other information here. How 0

0

. . a

. 1 long have you been employed by Comstock?

2 A Thir' teen months.

3 BY MR. GALLO:

4 Q Do }ou want to state your full name first?

5 BY DR. NULIN:

6 Q Yes. I'm sorry.

7 A My name is Charles R. Noble.

. 8 BY MR. GALLO

! 9 Q You have been with Comstock 14 months?

10 A Well, brokered out to them for 14 months. I came 11 here August 6th, so it has been about 13 months. .

12 BY DR. NULIN:

13 Q What areas are you qualified in?

14 A I'm qualified in welding, configuration and cable 15 pull.

16 Q And you are working right now in cable pulling?

17 A Right.

18 Q Do you think you have adequate -- you know, you just 19 described a problem that you saw. Do you think you have 20 adequate access to supervision if you have technical questions 21 you want to bring up?

22 A Yes.

1 8

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1 Q Who would you talk to?

2 A Who have I talked to?

3 Q Who would you talk to? .

4 A okay. If I couldn't get adequate from my lead --

5 Q And your lead is?

6 A Tony Simile had told me I've got ad open door right 7 to him, which I have only had to utilize that once. That is 8 only because the guide just didn't --

9 Q Your lead is Schirmer?

10 A Yeah, but not at that particular time.

11 Q So right now if you had technical questions you '

12 would probably talk to Schirmer first?

  • e 13 A Ch, yeah.

14 Q Who would you go to then?

15 A Then if I had any, then I would go to Harry.

16 Q Harry Revels?

17 A Right. Then after him, then I would go to somebody 18 like Tony.

19 Q Tony simile?

20 A Yes.

21 Q Okay. Do you ever have questions that come up on 22 the job about administrative matters, not technical issues O

9 e

'o 10 1 about the job, but administrative matters? Shift preferences?

2 A Not myself. I was hired in from the State of

', 3 Washington to come on swing shift. They told me not to take -

4 this job unless I could work swing shift. Okay. I've got no 5 problem with swing shift, so I would just as soon just stay on 6 swing.

7 Q How about any other administrative things, like 8 vacation time, days off?

9 A Well, being a union member, and I've been a union 10 member for some time, anytime you want a vacation, and I've 11 been on the job adequate, which I've been on this job 13

  • 12 months, which is plenty adequate, I can go on vacation anytime 13 I want. All I have to do is just follow their procedures,
14 write them a meno ten days in advance. That's all there is to i 15 it. If I didn't, then I would just go anyway. There's not l

16 auch they can do. Now, unless there is something real -- if 17 they just want to be just total -- then that would be 18 something else. If they say I have to be here, this has to be

19 done, then I will change it.

l 20 Q If you didn't get an answer that satisfied you when 4

21 you talked to Schirmer or Revels, you say you have an open 22 door to Mr. Simile.

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11 1 A Right.

2 Q Have you ever seen Mr. DeWald or Mr. Saltaann?

3 A No. -

4 Q Do you know who they are?

5 A Sure.

4 6 Q Would you feel free to go to them if you couldn't 7 get ahold of Tony or if he couldn't answer your question?

4 8 A Well, I would just as soon let Tony handle it from 9 there and let him find me an answer.

10 Q okay. You feel you have adequate access to Tony?

11 A Yeah. And if I wanted to go to Irv DeWald -- I have' 12 never had to go that far to get an answer, put it that way.

13 Q Do you have any reluctance to go'that far?

14 A I wouldn't mind going to Irv. I wouldn't mind going 15 to him. He can get you an answer.

16 Q Do you think there is a layoff list that exists here i

i 17 at Comstock?

i 18 A A layoff list?

i 19 Q There is going to be a cutback in personnel one of 20 these days when No. 1 unit goes on line and they are down to l

21 one unit they are working on, and they are going to have to i 22 cut back personnel. Do you think there is a layoff list, the i

D 9

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1 people that are going to be laid off first?

~

2 A Well, we have been told that the people that are 3 going to be on the layoff list, the first ones that are going ,

4 to be is going to be your absenteeism people. After the 5 absenteeism people, people that has missed the most time.

6 These are the two classifications of people that will be going ,

7 first. After that, they are. going' to have to utilize what 8 personnel that they have on the job. Otherwise, if they have 9 got a guy that has a multi-cert and they've that a guy that 10 has nothing but cable pull, who are they going to keep?

11 BY MR. MARCUS:

, 12 Q Who told you that people with the poor attendance i

13 are going to be laid off first?

14 A Who told us?

15 Q Yes.

16 A That was back at Bestco, when we was working for 17 Bestco. Tom --

  • 18 Q Skidmore?

19 A Skidmore, yeah. Because the question came up, what 20 I'm saying, there was a real bad rumor of a layoff here just 21 right before Bestco vent down that there was going to be some 22 people laid off and this, and the people from the State of O

O

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13

.- 1 Washington were getting a little concerned about this. Here 2 they are bringing us 2000 miles to keep us for a couple of 3 months? Who are you going to keep? If you are not going to

  • 4 stick with us, then we just might as well start looking for 5 another job because we're not going to wait until the. last 6 doggone moment because then the market just might be flooded

8 So Tom give us an honest and direct answer, which I 9 felt was an honest and direct answer.

. 10 BY MR. GALLO:

Are there a lot of inspectors from Washington?

11 Q 12 A We've got quite a few of them.

13 Q Is that right?

14 A Yeah.

15 Q Is that working at WPPS?

16 A Yeah.

17 BY DR. HULIN:

la Q Do you think that's a legitimate reason to be on a 19 layoff list, excessive absenteeism?

20 A If you're not here, the company can't make money, 21 you know, and which is very, very simple, you know. They are 22 here to make money, and if you have a person who is only here e

4

. l t 14

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l four days a week but yet they can get a person in here that r -

2 can be in here six days a week, it just stands to reason.

5 3 Like I say, again, we have to come in to the job also, and if .

4 that person is not here, if he figures he only has to work 5 three days a week to survive and four days will give him some 6 play money, that means he can take off the other two days, and q

7 the rest of us stay here and we have to cover for him.

t 8 BY DR. HULIN:

', . 9 Q Do you know of any QC inspector who was terminated 10 from here?

?

11 A I knew of one gentleman, and I can't even think of his name.

12 I knew you was going to ask me that. He got laid i*

. 13 off for looking through paint at welds.

14 BY MR. GALLO:

15 Q Cutter?

16 A No, it was a guy with him.

17 Q A'rdnt?

18 A Ardnt. I've worked with Ardnt on three jobs. Ardnt 19 is a damn good inspector and I can just about tell you that 20 somebody had told him to go do something like that, because he 2'1 wouldn't do it on his own. That much I do know.

22 I've worked with Ardnt too much, and that really o

G i

I 15 1 upset me a little bit, when I heard he got laid off because of 2 that.

D 3 BY DR. HULIN: ,

4 Q Do you think -- help me understand this. You think 5 that somebody told him to go ahead and inspect --

-6 A No, I'm just giving you just what I think, just 7 knowing Arndt. Like I said, that's not Arndt. That just 8 isn't him. I've known him too long. I've known him probably 9 for about five years, on about three jobs.

10 Q Did you talk to him after he got --

I 11 A No, he was already gone before I could get to him.

  • 12 In fact, he even left town.

13 Q Your main --

14 BY MR. GALID:

15 Q Let me ask him a question. What was your feeling

, 16 about the matter that they were concerned with, in that the 17 suggestion was made that they were inspecting through paint?

l 18 A Well, if they did, in fact, I can't pity anybody for 19 it. You know you can't. I don't care if they did tell you.

20 Ardnt was just on a job -- in fact, I believe he just got

(

I 21 certified. And doing a job, he might have thought that this 22 was common practice here. I don't know.

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16 1 .

j 1 But like I said, I've known Ardnt too long just to 2 go and do something like that.

3 Q Well, it's clear to you that procedures requiring ,

4 cleanliness of welds prior to inspection was --

5 A To me, yes.

6 Q They required that painted welds would have to be 7 cleaned before doing the inspection.

8 BY DR. HULIN:

9 Q Your main contact with the craft people out here is lo the cable pulling crews?

11 A Right. .

12 Q And probably you do more work with the forenan of 13 the cable pulling crew than with the crew itself? I mean,

, 14 that's who --

l 15 A Well, normally the way they have it set up here is 16 the foreman will give what they call the lead puller the hard l 17 cards, okay? From there, they will normally contact me and I j 18 do my research and then go do the pull. We have very little 19 to do with the foreman himself, other than to sign.off 20 afterwards.

21 Q Okay. You know, the crews and the foreman are out 22 there to string wire and you're out there to inspect it. And l

l l

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1 that can sometimes cause a conflict. You know, they want to 2 get something pulled and done and you stop them and make them 3 cle,an out a tray or something like that.

  • 4 Does this cause anything that you would cause 5 unprofessional conflict or conduct by the foreman of the lead 6 pull?. ~

, 7 A Again, I can only speak for myself. I've never had .

, 8 anybody get upset with me. They know, as well as what we do, i

9 what it takes to pull that wire. And you can bring it up to

, 10 them, and they say okay guys, stop. We have to clean this

, 11 pan.

12 I've never had no problems. I've never had any i 13 problems with anybody out here, as far as craft.-

14 Q okay, they might get a little irritated, but they

. 15 understand you're doing your job?

. 16 A They understand, yes. They get a little irritated, 17 yes.

, 18 Q You don't interpret that irritation --

19 A Not directed towards me, no.

20 Q Now about the relationships between the QC 21 inspectors and QC supervision? Is that professional?

22 A Professional up to a point. Myself, I like to stay 9

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18 1 away from the supervisors. The least they know about me, the t

2 better off I am. I just go out and do my work, do it the best 3 I can, and just let it be. If I have problems, I'll go and ,

4 talk to them.

5 Q Is this sort of arm's length relationship, is that 6 because you have --

i .

a 7 A That's just me. -

8 Q That's just you?

9 A Yes.

10 Q Have you have problems with it in the past?

11 A I had one problem. I used to be lead here for 12 welding and configurations. For not reason -- I was never 13 given a reason why I was taken out of welding and l- 14 configurations, never.

P 15 BY MR. MARCUS:

16 Q Did you ask?

17 A Yes, I did ask.

i 18 Q Who did you ask?

19 A I asked Harry and I asked Tony. And all Tony told

! 20 me was he said we're bringing in a guy that knows the l

'l paperwork a little better. And so I thought man, I'm really 22 messing up around here somewhere and I don't know where.

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i 1 Nobody's ever pulled me aside to talk to me, see where 2 I'm making any mistakes. Not one time.

3 The only time -- well, I've had several times. That 4 was Tony I'm talking about now.

5 Harry pulled me aside one time and had me go talk to 6 Bob Daniels, to have this guy back off and start accepting 7 some hangers. And I told Harry that he is within the scope of 8 his work. If he's in the scope of his work, I'm going to let 9 him be. Now if he's out of the scope of his work, then I'll

, 10 be the first one down his throat.

. 11 And so the second time Harry told me about it, I ,

12 still didn't do it.

13 Q Harry? .

, 14 A Revels. I told Harry, I said I will get the steward 15 and we'll go talk to Bob Daniels. So I got the steward and 16 got a hold of Bob Daniels and I told Bob Daniels what I can, l

17 that I have been told to come and talk to you about backing l

18 off from rejecting a lot of these welds. And I'm just letting i

19 you know right now that I do not have any problem with you.

20 And the steward was George Nemeth. And so that was 21 the and of the conversation.

22 BY DR. NULIN:

  • l '

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,,wr, -,----,n---- - - -----rw-- - - - - -

20 1 Q Were you lead then?

2 A Yes, I was lead then. At that time, I had myself, 3 George, and Daniels and three trainees. Bob Daniels was ,

4 taking most of the brunt of the inspecting. George had the 5 . stewardship plus the EAs and he was barring once in a while 6 for a cable pull, so we can't depend on him to do it.

7 And that left myself with three trainees. -

8 BY MR. MARCUS:

9 Q When va this, Chuck? When did this take place?

10 A About November or December.

11 Q Last year? -

12 A Yes.

13 Q What did Bob Daniels have to say about that?

, 14 A Bob Daniels said you don't have no problem? And I 15 told Bob Daniels no, I don't. I said I'm just telling you 16 what I was told by Harry Revels. And he says okay.

17 That was the end of the conversation and he got up

, 18 and walked out. Which was true.

19 BY DR. HULIN:

20 Q Who was supervisor then?

21 A Harry Revels.

i 22 Q Did he pursue it any further than that?

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s 21 1 A I don't know. I'm not lead any more.

2 Q Do you think that's why you're not lead?

3 A I don't know. It was only a matter of two weeks ,

4 after that. And there's something else, too, that they were 5 saying that I was missing a lot of pan nodes on my paper.

6 They can't come up with a bad inspection. At least nobody 7 over has. And the only thing they ever really hammered s me on was pan nodes on my paper.

9 I'm taking the pan nodes off what's out here. They 10 have a computer printout sheet up here that says it's. supposed 11 to be different. They're supposed to be the same, but it just 12 depends where the guy puts his label. He can go three foot 13 this way or three foot this way. You have no idea.

14 But the list itself, we had no access to it and the 15 night that I was let go was the night that they unlocked that 16 and started giving it to Art Frew. He was the new lead that j 17 night. Up until that day, we never had access to it. We were 18 never even told about it, that there was such a thing.

19 BY MR. MARCUS:

j 20 Q You mean a computer runoff?

l 21 A Yes, we was never even told about it.

22 BY DR. HULIN:

m W

. 22 1 Q Did you interpret this as a form of harassment against you a'nd Daniels?

2 3 A I don't know if you want to call it harassment. I , ;

4 did not' pursue it. They do not have to have a reason to let 5 me go, to take me out of welding and configuration. That they 6 don't have, s

. 7 Now, what did bother me more than anything else --

8 and I'm going to be totally honest with you on this -- they 9 put me in cable pulling. I told Harry, at the time, I do not 10 have the expertise to go out and do cable pull. I've been in 11 Qc 14 years and I've never had one hour worth of cable .

12 pulling. Not even one hour worth of electrical.

13 I can go out and inspect welds, hangers. It l 14 doesn't matter where you do a hanger. A hanger is a hanger.

15 Material is material. So that portion I'm not worried about.

16 But to go out and pull cable.

17 And he told me within 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />, you can -- he says 18 this is all well within the Ceco program. Well, it must have 19 been, because I went right straight through it.

20 Q Did you get -- you got qualified in cable pulls?

l 21 A Right.

22 Q You got training on the job?

i 6

k v ---e-,r,- ,---w,,---,-w--~--n--,vw---,e-e.- - m~~ - - - - --+--,,,-e,m------r,~=----wn --------e---------n-m.--n---m-- v-------,-'

~

4 1

23 1 A Oh, yes. And I got good training. l 2 BY MR. MARCUS:

3 Q So you feel you're qualified? ,

4 A Now. This is only for cable pull. If they was to

, 5 ask me to go into terminations, I would hesitate real bad, 6 being as terminations is no place for an amateur. And if 7 you've got six months, a minimum of six months, then I.

8 would say that you're qualified to do it. But I don't, and 4

9 that would really scare me.

, 10 I've asked Don Schirmer. I said when you go out, I .

l; 11 says let me go with you if I'm not doing anything. I said I - -

12 don't want any documented time, I said I want to see what

, 13 you're doing and how you do it. I says I just want to 14 understand and Don said okay. This was last week.

l 15 And so when they start the terms, I hope to be going f 16 out just to look and see what the heck's going on. Because I 17 would love to break into electrical. Cable pulls, to me, is isn't really breaking into electrical. Terminations is what I 19 would really like to get into.

20 But unistrut, conduit -- I've never done conduit, 21 per se, but I've done quite a few years in piping and there's 22 not much difference between the two. Just a little different 9

O e

I e

l . 24 1 fittings. There's a lot more stretching code in piping.

2 DR.'HULIN: Did you want to pursue t'his?

3 BY MR. GALLO:

4 Q Let me start with you were a lead on welding and 5 configuration. What point in time are we talking about? What

, 6 year?

. 7 A This last year.

)

8 Q '857 9 A Right.

10 Q You were on second shift? And Harry Revels was your m 11 supervisor? .

!* L 12 A Yes, first of all, it was John Waters. John Waters 13 was the one that appointed me the lead. He was there for 14 about three months and then he went on the day shift. Maybe 15 three, maybe~four. I don't know the exact dates.

16 And then Harry came on.

17 Q About when did Harry come on?

18 A I don't have the exact day. I can't tell you.

19 Q What month? Do you recall that?

20 A October. About October, I guess.

21 Q October of '857 22 A Yes, about that.

e 9

25 1 Q okay, so in october of '85, you're still the lead  :

2 and Harry's now the supervisor?

3 A Right.

i 4 Q And this other inspector was -- Harry thought he was 5 rejecting too many welds?

6 A Yes. Harry's going out and he's falling behind and 7 it's his choice, I guess. And he can't see it, so he's coming 8 to tell me. He told me to go out and look at it. And I told 9 him no.

10 Q What attributes, visual weld inspection weld

11 attributes were involved, if any?

12 A Okay, this particular one we're talking abcut, at 13 that time your cable pan had to do with -- if you had a grind f

4

14 mark or an undercut you were allowed 8/1,000ths. on your 15 unistrut you were allowed 12/1,000ths undercut.

16 You cannot look at that piece of unistrut or cable 17 pan and tell me that's 8/1,000ths or ,12/1,000ths. You p 18 can't do it. So he just rejected it all. And there's no way 19 you could do it. No way possible.

20 BY DR. HULIN:

21 Q Was it possible that Bob was -- Bob Daniels was l 22 really rejecting too many? I'm sorry, I phrased that badly.

L' i

t 9

e p .

, 26 1 A No, you didn't.

2 Q Okay', do you think he was rejacting welds that met

~

3 the code?

4 A Again, we can't make that decision because 5 8/1,000ths and 12/1,000ths --

6 Q Okay, I agree with that. It's a damn tough decision 7 to make.

)

8 A It's a very tough one. In his mind, they didn't 9 meet it.

10 Q Okay. _

11 I

, BY MR. GALLO: ,

12 Q Well, what was Daniels doing? Was he saying that 13 they -- which one was applicable -- cable pans were being 14 inspected?

15 A Right.

16 Q So it was 12/1,000ths was the undercut?

17 A No, that was 8/1,000ths and the unistrut was 12.

18 Q 12.

19 BY MR. THORNTON:

20 Q Is that 10 percent of the material thickness? Is 21 that what you're talking about?

22 A That's what they're saying, yes. And again, that e

e

i ,

c. .

27 1 can get into something else, too, because now you also have a

2 coating over it.

3 BY MR. GALLO:

4 Q Was Daniels saying that the undercut was greater I

5 than 107 6 A Yes, all you have to do is barely brush it with a

. 7 grinder and it's gone. Your 8/1,000ths is gone.

8 Q Well, was he saying that it was within the tolerance i! 9 of the allowable for unistrut, or was it outside the --

10 A He was getting them both. .

I 11 Q He was getting them both?

12 A Yes, he was getting them both. There wasn't two 1' 13 cents worth of difference. If he seen a grind mark next to 14 it, then he didn't fool with it, he just rejected it.

15 Q I see, i

16 BY MR. MARCUS:

4 17 Q What do you think about that?

18 A Some is pretty tight. But the thing about it, he

19 was the inspector on it and there's no way -- even as a lead 20 -- I could go out there and tell that man that he's under i 21 8/1,000ths.

22 Q I mean, would you reject it for grind marks?

e 4

_-%,~.-w.,

.+-s*-,-,--m- - - -- -- -

28 3 1 A Personally? It would have to -- I would have to 2 look at it on an individual basis. Because if I've got one 3 single grind mark there, yes, I probably would. But if you've ,

4 got a uniformity there and you can take a straight edge and 5 put it across. And if I can see a little bit of daylight --

. 6 again, you're going into a judgmant call.

7 Andonastraightedge,likeonapan[youcanhold 8 it up there and if you can see just a little bit -- but if you 9 see a single grind mark, that means they've hit it on the edge 10 or right next to the weld or you try to dish it out a little

, 11 bit and butter it up some. -

12 Q So Revels wanted you to go and try to persuade this 13 guy -- Mr. Daniels -- that he was calling them too close?

l 14 'A Yes, we tried also, for quite a while, to get him to 15 change it.

16 Q The procedure?

17 A Yes, change that procedure. 8/1,000ths,

  • 18 12/1,000ths, nobody's going to look at that. And Tony -- in 19 fact that's one of the things I wanted to talk to Tony about 20 was the 8/1,000ths and the 12/1,000ths and he said Chuck, 21 we're going to get relief here shortly, pretty quick.

22 Q Isn't it changed now?

O 9

.r.---.---_-.-- __ ___

r 29 1 A Now it is. And they got it -- now, if anything, 2 they've got it too lenient, now. They've got it now to where

{ 3 the undercut -- you can almost blow through it and it can ,

4 still be acceptable. But somebody has said that the stress on 5 it isn't going to bother the cable, so they put in a procedure 6 , so everybody is happy with it. It's something we can live by 7 now.

8 BY MR. GALIO:

9 Q Did Daniels change his inspection practice after you 10 talked to him?

11 A No. .

12 Q Did he continue to work on second shift? .

,l 13 A Yes, Daniels -- yes, in fact, it was shortly after I

'i

) 14 went'into cable, he came into cable not too much longer --

15 probably about a month after myself, and got trained into 16 cable.

17 Q You got transferred -- you were taken off the lead 18 and transferred to cable --

19 A Yes, ha was wanting to put me on days and, at that

! 20 time, I just wasn't geared up for days, in my home or anything l

21 else. My wife wac working swing and so I went back in to Tony l

22 and asked him what's the chances of just saying on swing. And 9

+ ,-y..-. - - - - . . . , , . -.,,-m. _ _ . - - _ , _-_,-_..-._,___..,_.,-.,-y,-.-_,,,.y_w,-,___--,,,__-,-,-,_%.,, .___,-__v__

30 1 Harry was in there and Harry says, yes, we can use Chuck as a 2 cable puller.'

. 3 So they put me into cable pulling. -

1 4 Q So approximately two weeks after this incident, 5

where you talked to Daniels about the undercut attribute, you 6 got pulled off as lead and transferred to days?

7 A No, I wasn't never transferred to days. I was told 8 I was going to days.

9 Q You were told you were going to days and you didn't 10 vant to. What were you going to do on days?

11 A Welding. .

12 Q Welding?

13 A Yes.

14 BY DR. HULIN:

15 Q But you went back to work for Revels on the second 16 shift and he, in fact, spoke up and said you could inspect 17 cable- pulls for them?

18 A Yes.

19 Q Okay.

20 BY MR. GALLO:

l 21 l Q Well, that suggests to me -- and that maybe that --

22 A I understand that was the only SSI that he had and i

l l

l .

a i

31 1 it's gone. I've got no real complaints --

2 Q Was it ever explained to you why you were going to 3 be transferred to first? -

~

4 A No. Like I said, I asked Terry. Again, I was told 5 by Greg Archambeault because Greg pulled me aside -- which I 6 didn't know whether to believe him or not. He said -- oh, 7 that's just pure' rumor, so that's all it was.

8 Q What did he tell you?

9 A He just told me that Harry told him that I was going 10 out of the scope of my work for welding. And there's nothing 11 out of the scope of my work. We was doing Rev A's and Rev O's' 12 and Rev A's.

13 Q You said at one point you asked Tony Simile why you 14 were taken off?

15 A Yes.

16 Q What did he say?

17 A All Tony told me was we got a guy coming in that 18 knows more about the paper.

l 19 Q Who was that?

20 A That was Art Frew. See Art Frew was the one that l 21 was wanting ma to do on days because he didn't want me in his l

22 crew. He thought there'd be a conflict of interest there.

O 9

32 1 Q You mean it was -- is it Frew or Frey?

2 A Frew.

f 3 Q How do you spell it? ,

4 A F-r-e-w.

5 Q so he was -- if I understand the sequence of events, c 6 you're on the second shift, you're the lead. Frew comes in 7 and he's the lead and for a while you're working for Frew?

s A one day.

9 Q one day? And he doesn't feel comfortable and it 10 looks like he takes steps to get you transferred to first 11 shift, so that there wouldn't be this potential conflict .

A 12 between you and him? -

P 13 A Right.

14 Q And you don't want to go to first and Harry said 15 well, we can certainly use chuck as a cable puller?

16 A Right. Like I said, that was the only instance I've

17 had so I don't know whether it's a gross amount, but --
18 Q Did it cost you money to make the switch?

i

! 19 A No, I made money.

i' 20 Q You made money?

, 21 A I made money.

i 22 Q How did that come about?

I .

L

33 1 A Well, at that time -- it's not as of yesterday, it's 2 gone. But anytime you go out of your discipline, you get five 3 percent more. You got welding is ote discipline, 4 configuration'is another discipline, electrical is a 5 discipline. I get another five percent.

6 Q I see. But you felt that your professional 7 reputation was somehow insulted by the way the whole matter 8 was handled?

9 A Yes, by the way the whole manner was handled. I've 10 been in nuclear now for over 18 years. And I've worked craft, 11 I've worked as a laborer, pipetitter. I got into QC. I've .

12 been in QC for 14 years. AWS. I've been through just about 13 every kind of course you could possibly think of. I've been 14 through three ASME courses.

15 And then you come in to here and --

16 Q How many nuclear plants have you been at?

17 A Eight.

l 18 Q Eight?

19 A Yes.

20 Q I'm sorry, I interrupted you. You said you come 21 into here?

l 22 A Yes, I come into here and for some reason they don't i

34

~

1 like the job I'm doing or what? I've been inspecting welds a 1

2 long time. I'know what they look like. I know the 3 procedures, a .

4 I can't interpret these procedures. I don't know what 5 they're like. ,I don't know what they don't like about it.

6 What am I doing wrong? Nobody's telling me nothing.

7 MR. MARCUS: Well, maybe they like what you're 8 doing.

9 BY MR. GALLos 10 Q And Daniels is on cable pulling now, too?

J; 11 A No, he's switched to days. .

I 12 Q What's he doing on days.

13 A I have no idea. I think he's on welding.

i 14 Q Welding. He's no longer calling that undercut close 15 because of procedures?

!' 16 A Well, they took him out of the field and put him as 17 lead over the vault.

18 BY MR. MARCUS:

19 Q Is that a better job?

, 20 A I don't know. He came right back out of there in a 21 week. He said that's enough.

22 Q Everybody gets changed around a lot apparently?

e

35 1 A Yes, as long'as I've been here, for six or seven

, 2 months I guess.

3 BY MR. GALLO: -

4 Q So this happened in October or November, 19857 5 A I'm trying to -- that's when Harry came on. Was

, , 6 that when Harry came on. I actually left welding in about 7 March, I guess. March or April.

8 Q '867 i

i 9 A Yes, that's when I actually left welding. '

- 10 Q When you saw this hanger with the hole in it, were ,

11 you pulling cable then? Were you a cable puller then?

J

12 A No, I wate doing welding. One of the craft -- in 13 . fact, the craft was working on a work table just right 1

14 underneath it and he brought it to me. If I would have 15 been working on tBe hanger to begin with, I would have. But f' 16 I'm not going to go out there and absolutely look for --

i, 17 Q Is it a Comstock installed hanger?

18 A Yes, I believe it is. ,

1 l 19 Q I'm sorry?

20 A Yes.

i l 21 Q So that the -- when an inspector does configuration 22 inspection, among other things, would you -- and there was a i

i ,

i

,i

  • l' l

)

m

4 .

36

, I hole in a metal member of the hanger -- I'm talking about 2 hanger configuration -- would that be a non-conforming 3 condition that you would write up? ,

4 A First of all, I would write it up as an ICR, and I'm

5 going to let engineering make that determination, whether i

6 they're going to turn it into an NCR. Let engineering 7 do it. But I'm not going to make*that -- I wasn't going to l s make that decision.

j- 9 That's how they pretty much have it set up. If you

. 10 see something write it up as an ICR. If they want to write it l

11 up as an NCR, let engineering do it because they might be able i

12 to fix it for in-house. If they can fix it with in-house, let il j 13 it be an ICR.

!' 14 'Q so as far as you know, the hanger is not being i'

! 15 tracked by either an ICR or an NCR at the moment?

!' 16 A I don't believe so.

l 17 BY MR. MARCUS: -

18 Q Well, John Smentok told you it was being tracked.

19 A He told me that Ceco was coming out with a letter of 20 acceptance for the plate laminations. That's not a plate 21 lamination. -

22 BY MR. GALLO:

O f

I l

-,---~.-,-w------ ,.._-,- ,m,_,- ,e w g.__ _ n.,v,_.

37 1 Q No, that's not his explanation. He's saying that he 2 was telling the Ceco guy about apples and he answered that the -

~

, 3 oranges are going to be there tomorrow. ,

4 BY MR. MARCUS:

5 Q Except the two of you were there and you were 6 looking at the same thing. There must have been something, .

7 maybe a miscommunication there, but you're both looking at the 8 same problem. Whether the words he used to describe the 9 problem were the same words that you would use, but I can't imagina John not understanding the problem.

10 11 A He said therefs quite a few of them in the plant. .

12 He said he's seen it all over.

13 BY MR. GALLO:

t 14 Q But where is this hanger?

15 A ch, gosh. It's in the wing wall in 426.

16 -

BY DR. NULIN:

17 Q Did you ever think about going back and writing up 18 an ICR7 -

19 A Yes, I've thought about it and that was about it.

l 20 Q What do you think would happen if you did?

21 A Today? They'd let it go through today. But then 22 back then, it would have probably been something else. '

e l

l

=

38

1 Q You mean you think they would write accept as is on 2 it?

4

'; 3 A Yes. -

4 BY MR. GALLO:

5 Q Well, that's not quite --

6 A I'm just giving my own personal --

7 Q You think you'd be criticized for writing the ,

, 8 document, or would you --

9 A After I was told not to, yes, I think so.

10 BY DR. HULIN:

11 Q Did that stop you -- if you thought it was a serious" 12 safety problem --

1 13 A Well, if there was a serious problem -- like I said, 14 we're only talking one hanger and I've looked at quite a few 15 of them on this job. And most of them, a good portion of 16 them, are excellent hangers. It's just that you've got -- I'm 17 going to s'ay less than one out of 1,000 hangers, I don't 18 believe is considered a problem.

19 In fact, I don't believe they've got a problem with 20 their welding program. If anything, they're over-welded.

21 BY MR. GALLO:

22 Q Would you consider going to Quality First with this O

e

39 j - l

, 1 one?

2 A Well, yes, I had considered it. But then again, you l 3 know, if you've got a supervisor that tells you hey, this has ,

4 all been turned over to CECO, I mean, what's left? What am I 5 going to do, go to Quality First and --

6 Q Was.this Harry Revels, that you --

7 A No, it wasn't Harry that said this.

8 BY MR. MARCUS:

, 9 Q But your supervisor said it was turned over and the 10 Edison engineer says yes, we've got it -- you've got some i

11 doubts about it apparently, but we're telling you -- -

12 A You was asking me what instances and I'm just 13 telling you the instances and for right now, as far as 14 I'm concerned, it's closed. What they're calling a plate 15 lamination and what I called a factory defect is two different 16 things.

17 Q But there is a big program in plate laminations and 18 they've got a non-conformance report out on that.

19 A Anytime you get into your larger beams -- you ought 20 to see -- this plant here is actually great next to the WPPS 21 plants. If you want to see some plant laminations.

22 BY MR. GALLO:

9 e

W

40

, 1 Q When did this -- when were you told that the system j 2 had been turne'd over to Edison? Was this in 19857 3 A Yes, this is in '85.

4 Q one could determine whether or not the system had 5 been turned over in '85 or not?

6 MR. MARCUS: Sure.

7 THE WITNESS:. Like I said, just for one instance, )

8 there wasn't no real call to raise a stink, so I just let it 9 be. And I'm not normally known, one, to let things be.

,, 10 BY MR. GALLO: '

11 Q But it had to be -- I know I wanted to ask you 12 something. I'm now guessing that it was Walters that told you 13 that it had been turned over.

14 A Right.

15 Q Do I recall that did you then take the matter to 16 Simile to discuss it? You later found out that the system --

17 A I later found out.

18 Q Yes, that the system -- or at least you later were 19 told that the system wasn't turned over, that led you to ,

20 question whether or not it had. Did you then go to Tony to 21 discuss the matter?

22 A I had discussed the matter, shortly after that, with e

e

- .- ; . . _ - . - = - --.

, 41

~

1 Tony and Tony told me pretty much what Smentek said, that they .

2 do have a rea'l lamination problem here. I wanted to go out 3 and show him, you know, show him that this isn't plate 4 lamination.

5 Q Do you know a guy named Mark Diederich?

6 A Yes.

7 Q Did you ever show him this one?

8 A He never wanted to see it.

^

9 Q Did you ask him to look?

10 A Yes, I sure did.

11 Q What did he tell you? .

12 A He said he's not into welding.

13 Q This is not a weld defect, to my understanding.

t 14 It's a hole in the material itself.

l 15 A He told me he didn't want to see it. - This was after 16 I first got here. I mean, into cable.

17 Q Did he explain why he didn't want to see it?

18 A He said it's not part of his attributes, or what ha 19 does on the swing.

20 Q Not part of his inspection circuit?

I 21 A Right. And that's when he referred me over to 22 Smentak, I guess.

9 i

G 4

I

_a 1._

!*' 42

-! l Q I see.

' -2 BY DR. HULIN

3 Q Joe mentioned, a couple minutes ago, he asked you if .

4 you thought about taking this to Quality First. Have you ever 5 been to a Quality First orientation program? -

, 6 A Have I ever been to one?

7- Q Yes.

  • 8 A Only on exits.

. 9 Q Exit interviews?

10 A Right.

11 Q You've never been to one here? -

12 A Only when they called me in for that NRC 13 investigation, about two and a half or three months ago?

14 Q Are you familiar with the Quality First program?

15 A Yes.

16 Q Could you describe it to me?

17 A Okay, if you can't get anything done within your 18 organization, you should go through your chain of command. If 19 you run out of all options, now you can call or go over and 20 see Quality First. Or you can call Quality First without even 21 going through them. That's a bad way to go because you should 22 always try to go through your chain of command first.

e I

l l

l

43 .

~

1 And they say they will get back to you.

2 But now we called Quality First the other night,

. 3 because of our little number, for a night nothing. It doesn't 4 even ring.

I 5 BY MR. MARCUS:

6 Q You mean the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> hotline?

7 A That's right. It didn't even ring.

8 Q Might I ask why you called it?

9 A Just to see if it worked. We just got it. George 10 came out and he handed us these pamphlets. -

11 BY DR. HULIN: ,

12 Q I got that number, we ought to try it. can we try 13 it on this phone?

14 A Wait until about eight o' clock at night.

15 BY DR. HULIN:

16 Q All right. We'll try it then.

17 Aside from the fact that there might not be anybody 18 there, do you feel free to bring quality concerns to Quality 19 First?

20 A I wouldn't hesitate whatsoever.

E21 Q Would you hesitate to bring the same concerns to the 22 NRC?

i I

l l

--*-w+--W--mng- p.-.----.y e 9,--,.y,*_,y,_, , . , - - p.%...y.w_ , , _ _ , . , _

~

44 1 A I want to go through all my channels first. I've l

2 never been to Quality First, I let them come to me, if they l 3 want to talk to me. If I have any quality problems, most of ,

4 the time -- in fact all my times -- I can usually handle it 5 , within house. But I have to, in my own mind, pick out what is 6 quality to what is personal. And this little instance with

. 7 them taking out a lead, you're not going to go to quality on i 8 something like that. So that's out of the question.

9 This plate lamination now that was something I l 10 probably could, but again I went through my channels and I

. 11 went as high as the supervisor and the supervisor told me this 12 has been turned over. I shouldn't have to go any further.

I 13 Why should I disbelieve the man?

14 BY MR. GALLO:

15 Q But you do?

16 A Nov. At the time I didn't. I believed him.

17 BY DR. HULIN:

i 18 Q What do you think would happen if you left here, 19 after this interview, and got to thinking about this and said, 20 you know, I don't have any reason to disbelieve him but I 21 don't believe him anyway and went to Quality First? What do 22 you think would happen? Do you think they'd be responsive?

e S

O

45 1 A Today? Oh, you know they would. I got no 2 problems. I've never had no problems.

3 BY MR. GALLO: .

4 Q What's the difference between now and early '86, 5 late '85? -

6 A I don't know. I've never been to them. I'm just 7 going with the way the news media was.

8 Q You answered his question and he said what do you 9 think would happen or how do you think Comstock management 10 would react. You said today and you suggest no problem.

11 A Yes, probably none today. Or even back then, I

  • 12 don't think they would have, if you would have went to Quality l 13 First. In fact, I'll honestly say that. At that time, if you 14 went to Quality First, they would appreciate it if you would 15 have went to them first, because they can stop them.

16 I have had problems with some quality concern when I 17 was in welding, and I've never had to go past Tony simile.

18 Q Did you relate this problem associated with the hole 19 in the hanger and this business about the system being turned 20 over to Edison, did you relate that subject, that matter to l 21 Greg Archambeault?

22 A Greg knew about this when -- for me, per se, to tell l

4

- 46

~

,  ; 1 Greg, no. Smentek was in the office and everybody and their 2 brother -- be'cause we've just got a little bitty office. And 3 everybody and their brother heard the conversation.

4 So for me to come to Greg -- because Greg was not

  • 5 in welding, he's not in configurations. And so, it really had 6 nothing to do Vith him.
. 7 . .

S 9

9-10 f

I 11 ,

12

.l 13

! 14 i t 15 l

16 17 18 19 20 21 22 9

I

'* 47

1 BY DR. NULIN
2 Q Do you think if you did go to Quality First, that 3 your name would be kept confidential? -

4 A I don't know. Like I said, I've never been to

. 5 Quality First on this job. I've heard -- again, it's only 6

hearsay -- that yes, before you got out of the offic,e,

, 7 everybody and their brother knew you went over to Quality 8 First. But again, it's just hearsay. I don't know for sure. .

t 9 Q Would it bother you if you went to Quality First and 10 your name got known? I mean, let's say --

11 A Would it bother me?

i .

No. I'd have to have a real

  • 12 good reason, first, a good legitimate reason.

13 Q Do you think you might be terminated if you took

14 something to Quality First?
15 A No, again because -- again today, with all the 16 newspaper and everything, I don't believe so.

1 Even back then, l 17 I don't know. Like I said, when I first came, I trusted i

18 everybody, and so I just had just an honest opinion, you know.

1 19 Q How about NRC?

1, Do you think if you took something -

20 there, you might get terminated?

21 A No.

22 Q Okay. There are other ways of making life

(

4 e

t 4

48 1 unpleasant for people -- no overtime, --

2 A I wish we should be so lucky. We've been working 3 10-hour days since I've been here, six days a week. -

4 Q Do you think any of these other unpleasant things 5 might happen to you if you went to Quality First, made waves, 6 so to speak?

7 A No.

8 BY MR. GALLO:

, 9 Q How about shifted to third shift doing weld 10 inspections?

11 A That would be fine. I'd make over $300 more a week I

12 by being shifted over to graveyard. I'm here to make money, 13 you know. I'm not here to -- I can handle a 40-hour job a 14 little bit, but then after that, once in a while --

15 BY MR. MARCUS:

16 Q Good job?

17 A I've got no complaints. On the overall, this is a 18 better job than Diablo Canyon.

19 DR. HULIN: Does Isham, Lincoln & Beale pay a shift 20 differential, too?

21 MR. GALLO: No.

22 DR. HULIN: They don't.

O

49 1 BY DR. NULIN:

2 Q okay. Have you~ever been unable -- you're doing 3 cable pulls now, and we've talked to a lot of cable-pulling i .

inspectors about basically what goes on during the cable pull.

4 5 Have you ever been unable to perform a proper 6 inspection because of production pressure?

7 A. Never.

s Q Have you ever been rushed, felt like you were rushed l

! 9 during the job?

10 A Ch, there's a couple of times when the old boy come i 11 in.and says, "Well, we have to get this in tonight," and we're

12 about ten minutes to twelve. Just handed the card back, say, ,

4

13 "We'll see you tomorrow, or I can get all the preliminaries j 14 done right now so we can pull it first thing when we come in, l 15 but for us to go do it right now, no. Not going to do it."

l 16 And the foreman says, "Okay," and that was the end of it.

l.

l 17 Q Do you think that there is an informal quota that 1 ,

la the cable-pullers are supposed to get per week? '

l 19 A Oh, they go for footage. Yeah, they have to get i l

l 20 footage.

21 Q Does that ever sort of get in the way of you doing 22 your job?

i e

o-50

1 A No.

, s i.

2 Q Do you ever get in the way of'them getting their 3 footage? ,

^

4 A Yeah. Yeah, I do get in their way.  ;

l 5 Q How does: this conflict -- '

6 A Well, a lot of times, see, if an inspector's there, 7 they have to have a man at every turn, band, drop, going up, 8 it doesn't matter. They have to have a man there to train 9 this cable around.

10 Well, when they're on a non-safety, they don't have 11 to. You just go for it, you know. '

12 I don't know how many it takes for them, but I know, t

13 just on a normal run, let's say 400 feet, we'll have to coil 14 it twice. Again, if we had to go up through any height, we 15 might have to coil it three times.

16 Q so if you slow them down, they make it up when they 17 do a non-safety pull?

18 A I don't know. I imagine. I know at one time, they 19 was wanting to get -- they was wanting each crew to get 1200 l 20 feet. 1200 feet is not a lot of cable.

4 21 Q Per night?

22 A Yeah. That's not a lot of cable. So a lot of ,

D e

e s

3

---.w-----,.,-,_-m .m._,,...._,.mm..., ,,,,,--..,,mmw-, ~_--.__-_r___ re,,,,_,_,,-,

. . 51 i

~

1 times, a foreman will try to take two, maybe three guys and go l

),

2 pull some non* safety, and then leave the rest of the guys in

, 3 safety, if they can. If he can't, he pulls them off that 4

4 non-safety, and everybody goes into safety pulling.

5 Q Have you ever approved or accepted a cable pull that j ,

6 you didn't think should have been approved?

. 7 A No.

[ 8 Q Do you know of any inspections or cable pulls that 9 were improperly accepted?

10 A I don't know of any, no. -

! 11 Q Well, let me put it this way. Have you seen any out ,

12 there that when you look at them, you think to yourself, "No -

l 13 way?"

i'

, 14 A For me, yeah, I've seen some. I've seen some.

!4 j 15 Q How do you think they got accepted?

16 A Well, at one time, the way they got their hangers --

l t 17 someone talked about the spreader rooms, 463 spreader rooms --

i i j 18 the hangers are so far out from the trays that when this cable 19 comes down, it comes up, then it goes down into the riser, ,

l 20 down into the gears down below. You've got guys coming

{

21 through here, and you've got masses of these cables. I j

22 They step on them, you know, to get from one area to 1

6

{ .

j . .

l t

--. , , , . - . , . . - - - , , . , - - .v,-- _,n,- -,-- n. , - , , . - , . - , . . -

  • . 52 1 another area, and these aren't necessarily electricians.

2 They'd be pipefitters, ironworkers; it doesn't matter.

And 3 when they do, they -- you're putting a bend radius violation .

4 in it. Not only that, you're cutting the cable, too.

5 BY MR. GALIA:

. 6 Q Is this the upper cable-spreading room problem that 7 Archambeault wrote up and noted?

9 8 A I don't know if it is or not. The one Smentek 1

9 showed me, some other guy from day shift wrote it up. No, it 10 wasn't Archambeault that did this particular one. Suentek 11 showed me the report on this one that wasn't Archambeault. -

12 Where Archambeault was, I had a good idea, but I don't know 13 exactly.

14 Q Had you ever been up in that area before 15 Archambeault was up in that area?

16 A Have I? Yeah. I think we all have.

17 Q Did you notice these nonconforming conditions, as

  • 18 we've described them?

19 A Yeah, I sure have. .

20 Q This was before Archambeault was there?

21 A Yeah, this was even before Archambeault. We brought 22 up to Harry. We brought it up to Diederich. And so Diederich 9

e G

m ii m i .

53 1 told us, he said something was already written on them, and 2 so, okay, sonething's written on it.

3 I went to Harry, and Harry told me that something ,

4 was written up on these. Come to find out that most of these 5 areas had been written, I guess. I haven't seen the 6, documentation, other than what Smentek showed me. But the one 7 smentek showed me covered quite a large area. Ir fact, it 8 covered a good portion of that.

9 Q But you don't remember the NCR number or anything

, 10 like that? ,

i 11 A No. On something that large, they don't even -- in -

12 fact, there was not even a hold tag issued. You'd have to put 13 it on the entire room.

14 Q How long ago did smentek show you this NCR7 15 A Ch, one and a half, two months ago. Other than 16 that, I wasn't aware that Greg had written an NCR against it.

17 Q It wasn't his NCR that you saw?

18 A No. It wasn't even his.

19 Q Okay. You didn't write an NCR? .

20 A Not on that, but -- no. I didn't write any of it.

21 BY DR. HULIN:

22 Q You seem to be telling there are some installations O

e

54 1 out there that are not up to code.' ,

! 2 A At one time when they was installed,'I'm going to d

3 say, yes, they was. When they was installed, they was. But, 4 you know, again -- and I brought this up -- they was saying 5 that just about everything up there is written one place or 4 another.

. 7 I guess some time ago, I don't know when -- Harry a was telling as this -- is they sent a guy up, and they wrote a 9 generic NCR against these rooms.

4 10 BY MR. GALLO: .

11 Q Now we're talking about the upper cable-spreading ,

i 12 room? .

13 A Yeah.

14 Q There's only one, right?

15 A Ch, no.

16 Q Now many upper cable-spreading rooms are there?

17 A, There are two of them.

18 Q There are two of them?

19 A Yeah.

20 Q One per unit?

21 A Yeah. One on each side.

22 Q The Archambeault room is which unit, do you recall?

6 e

D

55 A

1 I'm trying to remember.

2 MR. THORNTON: I think it's Unit II.

3 MR. NOBLE: Then, from that, they're even split,

+ ,

4 because now you're going into the room next to the chiller

  • 5 room.

6 MR. MARCUS: It's Unit II.

7 BY MR.,GALLO:

8 Q The cable problems that you're referring to, was 9 that Unit II or --

10 A Yeah,.it was Unit II, but it was the room next to 11 the chiller room, is -- that's, oh, gosh, I don't know the -

5 12 name of it. It's just a little-bitty room that you have to .

, 13 crawl over everything to get to this one little room, is where 14 I'm talking about, and it's at 25 NP, is where it's at .

15 The 463 elevation, 25 NP, 463 elevation.

16 Q 257 17 A NP.

18 Q And P7 19 A NP. - t 20 Q What does that mean?

21 A Okay, that's your coordinates to get you to that 22 room.

9 e

4

56 e

e 1 Q oh, I see. All right.

2 MR. GALLO All right, go ahead.

3 BY DR. NULIN

t .

4 Q Do you have any feelings that cost and schedule 5 override quality at Comstock or on the site?

6 A That has nothing to do with me, I mean, personally, 7 I mean, as a pull itself, it doesn't.

8 Q Okay. You don't -- as an inspector, you don't 9 experience any problems that you think are caused by the fact

  • 10 that they want to get 1200 foot of cable strung, come hell or t

11 high water?

12 A I don't -- no. What -- they've got so many people

, 13 .on that shift, okay, it doesn't take much to pull 1200 feet of 3 14 cable. Three 400-footers, we've done that in an hour and a 15 half, and we wasn't pushing ourselves.

16 And then you come in to, you know -- then you've got 17 a 10-man crew, you know, they're just -- I guess they want 18 something for their money, I guess.

19 But myself personally having -- it doesn't bother me 20 if they get 1200 feet or they get 800 feet. There's been 21 nights when we've only got 125 feet.

22 Q When you are doing your job, supervising -- or not o

I t

f

. 57 1 supervising ,- inspecting a cable pull, do you think that the 2 criteria and the procedures and the instructions for 3 inspection are clearly enough specified so you can do your '

4 job?

5 A Yeah.

6 Q Youdon'thaveanytroublewithtbeproceduresor--

7 A Uh-huh. There's only one problem, and again, that a goes back to Martin Diederich. He's doing his job, and, you 9 know -- -

10 Q Is this the 4.3.8 and the 4.8.8 problem?

11 A Yeah. And the notes. We've got a hard card. This 12 is the only thing I've got heartburn with all of it, is we've 13 got this little -- it's called a pull card. This is not a 14 quality record. It's nothing. You can write on it in pencil; 15 you can draw pictures on its it doesn't matter. But they want 16 QC to sign the back of it before a pull.

17 We got a CRR that says the same thing, and the way 18 the procedures and our notes read, in case of conflict, it 19 says the CRR shall override, okay.

20 so I got written up last week, because we went 21 80-some feet into the pull. I'd have signed three out of 22 four. The only problem was, was I didn't sign the fourth.

O e

. So 1 The Lead Fuller, Patty -- well, he took some calc cards, and 2 he went down'to place these guys. We're talking -- we're 3 talking about a pretty good sized cable, 5 KD cable, and we've ,

4 got three crews on it.

5 And I messed up, okay. But then the only reason why 6 I didn't sign the card is because, by mistake, he took it, and 7 he went down -- he went and placed his men and came back, and e

I was talking to him through the floor, and Mark came up, and 9 he was looking at all three cards. He says, "He's got four 10 cables." I says, " Yeah, I'm just waiting for the last one to 11 come up." .

12 so he came on up, and I hadn't signed it yet.

The 13 foreman signed it, but I didn't sign it. So I got hammered.

14 NR. MARCUS: What does the procedure say, Chuck?

15 NR. NOBLE: I know it (laughing). That's the only 16 thing I have a heartburn with.

17 BY DR. HULIN:

le Q But you know of no problems, that people can talk to 19 their supervisors and let them know --

20 A Yeah. They're changing the procedure.

1 21 Q They can change the procedure.

22 A Yeah. Mark did his job, and I should have signed i

1

59 1 it. I've got no problem. I can take the heat on it.

2 Q I mentioned the 4.4.8 and the 4.3.8 procedures just 3 a minute ago. Do you have any trouble working to those? ,

4 A No.

5 Q Do you know what the difference is?

s. 6 A I sure do.

7 Q Okay. What do you have to work to?

8 A What I work to? I work to 4.8.8, cable inspection.

9 4.3.8 is cable installation.

10 Q Okay. And if you're inspecting a cable pull, and 11 you see them doing something that's in violation of 4.3.8, -

12 what do you do?

f 13 A Well, first of all, we have to stop them, you know, 14 and find out why they're doing this. Do they have a 15 particular reason? If they are, they're in violation of their 16 own procedure, you know, which I've done many times.

, 17 BY MR. GALLO:

18 Q What do you do when you conclude they're in 19 violation of their own procedure?

20 A Well, what I'll do is, I'll just -- you know, I'll 21 say, " Hey, guys, we got a problem here now." I says, "Well, 22 I'm about ready to tell you," I says, "I can back up in G

S

60 1 writing," so if they want to see it, I'll show it to them. If 4

, 2 not, then change their ways.

4 3 Like in one instance, we had -- well, the pan just ,

4 made a big 5. But one guy was not enough to go and handle p

5 both spots. And so I stopped the pull right there, and I got 6 the Lead Fuller and told him, "I want a guy over here and one 7 over here. This one man can't handle it." And I told him, l; -

8 "That's what it takes, or we're going to train this around 9 it. We're not going to pull it through." And he said, ,

10 "Okay," so they went and got another man. -

t

,3 11 BY DR. NULIN:

  • i 12 Q Is this -- do you think this is the procedure that 3

13 your supervision would like you to follow -- that is, inspect

{i 14 to 4'.8.8 and make sure they work the 4.3.87 i

', 15 A Yeah, which is -- I've got'no problem with it.

i 16 None.

17 Q Mave you ever been instructed or discouraged from

  • i l 18 documenting nonconforming conditions on the proper foras?

l 19 A No. I'm not going to -- what they're trying to do t

i 20 more than anything else is, get it right. If you're going to i

~

21 write an NCR, make it sure that you've got an NCR condition.

22 If.you've got an ICR, then make sure you've got an ICR i

I I

i

. 61 condition.

1 2 They don't discourage them from' writing an NCR. Why .

3 write an NCR, when you can write an ICR7 And that's mainly 4

4 what they're stressing more than anything else. ,

5 BY MR. GALLO:

6 Q Well, what about this hanger with the hole in it, ,

7 though?

8 A Again, that wasn't -- if you want to get back to 9 that hanger with the hole in it -- and again, like I said, I 10 asked him, and he says, "This has been gone over to CEcol Ceco

, 11 knows about it." The problem's gone. .

12 Q Well, if that's untrue, would that suggest to you 13 that you were being discouraged from documenting a 14 nonconforming condition?

15 A Maybe he was told the same thing.

16 Q Well, let's assume he wasn't.

17 A Okay. Maybe then I'd say yes. But at that time, I is believed the man, and I didn't have no reason to believe no 19 otherwise. The guy is, as far as to me personally, has never 20 done anything like that.

21 Q I think in connection with the same hanger, you said 22 you'd write an ICR and let Engineering figure out whether or O

i

. _ _ , _ - . - .. _ , _ . _ _ _ . ---__,, , . _ . . . _ _ . _ . , . , _ y _ - _ __ . . . -

62 l 1 not --

f

'. 2 A That's right. If I had it to do over again, I'd l: 3 write an ICR and let Engineering make the decision, what they *f i

l i' 4 wanted to do. '

5 Q What do you mean, if you had it to do over?

6 A well, I'm not up on my welding configurations. I've 7 been out for several months. And I guess I do have the -- I O can go do it. But then you've got somebody from Ceco '

,, 9 themselves is telling you, too, that, " Hey, we're going to I . t

)

10 have a letter to cover this out shortly." .

11 Q It seems to me there ought to be some way that all 12 these explanations ought to convince you that the matter is 13 being --

14 A I'm a little hardheaded. I'm a little hardheaded at i

15 times, okay. I get a little hardheaded. I get that way.

16 Just I'm not used to it.

17 $Y DR. HULIN:

r 18 Q I have, I think, one more question. You've answered 19 that one.

20 DR. NULIN: That's all the questions I have. Joe, I 21 think, has a few.

22 MR. GALLO: Yes. Let me ask a couple of questions.

9 4

4 6

, 43 1 BY MR. GALIA 2 Q Do you recall an instance when Archambeault and 3 Tuite got into a discussion of whether 4.3.8 was something

  • 4 that QC worked to or not?

5 A That little meeting that you're talking about is the 6 only meeting I've ever missed,.the one when Tuite first came.

7 onto this shift. That's the only meeting I missed. ,

a They told me it was going to be held somewhere else, ,

9 and in the meantime, somebody -- everybody else got the word, 10 So I have no idea and I didn't, and I never showed up to it.

what he said at that particular meeting.

11

! 12 Q Well, I understand that it wasn't really a meeting, 13 but that Archambeault and the fellow that was his trainee were l

14 up watching cable being unwound from a reel, and they noticed 15 the footage markers were no longer correct. And it was in l

16 that connection that Archambeault sought some advice, and 17 that's when Tuite told him that he didn't inspect to -- that is QC didn't inspect to 4.3.8.

j 19 Mad you heard of that incident?

20 A Yeah, I have heard of that instance, and that's all 21 I've done. I've just heard about it. I've never seen it come 1

l 22 out of Tuite's mouth or, again, it's just hearsay.

i ,

l G

44 ,

1 Q Did they ever have a training session that addressed

. \

~

j. 2 the question of the applicability of the installation to the

.- 3 procedure, as far as QC was supposed to hold craft to comply .

4 with it?

i S A Yeah. Yeah, that we did.

4 Q what did they tell you? .

. i 7 A They told us that we are to see that craft now --

you know, that we check the footage.

l e And then we got into i

9 some big old discussions, which side do we out, you know, 10 because you can get a foot and a half off, you know, so they ,

11 went into a little bit of detail on it before we out it. Are' i 12 we going to start the sa.e?

L j 13 Q so if you were to run across a situation like I 14 Archambeault did where the footage markers became incorrect, i

j 15 what do you understand that you're supposed to do at this 16 point if the craft does nothing? '

i

{

17 A Okay. At this point here, we've got a letter out I

18 from Engineering -- in fact, I've got it hanging right over my

)

l 19 desk, just for this little situation -- that tells me that I'm - ,

i l l 20 to take actual footage by a tape and record that. In the  !

i

'l 21 meantise, ycu can go ahead and tell Engineering, let I

22 Engineering do what they have to do. We're not going to scrap 1 i i

i e {

j

[

-n l

. 65 ,

1 the cable; we're going to keep right on using it. It's just

  • 2 that we're just going to mark this iown on our checksheet,

! 3 that the actual footage was taken and not the numbers. .

4 Q Are you aware of a problem that Archambeault 5 observed near the remote shutdown panel involving cable 6 separation?

7 A I had hear'd about it, for what he was doing.

8 Q Mave you ever been in that area yourself?

9 A Yeah,'I have. But we -- I have always coiled 10 underneath the floor on top of the ceiling. We have not went i' 11 into a gear. If you wanted to go into a gear, now you'd be in 12 violation of it.

13 Q What is your understanding of the separation 14 conflict that Archambeault observed?

15 A okay. I guess he was going through the panel 16 itself, and I guess he was having a problem with that.

17 Now you're supposed to have 12 inches, you know, in is free air away from the different seg codes. And if you've got 19 that, again now, when you're coiled, you don't have that 20 problem, but if somebody brings it down, they go into a gear, 21 now you can have the two problems together. You can have less 22 than 12 inches or inside the gear.

h 4

6 i

e ~

'. 64

, 1 Q Well, if you've got some non-safety-related cables 2 coming out of s cable tray and coursing downward past a tray 3 below that has safety-related cable in it, and these ,

4 non-safety-related cables are passing over the top of the 5 safety-related cable tray, that tray has no cover, and so this 6 non-safety cable is coming down, kind of -- not touching, but 7 sloping across the top of the lower tray that has the e safety-related cable in it and then passing down the side of 9 that same tray down towards the remote shutdown panel -- that ,

10 is my understanding of the situation that Archambeault '

11 observed. .

12 A I really don't know. I couldn't tell you.

13 g can you picture in your mind the situation I 14 described?

15 A I'm trying.

la Q You've got these non-safety cables coming out of 17 this pan, and passing underneath it some three feet, two feet le below is another pan that has safety-related cables in it, and it, the non-safety cables are being terminated in this remote 20 shutdown panel, but to get there they've got to pass across 21 the top of the safety-related tray and actually go down the

/

22 sides -- it would look something like this -- if this is the E

4

, 67 -

1 safety-related tray, it would come down like this and then 6

2 right down the side. Here's the non-safety pan, the cables l

3 are coming this way and then down the side, down to the panel. ,

4 What distance has to be between the cables in the 5 tray in relation to the cables --

6 A (Laughing.) on something like that, I'd have to 7 seek advice from higher up before I'd do anything on that.

s Q Can you offer any judgment at this point?

9 A At this point, I would think something would have to 10 he done. We know there's going to be covers on it, okay, and .

11 once you get a cover on it, then now you've got a separation -

12 there, okay. But for at that point, I think I'd almost have 13 to seek advice elsewhere, because I don't think it really j 14 spells out black-and-white within our procedures for that 15 particular thing.

16 Q You know that Greg Archambeault passed out these 17 questionnaires on the second shift?

la A Yeah, I know about it.

19 Q And I've been asking whether or not, in your case, 20 for example, whether or not you received one and filled one 21 out. I've been telling the insp,ectors that if they wanted to, 22 they didn't have to answer the question, if they wanted to e

e

44

^

l decline, and you can do that as well.

2 A okay.' Well, let'me decline on that one. Yeah, that 3 will be the only one. I'll just decline on that one.

4 Q okay. Because if you were to say yes, I'd show them 5 ,

to you and ask you to identify yours.

6 Let me just ask you a couple of questions.

. 7 Archambeault talked to the NRC, and one of the questions or .

8 one of the points he made to the NRC was that because of 9 Coustock's emphasis on production over quality, he has heard 10 other inspectors make the following comments: "It gets to the 11 point where all you want to do is pull the wire, and that's .

12 that."

13 Have you ever heard anybody ever making that kind of 14 comment?

15 A I haven't myself.

16 Q "No one cares."

17 A That's not quite true. I care.

18 Q "All of these things never get taken care of. All 19 of these things never get taken care of." I assume they're ,

20 referring to nonconforming conditions.

21 A Hmmm, I don't know what to say.

22 Q How about, "I'm just hers for the money. As long as e

e

'.. 69 1 I get paid, I'll sign the papers?"

2 A Yeah, I've heard that one before, but that's not l

(< 3 quite true, okay. I've heard guys say that .

4 Q What do you mean, it's not quite true?

, 5 A I know everybody within our group up there cares.

6 They have down moments, and they might say it, but on the 7 overall, they do care. I know that.

8 Q If you had some suggestions for improving the 9 operation, what would you suggest?

10 A To improve the operation? Let's get just -- more or 11 less just get these dann hearings behind us, and let's get on -

12 and build the plant, and that'll give us more dann uplift than 13 anything else.

14 I don't think anybody's going to be out of work, a

15 because we've got just a few people that may not like it, but 16 you're looking at the livelihoods of how many thousands of 17 people. Quite a few.

18 Q How about suggestions for improving the things at 19 Comstock, if it's needed?

20 A Take that pull card out.

21 (Laughter.)

22 MR. MARCUS: We're going to look at that. We've 6

A e 4

6

_=

r .

, 70 f

1 already raised the issue.

. 2 DR. ULIN
You're not the first one that's brought

'i 3

1. that up.

4 (Laughter.)

5 MR. NOBLE: Okay.

s

6 MR. GALLO
All right. That's all the questions I

,'a. 7 have. -

8 BY MR. MARCUS:

9 Q Do you know Charlie Umbaugh?

10 A Yeah, yeah.

11 Q Do you have a good relationship with him?

.\ .

12 A Yeah. He'll answer everything. I mean, he's --

13 I've never had a problem with Chuck, Chuck Umbaugh. He's been 14 a -- he knows his stuff. I've had no problems with him.

t

, 15 MR. MARCUS: I don't have anything else.

16 MR. GALLO: Well, I guess we've finished.

17 DR. HULIN: Let me give you that. It's got my home

. 18 phone on the back, and it's got my office phone on the front, 19 and it's got George Marcus' extension here at the site.

20 s

(Business card handed to witness.)

l 21 DR. HULIN: If you think of anything -- sometimes it 22 happens, you know, you get back and, " God, I wish I'd told him e

S l

l

_ _= - -- - - -

. . _- a_ . .

,' 71 -

I that." If there's something you want to tell us that comes 2 up, give me a call collect or call George at that extension 3 and tell us what came up.

4 MR. NOBLE: Okay.

.5 MR. GALLO: Or if you, on reconsideration, want to 6 answer the question you declined to answer.

7 MR. NOBLE: That may change, too. ,

8 DR. HULIN: Well, thank you very much. We 9 appreciate it.

10 [Whereupon, at 7:47 o' clock, p.m., the interview was j 11 concluded.] ,

12 14

! 15 .

l 16 .

17 18 19 20 21 22 e

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  • 0 i .

[ DOUGLAS SCHLICHTER]

f e

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9 w

9 THIS DOCUMENT IS SUBJECT TO ATTORNEY WORK PRODUCT PRIVIL E

?

I l

l l -

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e 9

~ - ._ , ,_. ._

4 1

2

  • 3

________________________________x 4 Interview of:  :

5 DOUGLAS SCHLICHTER  :

6 1

,7 --------------------------------x 8

9 Braidwood Generating Station 10 Braidwood, Illinois 11 Tuesday, September 16, 1986 -

12 13 The interview commenced at 9:40 o' clock, p.m.,

14

'; examination by JOSEPH GALLO, ESQUIRE, Isham, Lincoln & Beale, 15 Chicago, Illinois.

16 17 18 -

19

! 20 21 '

22 o

G

. - . . . _ , , _ . _ , _ _ _ - - _y.. ,,..,,- _ . _ _ , , - _ . _ , - - ,, , - , . , - - - , _ - . . . _ _ , .. - - , . - - - - _ . - _ _ , - _.-,-,.--_--c.,

. - - .~ . - . . . , ._ . - - . . .

2 1

. 1 PROCEEDINGS 2 [9:40 p.m.)

t 3 Whereupon, i .

4 DOUGLAS SCHLICHTER 5 was called to be interviewed by Counsel for the Applicant, 6 Commonwealth Edison Company, was questioned and responded as I

7 follows:

, 8 EXAMINATION a

9 BY DR. HULIN:

10 Q Okay, you're Doug Schlichter.

l 11 A Yes, sir. ,

, 12 Q I'm Chuck Hulin. I'm from the University of

! 13 Illinois, and I'm here sort of as a consultant to Joe Gallo,

.- 14 who represents the law firm of Isham, Lincoln & Beale, which 15 is representing CECO at some hearings before the NRC, and 16 you've caen introduced to George Marcus, 17 What we're here for is to try.to determine the type 18 of relationship that exists between management and production

( 19 at Comstock and between the management and the QC inspectors.

20 We're trying to determine if QC inspectors feel that they have 21 freedom to report concerns, and we're trying to determine, 22 indeed, if there are any concerns that they have that they o

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. n 3

, I haven't reported for one reason or another.

2 Now that's the background. Bef. ore we start, I

~

3 should tell you that we can only ask that you cooperate with 4 us and talk to us and give us your frank opinions. You are 5 free not to do that. If we ask you any questions that you 6 don't want to answer, you are free not to answer them, and

~ ~

7 nothing will be made of that. It's your choice.

8 Now I think Joe would like to explain another part li 1

7 9 of what we're getting into, and then we can go on.

l

l. 10 MR. GALLO: The only other aspect is that, to some i

11 extent, we're inquiring into the concerns indicated by Greg ,

12 Archambeault to see just to what extent others feal the same 13 -- other QC inspectors on the same shift feel as he does.

i f- 14 BY DR. HULIN:

15 Q Okay. How long have you been employed by Comstock?

16 A Approximately six months.

17 Q Six months.

, 18 A I started on March 17th of '86.

l 19 Q Did you ever work at any other nuclear installations 20 before that?

21 A Yes, sir. This is my fourth nuclear installation, 22 Certified Level 2.

i l

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4 1 BY MR. GALLO:

2 Q Could you speak up just a little bit?

', 3 A Yeah. This is my fourth nuclear installation.

4 Q So you've been at three others?

5 ~A Yes.

6 BY DR. HULIN:

7 Q Where were they?

8 A Palo Verde in Arizona, Shearon Harris in North 9 Carolina, and Wolf Creek in Kansas. '

10 Q Okay. And you're a certified Level 2 in what areas?

11 A Electrical. On this particular site, I hold a cable,

, 12 installation cart only. .

13 Q okay. So here you're only cable.

. 14 A Yes, sir.

15 Q At others, you've had different certifications?

16 A Yes, sir.

17 Q Were you ever a craft employee?

18 A No, sir.

l 19 Q Do you think you have adequate access to the 20 supervision of the Comstock QC inspectors?

21 A Yes, sir, I do.

22 Q okay. Who would you go to if you had a technical e

9 6

i

) .

5 1 question?

2 A First I would meet -- my first response would be to

3 my Lead Inspector, at present Don Schirmer, and more than 4 likely with Harry Revels, our domstock supervisor.

5 Q okay.

6 A Either together or --

7 Q Do you have any hesitation about going'to them and 8 talking to them?

a 9 A No, sir, not at all.

10 Q If your questions didn't get satisfied at that 11 level, either Schirmer or Revels, what would your next stop .

12 be?

13 A I would probably -- with Mr. Revels, I would 14 probably ask to speak to Tony Simile, our next immediate 15 supervisor in'the chain of command.

16 Q Okay. Do you know who else you might talk to up the

! 17 line? -

i 18 A Well, Irv DeWald, if it came to that. I haven't had i

19 that problem.

l 20 Q Okay. Do you ever see them out on the site, Simile 21 or DeWald?

22 A Yes, sir, Mr. Simile, I have.

9 l -

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i 6

1 Q Would you have any reluctance to go if you didn't ,

. l 2 get a satisfactory answer to your problem, to go beyond Revels

3 to simile or DeWald?

'I .

d 4 A No, sir.

5 Q Have you ever done it?

6 A No, sir.

7 Q Do you think there's a layoff list that exists in Comstock?

8

+

9 A At present, I don't believe so; no, sir.

10 Q You've certainly heard shoptalk about one, haven't 11 you?

12 A Yes, sir, I've heard rumors, you know. But the way 13 I see it, we're hiring at the present day, or we just recently 14 brought inspectors on the site and certified them, and I know 15 ' the length of the job is -- well, you know, the length of the 16 job. When you're overmanned, you're overmanned, and we are 17 completing Unit 1 and moving into Unit 2. So there may be i 18 some reduction in force coming, but I don't see it as 19 immediate, you know.

20 Q Okay. Well, eventually they're going to have to 21 reduce the force.

22 A Yes, sir.

e e

7

.i -

7 1 Q Do you think -- what might determine the order in 2 which QC inspectors got terminated?

3 A Possibly myself, holding one certification, not

. 4 being able to be utilized in more than one area.

5 Q Okay. So that's a job-related --

6 A Yeah.

,7 Q Okay. How about inspectors that make waves, you '

8 know? Do you think they might be at the top of the list?

9 A That's a hard question to answer. I'd say it 10 depends on what kind of problems they were having with the 11 inspector.

If he was -- and they felt he couldn't function at, 12 the position he was in brought in to do or something, maybe, 13 but I don't know, you know -- I'm just saying, not everybody's 14

-- oh, I don't know how to answer that exactly, to tell you 15 the truth, you know what I mean.

16 Q All right.

17 , BY MR. MARCUS:

~

1G Q Let me ask a question. Do you have any reason to l

19 believe that someone who was creating -- making waves, so to 20 speak, is being considered for termination?

21 A No, not at present, no. I do know of people that 22 have been taken out of the field, possibly for their own O

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8 1 safety, because of problems they caused between themselves and 2 craft. That'was taken to Quality First, and one particular

j. 3 inspector who had a physical problem with a craft personnel on ,

4 the site.

5 Q And management reassigned him to another position --

6 A Yes, sir.

7 Q -- you feel for his own safety?

8 A Yes, in which case he may be overqualified for, so

~.' 9 there may be justification.

I don't -- I don't, you know --

10 I'm just saying maybe not, but -- because I'm not in a j 11 position to evaluate that actually, no. -

12 But that would be only -- that would be one of the 13 rumors I've heard.

l 14 BY DR. HULIN:

15 Q Do you know of any supervisors who were terminated 16 -- you've been here six months.

17 A Yes, sir.

18 Q Have any QC inspectors been terminated in that six 19 months time?

20 A No, sir, not that I know of.

21 Q Do you know of any -- have you heard of any in the 22 past that were terminated?

e

9 1 A I've heard rumors or I've heard things, but I don't

?

2 involve myself with it too much, sir. I'm just here to do a i

3 job, you know. I know the plant's had problems in the past.

4 I've read the paper, but I don't believe everything I read in 5 the paper.

6 Q Did you ever hear of an inspector named Hunter?

7 A No, sir, not that I know of.

8 Q How about John Seeders? '

9 A No, sir.

10 Q Rick Martin?

11 A Yes, sir.

12 Q Do you know why he's working where he's working?

13 A He had a personal confrontation with a craft foreman 14 on the job, a personal confrontation. It was not 15 work-related. 'It shouldn't have happened.

16 I was present. In fact, there was ten other 17 inspectors present, and we all saw Quality First, and the 18 craft foreman in question was terminated from the job site, 19 and Mr. Martin was removed from the field.

20 Q Is he the one you referred to when you said --

l 21 A Yes, sir.

22 Q Because of his own personal safety?

e

. 10 1 A I believe so; yes, sir.

2 Q Do you think the ".arenan should have been 3 terminated? .

4 A Yes, sir, I do.

5 Q He was out of line?

6 A Yes, sir, totally. x.

7 Q What was.he trying to do?

  • l' .

8 A Intimidate him. I don't really know. There was

,,. 9 always a -- as I hired on, I was training with Mr. Martin. He 10 took me through some of my DJT. And why there was a personal l

,. 11 confrontation, I don't know. It goes beyond me. -

i '

12 But Mr. Krone came into the office, got loud, i l-j 13 physical, up in Mr. Martin's face, and then after several of

^

14 us asked him to just go away, forget it, you know, he returned j 15 with some of the people that were assigned to his crew and i

16 started namecalling, pointing, and thumping of the chest and 17 this kind of thing, you know.

18 I really don't know why there was a personal 19 confrontation.

20 MR. GALLO: Could you talk up just a little bit?

21 MR. SCHLICHTER: Yes, sir. Excuse me. I don't 22 mean to -- I mumble. My mom's always on me about that.

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11 1 BY DR. HULIN:

2 Q We1I, this incident sounds kind of strong. Overall, 3 do you think there is an acceptable professional relationship .

4 between the inspectors and the craft foremen?

~

5 A Yes, sir, I do.

i 6 Q Well, all right. Let me rephrase that.

7 Craft foremen and crew are out there to pull cable, 8 spring wire, and you're out there to make sure they do it the 9 right way.

l 10 A Yes, sir. .

i 11 Q Do they have any informal production quotas that ,

i' 12 they like to meet every day?

l 13 A I'm not aware of an exact amount, though. I've l

14 heard that they try to get circuit numbers, and I've heard ,

15 that they try to get footage. So I don't really know.

't 6 Q okay. But it's possible during the normal course of 17 events that an inspector and a craft foreman might, you know, 18 have a head-butting out there --

19 A Yes, sir.

20 Q -- because you were saying, "No, that tray is dirty; 21 clean it out" --

22 A Yes, sir.

O e

i i

i. '

12

l. 1 Q -- and they might say, you know, "Come on; get,off 2 my back." These are inevitable conflicts because of the way i

3 the job is designed.

4 A Yes, sir.

5 Q How do they handle it?

6 A Well, as far as I know, they do clean the tray.

N 7 They have brought it,up as to, you know, where do you draw the a line, and that was also called up with Mr. Martin while I was 9 in OJT with Mr. Martin. A meeting was called between the 10 superintendent for the craft, Wendell Gilbert, myself there 11 with Mr. Martin, our supervisor, and the foreman in question. .

12 And what it amounted to is, they broke down the 4

13 difference between dust and dirt. I mean, you know,

, 14 Mr. Martin said he would like to eat out of the tray, and 15 there may have been a point he was getting carried away, you 16 know.

17 Q All right. But --

la A Other than that -- .

19 Q Do you think they're handled' generally 20 professionally?

21 A Yes, I do.

22 Q Do you think the rules of the workplace protect the e

e G

13 1- inspectors?

2 A Yes; I do.

! 3 Q Who protects the craft foremen? .

4 A His superintendent. I would have to say, I've never 5 had a problem with getting anything I've asked them to do done 6 or in a timely manner.

7 Q Okay. How about the relationship between the QC

.. e inspectors and QC supervision overall?

, 9 A I would say that since I've been here, it's improved '

10 a lot. There was a little bit of a shakeup at one point. Our 11 supervisor went back to days. There was a lot of rumor as to, 12 why. I don't know the facts.

! 13 Q Which one was this?

14 A Mr. Revels went back to day shift for approximately 15 30 days, and Mr. Tuite replaced him. And pretty much what 16 they were telling us was, well, Mr. Tuite was going to come 17 out to show us how it's done, to straighten out a mess that .

18 was apparently there.

19 I don't know that for a fact. That's just one of 20 the rumors that I heard. I didn't have any problems 21 personally either with Mr. Tuite. I just did my job. But 22 there was some feelings there, you know, that just didn't seem I

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14 1 right between some of the inspectors.

2 BY HR. GALLO: -

3 Q 'What was Revels doing differently than Tuite did, if .

4 anything?

5 A Nothing that I know of, sir. I never -- the 6 impression I had was that in some meetings that was called i 7 during day shift, the craft was blaming holdups on us that 8 were not adequate or whatever, you know, that were sufficient 9 to stop work and steadily blaming Quality for their production lo slowdowns, and Mr. Tuite wanted to alleviate those problems by 11 finding out for himself exactly what was happening. .

12 BY DR. HULIN:

13 Q So it wasn't so much that he was going to do 1

14 something different. He was going to -- he was there to find 15 out what was going on?

16 A Right, right.

17 Q Did he do anything different?

18 A Wel.1, a few things were changed until they made 19 some agreements on precutting cable. He stopped allowing them 20 to precut cable, if they weren't going to pull it, until they 21 did arrange for a specific area for the cable to be stored 22 protectively, which was a move that needed to be done.

O

5 15

, 1 Other than that, you know, these probably were 2 things that were handled in their meetings that I don't know 3 anything about. ,

f 4 Q Do you have any contact at all with middle 5 management, simile, DeWald?

6 A Mr. Simile, some; yes, sir. He's been present at 7 several of our Monday meetings and come out to the field.

8 Q Do you think that the relationships between the QC 9 inspectors and Mr. Simile are professional?

10 A Yes, I do. .

11 Q Did any ass-chewing go on in those Monday meetings? -

(.

12 A No, sir.

13 Q Have you ever been to a Quality First orientation 4

14 program?

15 A Yes, sir, I have.

16 Q Can you tell me what went on there?

l 17 A I was just informed of the function of the program

! 18 and what they, you know, wanted to do to help alleviate 19 concerns and make us know that they were there to help us from 20 our job and get solutions to problems that we felt weren't l

l 21- being addressed.

22 Q Okay. Did they tell you the chain that you should o

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16

1 go through?

2 A Yes, sir, they did.

4

. 3 Q What was that?

I -

My immediate supervisor and next the superintenden't 4 A 5 or whatever the situation until I was not satisfied and --

6 Q And then go to Quality First?

'7 A And then go to Quality'First."

8 Q okay. Do you feel right now that if you saw 9 something on the job you didn't like, would you feel free to 10 go to Quality First?

11 A Yes, sir, I wouldn't have any problem with it at .

12 all, if I didn't feel I could get the problem resolved in the 13 house with my own supervision. I would definitely have to try 14 that- first.

l 15 Q Have you heard anything out there in any of the 16 shoptalk that would keep you from going to Quality First?

17 A No, sir.

18 Q- Have you heard about the problems of 19 confidentiality? -

20 A Yes, sir, I have.

21 Q Do you think you would be -- do you think your name 22 would be kept confidential if you vent to Quality First?

l l

l l

1 .

. 17 1 A Well, to a degree; yes, sir.

~

2 Q Does it make any difference?

j 3 A No, sir. I wouldn't have any problem, because if I ,

4 was going, I'm sure everybody would know I was going anyway.

5 I would have been through all of management, and I don't see 6 where there would be any need for -- I wouldn't be trying to 7

hide nothing, so I don't see the need for confidentiality, 8 Q Okay. If you thought that Quality -- do you feel f 9 that Quality First and the NRC are responsive when people

10 bring them problems? -

b 11

~

A Yes, sir, I'm sure they are. .

=

12 Q Do you have any examples of something that they've 13 done that you know about?

14 A Not specifically, no, sir, not without --

15 Q Do you know about the' example of the 24 inspectors 16 that went over to talk to NRC7 17 A No, sir, I don't.

18 Q Did you ever feel that you might be terminated if 19 you took a concern to your Lead and then to Revels and then to 20 Simile and still couldn't get an answer, and you then took it 21 to Quality First?

22 A No, sir.

e S

1

,e 18 1 Q You don't think you might be terminated? c 2 A No, sir, by no means. No.

3 BY DR. HULIN:

4 Q Have you ever -- let me get a background for this 5 question.

6 When there's a long cable pull or a rush, hot pull, or something, you've'got one inspector trying to supervise a 7

8 crew that may be strung out over a long distance. Have you

9 aver been unable to perform a good inspection of a pull?

, 10 A No, sir, i

11 Q Did production pressure ever interfere with your -- .

, 12 A No, sir.

13 Q Did you ever get pulled off one pull to work on a 14 hot pull?

15 A No, sir.

16 Q Do you know what the term hot pull is?

17 A Yes, sir. I do. I have been pretty steady in my 18 crew. I'm specifically assigned to one crew that's been 19 pretty heavy into hot pulls. When I get to a point where I 20 may have a backlog of paperwork, or something, I've never had 21 any problem contacting my lead, Mr. Schirmer, and getting 22 relief until I can get on top of a situation.

8

i.

19 1

Q Have you ever had any trouble, say if you got a 2 pull and you really need another inspector?

3 A I've never had any problem getting assistance.

c .

4 Q Who do they usually send over? The lead?

5 A Another fellow inspector. If one is not available, 6 Mr. Schirmer has come out himself.

7 Q Have you ever -- you say you've never been really 8

interrupted in the middle of one pull to do another pull?

9 A No, sir.

i, But we have stopped pulls that -- through 10 some concern -- we didn't complete, temporarily coiled, and 11 then went on to another pull, only to return to that one. But 12 that's standard.

13 Q Have you ever done a pre-pull walkdown and then had

14 to stop and go do another pull?

)

15 A Yes, sir.

16 Q Does that bother you?

17 A No, sir, is Q Do you think it influences the quality of your work?

19 A No, sir.

20 Q Have you ever approved an inspection that you really 21 had some questions about?

j 22 A No, sir.

l .

20 1 Q Did ybu ever hear of any that were approved that 2 shouldn't havs been?

, 3 A No, sir. .

4 Q Did you ever walk through the. plant and see 5 conditions that indicate code violations?

6 A Yes, sir.

7 Q What do you do when you see them?

8 A Depending on the importance of it, if it's a grip on

.; 9 a cable or a tag or a damaged cable or it depends what it is.

10 I may turn it over to the craft supervision and recommend that 11 they do something about it, such as a grip on a riser. Some -

i' 12 inspectors do write an ICR, in h u- o se ICR, to have a grip 13 installed.

14 I don't see the need for it. I've never been 15 denied anything by the craft,'that I've asked them to do.

16 Q So instead of writing an ICR, you'd talk to the 17 craft foreman?

18 A In some instances, yes, sir. Only to a degree.

19 Damage or something that's not exceptionally easy to change 20 the status of, no.

21 Q When you see one of these cables that's in code 22 violation, do you sometimes think that somebody approved a bad O

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!* 21 1 pull?

2 A No, sir.

3 Q How do you think they got in violation?

4 A well, okay, maybe someone has missed something on a 5 pull, maybe. Depending on how serious. There are other -- a 6 lot of construction activities going on out here and I can't

7 -- you know, be there when the welders come in and a tray has 8

a temporary conditional release to have a cable placed in it, 9 aven though they're going to do some rework on it. Things 10 change.

11 Q so construction activity is going on continuously? -

12 A Sure, in effect.

t 13 Q And you do a pull and people come along afterwards 14 and work in the same area?

15 A Yes, sir. Things can. change.

16 Q That's possible -- a possible reason for the out of 17 code --

18 A Yes.

19 Q What I'm getting at is do you know of any 20 inspections that were improperly accepted? Any pulls that 21 were improperly inspected? '

22 A Not actually, no. Things may have been changed due o

D hare '

. 22

, 1 'to construction activities. I have found cables and risers i- .

2 that were not gripped, that had been pulled maybe five months 3 earlier, upon racerts of the cable identification.

4 It's possible that a group was rebundled to change 5 the grips out,* because they do allow different size cables, 6 different grips, and they missed one or something in the 7 regrouping procese. I have found that.

s I did find a cable that was pulled over a piece of '

9 unistrut. That was probably missed by the inspector. -

I

!. 10 turned over to the inspector, who was on my shift, in my

, 11 office, and gave him the first opportunity to correct the 1

12 problem.

13 Q Do you think these --

14 .A That's the only two instances I can think of.

15 Q Do you think these come about because of a pervasive i

16 pressure for production or do you think they come about 17 because of sloppy work habits?

?

18 A No, neither. We do the best we can, but we make 19 mistakes and that's why we're there, to help each other.

I 20 Someone reviews my documentation and I've left off things off 21 checklists. I've left dates off and someone's behind me 22 checking my work. We work pretty good as a team.

9 O

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23 1 I have probably missed a tag or allowed two tags to 2 be switched on two identical cables. But with'a QA person or 3 something -- I've never signed off a cable that wasn't correct

4 when I signed it off.

5 Q Do you have any feelings that production pressure 6 out there is sometimes more important than quality?

7 A No, sir. I can't believe that, no, sir.

8 Q Let me ask you a specific question about 4.8.8 and 9 4.3.8. Do you have sufficiently clear, in your mind, which of 10 those is the controlling document when you're supervising the 11 pull? ,

8 12 A Yes, sir, I do.

r 13 Q Can you explain that to me?

14 A Well, 4.3.8 is the guideline that craft utilizes for 15 the installation of the cable. We use it strictly for 16 information purposes only, such as our pull strings, to see l

17 that they do stay within the guidelines, traceability of 18 cable, how they set up power pulls, a lot of different 19 references.

20 4.8.8 suppliers me with the criteria to perform my 21 inspections.

22 Q Let me go back to 4.3.8 and if you observe a e

9 4

---r-e ..m.,.---.w--w--m.n..,,,,,,-,-,,r. ..,.e.,.,,_,-,,,.-,..w

i 24 violation of 4.3.8 while they're doing a pull that you are

^

1 l 2 supervising, do you stop the pull?

3 A No, sir. Not necessarily, no, sir. I can't think 4 of an instance that would cause me to stop a pull.

5 Q You see a cable -- you get a reverse band?

6 A Okay, I would document the exact location of the 7 cable band radius violation and the amount it was exceeded. -

8 And I'm not qualified to make that evaluation, whether or not 2

9 the cable was damaged beyond being able to be utilized in the 10 instance they want it.

11 Q Do you know what the policy is? Are you supposed to, 12 hold them to 4.3.8 and you're supposed to inspect to 4.8.87

  • 13 A Yes, sir.

14 Q And if you see a violation of 4.3.8, you're supposed 15 to stop it, write an ICR?

16 A Not necessarily stop the pull.

17 MR. GALLO: Can you speak up?

18 THE WITNESS: Not necessarily stop the pull. As far 19 as I'm concerned, damage, I'm not qualified to evaluate to a .

i 20 degree. I'm there to document and investigate, research and 21 visually inspect the installation.

22 BY DR. HULIN:

l e

13

- - , . . . - - - , - - , , . . . , -,.,ee,.,,.,-,_,,,---,e,w,, - - - , - -


_-n,--._--- -- -

25 1- Q How about the criteria for separations, free air?

?

^

2 Is that sufficiently clear, so that you're comfortable?

3 A Yes, sir. It is. I've jus't recently written a ,

4 separation violation report.

5 Q on one that you were inspecting or one that you saw?

6 A No, one that I was inspecting.

4

. 7 BY MR. GALLO:

8 Q What was the nature of the conflict?

9 A It was a wire way that I pulled approximately 21 10 safety c?bles through. It exited a tray and entered a wire 11 way between two bundles of non-safety related cable exiting a-

,t 12 tray below them, one on each side of the wire way. There was 13 conduits. There was no other place to put these non-safety 14 related cables and there was no other way for us to enter the l 15 wire way, without coming within contact.

16 Q They were actually touching?

.l 17 A Yes, sir. I L

18 Q What criterion was violated?

  • i 19- A CSCR C.2.B 12 inch in air between C.2.E and C.2.B.
  • 20 Q What have you heard about the conflict that Greg 21 Archambeault wrote up?

! 22 A For the first time today.

o G

f l

l l _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ . _ . _ _ _ _ . _ _ _ , - _ _ _ _ _ . . - - - _ _ _ . . - - _ _ _ _ . . . - _

26 J 1 Q The first time today?

, 2 A Yes, sir, actually.

t i

3 Q What were the circumstances that you heard about it 4 today?

5 A only that there was another inspector involved and 6 he didn't feel exactly the same as Greg. There was a

7 conflict.
8 Q There was another inspector involved in what?

9 A In the inspection, and that he felt that Greg may ~

10 have included cables that weren't all in conflict.

11 Q When did you hear that, just today? ,

?

12 A Just today, yes, sir.

13 'Q Was that Mr. Plumstead?

14 A Yes, sir. Mr. Plumstead, yes, sir.

15 BY DR. HULIN:

16 Q Have you ever been discouraged from documenting 17 non-conforming conditions in the proper form?

18 A No, sir.

A 19 Q Have you ever been instructed to ignore them and --

t 20 A No, sir.

21 Q Have you ever. observed non-conforming conditions 22 when you're inspecting a pull?

e 9

9

r.

27 1 A Yes, sir.

J-2 Q Not on your pull, but on some other?

3 A Yes, sir.

l 4 Q What do you do then?

5 A Depending on the circumstance.- Non-safety and BCAP 6 items I report to craft supervision. Safety related items I 7 report to me and to my supervisor. I document what I see on 8 a sufficient form, in-house ICR, NCR, whatever is required.

9 Q Have you ever been told that that's not your job?

i 10 Your job is --

11 A No, sir.

12 Q What would you do if that happened?

13 A 1
t may very well be not my job, depending on what 14 the situation is. I'm not a qualified -- I only hold one 15 certification on this job, and-I can only inspect to what I

, 16 know. I'm not supplied with the criteria for terminations, 17 equipment installations, and a lot of other items. I do have c 18 the background and I do feel qualified, and if I do see 19 something, I would report it. I don't have any problem with 20 that.

21 BY MR. MARCUS:

22 Q Doug, you said that if you found a problem with a e

S v 4-. _ _ _ _ _ _

., 28 1 non-safety related cable installation, that you would report

, ~

2 it to the craft?

-) 3 A Yes, sir. As far as I am concerned, that is not .

4 essential to the safe shutdown of the plant and that's Ceco's 5 property. If it's poor craftsmanship or damaged items, I'm 6 sure they don't want to buy junk. I'm sure they would want it 7 taken care of.

8 But I wouldn't write an ICR or an NCR or ask that 9 one be addressed to resolve the problem.

10 Q Do the craft usually respond to those reports?

11 A Yes, sir. As far as I know, yes, sir., -

7,.

12 Q Is this your understanding, of how the policy states j 13 you should handle these non-conforming conditions? '

14 A Basically, yes, sir.

i 15 Q How did you learn that policy?

{ 16 A This is an exact policy -- you mean as in 17 identifying and reporting and documenting? That's pretty 18 standard from every plant I've been on.

'19 Q So it's consistent across -- let's see, Palo Verde, 20 Shearon Harris.

I 21 A Well, I may have to exclude Shearon Harris from 22 that, yes, sir.

[

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29 1 BY MR. GALLO:

~

. 2 Q His questions related to a policy of handling 3 non-conforming conditions?

4 A Yes, sir.

5 Q And the circumstances that you were describing

, 6 involved non-safety related activities, non-safety related 7 components and equipment. Really, if there is something wrong a with them, they're not non-conforming are they? They may be 9 out of spec or something, but they're not non-conforming?

10 A Yes, sir.

11 Q That's a quality term, right? -

! 12 A Yes, sir. I get a little carried away with that,

  • 1 13 yes, sir.

14 'Q Let me ask the question a little differently. If 15 you go around and you pull and you see a non-conforming

- 16 condition on a safety related cable, only it's not associated 17 with your pull. Then what do you do, in those circumstances?'

18 A I would get a cable identification number, BR 19 number, any information I could get from the cable while I was 20 there, document the extent damage, jacket damage, intersheet 21 conductor, insulation damage, whatever. The amount of 22 damage. I would call the vault, ask for a 37 and find out as e

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30 i

1 auch as I could about the cable and take the information to my 2 lead, and then so forth.

?

3 Q You would write up a -- let's assume that the 4 non-conforming condition had not been previously written up?

5 A I would definitely document it, yes, sir.

6 ,

Q Would you have to discuss it with your lead, first?

I 7 A I would.

8 Q Why?

9 A Just because I would. I inform him of my activities -

l 10 at all time. If he would like to go out on another pull, he. i 11 would know that I was already into business, I had something -

12 of precedence.

13 Q Do you get any kind of feeling that supervision 14 would prefer that the inspectors not flag these problems?

15 A No, sir. I have not' encountered that problem at 16 all, no, sir.

17 Q Not because they want to ignore them, but because 18 they feel that they'll be picked up at walkdown, system 19 turnover?

20 A No, sir.

l 21 Q Let's get back to separation criterion?

l 22 A Yes, sir.

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. , _ - . . ~ _ . _ _ . - _ _ _ - _ _ _ . _ _ _ _ _ . _ _ _ - - . - _ _ . _ _ _ . _

31

, 1 Q You talked to our friend, Mr. Plumstead. Did you 2 talk to him about the application of the one inch criteria? l l

3 A No, he just said -- actually informed me that they .

4 were in a panel and that Greg had identified some cables that 5 he felt were outside the criteria.'

6 Q Let me ask you a question. How close can non-safety 7 '7

' related cables, in air, come to safety related cables sitting .

8 in a tray, open tray?

i .

9 A One inch.

10 Q How do you know that? When did you -- that's a 11 correct answer. -

12 A Yes, sir.

13 Q When did you first learn that?

!, 14 A' At Palo Verde, in 1980.

15 Q Palo Verde?

16 A Yes, sir. I went through a tray cover program there 17 and inktallation.

i 18 Q Well, in the circumstance I described, there's no

, 19 cover on the tray.

20 A Yes, sir. There will be, more than likely.

l 21 Especially if there's an area in concern. The top hats --

22 different. Most of this is probably in the computer for i

I l

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32 1 manual -- not for manual routing, but for computer routed 2 cables. *

. 3 BY MR. THORNTON:

i .

4 Q Does the application of the one-inch criteria depend 5 on whether the tray is going to receive a cover later?

6 A No, sir. It may depend on -- some cable trays, I 7 know, in the turbine building that are isolated may not have 8 covers on them. Very few within the plant, but I'm sure there 9 are some.

10

+

BY MR. GALID: .

11 Q I think you and Plumstead are the only inspectors ,

12 that we have talked to that understand the one-inch i 13 criterion. Have you had a chance to look at the procedure 14 itself that deals with that, either 4.3.8 or 4.8.87 15 A Ch, yes, sir. I carry them with me at all times.

16 All of us do, as far as I know.

17 Q Do you have any judgment as to whether those 18 documents are confusing on this point?

19 A I wasn't aware that anybody else was, no, sir. I do 20 know other inspectors that have written violations out here 21 that are in my group at this time, so I have just assumed that 22 most of them were very much aware.

e 9

. 33 1 Q I assume that you are aware that Greg Archambeault 2 passed out th'ese questionnaires?

3 A Yes, sir.

4 Q I have been asking the inspectors as to whether or 5 not they filled one out but giving them to understand the 6 opportunity to decline to answer if they wanted to.

7 A I filled one out, sir.

i a Q Did you fill one out?

9 A Yes, sir, I did.

10 Q If I show you these questionnaires, would you point 11 yours out? ,

12 A Yes, sir, if it's there.

13 Q See if it's among those three.

14 'A Okay. Yes, sir.

15 Q Is that the one?

16 A Yes, sir.

17 Q Let me ask you a couple of questions with respect to q 18 your answers, if you don't mind?

[ 19 A Yes, sir.

20 Q Question 2 was: How do you feel about the relations 21 between the management and the worker? It says "Could be 22 better but does seem to be improving."

e

34 1 What aspect did you have in mind when you said that?

2 A What'I spoke of earlier as the situation with our supervisor being shifted back to days, Mr. Tuite coming on for 3

4 the one month.'It seemed to bother several other 5 inspectors. They felt like we were being trdated as though we 6 couldn't handle the job and they were goingsto come out and 7 show us how it was done, that we were making mistakes or 3 errors or holding up problems that didn't exist, slowing 9 construction up and so on.

10 Q I'm going to put it.in front of you so that you can 11 see the answer better. .

12 Number 3 said: Do you feel that there are quality 13 concerns at the site that have not been addressed? And you 14 say, "It's hard to say. It appears as though some serious 15 problems that have been addressed are getting" --

16 A I don't know about this exactly.

17 Q I'm sorry.

18 A I'm not sure if I wrote that on there.

19 Q Ch, is that right? You don't think --

20 A I'm not sure. In actuality, I rewrote this thing 21 three times because I do not have any concerns that are not 22 being addressed. I'm not qualified to evaluate a lot of e

b e

. 35 1 concerns that may have been previously addressed.

. In the 2 function of my job, I can't go out of my way to look --

3 Q I understand that. .

4 A And I have had a hard time writing that up the way I 5 exactly wished to do it.

6 Q Do you feel that Engineering is dispositioning 7 use-as-is more than they should?

9 8 A No. They are more qualified to make that 9 evaluation. -

10 Q I understand that. Do you have that feeling, 11 nonetheless?

  • 12 A Well, the only concern I have seen out here that I '

13 really for a long time did not think was getting.the attention 14 it deserved was the spreader rooms on 63, the way the cable 15 dropped through the ceiling.

16 Q Is that right?

17 A l

But within the last week, I have been up there for 18 the first time in a while, and I've seen where they've sealed 19 the floor with the cables penetrating down, and the seal 20 itself takes a lot of weight off the cable. They may have 21 known that. I was not at Byron, which may have had a lot to 22 do with that. It seems to have alleviated that problem a e

, 36

, 1 lot, a lot of the weight on the cable.

+

2 Q Are we talking about the upper cable spreading room?

A 3 Yes, sir, we are?  :

4 BY MR. THORNTON:

5 Q Unit 27 x 6 A Unit I has just recently been sealed, and there has 7 been a lot of activity. I haven't been in there for a long I

8 time. And I did see in Unit 2 side where a lot of cables did 9 have a lot of slack. You're using a thin wire Kellus grip 10 that could cause jacket damage, and in some cases probably l

11 had. I know that it had been addressed through people at *

, 12 PCD. Some people I knew that worked at Wolf Creek I have 13 spoken to off the job, saying I seen this, in discussions, and

~

l 14 been told that it had been addressed. But within the last 15 week I have been in the spreading room in Unit 1 side, the 16 upper spreader room, 63 elevation, and I may have mismade a 17 judgement prior, a little early. Like I said, I know I'm not 18 qualified to evaluate a lot of this. '

19 BY MR. GALLO:

20 Q Yes, but you are still entitled to your opinions.

21 A Yes, sir, I an, and if I really thought it was very 22 serious and it wasn't going too far, I may have wanted to 4

6 6

1 t -

. 37 1 address it to some more people or something, whatever the 2 situation. .

3 Q In answer to Question 9, and the question was: Do you feel any personnel has been shifted around by management

4 5 because they addressed quality concerns or, as it is called 6 semetimes, making waves, and you indicated yes.

I 7 Can you tell us the circumstance you had in mind?

8 A Well, possibly Mr. Chuck Noble. I don't know. I an -

t 9 only going by what he has said. He was a lead welding .

10 inspector one day with no cable installation experience, and 11 now he is in cable pulling. Maybe they felt he was inadequat'a 12 to perform the function. I don't know. I really don't know l 13 the specifics behind that.

1

.[ 14 Q This is based on what he told you?

15 A Yes, sir.

j i

16 Q Your information is based on what he told you?

17 A Yes, sir.

1 .

18 Q What is your understanding as to the situation?

19 A I really --

20 Q I mean based on what he told you.

21 A It's still hard for me to say. I can't say that 22 Mr. Noble is not more than qualified to be a welding inspector 1

e S

38

, 1 or a lead or far and above. He has a lot of years of 1

1 2 experience. I know he knows -- I'm don't'have any kind of .

3 welding certification, so he loses me when he starts talking.

,. 4 Q Well, did he suggest that he was transferred for 5 reasons other than because of not being competent?.

6 A I don't know. I don't really know.

7 Q All right.

8 A This is just what I had an understanding of.

9 Q Okay. That's fine.

. 10 I might agree with you on Number 11 from time to 11 time.

12 A I didn't mean that in any quality concern at all.

13 MR. MARCUS: Is that on the record or off the

14 record?

'l 15 MR. GALLO: That's on the record.

z 16 BY MR. GALLos 17 Q Okay.

! 18 A You tend to get a little upset when you go into a t

19 cable spreader room, you open the door, and you either get on 20 your belly or you turn around and leave.

21 Q There's no room?

l l

22 A There's no feasible way to go through that. There o

t

.. - . . _ - - _. -- .- _ . -= . .. -.

t

' 39 i ,

, 1 is just an unbelievable amount of space wasted. I have never 4 . .

2 seen conduit or junction boxes on the floor and this kind of 3 r, tuff. I'm not saying that's any kind of quality concern, but 4 it's just a --

5 Q I understand.

l 6 What about Number 12? What did you mean there? How 7 does the security somehow rush you in some way?

8 A Not actually rush, but slow me down. Because I was

! 9 held back for some time getting my security clearance. Several 10 of us were in our group, and for no known reason, really.

11 There was lack of competence, I would say, on the part of 12 Wells Fargo investigators. Mr. Don Box held a security i

13 clearance at Dresden, transferred over here a month later and 14 couldn't get a security clearance here. He was one of the  !

e 15 last ones to get it, as a matter of fact. It just means you i 16 are escorted at all times. If you want to go to the bathroom, 17 somebody has to take you to the bathroom, and it just made 18 performing the function of my job -- yes, if I wanted to go 1

19 back to a critical area: " Hold it. Stop." Somebody has to 20 take me back over there. I can't walk to this next elevation 21 by myself.

! 22 BY MR. MARCUS:

I i

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,,_n,- ,.,. _ _ ,- _.,w _ , n --n"..,_n--,,---.- .----.-~,-n----- - - - - - - ,

i 40 1 Q How is it now?

2 A Ch,' excellent. I don't have any problem now.

3 BY MR. GALLO:

4 Q okay. Do you have anything more you want to say 5 with respect to the questionnaire? I don't have any more 6 questions.

7 A No, sir. I really don't feel there is anything 9

8 wrong with our program. I would say this program goes a

, 9 little farther than they have to, actually, in comparison to '

10 other sites. -

11 Q That's fine. ,

l 12 MR. GALLO: Do you have any more questions?

13 BY MR. MARCUS:

14 Q I was just going to ask you what you thought of the 15 interview. What do you think of this kind of session?

16 A I would say I saw it coming. I have known 17 Mr. Archambeault prior to employment here. I worked with him 18 at Shearon Harris, and he did ask me to read the statements 19 prior to him mailing them to the NRC. I had asked him if ha 20 had talked to other people on the site, and he is a quiet 21 person. I would say he is very much to himself. I read the 22 first article that he wrote, the beginning paragraph, e

e nemsii mia . . .ie i

. - _ . - . . - - . - -. -__- _ - . . - - . _ _ = ~ . - _ -

, . 41 1 production overshadows quality.

I asked him was he writing a 2 book. This sounded like he was reaching to me.

,; 3 After having read the full article, there were some 4

points he brought up, but they were all problems that should 5 have been resolved in our office, things he should have 6 discussed with us as a group, and they should have been 7

i resolved right there. There weren't even, I didn't feel, '~

8 .

concerns that needed to go to Quality First if he would have 9 discussed them. I think he is a quiet person.

i

! 10 But after having been at Shearon Harris, I really 11 can't understand it. We didn't have a safety program. We ,

12 didn't have a quality program there. We really didn't. We 13 were construction inspectors.

We didn't use IEEE, ANSI, any I

14 standards, any of the known standards present on any other 15 nuclear site in the United' States that I know of. They had 16 i

their own set of rules, and they were pretty bad.

17 Q So this is a big difference here.

18 A Yes, sir. This program is excellent.

l I couldn't l 19 function there. I wasn't there very long.

20 BY DR. HULIN:

\

21 Q okay. Let me give you some phone numbers.

j 22 A Is this a psychiatrist or --

i l

l e

4 E

w 42

~

t- 1 Q I an a psychologist, but I'm an industrial

( .

2 psychologist..

3 A Is that a hint or something?

4 'Q No, absolutely not.

5 A Okay.

6 Q If we didn't ask you anything in the interview that 7 you want to bring ug, if something occurs to you later that l s you wish you had said something about, call me collect or call j 9 George here on the site and say something about it, and we 10 will get the information -- but know, that is Pot a 11 suggestion.

12 A Okay.

13 BY MR. GAILO:

l 14 Q I just want to compliment you for having the courage 15 to identify your questionnaire.and to explain your answers.

16 A I thought about that, especially number 11. And I 17 was under the impression that he had already turned them in 18 and mine wasn't going to be utilized. I'm sure he is aware of 19 how I felt. I don't feel -- I couldn't tell him you can't do 20 that, or I couldn't say to everybody else, hey, do you know 21 what he is doing? I couldn't do that.

22 (Whereupon, at 10:32 p.m. the interview was e

a h a sus 'un is

4 ' *

/ , 43 9

, 1 concluded.)

3 F e

! 4 5

6 7 .

4 8

9 10 1

11 12 13 14 15 16 17 18 19

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p: . .. . - . - . . .. . . . . - . . . _.. .- -

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4 (JOHN THOMAS}

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THIS DOCUMENT IS SUBJECT TO ATTORNEY WORK PRODUCT PRIVILEGE s

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2-

. 3 --------------------------------x .

! 4 Interview of:  :

5 JOHN THOMAS  :

6  :

7 __________________________.... _x 8

4 9 Braidwood Generating Station i, 10 Braidwood, Illinois 11 Monday, September 15, 1986 -

e 12 13 The interview commenced at 10:23 o' clock, p.m.,

14 examination by JOSEPH GALI4, ESQUIRE, Isham, Lincoln & Beale, 15 Chicago, Illinois.

16 17 18 19 20 21 22 e

O n i,. i i .ii- ,,

T .' ~ _ ,. _ ,.

N .

2 7 ,

1 PROCEEDINGS 2 (10:23 p.m.)

~~

3 Whereupon, ,

4 JOHN THOMAS, 5 who was called for interview, was questioned and responded as 6 follows:

7 DR. NULIN: Let me explain a little bit of the 8 background and purposes of why we are here tonight.

9 I am Chuck Mulin from the University of Illinois, 10 and I an a consultant working with Joe Gallo, who is here.on '

11 my left, who is from the law firm of Isham, Lincoln and Beale,-

12 representing Ceco in the hearings that are currently going on,

  • 13 and this is George Marcus, QA from Ceco.

14 The purpose of the interview is to try to determine 15 the type of relationship that~ exists with the management and

16 the production department and with the management and the QC 17 people here at Comstock.

j We want to determine if the QC 18 inspectors have freedom to report any concerns they have, and f.

19 we want to determine if any quality concerns exist that are 20 unresolved in their minds.

21 Now, we are only requesting that you cooperate with 22 us and give us this information, give us candid answers to our ie .

)

.g - _ _ .. . _ . . . _ . _ . _ .

t 3

1 questions. If you would rather not particirate in any of this 2 process, you can leave now. If you feel uneasy about 3 answering any questions, you.can certainly decline to answer -

4 the questions.

5 This represents part of our purpose. Joe will 6 explain a little bit more about some other purposes,I think we 7 have. .

8 MR. GALLO: The only thing I would add to what has 9 already been said is that I'm sure you are aware that Greg

. 10 Archambeault testified at the NRC hearings last. week, and in i

11 the process of doing that, he articulated several' concerns 12 which he suggested that were held by other inspectors as well 13 that he works with. So one purpose that we are trying to get 1

14 at and one matter we are trying to clarify is whether these 15 other inspectors, like yourself, share some of the same 16 concerns that he had indicated. That is another and 17 significant reason for these interviews.

18 Chuck is going to ask the questions.

19 EXAMINATION 20 BY MR. HULIN:

21 Q With that as a long introduction, your name is John l

22 Thomas?

l l

l l

l .

1

=_- - . - ..

g. . _ . ._ _ . . . . . _ __ _. . - . . _ -

. 1 A Yes, it is.

2 Q How long have you been employed by LXC?

3 A Since August 12th of 1985. .

4 Q In what capacity?

5 A Level II inspector, three different certifications.

6 Q What are your certifications? -

7 A Cable pulling, terminations, and conduit.

8 Q And right now you are working in cable pulling?

9 A Yes. Well, I cover all. Actually, whenever they 10 have anything I --

11 Q Whenever any cable, terminations or conduit comes up' 12 on the second shift, you cover that?

13 A Yes. For a while, I was the only one on second

' 9) 14 shift to do it.

15 Q Have you worked in any other nuclear installations?

16 A Yes, I have.

17 Q Where?

18 A LaSalle and Clinton.

19 Q How long did you work there?

20 A Clinton I worked at a year and a half. LaSalle was 21 off and on. I worked for A&H out there and ConAm, which I 22 worked through Ceco through ConAm.

e 4

l

.g . . _ . . . . . _ . . . _ , . ._... .._._

. 5 l 1 Q Working on the second shift on your day-to-day 2 job, do you feel that you have adequate access to the i

3 supervision? By supervision I mean the leads and your ,

4 supervisor.

A 5 Yes.

6 Q For technical questions?

7 A Yes.

l 8 Q Who do you talk to if you have a technical question?

, 9 A I start off with my lead, Don Schirmer, and then if 10 he is not available, I try, Harry Revels.

I 11 Q And do you usually feel that you can obtain answers -

12 to technical questions from these two people?

  • 13 A Yes. If they are not there to answer my question, I 14 try to find somebody else unless it's a quality problem. I try to' find somebody else to answer it.

15 16 Q How about any administrative questions you have 17 about other things about your job: overtime, shift assignment, la stuff like this?

19 A I'm an assistant steward, so I go to my steward, but 20 I basically know what our contract is and so forth.

21 Q Do you think you have adequate access to the LKC 22 supervision for those kinds of questions?

9 e

6

1 6

1 A I don't pertain those questions to them. I through 2 my steward for them.

3 Q And your steward is Mr. Nemath?

4 A Yes.

5 Q If your questions or concerns aren't satisfied at

, 6 the supervisory level -- and again, let's go back to the 7 technical questions -- '

8 A What kind of technical questions are you talking 9 about, like engineering problems or just procedura problems?

10 Q Procedure problems, questions of code 11 interpretation, procedures and so forth. If you don't get

  • 12 them satisfied at the level of Schirmer or Revels, do you 13 think you have access to other people to answer them for you?

14 A If I had to call them up on the phone, yes. As far 15 as that goes, there is nothing that stops us from that.

16 Q Do you feel free to bring any of these concerns to 17 the middle management in LKC7 18 A What do you mean as middle management?

19 Q DeWald, Saltaann, Simile?

20 A Yes. I can go to them if I have to. As long as 21 they are not busy, you know. You know, they are busy with a 22 lot of things. There is no problem in going to them.

1 O

4

~

_. _. _ T_ . _ .-

7 1 Q Do you ever see them on the second shift?

2 A Once in a while. I have seen them when we have 3 problems. Like people sitting around and stuff. .

4 Q If you ever find them ever just wandering, coming 5 out on the site, do you feel you can stop and talk to them?

6 A Ch, yeah. They want you to. If you have got 7 problems, talk to them. That's what they want you to do.

8 BY MR. GALLO:

9 Q Do I understand that on occasion you have seen 10 DeWald out in the field?

11 A Yes. .

3 12 Q since you've been working.

13 A Yes, sir.

  • 14 'Q Do you work second shift all the time?

15 A Yes. Two days after I was hired, I was on the second 16 shift.

! 17 -

Q Have you seen Saltmann out there, too?

18 A Yes, I have. Yes. I didn't know him in the l

l- 19 beginning when I first started, but I have seen him out there.

20 Q How often are these occasions that you see these 21 people?

! 22 A Not very often. You're lucky if once every two

(

D 4

9

0 8 l

. 1 months or once a month that I would any more because I work 2 out on the real yard. I work completely opposite the plant 3 now. .

4 Q What about Tony Simile?

5 A I've seen.him out there. I've had him even come out 6 to get me. I mean they come out to talk to me.

4 They are not 1

7 afraid to*go out there and find the problems.

8 Q You say you work on the other side from the plant?

9 A Out in the real yard. I don't work in a plant right 10, now.

11 BY MR. HULIN:

  • 12 Q What do you do over there?

13 A Cut cable, pre-cut it for the --

14 Q Pre-cut it as it comes off the reels?

15 A Right. That's been the last six weeks.

16 Q Do you have any reluctance at all to bring any of 17 these questions -- I guess maybe it would be better if we 18 tried to find some specific kinds of questions you might'have l 19 to bring to these people.

l 20 A Just -- I don't know. There's all kinds of things.

I

21 There's interpretations of procedures. There's different i

i 22 questions everybody has. Like relating from one plant to the 6

e

- -- ~ . . . . - ~ . -. . _. .

i 0

, 9

. 1 next. When I waus first here, I had questions about from one 2 plant to the next, you know. I'm used to one area, and you 3 come here and some areas are slacker than other areas. But -

4 when your regular supervisor isn't around, you just ask the l 4 5 best one you can at the time.

  • 6 Q And you don't have any reluctance to do this with 3

7 either your supervision or your management?

8 A No. I never have.

t 9 Q Do you have any reason to believe there is a layoff 10 list?

11 A I don't believe there is, but just like any normal '

12 person can walk around and see the ones that work and the ones 13 that don't work. That's in your own eyes. You know, who 14 would you like to have work for you, somebody that is willing 15 to work or someone that sits around.

t j 16 Q Are you telling me, then, that you think there might 17 be legitimate reasons for people to be on a layoff list?

!- la A Let me put it to you this way. I know in my own t 19 eyes I know people that I would lay off.

20 Q Are they the ones that make waves?

i

! 21 A Not necessarily. The ones that are making waves now j 22 -- I was a lead at one time and I had opportunity to get rid c

O S

.o.-- -_ _ _ ._ _... ,

  • l 10 1 of one but I didn't.

2 BY MR. GALLO:

. 3 Q What do you mean when you say you had an opportunity -

4 to go to one?

5 A The guy was told to do one thing. Everybody knows 6 the story of the walk-off that we ha'd. That's when they

~

7 wanted everybody up front here. An'd the guy just sat there.

8 He didn't even tell anybody he was in. Nobody knew this guy 9 was out there in the field office. Well, then we came to find, a

i 10 out somebody reported in that this man, that two men were in-

, 11 the office out there. Well, I called out there and told them '

12 to come up. I was pretty angry at the time. One came up and 13 one didn't. And his reaction was, well, you don't tell me 14 what to do, you ask me what to do.

15 Somebody like that, he is not going to be 16 cooperative, so I would lay him off, instances like that, 17 because this happens quite often to me.

18 BY MR. HULIN:

19 Q There have been statements made about a layoff list 20 or people being on a layoff list.

21 A I don't know anything about that.

22 Q Do you know of anybody, any QC inspector who was e

9 4

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i 1 terminated?

I kn'ow Mike Kilgore is not here anymore, but that

2 A 3 was because of a test that he failed or something. It was his ,

4 MPPI test or MMPI test or whatever it was. He didn't pass.

5 Q . Anybody else? Do you know a Hunter?

6 A No, just heard of it.

7 Q Arndt?

8 A No.

9 Q Any shop talk about why Hunter isn't here any more?

10 A Not really. If I don't know them, I don't pay 11 attention. .

12 Q Your main contact with craft employees is through 13 the craft foremen; is that correct? I mean if you were 14 inspecting a cable pull, your main contact would be the craft 15 foremen.

16 A Yes, somewhat. I know all their general foremen and 17 everything.

18 Q What do you think about the relationship between the 19 QC inspectors and craft foremen?

20 A At one time it wasn't very good.

21 Q When was that?

t 22 A Oh, when we just got our big -- when the inspectors s

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l 12 I were all new, coming in to hear so many questions and 2 everything, and things just weren't going smooth. They had a i 3 lot of questions. .

4 Q Are they reasonably good now?

5 A Yes, I think they are. I have even had reports from 6 different foremen that they are really getting along good with 7 the inspectots.

. 8 Q The way things are organized, craft foremen really 9 want to pull some wire, get laid out, and is there an informal

^

10 quota of how many feet of cable they are supposed to string?

' 11 A No. They just average every week what percentage -

12 they pulled. There's a percentage. There's a rating of 13 whether you did good or bad, but these guys, you're not going 14 to tell them that they have to do it.

15 Q That is a potential source of conflict between the

! 16 craft foremen who want to get the wire pulled and between the 17 inspectors who say, wait a minute, I want to get something out 18 of that cable tray. Is this a continuing problem?

19 A No. Rephrase it. Say that again.

20 Q Do you think there is sort of a continuing head 21 butting or continuing conflict between the craft foremen and 22 the QC inspectors, with the craft foremen saying the QC l

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1 inspectors are slowing things down, and the QC inspector is

_gd 2 saying the craft foremen just want to pull it, regardless? -

x 3 A At one time there was that problem. j .

4 Q But no more?

5 A No. I mean that is the kind of questions that were 6 brought up to supervisors, like debris is the tray, what 7 constitutes debris, from the minutest piece of dust to a piece 8 of conduit. They were making them clean trays out when there 9 was just daily dust there. I can understand why a foreman 10 would get upset.-

11 BY MR. MARCUS: '

. 12 Q When was that, John? Earlier this year?

13 A Yes. It was -- doggone. It had to have been in June 14 or July, somewhere around in there. It was only certain --

15 not all inspectors were doing that. It was just certain ones 16 that were being so picky. I mean you have got to do your job, 17 but they didn't go and ask what constitutes dirty, stuff l'ike 18 that.

19 BY MR. HULIN:

20 Q Do you think there is an acceptable professional 21 relationship between the craft foremen and'the supervisors of 22 QC?

O O

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14 '

l

. 1 A Yes, between the foreaans, yes, and the QC l 2 supervision, yes, but between the craft men and supervision,'

3 they don't have a very good concept of what's going on. The .

4 men want to do the work, but the foremans understand why it 5 can't be done. I don't think they have the procedures out 6 there in the field like they should have, the foremans, to 7 explain to their men.

8 Q Let me shift gears here a little bit. Have you ever

! 9 attended a Quality First orientation?

10 A Yes, I have. Like a program?

11 Q Yes. -

12 A I have been to Quality First with some other 13 inspectors for something that was going on, but I have been i 14 through that over there, you know.

15 Q Did you go there because you had a concern or you

16 went there for training?

17 A Well, they called us over there. It was just like 18 this' meeting, basically. They had somebody turn in a concern 19 and we all had to go over there, four of us.

20 Q Do you understand what the Quality First program is?

21 A Basically. Mr. Shamblin went over it with us in a 22 steward's meeting here just last week.

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. 1 Q okay. Would you explain to me what you think the 2 Quality First program is?

3 A It's a program to take -- I don't know how to say it .

4 -- allegations or whatever, concerns or whatever. If you don't 5 want to be known, you won't be known, but if you go in there,

. 6 anybody can see you going in there. So somebody knows that 7 you brought a concern over. But you can call up on the phone 8 or whatever, and you can always get your results. I mean they 9 will -- they are supposed to. I don't know. They are lo supposed to be able to follow up on everything that has been 11 reported.

12 Q What is the difference between Quality First and, 13 say, NRC's people? Do they both exist for the purpose of

. 14 going to them with concerns?

'15 A Well, NRC is here for -- I mean it's not just 16 people's concerns, it's what they find themselves in 17 inspections and so forth. Quality is just a commonwealth 18 Edison form.

19 Q Do you think that they are another layer of 20 supervision or do you think they are independent of that.

21 A They are not supervision.

22 Q They are sort of a channel, an avenue for e

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16 1 complaints?

2 A- Basically. NRC would be more -- acted more like 3 supervision than anything. .

4 Q Do you feel free to take quality concerns to Quality 5 Firs't or NRC?

6 A .

Yes, but there's a better way to do it than t,o take B

7 concerns there.

8 Q What's that?

9 A Just go right to the source, you know, wherever it 10 can be fixed., You can't just be afraid to go to talk with '

. 11 people. You have to go talk to somebody. If you've got a

  • 12 concern, take it to QA or your supervisor or whatever.

13 Start off at the low and work your way up. If you don't get 14 any results, then go to NRC as a last resort, or Quality 15 First. There are so many things out here that can be resolved 16 without doing that.

17 Q So you feel if you couldn't get it resolved at the I

18 lower supervision level, that you would feel free to'go to 19 Quality First?

20 A Yes.

21 Q Can you think of any circumstances that might keep 22 you from going to Quality First?

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. 1 A No, not really, not unless somebody threatened my 2 life or something. I don't think that would even do it. That 3 would make me go even more.

  • 4 Q Do you think your name would be confidential if you 5 went to Quality First?

6 A Yes, if you wanted it to be.

2 7 Q How about if you went to the NRC?

8 A Their program is a little different. I had to go 9 there because of the same thing, but when I was sitting in 10 there, the guy that was in there before me came out, so it's-

'; 11 not very confidential there. That wasn't very smart on their" 12 part.

, 13 BY MR. GALLO:

14 Q They talk about confidentiality but they are not too 15 careful.

16 A Not here they are not.

i- 17 Q It is not a question of intentionally betraying the 18 trust; it's that the way they go about doing things is not 19 calculated to keep things anonymous.

l 20 A That's right.

I I

21 Q How about the Quality First?

22 A I don't think that's very good, either. I don't e

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. 1 know. I guess you could always call them up and set up a 2 meeting somewhere else besides here. I don't know how that t

But when you have got to go into a place and you know 3 works.

4 people just happen to walk by and see you going in, they know 5 you are going in for some reason.

6 ,

BY MR. MARCUS:

7 Q Although you could use the telephone, like you said.

8 A Yeah. .

9 BY MR. HULIN:

'i

,10 Q Do you think that the Quality First and NRC are 11 responsive to the concerns that are brought to them? ~

9 12 A That's their job. It's their job to do, and I think 13 they do. They follow up on it. I've seen them out there in 14 the field, even, so I know they do on some certain things. I 15 don't know if they do for everything.

16 Q Do you know of any specific examples of concerns 17 that were taken to them an'd they followed up on?

18 A Well, the matter of -- I wasn't here at the time, 19 but there was like 20-some inspectors or whatever that went 20 over because of a concern they had with a supervisor. The 21 supervisor no longer was there any more, so they followed up 22 on that. They have had court hearings on it and everything W

l i

19

, 1 else. It's still going, I think. I don't know. But that's 2 just what I have heard. I.was no part of that. I wasn't even 3 here.

4 Q Okay. But basically you say you have seen them out 5 in the field and you know that the supervisor who was being 6 complained about is no longer here.

7 Do you think you might be ta'rminated if you took any .

8 concerns to Quality First or NRC?

9 A I never gave it any thought, really. I don't think I 10 would be. It doesn't bother me -- if I go over there there is 11 a concern that -- -

12 Q Yes.

,, 13 A -- they are going to fire me. If they want to fire I' 14 me, they are going to fire me. No, that doesn't bother me.

15 Q But do you think you might be canned?

16 A I don't think so. I never have.

17 Q When you say you never gave it any thought, that 18 strikes me as being it's not something that occurred to you.

19 A No, it really hasn't. When you are here, they tell 20 you, you know, if you have problems, to go to Quality First, 21 when you first come here on the job. It doesn't seem to me 22 like they would fire you if you went to them if they told you e

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,4 2 BY MR. GALLO:

3 Q How about because they are smarter than that and ,

4 they wouldn't take an obvious action that might be suggested 5 was taken because you went to Quality First. They would have 6 a tough time defending that one. How about something more .

7 subtle, like not giving you overtime?

8 A .'

I don't know if they would play -- I have never 9 Worked for anybody that played some kind of games. I have 10 really never been put in that situation. This is the first 11 time I have ever seen such carryings-on as goes on in one of .

12 these plants, what is going on now. I have never even seen it 13 before now.

14 BY MR. HULIN:

15 Q Do you think that is because of the poor quality 16 work that is being done here?

. 17 A I don't think it's poor quality work.

18 Q Why do you think these carryings-on are going on?

19 A I myself don't think the inspectors are-as good 20 inspectors as what they think they are, myself. They have 21 never had to do this kind of work before, and I just don't 22 think they are as good as what they think they are, i

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. 1 BY MR. GALLO:

1 2 Q Some of the inspectors are experienced, aren't l 3 they? -

4 A They are supposed to be.

. 5 Q Like you, they have been at other plants.

6 A They are supposed to be, but like my. lead, he come N 7 off of a farm, a pig farm, you know.' You can't tell me that 8 he knows anything about electrical before he got here. I just 9 don't go for that. He is not very well experienced. A lot of 10 them have done that. They are right out of high school and 11 they come on a job like this and they have never worked in the 12 field before. They don't know what they are doing, as far as 13 I'm concerned. I have worked in the IBEW. I have worked with 14 tools.

15 Q Are you an electrician?

16 A Lineman.

17 Q What are you going to do when this job is over?

t 18 A Hopefully, I can go back to farming.

19 Q Pig farming?

20 A No, no, no. Mushroom farming. I'm ready to get 21 out of this if it's like this. I like working for 22 Commonwealth Edison, but the inspectors, it's bad.

I i

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22

. 1 Q You indicated in answer to his question that some of 2 these inspectors weren't as good as they think they are as one 3 reason for what you described as carryings-on. Are there -

4 other reasons?

5 A I'm used to working, and these people, they don't 6 care anything about working. They just don't care. I see a 7 lot of it, and that's one reason I couldn't be a lead out here .

8 any more, because I can't put up with them. That's not good

! 9 to say, but that's the way I feel about some of the
" 10 inspectors. Like Greg himself. He is one of the laziest 11 persons I have ever seen in my life. I don't know if you 12 heard about the incidence where he got caught inside of a 1

13 locked room. Did you? I don't know.

14 See, supervision is afraid to do anything to him 15 because he got locked in this room out here, and he wasn't l 16 supposed to be in there in the first place. They come down i

17 and changed the locks on this room, the lights were off and 18 everything, and they didn't know he was in there. Well, they 19 go back upstairs and they look down, and the lights are on in 20 this room. When they go back down there, they find Greg in 21 there. You know, something like that, I wouldn't hesitate to 22 fire somebody, but these people are. If it had been me or O

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. 1 some of the other guys, we would have been down the road. Now

..l 2 these guys are afraid of Greg.

1 3 Q This just happened recently?

4 A Yes, just on Saturday, on time and a half.

5 BY MR. MARCUS:

6 Q N Iast Saturday?

4 7 A Yeah, just this --

8 BY MR. GALLO:

9 Q Saturday. ,

10 A Yes, and they are afraid to do anything. Same way 11 with Rick Martin. They are afraid to do anything with him.

  • s .
s 12 To me, that's unfair to the other inspectors. That's not very 13 good.

14 BY MR. HULIN:

15 Q Have you ever been unable to perform the proper 16 inspection because of production pressure?

17 A No.

18 Q Have you ever felt rushed?

19 A Yes, I've felt rushed, but don't take that wrong.

20 When they are out there working, they are going to rush, they 21 think they are going to rush you. The inspector has got to set 22 the pace to do a proper inspection. You just tell the men e

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24

, 1 just to hang on and you will be done when you are done. Some 2 inspectors just get all upset and everything, and then they 3 just come unglued. ,

4 Q Okay.

5 A There is one inspector that thought he was being 6 intimidated because he got rushed, and that caused a big 7 problem. .

8 Q Are we talking about, say, the walkdowns and the 9 cable pull inspections? Is that where the pressure seems to it 10 come?

11 A Yes, especially when there in a system that, from -

12 the way I understand it, that CECO wants turned over, ready 13 for the next day, cables they want in for the next day. Well,

'l 14 they want them in that night. To me, it doesn't make any 15 difference if they want them in that night or the next night 16 or whatever. If I'm going to do my inspection right, I will do 17 it the proper way. I don't care who it is. They are not l

t 18 going to rush. The foremans know that. You have just got to l

l 19 tell them.

20 Q Would the craft foremen have a tendency to sort of 21 bully and push the inspectors around?

22 A If the inspector lets them, yes. They got rid of l

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25 1 that problem, though. They got rid of those problems.

2 Q How did they do that? -

4 i

3 A They are now working on' day shift. They got cut 4 back, the problems, for being bullied.

5 BY MR. GALLO:

6 Q I guess I don't understand.

7 A Comstock cut some of their people back from night 8 shift, some of their supervis' ion, and changed supervision. I 9 think that had a lot to do with it.

6 10 Q How does getting switched to days solve that?

. 11 A Well, there are not any more general foremans. They 12 are back into the tools. ,

! 13 Q I see.

14 A There's no power to them now at all.

15 Q They don't supervise people?

16 A Right. I think that was a big problem why the craft 17 people were losing production, because certain men tried to i

18 push the men to do the work. .

i 19 BY MR. HULIN:

20 Q Have you ever approved or accepted an inspection 21 that should not have been accepted?

. 22 A Accepted something that shouldn't have been

.l l

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- a-i 26 1 accepted? No, I haven't. I have made mistakes out there and 2 I've had to write myself up for them, but other than just 3 something that has happened.

4 Q I guess the intent of the question is did you ever 5 sort of deliberately say: Aw, the hell with it, that's close 6 enough for government work, and signed it off?

7 -

A No. No, I have never done that.

8 Q When you say you wrote yourself up, that sounds kind

, 9 of strange.

10 A Well, I pulled cable through a wrong pipe, you

. 11 know, and I come back later on another pull and I had to go to 12 the sister pull and found that I put the cable in the wrong 13 pipe. Well, you've got to do something. You've got to 14 address it. So you write yourself up. It's not very good, but 15 it's better to do it yourself than have somebody else do it.

16 Q Any repercussions when you did that?

17 A Just getting retrained, that's all.

18 BY MR. MARCUS:

19 Q The other part of that question, John, might be 20 would you have accepted an ins'pection that you would not 21 normally have accepted because of conversations that you had 1

22 had either with your management or supervision or production t

l l

. 1 department?

2 A What'was that, again? .

3 Q Did you ever accept an inspection that in your own 4 mind you should not have accepted but you did so because of 5 conversations you had with other people?

4

6 A No. They have always had to show me why they wanted 7 it the way they did. As long as it was down on paper or 8 whatever, yes, is the only way I would do it.

., 9 Q So you are always convinced it was the right thing.

10 A Right. There have been many times that I have 11 - stopped pulls where I have been told that I didn't understand, 12 it and they had to show me. Well, I was wrong, you know. I l 13 still didn't like it, but as long as they explain it to me and 14 it comes out in writing, it has gone through.

15 BY MR. HULIN:

16 Q Do you know of any inspections that were improperly 17 accepted?

18 A No, not that I know of. Well, it all depends. It 19 goes back.to the -- like I installed cable wrong. Well, 20 I accepted that when it wasn't really right, and other people 21 have done that, too, you know. But eventually it is found 22 out.

l 1 -

, . . l

. 28 1- Q I guess the question is do you observe things out

! 2 there that are clearly in violation of the code, that have 3 obviously been accepted because they are installed and there 4 are no hold tags on them?

5 A I see that from procedure changes. You know, at one 6 time it was installed to this, and now the procedure is 7 completely different and it is wrong now. Like in conduit, a you know, there's a lot of discrepancies going on now because 9 of procedure changes. I have 100 and some reinspections of

. , - 10 conduit which only 75 percent of them are getting rejected now 11 because of this. ,

12 Q so what you seem to have identified is a problem 13 that something that at one time was acceptable is no longer 14 acceptable not because it has deteriorated but because the r

15 standards it was supposed to meet have changed.

16 A Right. That's it. Besides flex problems, but i 17 that's going to happen.

18 Q The flex gets broken?

l 19 A Yes. But I've got a problem with that. Like 20 when they called me in at NRC, we have been told and there is 21 even a letter out that says for us not to write up flex like 22 that. I mean that was wrong. I don't go for that at all, 9

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29 1 because when flex is broke, you know, with the wire in it, 2 it's broke. You know, you've got to write it'up. But it says

<, 3 the turnover systems will catch it. Well, that's not right.

4 When it's a problem, it's a problem.

5 BY MR. GALLO:

6 Q This flex you're talking about, was this discovered 7 dur'ing the course of an inspection? .

q 8 A I was inspecting other conduits.

9 Q Did you just observe the broken flex?

10 A Yeah. Again, you've got three flexes coming. If 11 you are only doing and one of the others is broke, that's 4

12 pretty -- you can't -- you know.

13- Q How do you write that up?

14 A I write it as -- well, you don't have nothing to 15 cover. surveillance. I used to write them up as surveillance, 16 but I just write it as a final now. I just go ahead and write 17 it up. .

! 18 Q Do you use an ICR or an NCR7 19 A ICR.

I 20 Q ICR7 21 A Unless there's cable in it and you can see the 22 cable is damaged, then you write it up as an NCR because of i

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30 1 the cable.

2 Q This advice that you got that they will get it as 3 what, system turnover?

! =

4 A Yeah. It wasn't advice; that was the word. They 5 refused, basically, to let me write them up. You know, there 6 was a letter out telling us not to write them up anymore.

7 Q Was this flex holding safety-related conduit?

8 A Yes.

9 Q Who did the letter come from?

10 A From our management, I believe. It's either our _

11 management or Ceco, one of the two. I don't remember the name 12 on the bottom. ,

~

. 13 Q Do you recall how long ago this was?

14 A It was back like May, somewhere around in there.

15 Q '867 16 A Yes.

17 BY MR. MARCUS:

18 Q Is it still in effect?

19 A I don't know. I haven't seen it in so long. I 20 haven't done any really conduits for quite a while. They 21 don't ever want to turn it back on me because then they would 22 be in trouble for turning back an ICR or NCR. I write them o

S

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s 31 1 up. ,

2 BY MR. KULIN:

3 Q Did you ever get any bitching about the number you 4 wrote up?

5 A No.

6 Q Were you ever told you were writing too many of them

, 7 up?

8 A I got told I was acting like another inspector for 9 writing so many up, but it goes in one ear and out the other.

10 Q Who is this other inspector?

11 A Jeff Dominique.

12 Q ,He wrote a lot?

13 A Oh, yeah. He did his share. But it was all stuff 14 that.'s wrong. When it's wrong, it's wrong. But the thing is 15 that we would write them up on three-day ICRs, all right?

16 They would be taken care of within the first hour and a half 17 , after we wrote them up. They would all be in process. We 18 never turned them in to go through the whole system. At that 19 time we had a good working relationship between craft and the 20 QC inspectors.

21 Q Do you have any feelings that cost and schedules 22 sometimes override quality?

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s 32

. 1 A No. I don't think it ever overrides it. They want 2 it to; they just act like it.

3 Q Do you mean the craft workers or the craft 4 management? '

5 A Yes; basically. It's not nothing major. I don't 6 know how to explain it.

7 Q .What we are talking about is the relationship 8 between the craft foremen and the ICR's. I was trying to 9 convey the idea that there are some kinds of conflicts on a s

. 10 site like this that are inevitable, they are just going to 11 happen. They are part of it. It is just the way things are ,

j 12 on all constructicn sites.

13 Is that what you are talking about here, or are you 14 talking about something the craft desires for production that i

15 maybe does get in the way of quality?

l' 16 A No. Production, that doesn't get in the way of 17 quality. You know, as that goes. Craft always has a cost i

I 18 quote to meet. There are so many times that you hear out 19 there, you know, but on our part, it has never affected me, in 20 worrying about their costs. I don't know how to explain it.

21 Working for both sides of it before -- I don't 22 know. It is the individual -- craft is always saying they T

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. 33

. 1- have a cost quota to meet. They all have cost quotes. They 2 always say quality is the hold up on a lot of it, on the

, 3 costs, you know. That's what I'm getting at.

4 Q Has that ever changed your behavior?

5 A No. I just tell them it's not quantity, it's .

o 6 quality. That's what I think.

7 Q When you do your job, are the inspection 8 instructions and procedures clear enough so that you are able )

9 to do your job the way it is supposed to be done?

e 10 A They are getting better about it. It wasn't -- just -

11

[

like on debris. That was never explained before to anybody .

12 what they meant by " debris," until they had Ceco QA to explain 13 it in general or whatever.

14 BY MR. GALLO:

15 Q Has the procedure been clarified in that respect?

16 A In the back of the procedure, they give a listing of 17 how each portion of your checklist is supposed to be written

$ 18 out. For that part of it, debris, they give a few examples, 19 which is a help.

20 Q Why doesn't it just say that debris is anything that 21 might adversely affect the integrity of the cable or the cable 22 jacket?

A e

6

f 34 1 A I think the old procedures did say it that way.

2 In some places, there was a lot of dust.

~

The dust is 3 flammable at certain times; some dust is, which would hurt 4 your jacket. That is what they were getting at. There were 5 times that they got carried away with certain parts.

6 Q Do you think that is what Martin was worried about 7 when he was inspecting for -- . .

8 A I don't like saying things like that. I think he I 9 just did it to aggravate them, myself. There were too many 10 times that -- you could eat off the pans. There would be just 11 i one piece of paper, what you write your cable number on, he ,

12 would shut them down for that, when he could have one of the s

l 13 guys take it out of there. He would shut them down. That 14 brings conflict between workers and QC.

15 Q If he shut them down,.what was the effect of that?

16 Would it mark it unacceptable?

17 A No. It's all in-process, so there is no reason to 18 write an ICR on it. It's in-process. You can have the work 19 done at the time. When you start shutting people down for an 20 hour --

21 Q How would you do that in this circumstance?

s 22 A Shut them down?

4 S

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35

. 1 Q Yes.

2 A Just tell them, your tray is dirty, or this part of J

3 the tray isn't right, whatever. By the time you go back and ,

4 tell your foreman that, by the time the foreman comes back and 5 tells the people what to do, you have to absorb some time 6 somewhere. Sure, he was doing his job, but that's pretty --

7 BY DR. HULIN:

8 Q Could he have just asked the crew to take it out?

9 A Yes; he could have. They have lead men to do that.

10 He could ask anybody. '

11 Q Could he have taken it out himself? I'll withdraw -

12 that.

13 A Would you?

14 'Q It depends on the Union, I guess.

15 A He could get --

16 Q He could get a grievance.

17 A Right. A good relationship between the men and 18 their inspector, they would never say anything like that. He 19 could have.

20 Q We have heard quite a bit about 4.8.8 and 4.3.8.

21 Can you explain to me what the difference is between those, 22 what is the governing document?

O l

l 1

36 1 A 4.3.8 is for craft, that is what they work by. What 2 we inspect by'is 4.8.8. We use both of them. We have to hold 3 them to theirs.

4 Q You do?

5 A Right, even where some of this stuff we inspect to

, 6 is worded differently than what we have.

7 BY MR. GALID:

8 Q Are you aware of an instance when Tuite and

(( 9 Archambeault got into a discussion over whether the inspectors

, 10 worked against 4.3.87 11 A Yes, instruce t d th ta we weren't to work to 4.3.8. .

l 12 That's another problem. You have people like -- Tuite is i

j 13 fine. DeWald is fine. Simile is fine. They have never been 14 in electrical work before. They are only welders. They don't 15 -- to me, they shouldn't be in'that position to be able to say l

16 that stuff. He was wrong in saying that.

17 Q Did that get corrected?  !

18 A I don't know. At that time, I was in-process. I*

19 don't know what happened after that or anything.

20 Q Were you pulling cables when that incident occurred?

21 A Yes.

22 Q Were you in the area?

e 9

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37 1 A i I was the lead at that time. As soon as he left, as 2 soon as Tuite'and Lechner left, I was lead after that. I 3 wasn't there when it happened, but I heard about it after. .

4 BY DR. HULIN:

5 Q When you are inspecting an in-process operation, 6 like a cable pull, and you observe the craft crew doing 7 something.that is in violation of 4.3.8, you as an inspector 8 think it is your duty to say, wait a minute, and stop the 9 pull?

10 A Yes.

11 Q We heard something about a backward wind on the 12 cables.

s' i'

13 A Reverse band.

14 Q Is that one of the things?

15 A Yes, but that is in our procedure, too. There are l 16 things in our procedure that they are not aware of, and there 17 are things in their procedure that we don't have in our .

18 procedure.

19 BY MR. GALLO:

20 Q Like footage markings?

t l 21 A Right, that's in theirs and it is not in ours.

22 Q The installation procedure provides that if the W

e e

t

+

38

. 1 markings are discrepant, the foreman is supposed to stop and 2 call Engineer'ing to check out the cable? -

3 A Right. As I see it, that's not a quality problem. ,

4 That's a manufacturing problem. There is cable out there that 5 doesn't even have numbers. What do we do for that? That'is 6 not going to hurt the integrity of the cable. It's just for 7 accountability. The cable number will give you accountability 8 anyway for that.

i 9 . :BY DR. HULIN:

10 Q You vould put a meter on it when you pull it? '

,; 11 ,

A Yes. They will mark off somehow or another 100 -

j 12 foot. They will mark it off somehow.

13 BY MR. GALIO:

14 'Q If the craft is observed violating this procedure, 15 assuming the QC inspector sees it, he is supposed to write it 16 up?,

17 A Right. To me, I don't think that is going to stop 3

18 the cable from going in. It is just gol.g to show that the 19 n1mbers have been printed or there wrong or whatever.

20 BY DR. HULIN:

21 Q Do you think it should stop the cable from going in?

l 22 A' No.

9 b

o 9

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39 5

, . 1 Q It is not going to affect the integrity of the 2 operation?

3 A No; it's not. All it is doing is documenting a ,

4 4 manufacturer's deficiency of cable marking; that's all. I 5

could understand if you have markings of two conductor ten in l 6

one part of it and two conductor fourteen in another part.

- 4 7 You had better get somebody to make a decision on what it is.

8 They could have marked the real wrong, or something like .

~

9 that. The amount of footage; no.

10 What are you going to do? You are going to cut off. -

11 both ends anyway. You are going to have ten foot on each end-12 scrapped anyway.

13 BY MR. GALlo:

14 'Q Do you think the installation procedure needs to be 15 changed?

16 A I can't see why it can't be combined to one l

l P 17 procedure. Everybody knows what is going on. It's not that 1

18 craft gets one procedure and not the other. They need both of 19 them. Craftsmen are in a worse position than we are.

l- 20 Q On footage markers, it is pretty clear. You are 21 supposed to stop, if they are not consecutive, and consult  ;

{ 22 Engineering.

1 o

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40 1 A Right. There are things that we inspect for and 2 ~t hey don't even know it.

3 Q For example? '

4 A If I had a checklist, I could tell you.

5 Q I don't have one handy.

6 A. Temperature; they know that. CRR's. They have no 4, . .

7 .

idea about the CRR's, that they have to have a cable raceway 8 release form. Damaged trays. A damaged tray consists of a 9 lot of different things. Obvious damage, they understand, 10 that you can't go through there. Some of the others, I don't

11 know. -

12 BY DR. HULIN:

13 Q How do you handle quality concerns, safety and non-safety related,'that are not directly related to

~

14 15 inspections you are doing but'that you observe when you are 16 doing your job?

17 A If there is something I can do about it, I'll 18 address it. Like in the areas that I'm not certified in, all 19 I can do is tell somebody else about it.

20 Q Suppose you were inspecting a cable pull and you saw i

t 21 an obvious radius band problem or cables hanging out of a 22 tray, that are not the ones you are working on. What do you e

9

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i i I 1

l j -

41 '

> . 1 do?

2 A Address the problem. It all depends on what it is.

! 3 Q ICR or NCR? ,)

. l 4 A Right. If it is damage to the cable itself -- we 5 are put in a position where we have to determine whether or 6 not it is cable damage. I don't like that. They have it in 7 our procedure where if it is 50 percent of the jacket or 8 whatever, then it's a non-conformance. We are doing 9 Engineering's job. We shouldn't be doing that.

10 Q When you see it, you address it. Is that the 11 policy? -

12 A If you find something that is wrong, you are 13 supposed to address it.

14 ~Q Even though it is not on the in-process you are 15 inspecting?

16 , A Right. The procedure doesn't spell it out. If you 17 find cable damage, it doesn't say it has to be in your cabla 18 pull, but if you find damage, yes, you are supposed to address 19 it.

j~ 20 Q How about separation violations?

21 A Yes. It is easier to do when you are doing that 22 then it is to come across it possibly.

e G

,_.,._e, - . . . , - - - - '

42 1 BY MR. MARCUS: -

2 Q How about non-safety related cables?

3 A That is a whole problem in itself. I have observed ,

4 bend radius problems tonight that people were doing with 5 non-safety cable. They are supposed to treat it just like 6 safety related cable, but they don't. They could care less --

7 they do care but they don't care.

8 Q What did you do with it?

9 A There's nothing I can do with it. There's not a 10 thing I can do with it. We don't.have a procedure to address 11 non-safety items. -

12 Q No one has ever told you what to do about that?

13 A Well, I've been told there is nothing we can do 14 abou't it, besides just tell craft supervision. There's just 15 nothing we can do about it, not unless it is like a conduit 16 wall, when you have to go out and inspect non-safety conduit.

17 There are only certain items that you can inspect on it, 18 because it is non-safety.

19 BY MR. GALLO:

20 Q You had mentioned that you were called over to 21 Quality First at some point. Was this recently?

I 22 A No. It must have been early Spring or around there; 9

9 9

. 43 1 April. I don't know for sure. That was on a concern about 2 craft personnel, people walking on cables and trays and so 4 3 forth. Basically, some of the questions you all asked. ,

4 Q Was this pursuant to some complaint that somebody 5 had filed? .

6 A Yest one of the craft personnel turned it in. They 7 wanted to know the QC part of it, the quality part of it. I 8 can tell things have happened, things are cleaner now, but it 9 still doesn't mean people have changed the treatment of 10 cables.

11 Q You still think people are walking on cables? -

12 A I know they are. I had one of the Ceco personnel do .

i' 13 that to me, and they didn't care. They told us. flat out they 14 didn't care.

! 15 Q some Ceco employee was walking on cables and you 4

16 called him on it?

17 A Ch, yes. I even talked to the shift supervisor. It i 18 almost came to a fight. It was really strange.

. 19 Q Was this recently?

20 A Not a couple of months ago; two and a half.

21 BY MR. MARCUS:

I l 22 Q Are there any Ceco supervisory people around who you l

e l

44

~

1 could, talk to?

2 A Just the shift supervisor, if they are in the 3 control room. That is where we had to go talk to them at.

i 4 Q That is where you went, to the control room?

5 A Yes.

6 BY MR. GALLO:

7 Q Who was the Ceco guy?

8 A I don't know his name. I asked him for it and he 9 wouldn't give it to me. I don't know if he had a bad night or 10 what was going on. Things got pretty out of hand.

11 Q What was he doing there?

12 A We were pulling cable in a riser. He came in to 13 check one of the gears. He was just standing right there on ji .

14 the cable. It was a hot system that we had to get in and we l, 15 had a lot of cable out there.. He was asked not to walk on l

l 16 it. He didn't change his mind about it. He went ahead and i

l 17 did it anyway.

l 18 Q Was he the subject of the inquiry by Quality First?

19 A What do you mean by that?

20 Q Was that incident reported to Quality First?

i 21 A I don't know if that one was not. I didn't report 22 it in any way. The General Foreman that was there didn't 9

e O

45 1 report it, that I know of. That's the kind of matter that you 2 should be able to take up on your own, just go talk with their 3 boss, instead of letting it get out of hand.

4 Q Were you interviewed by the NRC in connection with 5 the Archambeault matter?

6 A Yes; I was.

x.

7 Q Westberg? ,

8 A I don't remember. There were two people there, two 9 from NRC.

10 Q What were the circumstances that you were selected 11 for that honor?

~

12 A I really don't know. I thought I was just one 13 picked out, you know, myself.

14 Q Had you been involved with any of the concerns that 15 he raised, in terms of witnessing them?

16 A I don't know. I honestly don't. I think a lot of 17 times -- Greg and I never really saw eye to eye or whatever 18 because I read the procedure a lot different than he does. I 19 aven trained Greg. He even thought he had a concern with me, i 20 on coiling cables. He got shot down on that. He has a 21 problem.

22 Q In this instance, what did the NRC ask you?

f 9

-- , , , . , - - - - , , - - - - - , - -, -,,--m_--.n--

46

. . 1 A They had a list of questions.

2 Q They asked you whether there were too many " accept 3 as is'?"

i 4 A I didn't pay attention to the questions because they

, 5 didn't seen very important. They.didn't seem like they were 6 really concerns. As a matter of fact, I don't think they were 7 their questions. I think they were Greg's questions, to tell 8 you the truth.

9 I may have misunderstood.

Q You referred to some 10 inspector being intimidated. Did I hear you right? "

t .

11 A Yes. .

12 Q What was that?

13 A I don't know. He did get intimidated by a plate 14 fitter, but we got that squared away with their superintendent 15 and their steward and the inspector.

16 Q somebody with Geschow?

17 A Yes. The guy got threatened with a pipe. That led j 18 to a disturbance between an inspector and the cable pulling 19 crew. They kept teasing him and stuff like that. That caused l

t 20 a problem between that inspector and his crew. He kept 21 thinking he was getting intimidated by them. They were just 22 joshing around with him.

i w,- ,n,nn,_-._,-,,,,,,-~,,n. _,,,,,,n,.,.___,w__,

-,._,,w-.-,,, ._ , . , - ,

47

., 1 Q When did this happen, how long ago?

2 A- Right before the man got transferred to day shift.

r

. 3 I don't know.

t 'i 4 Q Which inspector was this?

5 A Nelson.

4 6 Q Didn't he get involved with some dispute involving 7 people . walking on cable, too? .

8 A Right, that's what started it with the fitters. I had to follow through with it so I went and got the people 9

l 10 involved and we got it straightened out right there. We have 11 never had anything else from that, that I have heard. ,

12 Why did he get transferred to days?

Q .

13 A Because he kept pursuing it enough that they put him 14 on days.

ll I take that back. They had an opening for two

." 15 people to come back to days. He fell into that. He was 16 harping on them a long time to put him back to days.

17 Q Did they transfer him in order to separate the craft 18 people involved from Nelson?

19 A No. If you have a problem, fine, talk about it and 20 see if you can straighten it out, and as a last resort, they 21 will transfer you, but other than that. At that time, Greg 22 had an opportunity to go, too. He refused. I see in the I

1 O

s-w,rv. rm---y~e- m,ww,

48

. 1 paper that he is back to days now because of -- the way I read 2 it, it is because of the hearings and stuff. He wanted to 4

3 stay on nights until recently. ,

4 Q What was the story on Dominique and the additional

, 5 ICR's, all these ICR's he was writing?

6 A The conduit lead on days, he just gave him a hard 7 way to go, because he was writing so many ICR's. He kept 8 making him bring in copies of the ICR's he wrote and stuff, 9 stuff that he could do legitimately, but you could tell he was 10 just doing it to --

11 Q Dominique was working days at the time? -

12 A No; nights.

13 Q He was working nights, doing cable pulling, conduit?

14 A conduit. He didn't get cable pulling until he got 15 back on days, I think.

16 Q What kind of discrepant conditions was he noting?

17 A Broken flexes. He is a very thorough inspector and 18 ' good. He got his job done and everything that he did was 19 legi:imate. Engineering tried to send a lot of stuff back on 20 him, but he had always shown where they were wrong. He was a 21 good inspector and still is.

22 Q Who is the lead on days?

e D

6

- l l

49

, 1 A Mike Lechner. If it wasn't for him, Tuite wouldn't I 2 be anything.*

3 Q He comes across to'me as kind of a mild mannered l .

4 fellow.

5 A Lechner?

6 Q Yes.

.. 7 A Yes. He keeps quiet.

1 8 Q I wouldn't have guessed that he would have grabbed a ,

9 bunch of ICR's and send them back.

10 A No, he's not sending them back, just making him make .

11 copies and so forth, making it rough on Joe. Mike knows he .

12 can't stop the guy from writing them but he can make it a 13 hassle on the paperwork. That's easy. Things like that can 14 he done.

t 15 Q Dominique was in the training business for a while; 16 wasn't he?

17 A Yes; he was.

18 Q This incident that you are referring to, did it 19 happen before or after he was in the training business?

20 A After.

, 21 Q What did Dominique get transferred to?

22 A What do you mean?

4 i

50 1 Q I understood that because it was perceived that he 2 was writing too many ICR's, he got transferred to some other 3 area.

4 A- No. They told him that he was doing such a good 5 job, to come back to days because they needed a good conduit 6 inspector on days.

7 . Q I guess he was transferred to days.

8 A Yes, then they trained him in cable pulling and -

9 stuff like that; different certifications now. They couldn't 10 keep an eye on him on nights. I guess that's what it comes t

11 down to. I heard both sides of the coin from both people. ,

12 Q From his point of view, they moved him to first to 13 keep an eye on him.

14 .A Yes.

15 Q What was the other side of the coin?

- 16 A Mike's side, he said too many ICR's.

17 Q Is he still on first shift now?

18 A Yes.

l 19 Q Is it true that you write less ICR's in cable i

20 pulling than you would in conduit?

21 A Yes. You really shouldn't have to have too man i 22 ICR's or NCR's in cable. Even on cut cable, damaged cable, if i

l 1

~

f

'i

. _ _ . - - _ _ _ . . . _ _ _ - , _ _ . _ _ _ . , _ _ _ _ . ~ . _ _ _ _ -

51

, 1 you are taking it off -- say you find it within the first ten 2 foot o'f the cable run, there is.no sense in having to write an 3 NCR up on ten foot of cable, when you have -- all cable pulls 4 are estimated 15 to 30 percent over because of the run. You 5 never know how long it is going to be. You can always cut off I

6 and write out a scrap report for that ten foot of cable where 7 it was damaged, which would save an NCR.

8 BY DR. HULIN:

9 Q The difference is if you are inspecting an 10 in-process operation, you can do something to keep the 11 installation from being out of code? ,

12 A Right.

13 Q That doesn't stop you from being a tough minded i 14 inspector. It just means you are doing it in a different way.

15 A Right. You are not supposed to think this way. You 16 can use common-sense out here if you really wanted to. Some l 17 people don't want to do that. They would just as soon write 18 it up than to have the foreman write out a scrap report for 19 that ten foot, cut it off and be rid of it.

20 BY MR. GALLO:

21 Q One of the concerns that Archambeault identified was 22 a large number of non-conforming conditions in the upper cable e

l l

l

. 52 1 spreading room. ,

i 2 A Yes."

3 Q There were cables there that were out of tray, not

'1 4 trained right, band radius violations, Kellum grips cutting 5 into the cable, separation conflict.

6 Where were you working when he identified that? It 7 was about March --

8 A Every inspector that has been up there has seen 9 those items. It has been brought up more than once.

10 Q Was this before or after Archambeault was up there? -

11 A Before. That whole area has been wrote up before, .

12 on NCR's. From my understanding, CECO even has the NCR's on 13 that, of the areas.

14 Q As of now?

15 A Even then. Those areas have been wrote up before 16 for that.

17 Q Did you check it out yourself?

18 A No; not personally.

19 Q What led you to believe they were already written 20 up?

21 A From talking to the upper supervision.

22 Q Like who?

4 e

9

- - , - - wa,--,wr,, ,,-4, , , , . . , -,-,.,ya -, _ - - , _ . , , _ _ , _ _ , _ , . _ , , , , , _ _,_ _,_ _ .,_, ,_ __..___,_.n_, , , , - _

53

, 1 A I think I talked to Harry about it. I don't know if 2 it was Irv or'not. I even talked to -- it is just like the 1

, 3 Rosemont transmitters. Those have all been wrote up on NCR's, 4 too. I have talked to bd Netzel on that, stuff like that. It 5 seems to me that I heard it from a CECO person, too, that the 6 NCR's had covered those areas up there.

7 Q Did you notice any hold tags in the area?

8 A Yes. There has been hold tags up there on a lot of 3

9 cables, for that, raised violations and so forth.

10 Q Were you aware of the debate that Archambeault had ,

11 with Revels and with Simile over how the NCR's should be ,

1 12 written?

13 A I didn't even know that was going on, until just 14 recently.

15 Q How about the matter that Archambeault observed in l

16 and around the remote shutdown panel, the separation 17 conflict? Are you familiar with that problem? .

18 A No. I heard about it but not to the extent of what 19 was going on. I think it is the same remote shutdown panel 20 that -- it must be on the Unit II side.

I 21 Q This is the one where there was a tray with l

4 22 non-safety related cable in it over a tray with safety related i

l .

54

, 1 cable in it. The non-safety cable ran from above the safety 2 tray down towards the safety tray, over the top, within a certain distance and then passed down the side of the tray and 3

4 continued below and was terminated in the shutdown panel, I 5 guess.

6 Did you attend a meeting recently to discuss the 7 clearance criterion that apply, the separation criterion that .

8 apply?

.s 9 A I haven't.

10 Q Can you picture in your mind the circumstance --

11

~

A Yes. I have even pulled cable down there. .

12 Q What clearance criterion would apply?

13 A Free air would be 12 inch. Once you are inside the 14 panel, it would be different.

15 Q Do you recall if the procedure provides for a 16 circumstance where you have to separate on the one hand cable 17 in free air as compared to cable in tray?

i 18 A Yes; there is supposed to be a separation 19 difference. There is different criteria for different --

20 Q What is the criteria that applies to a situation l 21 where you have cable moving in free air, coming close to cable 22 in tray? What is the separation criterion that applies?

O

i 55 1 A I believe it is one inch,, if I am not mistaken, if 4

2 it comes down to that. One. inch; 12 inch, free air; 6 inches 3 inside and one inch between metal barriers, if I am not 4 mistaken. I think it is 12 inches for the free air. Anything f

5 outside the panel is 12 inches, even if it is inside the cable 6 pan. I'd have to look through my procedure again.

i 7 BY MR. MARCUS:

8 Q Do you have a copy of your procedure with you?

f 9 A No. Getting back to that, in all actuality, '

10 whoever dropped the non-safety down should have reported that i.

11 part anyway. Cable separation is no big deal, as long as you, 12 just address it. It is just writing it down in a book, saying

- 13 that it is there.
, 14 BY MR. GALLO

1 15 Q My' reading of the procedure says that the criterion 1 16 that applies is one inch and you don't need any cover, that i

17 , the space needed between the cable --

18 A That for metal and metal; right?

19 Q The space needed between the cable running down, as 20 we have been talking about, and the safety related cable 21 laying in the tray, without a cover, is only one inch.

22 A Right.

9 l

56

. 1 Q It could actually touch the side of the bottom of 2 the tray, that is the non-safety related cable could actually 3 touch the side of the tray.

4 A It just couldn't come in contact with it.

5 Q It just can't touch the cable. It can touch the 6 side of the tray and the bottom of the tray. If it has a 7 cover, it can touch the top of the tray. .

8 A All right. I'd have to look at it and re-read it.

, 9 I can't see it being a problem. When you go up to the control 10 room, you have all that up there anyway. They are touching 11 and everything else. It's not going to hurt anything. .

12 Q I think in the Archambeault situation, it was 13 ultimately concluded there was no separation conflict.

14 A That's good.

15 Q He was applying the wrong criterion.

16 A I mean I'm not glad to hear about Greg, but I'm glad 17 to -- you know. There are a lot of cables down there. I've 18 pulled down there. I never thought there was any problem 19 myself.

20 Q At the same time, it certainly is clear that the 21 application of the right criterion is not clear either.

22 A They just changed it again. They just changed that e

a

. 57

, 1 procedure. There is a new procedure coming out. Since it has 2 been out, I hhven't pulled any cable.

3 Q - Have you ever been denied any assistance on pulls? .

4 A No; never. I know people that have.

5 BY DR. HULIN: ,

6 Q Did you ever ask for any?

7 A Yes, but I have always used -- I am probably the one 8 that started it like that, for second shift, not having to 9 have so many.

4 10 BY MR. GALLO:

11 Q What do you mean, you are the one that started it, ,

12 started what?

13 A There was a big conflict because everybody was 14 wanting four inspectors on a cable pull. In my eyes, there is 15 no way you need four people on a cable pull. You need one l

16 other person besides yourself, if you are coming off a reel.

17 Other than that, you can do it yourself.

18 Q To your knowledge, who was it that was denied help 19 when he asked for it?

20 A Rick Martin. That was another instance where I 21 think he was trying to show his -- I don't know. Trying to 22 show a little bit of authority or whatever he thinks he has, O

e 9

-- -- ,,. -~_,---o--,v-- ,,e.--e.- -,__,._,--,--r-.,m,_mm_-- -

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58 1 you know.

2 Q This'was the hassle with Lachner?

3 A ~Yes. It was pretty silly.

4 Q- I guess you are aware Archambeault handed out a 5 questionnaire to some of the people on the second shift to 6 fill out. ,

l 7 A ,

I wasn't aware of it until I read the paper. ,

l l

8 Q Did he offer you one? l 9 A No. He was very selective in the people he gave 10 that to. When I read the paper, I was pretty upset. I didn't 11 care for that at all. He was not speaking for me whatsoever.,

12 Q It is my perception that you are an exception among 13 all these inspectors. You are the most outspoken inspector I 14 have talked to, in terms of asserting your viewpoint and not 15 being reluctant to point out the weaknesses, to the extent you 16 believe they exist, with respect to other inspectors.

17 A I think it is because I have worked the craft side 18 before. I can understand the problems there and understand --

1 l 19 to me, I have a good working relationship with the craft, with I

i 20 Engineering, and with Quality. There are ways you can work

,4 21 out there without a big problem. The job can go smoothly if I

( 22 you just use a little common-sense.

l l

l I. -

s


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  • i 59 1 Q You are an assistant steward now? You were a lead 2 for a while. -

3 A I was going to work for another company. By the 4 time the information got to me, they didn't say the same thing 5 on the phone as they did in the letter. I gave up my lead 6 position. I was glad because I couldn't handle it anyway.

7 Q Have people suggesting you were harassing them?

~

8 A They just knew. I already knew they weren't going 9 to like me as a lead. I like to work and I would have kept 10 them busy. Like John Walters. They took him off night 11 shift. He is a good supervisor. He kept everybody busy.

12 Now, the new supervisor doesn't do that. He's very lenient. .

13 I don't care for that at all.

  • i 14 Q You are at the real yard?

.' 15 A I asked for it, to go out there. It was a new job 16 they started. I had worked a cable real yard before at l

17 another plant, had knowledge of a reel yard. I didn't work 18 there personally.

19 Q How many inspectors are out there?

20 A Just me.

21 Q What kind of a crew do they have out there?

22 A All ex-foreman's; all the foremen that were out here e

4

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60 4

1 pulling cable stepped down to go do this. It's a good job.

. 2 It's relaxing, relaxing as far as being out of the plant, from 3 the noise and a lot of the pressure.

4 MR. GALLO: George?

5 MR. MARCUS: I don't have any comments. /

6 MR. THOMAS: It is just too bad you guys can't get 7 out there a,nd watch some of this stuff that goes on. You a would be surprised.

9 BY MR. GALLO:

, 10 Q' What accounts for the fact that most of the 11 inspectors won't tell us, the NRC or anybody, that this sort ,

12 of thing goes on? It is to be expected, in my experience, 13 that some guys work hard, some guys don't, some guys fool 14 around, some guys don't, some guys play the politics, some

15 ,

guys don't.

16 A I don't know. To me, I don't think any of them have 17 been on a real job before. I really don't.

l l la Q Are you the only ex-craft guy among the inspectors?

19 A I think so. They might have worked as welders, 20 maybe. I think that is a big problem. We don't have anybody 21 that has worked electrical work before. Jeff Dominique, I 22 think he worked instrumentation. He 1.* s a good knesladge of b

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  • 61

, 1 things. Other than that, I don't think many others have any.

2 I think they'have always been in QC.

3 Q What was Revels' prior experience? ,

4 A He worked for Comstock. I don't know what he really 5 did there. He's not old enough. He just got out of college.

6 He has never really been out in the field too much, I don't 7 think. -

8 Q Did you have more management experience at LaSalle?

9 A My part?

10 Q Supervision.

. 11 A No. I did a lot of surveillances on cable pulling; .

12 just about everything really out there.

13 Q How about Clinton, did you do pulling there?

14 A I was certified across the board there. It didn't 15 make any difference.

16 Q How was your supervision there in terms of 17 experience? -

18 A It was all right. A lot of them came off 19 submarines. They did do some kind of testing and they did do 20 work.

21 HR. GALLos I appreciate your time. What time do 22 you go eff shift?

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  • 62

. 1 MR. THOMAS: 2:30.

2 DR. HULIN: My home phone is on the back of that. .I 3 put George's extension here at the site on it. If there is 4 anything that we didn't go over, anything you think of between 5 the next few days, call me collect, call George, and we will 6 get the information.

7 MR. THOMAS: All right.

8 DR. HULIN: We do appreciate your time and your 9 candor very much.

10 MR. THOMAS: Thank you. If more people would come 11 out and tell their vengeance, I think you guys would get -- I ,

12 didn't realize they weren't doing it.

13 (Whereupon, at 11:48 p.m., the interview was i

14 concluded.)

15 16 17 18 .

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[ DONALD SCHIRMER]

THIS DOCUMENT IS SUBJECT TO ATTORNEY WORK PRODUCT PRIVILEGE -

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3 --------------------------------x 4 Interview of:  :

5 DONALD SCHIRMER  :

6  :

7 --------------------------------x 8

9 Braidwood Generating Station 10 Braidwood, Illinois 11 Tuesday, September 16, 1986 '

12 7

13 The interview commenced at 8:13 o' clock, p.m., ,

14 examination by JOSEPH GALLO, ESQUIRE, Isham, Lincoln & Beale,

,15 Chicago, Illinois. ,

16 17 18 19 20 21 .

22 i

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PROCEEDINGS 2 [8:13 p.m.]

3 Whereupon,

  • i 4 DONALD SCHIRMER i 5 was called to be interviewed by Counsel for the Applicant, 6 Commonwealth Edison Company, was questioned and responded as 7 follows:

8' EXAMINATION i 9 BY DR. HULIN:

lo Q And you are Don Schirmer, right?

11 A Right.

12 Q You are Lead on the cable-pulling inspections?

j 13 A Right, on second shift. ,

14 Q Second shift, okay.

j 15 I'm Chuck Hulin. I'm from the University of 16 Illinois. And this is Joe Gallo from the law firm that is 17 representing Ceco in some hearings that are going on today, or 18 the past few weeks, I guess.

19 Let me explain briefly what the purpose of this i . .

20 meeting is, this talk is today.

x 1 21 We're trying to determine the kind of relationship 22 that exists between management and the production departments 5

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1 and between management and the QC inspectors. We're trying to 2 find out if the QC inspectors have the freedom to report ,

3 concerns that they may have, and we're trying to find out, 4 indeed, if they have any quality concerns that they want to 5 bring up. '

6 Now before we get into it, Imt me note that we're in 7 a position where we can only ask for your cooperation. You 8 should feel completely free to leave at any time you want, or '

9 if you don't want to take action that drastic,'to simply not 10 answer one or more of our questions.

11 A All right.

12 Q Now obviously we would like to have you cooperate --

'13 A- Sure.

14 Q -- because the more people that give us candid, 15 frank answers, the more information we're going to have. '

16 So with that, let me let Joe explain briefly what l 17 some of his purposes are, and then we'll go ahead.

l 18 MR. GALIO: Well, I think that's good enough. You i

19 should know that we asked Don some questions last week, a week

, 20 ago, 2 guess.

21 DR. HULIN: Oh, yes.

22 MR. GALLO: In connection with the concerns T .

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. 1 indicated and stated by Greg Archambeault.

2 DR. HULIN: Okay.

3 BYDR[HULIN:

4 Q How long have you been employed by LKC?

5 A I've been on the site since March 11, 1981. I 6 started out with the Construction Department and moved to LKC 7 Engineering or the QC Department in November of '81.

a Q okay. Do you have a craft?

9 A Pardon?

10 Q Did you work in a craft?

11 A No. I started out as a trainee and then became a 12 Level 1 inspector and then up to a Level 2. '

13 Q okay. What areas are you certified in right now?

14 A Terminations and cable-pulling inspection.

15 Q Do you think that you have adequate access to 16 supervision to obtain answers to your technical questions? ,

17 A Oh, definitely. -

I

! 18 Q okay. Who do you go.to?

l 19 A My direct supervisor, following the chain of .

20 command, I report to Harry Revels, who is the supervisor over 21 inspectors for second shift. Following him would be Tony 22 Simile, who is the general supervisor, who I can report to, if

  • e 1

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. 5 j 1 Harry does not happen to be around or, you know, Harry would 2 not be able to 'readily answer my question or, you know. Then 3 after that would be Irv DeWald, the QC Manager, and then Bob 4 Seltmann, the QA/QC Manager.

5 Q okay. So you think you have pretty free ac' cess to 6 these people to get technical questions answered?

7 A Oh, sure. I've never had any problem knocking on 8 the door and walking in on any of them to ask them a question, 9 you know, unless they were in a meeting or something like 10 that, you know, but as far as.being -- having access to them, 11 I've never had a problem.

12 Q All right. Do you ever have any questions about the

'13 administrative part of your job -- that is, not the technical 14 part of it?

15 A What do you mean?

16 Q Oh, questions about time off, workmen's 17 compensation, stuff like this that comes up? -

,' 18 A Well, anything like that right now would go through l

19 GMCIS, you know, like requesting time off, we have a request 20 form that is processed through tham. .

21 Q Do you have any questions about what to do, though?

22 A Ch, no, no. Nc, I don't have any problems there.

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. 1 MR. GALLO: How do you take your coffee?

2 MR. SCHIRMER: Pardon?

3 MR. BALLO: How do you take your coffee?

4 MR. SCHIRMER: Black.

5 BY DR. HULIN:

6 Q That's on the record, now.

~

7 [ Laughter.)

8 (Counsel Gallo takes orders for coffee.]

9 Let's see, you've already answered my next 10 question. You are reasonably free to bring questions to 11 DeWald, Seltmann, or simile?

12 A Sure.

13 Q Okay. Do you have any reluctance to, you know, 14 knock on the door and walk in and ask questions?

15 A No, I never have. I've never had any reluctance.

16 Q Okay. Do you think there's a layoff list at 17 Comstock?

18 A No, no.

19 Q Have you heard any talk about it?

20 A No, I haven't. We've had -- every Monday we have a 21 meeting with our inspectors on the second shift, and the past j 22 few weeks, Tony Simile has been coming in on our meetings, I

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7 1 and, as a matter of fact, two or three weeks ago, he came in 2 and pretty well", you know, laid that to rest with everybody, 3 that Comstock did not have a layoff list. They are not 4 planning on laying any people off. As a matter of fact, 5 they've been hiring people, you know, up until, you know, 6 awhile back, and as from, you know, his standpoint in 7 management, that there's plenty of work to be done, and 8 there's --

9 BY MR. GALLO:

10 Q Well, how long can this last?

11 A Well, the job's going to wind down sooner or later, 12 you know. I don't know.

13 Q Okay. Well, when the job starts to wind down, 14 they're going to have to terminate some people and lay some 15 people off.

16 A Sure.

17 Q Do you think that there is an order known to some 18 people now as to what order they're going to terminate people 19 in?

20 A Well, you know, looking at it -- if I was looking at 21 it, I'd say when that time comes, there will probably be 22 somewhat of an order, you know, to the demand of what 9

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8 1 inspectors they're going to need and what disciplines.

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2 Q Do you think people that make waves are going to be 3 among the first to go?

4 A No, no.

5 Q How about people that are excessively absent?

6 BY MR. GALIA:

7 Q What makes you so certain about that?

8 A Well, I don't -- people that make waves, you know, 9 you have to define that a little more, what you mean by making 10 waves, right. I don't, you know -- if you're trying to get 11 back to what we've read in the paper about blacklists and 12 things like that, I do not believe they exist.

'13 Q Is Rick Martin going to be one of the first to go?

14 I would say he makes waves. How's that for a definition?

15 A I doubt if he would be one of the first to go.

16 Q How about Greg?

17 A If he's need for -- in his inspection area, you 18 know, if it comes down to where they don't need cable-pulling 19 inspectors anymore, he could be on it, because he's certified 20 in cable-pulling, and at this point, it's the only discipline 21 that he is certified in. You know, if that discipline is no 22 longer needed, there's a possibility. You know, if they don't

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, 9 1 need cable-pulling and termination inspectors when it comes 2 time to lay off", I could very well be on the list, because 3 those are those disciplines I'm certified in.

4 BY MR. MARCUS:

5 Q Would time on the job with Comstock be a factor in 6 determining who goes? l i

7 A Well, I don't -- if, like I said, I've been on the l

8 job for five years, but if it comes down to the point where 9 the only thing we have left is records turnover people that 10 they have, you know, enough of, and they don't need a 11 cable-pulling term inspector anymore, you know, to ne', it 12 doesn't matter how many years you've been on the job. If 13 you're not needed, you're just not needed, you know.

14 BY MR. GALID: l 4

15 Q I can' understand your point. Has there been any .

16 effort in your experience here to take someone with, say, just 17 a cable-pulling cart and, out of some recognition of the 18 problem at the and of the game where only certain certs would 19 be needed, has there been any effort to train people across 20 the board? ,

21 A Okay. Now the only job I can speak for is this 22 job. This is the only nuclear installation I've been on.

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10 1 Q Right. And I'm referring to this job.

2 A I'm not sure what they're going to do. You know, I 3 don't -- I dont know their game plan, you know. -You know, if 4 they need, you know, people with other certifications, and if 5 it would be easier to train the people that you have on the 6 site, rather than bring in new hires and running through the 7 training program, I'm sure that's, you know -- in my own view, 8 that's what they should do. But what they, you know, are 9 going to do or plan to do, you know, I really can't answer 10 that.

11 BY DR. HULIN:

~

12 Q Do you think people that have been absent 13 excessively might be early terminated -- might be terminated 14 early? -

,15 Let me put some background to this. There is one 16 Lead on second shift on cable-pulling, right?

17 A Right.

18 Q How many inspectors do you have working for you?

19 A Right now, I think I've got eleven.

20 Q Eleven, okay. Are those eleven always there every 21 day when they're supposed to be?

22 ,

A ch, for the most part, yeah.

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11 1 Q If.you had any that weren't there, do you think they might be lead candidates for early termination?

2 3 A I don't know. I don't know how they're going to 4 base their terminations.

5 Q Do you think that would be reasonable, if it did 6 happen?

7 A Well, let's put it this way. If I was working on a 8 -- in a manufacturing job or any other job or even this job, 9 if I had an employee that was excessively late, you know, 10 compared to the other employees and, you know, it came down 11 to, well, yeah, I could keep him, or yeah, I really don't need him, I'm sure he would, you know, be a candidate for a 12 13 layoff. The same way the electricians, you know, when they --

14 construction, you know, comes up with their layoffs, a lot of ,

15 times their candidates come from an excessive absenteeism 16 list.

I 17 I think something like that is justifiable. .

l 18 BY DR. HULIN:

  • 19 Q Okay, so there criteria for lettin,g people go?

l 20 A I don't know if there is criteria.

21 Q Okay, we could construct some criteria for letting 22 people go that would be reasonable?

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2 Q But you have not been told of any game plan that 3 Comstock has for doing that?

4 A No.

5 BY MR. GALLO:

6 Q Have you asked?

7 DR. HULIN: Yes, while you were out he said that 8 Tony Simile explained it to them.

9 THE WITNESS: Tony Simile had a meeting and he 10 explained to us that work efforts that are going on right now, 11 that within the near future or the future, there seems to be 12 plenty of work, that a lay-off list has not be'en written up or ',

~13 plans.for a lay-off in the immediate future have not been '

14 made.

15 BY MR. MARCUS:

16 Q How about MCIS people? Have they ever told you 17 about how people would be released? -

18 A No.

19 Q BESCo?

', 20 A No. '

21 Q Have you ever asked?

22 A No, I've never asked.

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. 1 BY.DR. HULIN: ,

2 Q What do you plan to do after this job?

3 A I dont know yet. I've got a lot of different 4 ideas. I've been thinking about becoming self-employed. My 5 wife is from this area and I own a home in this area, so the 6 thought of traveling to other nuke sites or job shopping or 7 whatever, is kind of distant in my mind. So I don't know for 8 sure. I haven't made my choice, yet.

9 Q In your work you -- every night out on the floor --

10 you come in contact with the production crews, the. cable -

11 pulling crews. Do you think there is a reasonable, 12 professional relationship between QC inspectors and the 13 production crews?

14 A Yes, I do. With the crews that we have right now,

, 15 and the inspectors we have, I think that there is a real -- -

16 what am I trying to say -- they work well together. The men i 17 that we have assigned -- I usually, what I have is certain l

18 inspectors assigned to crews to keep down the confusion. When 19 a crew is ready for a pulling inspector, they don't know who 20 to contact. Sos they work with the same man all the time. And 21 they all seem to have a real good rapport. That's the word I 22 was trying to find. A rapport with one another.

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'4 14 1 As far as professionalism, I think it is very high.

2 Q Sometimes the goals of the inspectors and the goals 3 of the foreman'of the crews are at odds with each other.

4 A Oh, sure.

5 Q Does that lead to conflict out there?

6 A Not really, no. I've always told my inspectors that 7 -- if you might want to think of an instance where there could 8 possibly be a conflict. If the foreman receives a priority 9 cable that needs pulling, his general foreman might give it to 10 him and say we need this pulled tonight. And the inspector 11 that's assigned to the crew, they've always been told and I've i 12 told them myself -- they say hey, the foreman wants to pull i 13 this right away and I say when you're ready for the cable to 14 be pulled, it will be pulled.

i

, 15 If it takes you 15 minutes or eight hours, or a 16 reasonable amount of time to perform the pre-pull walkdown to l

17 make sure the cable can be pulled, then they can pull it.

- 18 I've always told them not to let the foreman rush them because .

19 he's just going to have to wait.

20 Q Well, that sounds to me like your describing 21 conflict between the foreman and the QC inspector?

22 A Well, I'm just telling you what I've told the e

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s 15 1 inspectors, that if that conflict should arise, if the 2 foremen try and in any way tell the inspectors that they 3 really need to get this job done and to get it done tonight, 4 or whatever they have to do. I've told inspectors to make 5 sure that they don't rush themselves, that they don't think 6  !

that they should be pressured to get this done and to try and 7 do it any faster than they should be doing it.

8 Q Is there a quota of cable that the crews are 9 supposed to get svery night, in terms of the number of feet of 10 wire they string?

11 A I don't know if they have a quota, but I do know 12 that they keep track of how many cables are installed.

13 Whether they have a quota, or how many feet of wire they're 14 supposed to do, or how many cables, I don't know that. I 15 would assume that they have some schedule that they're 16 planning to meet and they probably have -- to meet this 17 schedule -- they have it tracked out on how many cables they l

l 18 should get installed. But for an actual number, I don't know 19 if they have one.

20 Q How about the relationship -- again, we were talking 21 about the relationship between QC inspectors and the 22 production. How is the relationship between QC inspectors and 9

  • i 1

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1 their superyision? Are you considered part of supervision? l

. l 2 A Not really. I am a lead inspector. I am qualified-3 to perform the' work in the field and I can do the work in the 1

4 field.

5 The supervision,. right now, with our union, with 6 GMCIS and Comstock, supervision is employed by Comstock. I'm 7 basically a lead inspector who assigns the work to the 8 inspectors and takes the time.

9 BY MR. MARCUS:

10 Q Do you answer questions for the inspectors?

11 A Yes.

I 12 DR. NULIN: That's all.

13 BY MR. GALID:

14 Q Let me ask him this. I was going to ask him, and 15 you opened it up, how do you consider yourself? Are you a --

i i

16 A I just consider myself as a foreman, basically. The l

17 word lead might be misrepresentative. I just consider myself 18 a foreman, assign work, answer the questions as best I can in 19 any situation that arise, keep the men's time.

20 -

Q Does that mean you consider yourself as part of the 21 supervisory group?

i 22 A No, I consider myself an inspector. I don't really 4

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1 consider myself -- I consider supervisors on up management, as d 2 management. I consider myself more the quality group, the 3 inspector group. I don't really consider myself management.

l 4 Q What is the foreman on a crew? What's he considered 5 in the construction area?

. 6 A In the construction area, my main duties or --

7 Q No, a foreman who is assigned to a craft? Isn't ha 8 a member of management?

9 A I'm not sure how they figure that out. They have 10 their general foreman. Their structure is a little bit 11 different than ours. Our leads or foremen report directly to 12 a supervisor. Their foreman report to a general foreman who .

13 reports to an area general foreman, who reports to the 14 superintendent, who has somebody else he reports to.

,15 The superintendents are employed by or can be 16 non-union personnel and the area general foreman and down are 17 union personnel. Now whether they consider themselves just a 18 foreman or part of management, I don't know.

19 Q So you kind of relate more to the inspectors than 20 you do to th's managers?

21 A Right.

22 BY DR. HULIN:

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18 l 1 Q All right. How does the relationship, do you think, 2 in general betw'een the QC inspectors and QC supervision?

3 A I think it's really good on this shift, with our i

l 4 supervisor area. I think there's a good communication flow.

5 Q Did you ever work any other shifts?

6 A Yes, I worked first shift for over four years. I 7 have never had any problems. I worked for several'different 8 supervisors, over a period of years, and I've never had any 9 problems with communication, as far as supervision like we 10 talked about before. I've never had any problems seeing the, 11 what I consider upper management, the assistant manager and 12 nanager.

13 As far as the communication level, I think it's 14 pretty good. I've never been turned away.

15 Q How about the accuracy of the information you get 16 and the communication?

17 A Through talking to individuals? -

18 Q Revels?

19 A Revels?

20 Q Yes. We've had some indications that some 21 inspectors have brought quality concerns to Revels or other 22 people in the supervision and have essentially been told don't t

l 19 l

. I worry about writing that up, that's already been turned over 2 to Ceco or don't werry about writing that, that's a generic l

3 NCR. '

4 And there's some question in the mind of these i 5 people if that was straight information they were getting. Do 6 you have any feeling about that?

7 A If the inspector had a question in his mind, whether 8 something should be written up or not, then he should -- if he 9 doesn't know what it is -- he should see his lead or his 10 supervisor. As to whether his supervisor told him it wasn't 11 necessary to write it up, or he didn't need to write it up, 1 12 that I don't know.

13 If they talked to the supervisor and they talked to 14 me about it, I don't know what it would be.

. 15 BY MR. MARCUS:

16 Q Well, what do you do when somebody reports a problem l

4 17 to you, Don, the cable is not trained right and he's not ,

18 something that he's working on? He's inspecting and it's just 19 something else that he sees? What do you do?

e 20 A Well, I've had different cases where. inspectors have 21 come up to me and said I found this. A couple of times with' 22 the welding inspection group that they have on the shift.

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o 20 1 Welding inspectors have called me up and say hey, we found a 2 cable out in the building that's been damaged. It looks like 3 the welder's damaged it. I've gone out and written it up.

4 If they call me up and say -- if one of my pull 5 inspectors were to call me up and say hey, while I was doing 6 this pull, I noticed the cable over here. It's damaged and 7 not trained right. The first thing I said is well, if you 8 already know where it is, if you have time, why don't you take 9 care of it. If it needs written up on an NCR or ICR, where

  • 10 the condition is, do it. '

11 If they are, you know, really into a cable pull and 12 can't break away from the crew, then either myself or I'll 13 find somebody else available to go write it up.  ;

14 Q What about a hanger that would have faulty steel on .

. 15 it? -

-16 A Well, if they called me up about a hanger that had

17 faulty steel, I'd refer them to Art Frew, the welding and 18 configuration lead, beings I'm not certified in the area. I i

I 19 don't know that much about it, so I would refer them to him 20 because he would be able to better answer any questions they 21 would have.

22 BY DR. NULIN:

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21 1 Q Ha,ve you ever been told what the policy is on that?

2 A The policy on what?

3 Q An inspector noticing something wrong, but it's not 4 the job that he's inspseting? I 5 A For instance, if he was doing a cable pull and saw 6 something other than a cable pull, like a conduit or whatever?

7 Q Or he saw a separation violation or a minimum band 4

8 radius violation on another cable? What's the policy on that?

9 A Well, if he is the inspector that found the problem, 10 then he should address it.

11 Q Even though, he's not supervising the pull? It's 12 something that was installed six months ago?

13 A Sure, yes, he can write it up.

14 Q But should he? I mean, is that what -- ,

15 A Sure, he's out here to notify the client or the 16 contractor of any deficiencies he finds on the pull. If he 17 sees another cable that has a minimum band radius problem or j, 18 damaged, if he is certified in the area and understands the 19 situation and knows what has to be done to take care of it, l

20 and write an ICR or an NCR, he should do that. -

21 BY MR. MARCUS:

22 Q Don, would you automatically write up one of those t

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o 22 1 kind of problems rather than checking or asking to see if it's 2 already been written up by somebody else?

l 3 A Now, in the case of an ICR or an NCR, yes, you 4 should. You should, if you see a hold tag on it, right away 5 you should investigate the hold tag to see what it is written 1

l 6 up on, to make sure it's not for another situation that might 7 have arisen.

8 And it's not a bad idea to check the vault records, *l 9 previous inspections, to see if anybody had documented 10 anything else on it.

11 Q Is that easy to do?

12 A Sure, sure. All you have to do is call the vault 13 and ask them to pull out the files for that cable number, if ,

14 you know the cable number. Ask the records clerk to pull the 15 file on it. She could even tell you over the phone whether an 16 ICR or an NCR had been written. ,

17 Q How would you check if that problem was covered by >

18 an Edison NCR and somebody in Edison was tracking it?

19 A I would get a hold of Mark Diederich, in QA. We ran 20 across a situation -- what's today, Monday? Either yesterday 21 or Fri, day, one of the inspectors was pulling above the main 22 control room and ran into an Edison hold tag and brought it to 6

e e

23 1 my attention. l 2 I went over to the Edison vault, and there just l 3 happened to be'somebody working over there. I got a copy of 4 the NCR to find out if it had any work limitations involved in 5 our pull. I found out that.the NCR was noted as work may 6 proceed through these itans, and got the information, got a

. 7 copy of the NCR back to my inspector.

8 BY DR. HULIN:

9 Q Have,you ever been to a Quality First orientation 10 program?

11 A Yes.

12 Q You're familiar with the program?

13 A- Right.

14 Q Can you describe it to me?

, 15 A From what I remember from the Quality First .

16 orientation we had, when they first brought it onsite, Quality l 17 First told us that if we had any quality problems, any i 18 concerns, to take our general flow of talking to our lead or l

l ' 19 supervisor, our chain of command. And that after going 20 through our chain of command, if we still did not receive p 21 satisfaction of the problem, to contact Quality First and that l

22 any reports made to them would be confidential if we wish.

t 9

l i

-- -,n, ,-. -,,,,,,,,m -.,,e.,. - , - - - - - - - - - - - - , , , -, - - -

~

24 1

They gave us the information for a hotline that they 2

T have on the job, that you could call, a toll-free number or 3 you call you them collect.

And that they would give you some 4

type of a file number, or an index number, to put on this 5

thing and that you can call back later and ask for that file 6

or index number to find out if anything has been resolved on 7 it.

8 They pretty much told us that they had an open door 9 policy, any time.

But they recommended that you do seek out 10 the chain of command and try and resolve the situation before 11 you come and see them.

i i 12 Q Do you feel pretty free to take quality concerns to 13 Quality First?

i 14 A I would not hesitate to do so, if I would run into

,15 the situation?

16 Q How about NRC?

17 A If I went through my whole chain of command and went -

18 i

to Quality First, if the problem that I had could not be 19 answered by them.or I did not feel that the thing was taken 20 care of' properly and the answer was not good enough, I would i

21 not hesitate to go to the NRC. "

22 Q Is there anything that might keep you from going to

,2 i

I

- .~ - ~ - - . - . , - - - , , - . , _ - , , , , . . - . _ , . . - ~ . - . , . - . - - - - - - . - - - - - , _ . - - - - - - - - - . . , , , - . , . , . . , . - , , , - - - - . - . _ - .

I p

25

. 1 QF or the NRC?

  • 2 A No'.

3 Q Supposing you thought that if you took a concern to 4 them -- I think the phrase is that "your name would be known 5 before you got out of the trailer?"

6 A I don't think that's true.

7 Q But if it were true, would that keep you from going

8 to them? '

9 A No, if I have a legitimate concern. That's my job -

10 out here, is to report defects or non-compliance, to make sure l- 11 that the installations were performed per procedures and 12 outlines. If there was a problem that I thought was serious, .

13 that warranted me going through Quality First, I don't care if 14 my name would be known or if it got put on a list so that

. 15 everybody -- the papers were talking about it, or whatever.

i 16 If there's a problem that needed to be addressed, I '

17 would go ahead and take whatever actions were necessary to get 18 it addressed. ,

19 Q Do you know of anybody that has taken concerns to 20 Quality First?

21 A Not offhand, no. I don't.

22 Q You don't know for sure, then, if they are kept l

l

, - . - . . . - _ . _ . . , _ ._ ,,__i-.m._.c._.-__ . _ . , . - . _ . _ _ _ , . , . _ . ,_--,,_,____._-_._----__m.

~

26 1 confidential?

2 A Just from what they've told us, Quality First 3 themselves. ,

l 4 Q What's the shop talk? Do they believe that they'll 5 be kept confidential?

6 A I've never talked too much about it, to the guys.

7 They've never come up and said hey, do you think if I were to 8, have to go over there, would my name come out? Nobody's ever 9 asked me that question.

10 Q Do you think the Quality First and NRC are 11 responsive when people do bring concerns to them? Do they do

. 12 anything about it?

13 A From the past -- you know, my past history on the 14 job, we had a period of time, back in '84 and '85, when there 15 was a problem with a supervisor, with harassment. And the

~

, 16 supervisor was let go when the inspectors went to the NRC and i 17 brought their concerns up. -

18 After that, after the concerns were brought out, 19 Quality First, along with the Ceco QA Department and the NRC 20 had interviews with randomly picked inspector's -- pretty much N

21 probably something like the way this thing is going -- to ask 22 questions and find out any information they could on the I e e

f 9

, . , ,---,,a.n,--,., r-, - - ----,,,_.,.a,,,.-,n- --,-----n-,

O 27 1 topic, or what anybody knew about it.

2 I think that it seemed to.no that they pursued it ,

. 3 rather well, got involved with it to find out what was 4 happening, what was the problem.

5 BY MR. GALLO:

6 Q Do you think they resolved it or managed to deal 7 successfully with the concerns?

8 A The supervisor's no longer onsite.

9 Q That wasn't what prompted the question. You 10 characterized the inspectors going to the NRC with concerns.

11 A Right.

12 Q Was there more than just one concern?

13 A Ch, I don't know. 26 people, I would imagine there 14 was more than one concern. The newspaper talks about the 26 +

15 and I know there was more than 20 that went over at that 16- time. I'm sure if you get more than a group of two people, 17 you could probably come up with more than one thing from each 18 person. People are different.

19 ,

BY DR. HULIN:

20 Q Do you ever have the feeling that you might be 21 terminated if you brought concerns to Quality First?

i 22 A No.

T

[

29 1 BY DR. HULIN:

~

2 Q How ab'out Mr. Hunter?

3 A Harvey Hunter? From what I heard, from when 4 R.D. was terminated, it was due to a problem with his welding 5 inspection. That's about all I know about R.D. Hunter's 6 termination.

7 BY HR. GALLO:

8 Q Getting back to Puckett, I think you said you didn't 9 know --

10 A I really didn't know Worley Puckett.

11 Q You didn't know him personally, in terms of what 12 he was doing?

13 A Rignt, and the reason for his termination, I really 14 didn't know that much about either. -

15 Q What was the shop talk that you heard about it?

16 A From what I heard, the shop talk was that Worley 17 Puckett really wasn't doing his job, to be real honest. -

18 That's what the other inspectors were saying?

~

Q 19 A Yes, at that time, yes.

20 BY DR. HULIN:

21 Q How about John Seeders? Is that his name?

22 MR. GALLO: He was transferred from one organization

(

l ,

I

\

l

30 1 to another..

2 BY DR. HULIN:

3 Q Did you know him?

4 A Yes, I knew John.

5 Q Why did you think he was transferred?

6 A I don't know much about that. I knew John and I 7 knew he got t'ransferred. The reason for the transfer, I never 8 heard any shop talk about that.

9 BY MR. GALlo:

10 Q Would it be fair to say, with respect to.Puckett, 11 you don't know whether he was terminated for creating waves or 12 not?

13 A- No, I don't know what his reason for termination 14 was.

, 15 BY DR. HULIN:

16 Q Did you ever of the theory where there's smoke 17 there's fire? ,

18 A Sure, I've been hearing that since I was a little 19 kid in school. ,

20 Q Well, there's a lot of smoke out there, isn't -

21 there? Puckett, Seeders, Hunter, Archambeault.

22 A What do you consider a lot of smoke? See, I don't e

i 6

,__.------e- -- v, -,-,wm- -

y-, - . -m- - - - - - - - - - , - - - - - - - + - -

p 31 1 know the reasons for these people, their terminations. I ,

i 1 2 don't know their complete stories. I, myself, haven't had 3 any problems. 'If I find smoke that turns into fire, I address 4 the situations. I've never had any problems. I've never had 5 my job threatened. I've never had a question.

6 Q Have you ever been able to. perform a good 7 inspection, say on a cable pull, because of the rush pressure j 8 to get the job done?

1 9 A I don't let myself be pressured.

10 Q Have you ever been pulled off or had to interrupt 11 one cable pull to do a hot pull?

12 A Have I been interrupted? I don't know that I have.

13 Q Do your men, that you assign, does that happen to 14 them very often?

I 15 A Well, probably from the way your question is leading 16 what you're referring to is the one that Greg Archambeault --

l 17 Q Just in general.

[

I

(

l 18 A Just in general?

19 Q Yes.

20" A If tonight.t/e had a situation w' ere h one of my 21 inspectors gained access to the bu'ilding, using his ADT card,

' 22 was on a cable pull, got into the control room about 6:00 and l

1' l

- - , - -w- , - - -- _ -- ,-.-we --,--,--,m,.- - - - -. - , - - ,,.-w,, -

32 1 the card reader wouldn't let him out. He received red Somehow he got blanked off the computer.

2 lights.

3 He came back over to me about 7:00 and said I didn't i 4 even get a chance to tell the crew I left because the guards 5 got me out. I called another inspector, Carl Biskey, to ask .

6 him if he could finish the pull. He asked me -- the pull is.

7 about 80 foot through some pan, it would only take them before a lunch to complete. So he told me he would go finish it and 9 then he's got his crew after lunch, they're cleaning pan right 10- now, and then he'll go on to his pull.

11 In a case like that, yes, we do swap around.

12 Q Do you think that has any adverse affect on the '

13 quality of the pulls?

14 A No, I do not.

15 Q So they can interrupt one pull, coil the cable, tag

  • 16 it, go do the other?

17 A We usually do not try to interrupt pulls in the 18 middle of the process. I would not pull an inspector off the 19 middle of a pull. If the cable is being pulled through the i 20 building, the crew is out there with their hands on it, they

(

21 would not be interrupted to pull that inspector, unless it was 22 to come over here to talk to you people, then I'd put another l --

. __ __ _ _m.--.__.. _ _ _ - _ . . _ _ . _ _ .

33 ,

1 inspector on it.

2 Q Suppose they may have done the pre-pull walkdown, 3 hadn't started'the pull yet, and they got a hot pull?

4 A They got a hot pull? Then I would call the area 5 general foreman and say if this pull is as hot as it is, then 6 I'm going to take the inspector that performed the walkdown 7 for this other crew, and I'm going to put him on this pull, so 8 the other crew is going to have to sit on the side burner 9 .,

until he gets done with it.

10 Then when he comes back, takes a day or two, and ha 11 needs to do the walkdown again, just remember that it's going 12 to take time te do it over again because we can walk this pan .

13 down in one day and go back the next day, and it's going to be 14 dirty agafn.

15 So I left the craft know what they're doing with 16 their screwed up schedule.

17 BY MR. MARCUS:

18 Q Well, are there very many of these hot pulls going .

19 on out there?

l 20 A It doesn't happen every night, where you have to 21 pull somebody off of one pull to another pull. Usually, the 22 pulls run fairly good, with the inspectors assigned. We 9

1

,O' -' ' '

\

34 1 usually hav,e enough manpower. Right now we've got more than i 2 enough manpower because we're pulling non-safety. And if a 3 hot pull were to come up tonight, I would have enough 4 inspectors that aren't assigned to a crew right now, that I

5 would just go out and do the pull.

6 BY MR. GALLO:

. 7 Q What unit are they pulling in?

8 A In both units.

9 Q Both units?

10 A Yes, we still have some cables -- I wouldn't say how 11 many. We haven't pulled a lot of cable the last couple of 12 weeks. >Before that, we had pulled some Unit 1 cables.

13 Q- There's still a lot of cable to pull in Unit I?

14 A Yes. They have -- cables are finishing up reworks, ,'

15 cable completions, partials that they're doing. We still do ,

16 have scme stuff in Unit 1. ,

17 Q Is there still -- with all this cable being pulled b

18 in Unit 1, is there termination work to be done?

19 A There is a little bit of termination to be done?

20 Q 'Just a little, you think? ,

21 A From what I see. We have one terminating crew on 22 second shift and they are doing some terminating work. They.

4 e

9

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,,___-.,--.,-_..,--..m.,,. . . . - - . _ - , , . . . , . , _ . - - . . - . . . . - - . - . _ , - . _

35 1 have more on day shift. And as far as I know, the day shift 2 is doing a lot of terminating, the inspectors have plenty of 3 work.

4 BY DR. HULIN:

5 Q Have you ever approved an inspection or a pull that 6 you didn't think should have been accepted?

7 A -Never.

8 Q Have you ever been pressured to do that?

9 A Never.

10 . Q Do you know of any inspections that were improperly 11 accepted?

12 A No, I don't.

13 Q When you walk through the plant, do you ever see any 14 out of coda cable separation, minimum band radius? *

,15 A If I do, I document them.

16 Q If you see out of code installations, doesn't that 17 tell you that whoever accepted it accepted a bad pull?  ;

18 A That's not necessarily so. You have to remember

~

19 that an installation in a cable pan does not remain by itself, e ,

20 forever, that there are other cables coming around it. You've 21 got a lot of other crafts working in the area. Things can be 22 moved after an inspector has seen it and walked away. Those 4

t i

O e

e m w y --

-rw , ----,,---..-----.e-w,_ -.--.-n . ,,, ,,--m-. - - - ,we-re . , - - . - - - - -w- - , ,.--.--em-,, --w,,-v- .- - - , -- , . - - , - - . -

36 1 things can happen.

~

2 To say that the inspector left it that way would not 3 be a valid stat'ement, because there's a lot of people out in 4 that building besides him. Anything can happen.

5 Q Do you have any feelings that cost or production 6 schedules sometimes override quality?

7 A No, I do not believe that cost or producti,on 8 scheduling overrides quality.

9 Q What's the -- I mean, you're pretty firm about i

10 that. What's the basis for that?

11 A I've never had any production pressure. I've never 12 had -- if a crew came up and said this is a hot pull, we need 13 to get-it done tonight, I'd say fine. When I get ready and 14 you get started -- by the time I get ready and you get -

15 started, if you can get it done within the time that's got 16 left, fine, we'll get it done.

17 I've never tried to be at 12 places at the same 18 time. I do my job as necessary.

19 Q How many -- .

20 BY MR. GALTA:

21 Q No, wait a minute. What you're saying though is 22 that you've never succumbed to production pressure?

J t - u -

, 37 1 A If there was production pressure, I didn't succumb 2 to it. You wouid have -- what I could say, maybe general 3 pressure, you know, a foreman calls up and says hey, we need 4 to get this done tonight, my boss wants this done. Fine, if 5 it can be done, then it will be done. If it can't be,.it 6 can't. That's always been my look on it.

7 If it's not physically possible for the time that 8 we're alloted in one day, the ten hours or the nine hours, for 9 me to get my section done and then for them to perform their .

10 section, if there's not enough time left for them, either they 11 have to work more overtime or pick up tomorrow where we left 12 off. That's always the way I've looked at it. * .

13 BY DR. HULIN:

-1 i

14 Q Do you ever -- some cable pulls need more than one 15 inspector?

16 A Sure.

I 17 Q Do you ever have any trouble getting the help you 18 need on a pull?

  • 19 A We've had nights when cable pulling was really --

20 you know, we had ten cable pulling crews and ten inspectors 21 and if all the inspectors are busy, all the crews are pulling 22 safety related cable, we will run into a problem from time to O

f J

. - _ . . - . ,, _ . , . - - - . _ - - . . - . . , _ - _ , _ , .-,,,,,..~.--_,.-e.. -,,_ ..,__,.. ,_ - ,r.e.,,,--,_,,m,.._____..,e, __,,r,...,___-,,w.

~

38 1 time, wher.e an inspector will need some assistance on the 2 pull.

3 Usually, I try to keep myself -- as the lead -- I've 4 got all my inspectors assigned. I usually try to keep myself 5 free to aid those inspectors who need help. When it comes to 6 the point and an inspector calls me up and we do not have 7 anybody to give him, I tell him to regulate the pull as 8 needed. If he cannot make it through into the next room or 9 the next area without another QC man, have the crew stop it 10 and coil it so that he himself can set back up again to the 11 other portion of the pull, if necessary, and go from there.

12 Instead of doing the pull in such a long span, do it 13 in segments, if it comes down to that. Usually we get 14 somebody out there. .

But there have been a few cases where we .

15 had problems getting another inspector out because everybody

.16 was busy. -

. 17 BY MR. MARCUS:

18 Q But if a crew has to wait because your QC inspectors ,

19 aren't there, do you hear about it?

20 A We have, on a few occasions.

N 21 Q Who do you hear about it from?

22 A Usually it would come from the superintendent. He I

e

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~ ~ - '~ '

39 1 would come over and ask myself or Harry, whoever he ran into 2 first, why did we have to wait for two hours or why did we 3 have to wait for half an hour, or whatever. -l l

4 That's happened to me twice. Once it was for 5 myself. They wrote on a time sheet that they had to wait for 6 two hours for a QC inspector and it just happened.to be myself 7 on the pull. They did not have to wait. So that was 8 corrected.

, 9 They had another case -- maybe we've had, when we 4

10 first started with the badging process out here, I had foremen l 11 calling up because inspectors would be a half an hour late 12 because we'd be over here signing in as visitors and getting .

13 them escorts and escorting them in. We've had that j 14 situation. And that was a hassle when it first started out.

15 A foreman might call up and say hey, I was supposed 16 to meet the guy down there at lunch time or after lunch, and 17 they're not here yet. And I'd say well, we got over to the m

18 gate, the list wasn't there, we can't get the guys in. That's 19 happened several times.

20 But if they -- usually if they have a problem, an

  • 21 inspector is not out there, they would call mypelf or Harry, 22 whoever was available. But as a large problem, it's not a

. - - . . - - - . + w.,- w,--r r-e- , -- + er w e armr+www

. 40

> 1 large problem.

~

2 BY DR. HULIN:

3 Q Are the inspection procedures and instructions clear 4 enough for you to perform your job?

5 A Yes, they are.

6 Q How about the criteria? Are they spelled out well 7 enough?

8 A Yes, the criteria is spelled out real well. There's .

9 always going to be a time, from time to time, you might run 10 into something that you're just not sure of. You can run into 11 that case, something new that you've never seen before, or 12 something has happened. Then you try and. utilize your chain 13 of command to see if you can get a resolution to the problem.

o 14 Q Two of the documents that control quite a bit that 15 goes on are referred to as 4.8.8 and 4.3.87 '

16 A Yes.

17 Q Is there any confusion in your mind about what 18 you're supposed to do on your job with those two documents?

l 19 A The 4.8.8 is our inspection procedure. 4.3.8 is our I i

20 cable installation procedure. 4.8.8 gives us our guidelines 21 for our inspections. 4.3.8 gives the guidelines for the 22 installation of the cable, which we can also utilize in our I e

O

, - , - -c- -

. - , - - - - - . ._..y_-.-.-..m.-~ , - - . - - - - - - . . - ~ - - - - - . . . , , - , - - - - , - - -, - . . . . . . . - - -* - - - - - -

41

. 1 inspection / to make sure that the craft is installing the l 2 cable per their guidelines, along with our inspection 3 criteria.

4 I think the procedures do provida -- you know, we i

5 went through some updates here lately and revisions and we're 6 constantly updating procedures as the case is needed. They do 7 pretty well, what needs to be done. =

8 Q Is it clear, in your mind, what you're supposed to 9, do if you see a violation of 4.3.8?

10 A Yes. If I see a violation of 4.3.8 that requires ,

11 either an ICR or an NCR, they will be documented. We have 12 different things in 4.3.8. A common one, that you might have

~

13 heard of, that brought some questions up, would be removing 14 the cable from the real, finding inconsistent footage numbers  ;

. 15 for the markers.

16 If that arises, we suspend removal from that real 17 until engineering notified and a correction on the real card 18 is made. We have to make sure that the craft adheres to their 19 procedure. ,

20 BY MR. GALLO:

21 Q Do you do that now?

22 A Yes.

G 6

'I

' ' '-Ri --

i

. l 42

. 1 Q I" thought that engineering had put out a memorandum 2 that indicated that if you encountered that circumstance, you

[ 3 simply measured the cable by tape and keep track of it that 4 way?

5 A I haven't seen the memorandum. It has not been sent 6 to me. ~ If the memorandum is out, I haven't seen it. And I f

7 don't work to menos. If that procedure is going to be 8 changed, fine. But I don't give a shit what that memo says.

4 9 Procedure says you're going to stop taking cable off the real, 10 you stop taking it off the real. It's as easy as that.

11 Q Do your inspectors understand that? .

12 A The inspectors have the procedure. They,would be 13 the first ones to question the meno. If I were to walk out

. 14 there and hand my inspectors a memorandum that would actually, 15 in fact, in its wording change the procedure, they'd be the 16 first ones to question it. They'd say what are you trying to 17 do to us? Our procedure says this. What are you giving me a i 18 meno for?

i- ,

19 Q I understand the memorandum to be a standing , ,

20 corrective action order. It says don't bouher calling us per

! 21 procedura, because we're going to tell you to do the 22 following, so just --

9 O

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3 e

43

.1 A I haven't seen the memorandum, so I don't know what 2 it reads.

3 Q If there was one, is it likely you've seen it?

4 A If there is one, I've probably seen it. I usually 5 get that information through my supervision. I don't -- and I 6 Harry has never -- Harry Revels has never mentioned it to me.

7 So either they forgot about second shift and didn't send us a one, but I haven't seen it.

9 BY MR. MARCUS:

10 Q Well, you do all the cable pulling, though. l 11 A Sometimes that happens, that people that need to

! 12 know don't get those kind of menos, if it is supposed to be. ,

13 I would question it right away, because I don't work to 4

14 menos. I don't believe that a meno can change my procedure.

, 15 They have a program for changing their procedures, with the '

. 16 new PCM program, where they can get a faster change than an i 17 entire revision.

I '

! la If they plan on changing it, that's what they need 19 to do, document it on the PCM.

20 BY DR. HULIN:

21 Q Have you ever been instructed or discouraged from 22 writing up a non-conforming condition?

S e

-,,..,w--,-m.,-,,--m-,,, - v._.- - . - , - . - - ,.,y. #- --__ y. , ..----,-_. . - - - . , , - , - _ . _ _ _ _ _ _ _ _ . _

44 1 A

. No,, I've never been discouraged from writing a 1

2 non-conformance.

3 I Q , Have you ever been told not to?

4 A No.

t 5

BY MR. M1JCUS:

6 Q Do you ever write any?

7 A Do I ever what?

8 Q Do you ever write any non-conformances?

9 A Read?

10 Q Write?

11 A Ch, write? Oh, yes.

I've written several. I don't 12 know how many.

In deficiency reports, ICRs and NCRs, I'm sure .

13 I've probably written a couple of hundred since I've been on '

14 the site.

15 BY MR. GALLO:

16- Q Did -- are you aware of your inspectors that have 17 .

been discouraged from writing out either an ICR or an NCR? ,

j 18 A No.

)

19 Q What about Archambeault?

20 .

A .

I Archambeault asked ne'once about writing an NCR on 21 cable separation and I told him that his procedure defined 22 l

that he write a cable separation conflict report. His 4

e

45 1 guidelines in the procedure provided what report he was 2- supposed to write on that, that it wasn't a non-conforming 3 condition.

4 Q What about the NCR that was written with respect to 5 the problems he observed in the upper cable spreading room?

6 A I would not tell him not to write one for that, 7 because I wrote one for the same thing, about a month before.

8 Q You had written that earlier NCR7 i 9 A Sure, on a different section of the room, yes.

10 BY MR. MARCUS:

11 Q You wrote one before Archambeault did?

12 A Yes. ,

. \

13 BY MR. GALIO:

! 14 Q As I recall, it was not a generic NCR, was it? '

I

, 15 A The one I wrote, no. It was in a' secluded spot, like 16 over in the corner. I don't remember why I was up there, you i

17 know, the reason for my being in the area. But I found an l

18 area.

4 19 At that time, the NCR that I wrote was more on cable 20 damage due to the pressure applied from the extra amount of I

21 length onto the cable grips themselves. That NCR was not 22 really on the bend radius situations that Greg had gone into.

i .

3 I

f m +.. ., _ _ , _ . _ _ - , - . , , _ _ , . . _ ,...m_m-,__,..-_ ____,_.---,.w-.r_,.,. ._._,-..-.._,__-.,_r___.-__,.,_.v._ , . _ _ , ..m.___..._,_w..

46 1 .Q You had tags on the cable?

2 A Right, all the cables were tagged because I had went 3 through each one of those groups of cables one by one to check, 4 the grips.

5 Q Now is this in the same area where Greg was?

6 A I'm not sure if it's in the same area. I'm not sure 7 where Greg's -- I know his was in the upper spreading room.

8 BY MR. THORNTON:

9 Q Is that 463 in the second unit?

10 A 463. Oh, the second unit? I think mine was in Unit 11 1. It's a possibility. I think mine was in Unit 1. I'm not 12 sure.

13 BY MR. GALLO: ',

14 Q Well, you must know Greg's experience, in terms of '.

,15 whether or not he should have written an NCR in that 16 instance. In the first instance, he wrote Harry Revels a 17 memo?

18 A Yes.

19 Q I assume you're aware of it?

e 20 A I'm aware of it, yes. I haven't read the meme, but 21 I'm aware of it.

22 Q And then some three weeks later, after Tony simile e

. , - . -- - --n- , - - - - - . - . . , - - -

. . _ - ~ , . - - - , , - - - . - - . _ , - , , - - , , . . _ - - ~ , - , . - - - , . - - . - , . . _ , - - - , . , - . . - . . . - . _ , , , . . - - - -

47 1 went up and,took a look, they wrote the NCR?

2 A Yes.

3 Q Would'you -- could the Harry Revels' suggestion, 4 that instead of writing an NCR, write a memo, be interpreted 5 as discouraging writing NCRs?

6 A Is that the statement that Harry Revels made?

7 Q No, he was making a lot -- well, I don't know. ,

8 Let's assume, for purposes of my question, that the meno was 9 written and Harry said don't write an NCR, write me a meno 10 that explains what you found up there?

11 A Yes.

12 Q And then some -- because I want Tony Simile to look 13 at it. Three weeks later, simile does look at it. Almost 14 immediately, an NCR is written. Would you interpret those 15 assumed set of events as discouraging the issuance of an NCR 4

16 on the part of Revels with respect to Archambeault?

17 A No, I don't. If that were the situation, I would 18 imagine that maybe -- I think in this case there was a '

19 question of a generic NCR or an NCR listing all cables that 20 were found to have been wrong. If th'at were the' case, you 21 know, H,arry might have a question in his mind of whether a 22 generic NCR should be written or one written to address just e

9

' 48

. 1 the-cables found.

2 In that case, he might have wanted to confer with 3 his supervisor ~,' Tony simile.

, 4 BY MR. MARCUS:

5 Q Were you aware of the Unit 2 upper spreading room 6 problems before Greg brought them up?

7 A When I came on that NCF was written in March --

8 March, was it, from what I remember reading in the paper. I ,.

9 didn't come on the shift until -- on to this shift until May 10 of this year. Before that, I was mostly in the termination .

11 area. I had done some cable pulls in Unit 1. I never really 12 did much work in Unit 2 in the cable pulling area.

13 Like I said, I believe that NCR I wrote was in the 14 Unit 1 spreading room. I'm not sure. As far as seeing those I

. 15 band radius violations, or whatever was there, no, I didn't 16 see it.

17 DR. HULIN: That's all I have.

BY MR. GALLO:

18 19 Q You mentioned at some point that you had eleven inspectors working for you?

~

20 21 A Yeah, I believe I have eleven working for me.

22 Q We've got a list of nine. I wonder who we're i

e e

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49 1 missing. .

2 A Who's on your list?

3 Q You w' ant me to --

4 A Sure. '

5 Q Biskey, Box, Kimble, Noble, Thomas, Plumstead, 6 Schlictor, Knombber --

. 7 A Who?

8 Q K-N-0-E-B-B-E-R.

9 A Oh, Knombber (pronouncing differently).

10 Q Knoebber (confirming pronunciation.) Meeker.

11 A Right.

12 Q That's nine and yourself.

13 A- Okay. Michael Frey is listed under welding, but he '

14 actually works for me.

15 Q Oh, I see.

16 A And then with myself, that would be eleven. That '

17 counts eleven on my timesheet. That's why I remember that 18 number.

19 Q Okay. ,

20 BY MR. MARCUS: '

21 Q Michael Frey, he doesn't do any cable-pulling. -

22 A Yeah, he does do cable-pulling.

4 6

9 e

50 1 Q . C2}, but he's listed under welding?

2 A Hafs been listed under welding because he's been 3 loaned to me for cable-pulling. When we were up to ten 4 pulling crews, he was loaned to me, and he's still working I

'l 5 for me, because they haven't needed him back in the welding 6 area.

7 BY MR. GALIA:

8 Q Now long has he been doing cable-pulling?

9 A Let's see, I'm trying to think. I came on the shift 10 in May. Probably the end of June, he came into the 11 cable-pulling group after his certification. I believe it was 12 in June.

13 Q. How would you describe your duties as a Lead?
  • 14 A My basic duties are to assign the work to the i

I 15 inspectors. In th's case of, you know, this type of work, it 16 would be assigning them to a crew to cover, you know -- this 17 is your crew; this is your crew, you know -- cover their needs '

18 if you can.

19 Q Go ahead. I'm sorry.

20 A Farther, keeping their time, notifying GE of the 21 people that are av,ailable to work overtime for saturdays and 22 Sundays or whatever they require or ask for, keeping their l

l .

O

_ . . , - . - ~ ~ -

.=

~

. 51

, 1 time, finding out, you know, if they are on the job, you know, 2 if they come in late, what time.they come in.

3 Usually every day I check with GE to see if anybody 4 did come in, because sometimes they forget to call me and tell 5 me, and then make sure that if that person isn't in, you know, 6 if we have somebody to cover his work, we cover it, and if we I

7 don't, to notify the craft that, you know, we're missing that ,

8 individual and that they might not, you know, be able to get 9 another individual.

10 Fielding questions from the inspectors, you know,

(

11 any questions that might arise. Usually the inspectors will 12 ask me, you know, and if I don't -- can't give them, you know, 13 a definite answer or an answer to their, you know, what they 14 vant, we'll talk to Harry.

,15 Usually I field a lot of questions from the craft on 16 some things that they're not sure of, like the new terminating 17 form that I've got. It's still a little new for the second 18 shift, and so they usually come up with questions on what 19 they're supposed to do, you know, things like that.

~

20 Q What is this white-colored debris that you find in 21 cable trays, that is found in cable trays?

22 A The white-colored debris that you usually find in

se 52 1 cable trays,is Pyrocrate.

2 Q Pyrocrate?

3 A off the ceilings, the fire-barrier insulation that's 4 put all -- that covers all the beams in the building.

5 Pyrocrate is a never-ending product out there. They'll come 6 in and Pyrocrate the room. The installers will come in to put 7 up hangers or beams or to do rework, and they tear it down.

8 They'll come back and Pyrocrate it. They'll come back later 9 to do something else, tear it down again. The stuff just 10 keeps growing out there. They pull it down, and it goes right 11 back up.

12 I wish I had the contract for that work. It would .

13 be some good money.

4 14 Q Is that the basis for writing an NCR, if you can't 15 get it cleaned, or is that considered to be negligible like 16 dust?

17 A If there's debris in the pan and the debris has not 18 created any damage, with the case of Pyrocrate, if it's just 19 laying there in a pan and laying on top of the cables, 20 sometimes you have to watch the Pyrocrate, because when they 31 do tear it down, they have a wire lathe that they use, an 22 expanded steel, wire lathe. If that would get into the tray

53 1 and get, you know, smashed down into it from some weight, that f

2 could possibly damage cable. '

3 If th's debris has not created any damage and the 4 crew, you know, has taken the stand that they aren't going to l 4

5 clean the pan, that would be an ICR condition that you would 6 comment on your ICR, that during your pre-pull walkdown it was 1 .

l 7 found that the tray was full of debris, and then that ICR 8 could be written up on what the call like a three-day ICR, 9 where you would give the foreman three days to correct the

~

'lo deficiency. .

11 If the foreman couldn't correct it, then it would be 4

I 12 turned in to Engineering, and they'd find somebody that could 13 ,or would disposition it. '

l 14 Q- Let me pose a hypothetical question. If an ,

l , 15 inspector was consistently writing ICRs in circumstances where j 16 this Pyrocrate was in the tray, and it appeared to be the kind

l 17 of debris -- I'll use that word -- that really didn't affect 18 the integrity of the cable or the cable jacket, but l

19 nonetheless the inspector, in his judgment, thought that it .

l 20 should be cleaned -- he couldn't get it cleaned -- and he l

! 21 wrote up an NCR, would it be appropriate for you as a Lead to 22 take' him aside and say, "You are just cutting too square a 1

e l

. . - - - . - - - , _ . _ ,- , .. _ _ _ , .._. _ - _.-m_,,__.-_ ~ ,,_ ,-_--,- . . _ - , - , - -,_ . . . . - . -

54 1 corner here.on this one. Sure it's debris, but you've got to exercise some judgment, and you're really calling this one too 2

3 close?"

4 A No, that would not be good judgment, because then I 5 would be telling the inspector how to do his pull and telling 6 him to accept something that he doesn't want to accept.

7 An inspector came up to me the other night and said, i

8 " Hey, the crew got mad at me because I told them to clean the 9

i dust out of the tray,",and I said, "Was the dust heavy?" And he says, " Yeah, it was pretty heavy." And he asked me, "What 10 11 do you do?" And I said, "If it's just dust," I said, "I check l 12 it with my flashlight to make sure there's no metal filings in 1

13 it. If it's a light film of just dust, you know, there's no ,

14 debris, any other debris but dust that you wipe off with your

, 15 hand," I said, "I check it for metal shavings or eny other l- .

16 foreign objects, like glass, and if you pan a flashlight

17 across it, you can usually pick up any shiny objects."

i 18 And I said, "If there's nothing in there except for f* 19 dust, and it's not a heavy dust, you know, it's just a light l

l 20 film," I said, you know, "I would maybe have them brush it for l

{ 21 appearance."

i j 22 But I also told him that it's his pull. He's the l

t

l 55 1 inspector signing off the pull. If he feels the dust is too 2 thick and it needs to be cleaned out of the pan, then it needs I 1

3 to be cleaned out. l 4 Q You wouldn't second-guess him on that one?

5 A No. He's the man that's got to sign it off. I 6 would tell him my opinion on how I might do the pull, but I'm 7 not going to tell him that he has to sign something off or 8 this is the way he should do it.

9 BY MR. MARCUS:

10 Q But don't you ever coach those inspectors and tell 11 t, hem that they're --

12 A Sure. Well, that's why, like I say --

13 Q -- that they're doing something a little bit too 14 tight or not tight enough? What if he wasn't doing his job .

15 exact enough? What if he was letting too much dust -- .

16 A If he was letting too much debris go, than I would 17 bring it to his attention'that he might --

18 Q Well, so you would coach him, though.

19 A I'd coach him, but I would not tell him how to make 20- up his mind. I would coach him. You know, to a certain

  • 21 extent, you know, the Lead's job, you know, is to help the 22 guys out whenever he can. But I would not tell him definitely O

56

. 1 one way or.another what he had to do.  ;

2 Like in the description I gave you before, with the 3 coaching description on how I, you know, make my decision over 4 dust, you know.

5 Q But let me ask a question. Would Harry do more 6 coaching than you, or whose role is that? Your role or 7 Harry's role?

8 A Usually it's my role.

9 Q It is your role?

10 A Right.

11 Q Does Harry ever talk to you about coaching the 12 people one way or the other to do a better job or --

13 A- Well, we all strive for a good job.

14 Q Yes, but I mean, -- ,

15 A As far as coaching an individual? There might be 16 times when something might come up. If, say, we had any ,

17 inspection checklists come through that made it to the doc 1

18 reviewers, and maybe the inspector forgot to fill out a box or 19 two or left a box blank, or was not doing something, you know, 20 making a. comment like the statements of complete pull or 21 partial pull, is not making a correct statement, you know, 22 wrote the wrong one down, he would let me know about it, you f

p 9

0 m

57 1 know, that the inspector -- you know, "Here, the doc review 2 group kicked these up," you know. "I want you to talk to him, 3 you know, show this to him." -

4 Q Harry would call that up?

5 A Yeah, yeah. It would be brought through him.

6 Q But he wouldn't go directly to the inspector. He'd 7 go through you.

8 A He comes through me.a 9 , Q So, it's your job to talk to the inspector about it.

10 A Right. We usually follow a chain of command. Harry l 11 and I work real well together. If Harry has a problem with 12 one of my people, you know, in regards to something like that, 13 he would come to me. If I can't be found, you know, and it i

14 was something that needed attention, he would talk to the '

. 15 inspector, but he would always come back to me and let me know 16 what he did. '

17 BY MR. GALLO:

j 18 Q Is there a distinction to be made based on the 19 nature of the inquiry?

i 20 If Revels or some'one else suggests that one of your '

21 inspectors is, in some respects, not doing an adequate job,

! 22 and he needs some guidance or some training or some advice, I i

I I

l

58 1

1 understand that you're telling me that you'd undertake to

~

2 provide that.

3 A Yeah, if it was within my means, you know, if it was 4 something that I could perform.

l 5 Q Yes, assuming that you have the understanding and

6 the capability to do it.

4 i 7 A Uh-huh.

8 Q Would that be the same if he came to you and said, 9 "Say, I think this inspector is calling these too close. I've 4

i 10 got a bundle of ICRs about all this Pyrocrate. I think you'd ,

1 11 better tell him -- explain to him, you know, we don't'want --

. 12 we want him to write them when it's appropriate, but you ought' i

13 to explain to him that maybe we ought to exercise some a

l 14 judgment here?"

15 Would you treat that kind of request the same as if l

16 he came to you and said -- suggested that one of your l 17 inspectors was missing something?

l'  :

18 A If -- usually what I would do in a situation like 19 that, if one of the supervision came up to me and said, "h.re, l

i 20 I've got this whole pile of ICRs here, and it's all written up ,

21 on Pyrocrate. You know, he found all this problem in the 22 trays," one of the things I would do is say -- well, I would I

l T

i Y

9

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4!

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5

. 59 1, talk to the, inspector and say -- find out if he's having a 2 problem with the crew, you know, that the crew is not --

3 doesn't feel that they have to clean the pan or something like 4 that, and they say -- you know, in a coaching way, ask him, 5 ,

you know,'what problems he's finding in the pan. You know, is 6 he finding a lot of Pyrocrate, which a lot of times you can, 7 because if you work in these areas that are worked in heavy 8 during the day.

9 Then I would find out if he was having a problem
10 with the crew, you know, if the crew, for some reason, they 11 weren't cooperating, you know, if he found a small section of i '12 pan when he was doing his pre-pull and said, " Hey, can you 13 guys, you know, brush this out. You know, it needs cleaning,"

14 and they're rejecting that and saying, "No, you know, we i

! 15 aren't going to do it."

l l .

16 And if that was the case, I'd go directly to the 17 foreman and on through Construction's chain of command. '

18 We had a case one time with one crew that one of the l ,

19 guys was working with, and he asked them to do something of s.

20 that nature, you know, clean a section of pan or something 1

21 like that, and the crew said, "No . Write it up." And the 22 inspector called me and said, " Hey, you know, we've got this 9

e t

> , - - - ,.'v- -----n., n,,,,.--7n n,m,__,,--,,._-,w,_ ,,,n,,ee.w,n___ ,_ _ , , - - ,

  • r 60 1 situation.. The crew told me to go ahead and write it up."

~

2 And it was something minor, you know, like cleaning out, you 3 know, a little'section of pan, you know, at the end of a riser 4 or something like that that they could brush out in a matter of minutes, and I called the Construction Superintendent, and 5 '

6 they just love to hear things like that, you know, where the 7 crew isn't cooperating.

8 He was -- the crew was out there in less than an 9 hour cleaning that piece of pan out, because they want, you 10 know, as much -- they want to cooperate as much, you know, to i 1 .

/11 make the job run as' easy, you know.

4 12 Q But if, upon your investigation, you discovered that 13 basically the inspector was being a little more stringent that 2

14 you would have been in the same circumstances, what do you do 15' in that instance?

16 A Well, whatever I can do. If I can, you know, sit 17 down with the inspector and, as we said before, provide a ,

i .

18 little coaching. .If he, you know, still feels that way and '

~

19 still has to write the ICRs, well, that's something that he i

! 20 has to do.

I 21 If it's a problem, then, you know, if it's something 22 ,

that I can't work out'with him, then he's going to have to 6

f. * .

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i

. l

, 61 1 talk with s,upervision. You know, they will have to, you know,

,- 2 take the situation further, if they consider it's still a 3 problem or the inspector considers it a problem, you know.

4 I'm not going to pressure the guy not to write them up. You 5 know, if he still feels that this is a situation where it is 6 dirty enough and I'm not going to pull the cable through, I'm 7 not going to twist his arm, because he's still the guy that's 8 got to sign it off.

9 BY MR. MARCUS:

10 Q Don, could I give you a little different example, 11 though?

12 You know, the cleanliness of cable trays, we've been

'13 talking to all these inspectors, and we're finding that 14 there's some judgment involved there as to what constitutes -

15 clean.

16 A Sure.

17 Q Let me give you a case where you have an inspector 18 who came out there and insisted on vacuuming every single 19 cable tray run before he'd put a cable in, and he's working 20 for you.

21 Now that's the extreme of the judgment. Now clearly 22 they're not vacuuming for every run.

e D

e 9

't _ . - - - _ _ - - , . - - . - w. _ , . ,- - - - - - - - , --- - - - - - . -

~

62

, 1 Now how would you handle that? Wouldn't you talk to 2 the inspector?

3 A If th$ inspector made them clean every single run 1

4 with a vacuum cleaner, I would probably say, you know, "Do you 5 really think it needs to be vacuumed?" I would give him my 6 advice on checking dust or what type of debris it has, you 7 know.

8 I would possibly then go out and do a walkdown with 9 him, you know, "Take me out and show me your problem. Let's

10 see if we can figure out, you know, what we're looking at here 11 that needs to be completely vacuumed out of the tray." You

'12 know, try and work with the inspector and find out, maybe j 13 somewhere along the line, he had some misleading training or 14 something like that or misinterpreted something.

. 15 If I find it is a definite problem and all of the 1

16 tray does need vacuumed out, well, then it's got to be 17 vacuumed out. It's going to go one way or the other.

18 BY MR. GALID:

o 19 Q What if y,ou find that, in your judgment, you don't 20 have to vacuum out. these trays, each and every one of them?

21 A Usually -- I shouldn't say usually -- in a case like 22 that, myself, if I thought that the tray, that every tray in e

63 1 the building that he had a pull through did not need vacuumed 2 out or the ones that we looked at together, I would express my 3 views on how I would inspect it and see, you know, if he 4 disagreed with me, then I'd say, "Well, maybe we need to go 5 talk to supervision and see if they can shed any light on it,"

6 you know.

7 BY MR. MARCUS:

8 Q But don't you think, as a Lead Inspector, if you've

. 9 got nine inspectors out there -- I'm just trying to get an 10 impressio.n for how you actually would handle the situation --

-11 if you had nine inspectors out there, and one guy was having 12 --

13 A. That's why I would say I'd go out and look at the 14 runs with him and find out what he is looking at.

i 15 Q You certainly would feel it incumbent upon you to 16 take some strong action, wouldn't.you?

17 A Sure. If I've got one guy out of nine that is

.~

18 looking at it, you know, differently than the others, the 19 question would run through my mind, either the one guy is 20 doing job and the other eight aren't, or the eight are, and 21 the one guy is going -- you know, he's looking at something 22 different than everybody else is.

S

. l

, 64 1 . I would, you know, try and find out what, you know ,

. l 2 -- what is happening. We'd like to see uniformity, you know, 3 among all the inspectors, have all the inspectors, you know, l

4 see the same things, you know, and not overlook anything, you  ;

5 know, make them all ware of the problems.

6 O But you would feel it's part of your job to address 7 that situation? '

8 A Yeah.

9 Q You wouldn't let it go.

10 A I would -- if there was nothing I could do about it,

11. you know, like I say, if it got down to the point where, you 12 know, talking to the inspector, you know, by the time we got 13 done, you know, looking at it, discussing it, if he said, 14 "Well, I still think it's a problem, and, you know, I'm going ,

,15 to keep doing it," I'd say, "Well" -- you know, if supervision 16 had asked me to go out and correct this problem, then I would I

i 17 have to go back and tell supervision, well, you know, I've ,

i l 18 discussed it with the man, you know, we've looked at this case l 19 and this case, and the inspector still feals that it's -

l 20 necessary to vacuum out the tray, and then, you know, that's 21 as far as I can go, you know.

22 BY MR. GALLO:

4 e

65 1 -Q Did -- I guess you were aware that Archambeault 2 passed out that questionnaire a few days ago?

e 3 A Right.'

  • 4 Q We've been asking the inspectors whether or not they 5 filled one out, and I've been giving them the opportunity to 6 decline to answer, if they wanted to.

7 A I never received one of those questionnaires. I did 8 not -- I've seen one, glanced at it laying on a desk. I never 9, read it. I didn't feel it was mine to read, because I was 10 never presented one.

11 Q Okay.

12 MR. GALLO: I guess that's all the questions I have 13 for Don.

14 BY MR. MARCUS:

.15 Q How did you like the interview?

16 A I think it basically covered everything that, you 17 know, has been brought out in the open, I guess you could sort 18 of speak.

19 Q Is there anything we didn't cover that we should

~

20 have?

21 A No, I don't believe so. I think you've pretty well 22 covered everything.

e

66 1 As a summary on my own part, you know, if I could, 2 I'd like to say that as an inspector, I've been out here for a 3 little over five years, and the direction, you know, that most 4 of your questions led, you know, just to summarize it, I have 1

5 not been intimidated. I have never b.een stopped from writing 6 an NCR, an ICR, or noting a deficiency. I have not been 7 pressured by the craft or the production. And I've always had 8 a good rapport with the craft, and I've never had,any problems 9 talking to my management people.

10 And as far as what I've read in the paper, I -

11 disagree with the comments I read in the paper of -- to the 12 point that, you know, statements that the newspaper made, from  :

t 13 one of the excerpts they made, from whatever information they I

14 had that some of the inspectors feel this way, and all the

, 15 inspectors are like this, you know, I disagree with those kind <

16 of comments, and I think they're pretty God-damned one-sided, 17 you know, for a paper to print something like that, and I 18 dislike the way that they're always trying to print the cons, .

19 and they never come out and ask us, any of us, if we know any 20 of the pros, you know.

21 And as far as that questionnaire, no, I never did 22 see that questionnaire, you know, and it was never presented 9

0 l

. . ~_. . , _ . _ _ _ _ . _ _ - , . . . . _ _ . . . _ _ _ . . _ , . . _ . _ . . . _ _ _ _ . _ . _ _ . . . _ _ _ _ _ . _ . _ _ _ _ _ _ _ _ . _ _ _ . . . . . _ . . _ _ . .

o 67 1 to me. And from what I've heard about the questionnaire that

. 2 was utilized, t'here weren't that many passed out to the amount 3 of inspectors who are on the job. There's a 160 or some 4 inspectors we have, that there weren't that many 5 questionnaires passed out.

6 Q Do you have any idea how many questionnaires were 7 passed out?

8 A From what I understand from the shoptalk, 20 9 questionnaires were passed out, and seven were turned in, or 10 were turned in by Greg. Now that's just shoptalk from Rumor 11 Control, you know, and, you know, actual numbers, I don't 12 know.

13 I disagree with a lot of things that Greg 14 Archambeault's statements that have come up in the papers, and 15 I, you know, I disagree with their blacklist or layoff list.

16 I don't think there is one. It's never been shown to me, or 17 nobody has ever told me there was one. I guess it's always C

18 been a Construction myth.

19 And that's basically about all I've got to say, and 20 I do appreciate you giving me the chance to come over here --

21 Q Good.

22 A -- and express my views.

e e

. l

Y

- 68

, 1 Q Can I ask one more question on this? Out of the 20 2 that were passed out and the seven that were turned in, have 3 you heard any shoptalk as to what happened to the other ones?

4 A I talked -- comments from one inspector that he 5 didn't think his got turned in, and that he didn't think 6 another one had got turned in, because they had too many pro 7 comments on them.

8 BY MR. GALLO:

9 Q And that inspector since has learned that it was 10 turned in.

11 A Okay.

~

12 ,

Q He told us about it.

13 A Okay. Well, that's just, you know, from the 14 shoptalk that I'd heard.

15 Q Archambeault said he passed out 14 at the hearing.

16 A okay. Well, by the time it gets through so many 17 people, as I said, from Rumor Control. I'm surprised that 18 it's not higher, but --

19 BY DR. NULIN:

20 Q Okay. I'm going to give you my card here. It's got 21 my home phone on the back, my office phone on the front. If 22 any questions come up or anything that you remember tomorrow e

- . - - - - - - - - - - - . _ . _ - _ - - , - . - - - _ . , , , . , - ----,m.---- - - -,.- y- , , - - - - - , . , , , , - . .

t s

, 69 l ,

1 or next week that you didn't tell us that you wanted to --

2 A Okay.

3 Q -- give me a call collect. And that's George 4 Marcus' number there. He's here onsite, as you know --

5 A Okay.

6 Q -- and call him, and we'll see to it that the 7 information gets used.

8 A Okay. Well, is this information, you know, that 9 you're gathering going to be used at the hearings or whatever, 9

10 or --

11 BY MR. GALLO:

12 Q Well, we don't know. The one reason why we're 13 recording it is to -- it's so voluminous that we want to 14 evaluate it. So I'm not sure it's going to be used at the

. 15 hearings. It's basically for our information and for QA's 16 information and also for the consultant.

17 We would use it if we thought that it was, you know, 18 necessary. Our evaluation of the Archambeault concerns, I

~

19 think, is that, at least as we see it at the moment, we think 20 that the situations that he describes have been explained.

21 So I don't know, you know, just how we will use it, 22 but that's the reason we're gathering it.

W m

.' l 70 L

1 I take it Mister -- his name is Knoebber -- he's not

~

2 here tonight?

3 A Knoebber (pronouncing differently.)

4 Q Knoebber (confirming pronunciation). l 5 A Knoebber called in earlier and said he was going to 6 be here at 9:00 o' clock, and just before I cane over here, 7 when George called me to let me know I had to come over here, 8 he told me that Mr. Knoebber was not going to be in at all 9 tonight.

.10 Q I take it, we could take advantage of the fact that 11 we have the Lead here to get our next person.

12 A Who do you need?

13 Q. Schlichter.

14 MR. GALLO: Do you w' Ant a break (addressing the 15 reporter).

16 Yes, we're off the record.

17 (Whereupon, at 9:32 o' clock, p.m., the interview was

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18 concluded.)

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.. x . . . . . . .- . .~. -. .- . . . . - .-- - -----. ~._

"{ *$ ,

[ DONALD BOX]

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e THIS DOCUMENT IS SUBJECT TO ATTORNEY WORK PRODUCT PRIVILEGE l

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2

.i 3 --------------------------------x ,

4 Interview of:  :

5 DONALD BOX  :

6 .

o 7 --------------------------------x 8

9 Braidwood Generating Station

' 10 Braidwood, Illinois 11 Monday, September 15, 1986

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12 f

13 The interview commenced at 6:03 o' clock, p.m.,

14 examination by JOSEPH GALLO, ESQUIRE, Isham, Lincoln & Beale, 15 Chicago, Illinois.

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, 18 l

19 20 21 1

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2 d

1 PROCEEDINGS

, 2 [6:03 p.m.]

3 Whereupon, * .

4 DONALD BOX, 5 who was called for interview, was questioned and responded as 6 forllows:

7 MR. HULIN: Let me briefly explain our purpose in 8 meeting here today. We are trying to determine the type of 9 relationship that exists between management and the production 10 department and QC inspectors out here on the site. As part of

{ 11 this, we are trying to determine if quality control inspectors 12 have freedom to report any concerns that they have to 13 whoever. We are trying to determine if quality concerns exist 14 in the minds of the quality control inspectors.

25 Now, obviously this didn't come up out of the clear 16 blue sky, and there are some specific issues Mr. Gallo is also 17 concerned with relating to some of the allegations that have 18 been appearing in the newspaper and so forth.

19 Now, before we go any further, let me state that we 20 are asking for your cooperation here and we would like you to 21 answer the questions as candidly and as openly as you can. You 22 are certainly under no requirement to talk to us, and you can O

1

. _ _ _ _ _ _ _ _ _ _ _ _ _ _ l

s -

. 3 f 1 certainly not answer any specific questions that come up.

2 Let me let Joe explain what his -- not what his f 3 concerns are, I think we have closely-related concerns, but -

4 the specifics of what he wants to find out.

5 MR. GALLO: I think Chuck has pretty accurately and 6 adequately covered the purpose of why we are here, but i' '

7 basically, it stems from some of the concerns indicated by ,

8 Greg Archambeault to the NRC. You must be aware that ha 9 testified at the hearings last week, and I know that a

. 10 newspaper article appeared about his testimony. He has made 11 known some concerns which he essentially has attributed to '

l 12 other inspectors that he works with on the second shift to e

13 indicate that he thinks that they hold the same concerns, and 14 we are here to just try to talk to some of the people and see 15 if that is the case.

16 DR. HULIN: We are specifically not singling you 17 out. We ar' s going to be talking to most of the QC inspectors.

18 MR. BOX: That's fine. That's okay.

19 EXAMINATION 20 BY MR. HULIN:

21 Q Your name is Don Box?

22 A Don Box. B-o-X.

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,s 4

1 Q How long have you worked for Comstock?

2 A Five months.

3 MR. GALLO: You are going to have to speak up a .

4 little bit.

5 MR. BOX: Five months..

6 BY MR. HULIN:

7 Q In what capacity?

8 A Level II inspector in cable pulling.

9 Q Were you hired in that capacity?

10 A Yes.

11 Q Are you qualified as an inspector in any other

  • 12 areas?

13 A On this site, no.

l? 14 Q You have been on previous sites?

15 A Yes.

16 Q Where did you work previously?

17 A I worked the LaSalle station, worked for vista 18 Construction Company, and I was certified across the board, so 19 to speak, all classifications.

20 Q Welding, cable pulling, terminations?

21 A Right.

22 Q Did you work at any other nuclear installations o

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. 5 1 before that?

2 A lio, not prior to that.

3 Q How long did you work at LaSalle? -

4 A Approximately 13 months.

5 Q I would like to ask you a few questions now about 6

your access to supervision, and specifically, do you think you 7 have adequate access to supervision? By that I mean both your 8

lead and your supervisor, for technical quest. ions that come up I

9 on your job?

10 A Yes, I do.

4 11 Q Who would you talk to if you had a technical '

12 question?

13 A First of all I would go to my lead, but if he is not 14 available, I would go on up.

15 Q Okay.

16 A My lead being Don Schirmer, and my supervisor is 17 Harry Revels.

, 18 Q If things come up in the middle of a pull, for 19 instance, would you be able to go and talk to them?

20 A Sure.

21 Q You stop the pull right there and say I've got a 22 question here, I don't know the answer?

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.- 6 1 A If I feel there's a need for it, yes, I would stop 2 the pull.

<j 3 Q Would you get any pressure from craft if you did ,

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4 that?

5 A No. I would just say: Hold it fellows, we've got to 6 check this out. If I'm not'certain of it and should there be 7 any changes made, I would rather stop it right there.

8 Q Do you think you have adequate access to your lead 4

9 or to your supervisor if you have any administrative 10 questions,, things to do not with the technical aspects of 11 your job but with your employment? You know, vacation, your -

12 insurance, workman's compensation.

13 A Yes, I think I do. Excuse me for laughing there, i

but when you talk about vacation time and insurance, it's not

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14 15 very good on this job.

16 Q But you could go get answers to your questions?

17 A Sure.

18 BY MR. GALLO:

19 Q You just don't like the answers you get.

20 A Yes.

21 BY MR. HULIN:

22 Q How about overtime?

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1 A on the overtime? I don't have any problems with the 2 overtime at all.

3 Q If you were getting too much or too little, you -

4 could go talk to them?

5 A I'm sure I could.

6 Q And you specifically talk to Schirmer and Revels, in 7 that order?

8 A Yes. Whichever one is available at the time, that's 9 who I talk to.

10 Q If your questions when.you went to talk to these 11 people, if the answers that you got didn't satisfy you, if yod 12 still thought there was a problem, would you feel free to talk 13 to middle level management, like DeWald or Saltmann or simile?

14 A Sure.

15 Q Have you ever done it?

16 A Have I ever? No, I haven't, but if I thought the 17 need was that great, yes, I would. I mean if you didn't have 18 satisfaction.

19 Q Do you have any reluctance at all to bring any of 20 these questions to your supervision or middle management?

21 A No, none at all.

22 Q You don't feel anything is going to happen to you?

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1 A No, I don't.

i 2 BY MR. GALLO:

i 3 Q can you give an example of a question you might ask .

4 your lead or Harry Revels the last few months?

5 A The only prime target that I would have would be s6 trying to get on the day shift. I would like to go to day 7 shift, and I have asked." Through no reprise, I'm still on 8 second shift.

'- 9 Q You have ma,de a number of requests for the day 10 shift?

11 A I have asked several times, yes. -

l, 12 BY HR. NULIN:

. 13 Q What kind of an answer do you get?

14 A Not at this time. That's basically the answer, they 15 are not taking anyone at this time. But yet there is quite a 16 bit of turnover, so I can't understand his justification for 17 his answers.

18 BY MR. GALID:

19 Q Who is giving you this information? Who are you 20 getting it from?

21 A Through? Well, I have talked to Don Schirmer, Harry i

22 Revels, Dick Bower.

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1 Q Who is he?

2 A He is one of the quality managers. And Bob Brown, 3 which is his manager. I am trying to go by the step-by-step .

4 operation.

5 Q Have you gone through McIS at all?

6 A Yes, I have even asked,them. I said: What do you 7 have to do to get on day shift? Who do you have to talk ,

8 to? It's basically my only question.

9 Q What did MCIS tell you?

10 A We'll see what we can do.

11 Q Who is that, Mr. Cartelli? "

12 A Well, yes. I have also talked to my union, and 13 basically the same answer. So it's like pass the buck, you 4

14 know.

15 BY MR. NULIN:

16 Q Does this affect your work at all?

17 A No, it doesn't affect my work.

18 Q Does it affect your attendance?

19 A No. I feel I have a good attendance record.

  • 20 Q Do you have any reason to believe that there is a l 21 layoff list?

22 A No. No, I don't.

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10 1 Q Well, there are going to be cutbacks in the work

, 2 force as Unit 1 reaches completion. What order do you think 3 they are goin'g to lay the QC inspectors off in? .

4 A I have no idea. I can't answer that.

5 Q Do you think the ones that make waves are going to 6 be the first ones to go?

7 A I can't answer that. That's not up to me to answer.

8 Q okay. Let me put it this way. If you were going to 9 make up a list, what would cause you to put some inspectors at

.10 the top of it and some at the bottom? '

11 A I wouldn't know where to put any inspector. I -

. 12 wouldn't judge one over the other because I feel as inspectors c<

. 13 they are all qualified, so therefore I couldn't say this is a It 14 better inspector than this one. I couldn't do that.

l 15 Q They are all qualified, but do they all work equally l

l, 16 hard?

17 A In my mind, when they are doing their job, yes. I 18 am sure of that.-

19 Q Do you know of any QC inspector who was terminated?

l 20 MR. GALLO: Let me ask another question first.

21 DR. HULIN: Sure.

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1 BY MR. GALLO:

. 2 Q Do you think they are all doing their job during the

. 3 eight hours they are on the job? .

4 A Well, to put it this way -- I believe I know what 5 you are leading to -- if the job is available, yes.

6 Q I guess what caused me to ask that question was when 7 you said that they all work hard when they are doing their 8

i job. I happen to be aware that sometimes there is nothing to h 9 do. .

f 10 A That's true.

11 Q So were you making that distinction? "

12 A Well, when they are working, they are working.

13 Q When they are finished with a pull, do some seek out 14 their lead and say: I'm finished with that pull, what else 15 have you got? Or seek out their foreman, as opposed to others 16 who don't do either of those things.

l3 17 A I am quite sure that any time when the pull is i

18 finished, they do ask their foreman because they are going to 19 turn in their paperwork on this finished pull, and the last 20 thing that has'to be done is the foreman has to sign it, and 21 if he has got anything else, he will tell you at that time.

22 Q Is it a practice at all on the second shift to, a

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. 12

. 1 after you have finished your paperwork on a pull and the

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2 foreman signs'it,.the inspector has signed it, and that 3

i foreman doesn't have any more pulls assigned to him, is it the .

4 practice at all to go to the lead and say: I'm finished here, 5 have you got anything else? Or do you just wait for your 6 foreman to get a new assignment?

7 A You could call your lead and ask, if you want 8

something else to do, see what else is available, and that has 9 happened.

i 10 Q Is it the practice to do that or is it not the '

11 practice?

12 A Basically, no, but there is a few that do.

13 Q A few inspectors who do that?

14 A Yes.

15 BY MR. HULIN:

16 Q Do you know of any QC inspector who was terminated?

17 A No, I don't.

18 Q When did you start here, five months ago?

19 A I started here first of April, yes.

20 Q Was Mr. Hunter here when you started?

21 A I don't know Hunter.

22 Q Arndt?

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'. . . 13 1 A I don't know him.

2 Q so you don't know of any QC inspectors who were 3 terminated since you have been here?

4 A Not to my knowledge, no.

l 5 Q Do you hear any shop talk about any terminated 6 inspectors?

\

7 A No, I haven't.

8 Q Do you think there is an acceptable -- what do you 9 think of the relationship between QC inspectors and QC l 10 supervision?

l 11 A I think we have a good working relationship. .

12 Q How often do you meet with your supervisor?

1 13 A In the course of an evening, or what?

14 Q Give me a week.

l 15 A In the course of a week I probably run into my 16 supervisor a good four to five times an evening, so 20 to 25 17 times.

18 Q Do you have any regularly scheduled meetings?

19 A We do have a scheduled Monday meeting, yes.

20 Q What is the content of that meeting?

21 A What we have at our Monday meeting, our work 22 schedule, what has happened, new procedure changes, if there e

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. 14 1 is any procedures changes then we are aware of it. It's basic 2 knowledge that we should be aware of.

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1 .

3 BY MR. GALLO:

4 Q When he uses the term "QC supervision, who do you 5 underst'and that to mean?

6 A Well, I would say Mr. Harry Revels. That's my 7 supervisor. '

8 BY MR. NULIN:

9 Q If I use the term "QC middle management," do you 10 know who I would be referring to?

, 11 A I believe so. .

12 Q Who would that be?

13 A Well, middle management, that could be Tony Simile, 14 Bob

  • Brown.

15 Q DeWald?

16 A DeWald.

17 Q Seltmann? -

18 A I don't know Seltmann.

19 Q Have you ever seen any of these middle management 20 people on the site, on the work site during your shift?

21 A I have seen DeWald on site, and the other gentleman l 22 you mentioned, I --

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  • ~

l Q Do you see Tony Simile out there?

2 A Tony,' yes, I have.

3 Q How is the relationship between the inspectors and, ,

4 say, Brown and Simile and DeWald? If you saw Simile on the 5 site, would you feel free to walk up and talk to him about.a 6 concern you had?

7 A Sure.

  • 8 Q Have you ever done it?

9 A No, but I walk up and talk to him. If I had a 10 problem, I wouldn't be afraid to, no.

11 Q How about the relationship between the inspectors -

12 and LKC production? Your main source of contact with 13 production is through the craft foreman; is that correct?

14 A Right.

15 Q And what is the relationship you have with the craft 16 foreman out thora? Kind of an antagonistic relationship?

. 17 A No. I feel I have a good relationship with all the 18 men that I work with.

19 Q Do they ever get on your case for holding up their i

20 wire pulling?

21 A No.

22 Q Do they have sort of an implicit production norm i

l I .

d 16 1 that they have to achieve over the course of a week?

A 2 It's my understanding that they have like a certain 3 footage output to reach. I am not concerned with their .,

4 'ootage f or whatever they are told to do by their supervision.

t 5 That's not my concern.

6 Q What is your concern?

7' A My concern is the quality of what we are doing. In ,

8 other words, if it's going to take two hours to do this job

9 rather than one hour and they have got another job waiting, we 10 are going to have to do it. If it's going to take two hours, 11 it's going to take two hours. '

12 Q How about hot pulls? Do you get pulled off one, 1

j 13 taken off one cable pulling operation and put on a hot pull 14 very often?

15 A Not very often, no.

16 BY MR. GALLO:

17 Q Did you ever have it happen?

18 A Yes, we have. or yes, I have. When they was pulling the big 5 kV cables, that way they shut down 19 20 everybody, four or five crews to pull that one cable.

21 Q Was this a power pull?

22 A No.

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, 1 Q No mechanical assistance?

2 A No," manual.

i. ,

3' Q How did you feel about that, being pulled off

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c '4 whatever your other assignment was and transfe'rred to this l /'5 pul,1? ,.

6 A It doesn't bother me.

>> 7 Q Did it interrupt whatever you were doing?

. 8 A Basically no.

> ^ ?. .

i 9 Q Were you in the middle of a pull?

10 A If we are in the middle of a pull, we just stop the 11 pull, flag it off, go do what we have to do, come back and .

12 proceed.

13 Q Was that the case in this instance or were you --

$ 14 'A Yes, it was.

13 Q Did they catch you in the middle of the pull or in 16 the middle of your paperwork?

l 17 A In the pull.

18 Q Is that the only instance that you have experienced?

19 A For a hot pulle yes.

'20 Q When did this happen, roughly?

21 A Approximately four to five weeks ago.

22 Q Do you think that's an example of emphasizing o

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18 G

1 production over quality?

2 A No.

3 Q Why not? -

4 A I don't think that at all. I think I may have had 5 the only pull going through the course of the evening. I 6 don't know, but I believe the manpower was available for this 7 pull so they asked me to shut down, which I did. Let's go ,

, 8 pull. That's fine, too. As far as I'm concerned, I'm still 9 doing my job.

10 Q It doesn't make any difference whether you are l 11 Pulling one cable or the other?

  • 12 A It wouldn't make any difference at all.

13 Q Was this pull that you were on -- what was it, you 14 said, a 5 kV cable? -

15 A Yes.

16 Q How many QC inspectors were on it?

17 A I believe five.

18 Q Was Mr. Revels the supervisor then?

19 A Yes, he was the supervisor.

20 Q At the time of this pull?

21 A Yes.

22 Q Who was the lead inspector; do you recall?

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l A No, I really don't.

2 Q Was it somebody other than you?

3 A Yes, it was. It wasn't I. I was not the lead i

4 inspector.

5 BY MR. HULIN:

6 Q So you seemNto be telling us that you have adequate 7 access to your lead'and your supervisor and to middie 8 management for both technical and administrative problems, and 9 the relationship between you and the craft foreman, or I guess 10 I'm talking QC inspectors in general, but you don't know about 11 the rest of them, so between you and the craft foreman. I 12 guess I'm surprised at your answer because I would assume that 13 the craft foreman and the QC inspectors would sort of have a 14 little bit of a head-butting relationship going on.

15 A I don't know why.

16 Q Oh: "I want to get ths wire pulled, and here you're 17 telling me to get the dust out of the tray, and you know dust 18 isn't going to hurt the cable." It doesn't happen?

19 A Not with me it doesn't.

20 Q You just tell them to get the dust out anyway?

21 A I ask them to do it and they do it.

22 Q Or ask them to do it. I'm sorry.

O e

20 1 A I don't tell anybody to do anything.

2 BY MR. GALLO:

3 Q Have you ever asked them to get the dust out of the .

4 tray?

, . 5 A Yes, I have.

6 Q Is that right?

7 A Yes.

8 BY MR. HULIN:

-i .

9 Q And they do it? Do they complain?

10 A No, not really. "We'll get it." That's their 11 answer. They go do their job, I'll go back and I'll reinspect 12 it and say "Let's pull cable" if it's acceptable.

.i 13 BY MR. GALLO:

14 'Q Was it really dust or was it something more than 15 dust?

16 A It's more than dust. It's fabrication falling 17 into the trays.

18 Q And in your judgment it could possibly affect the 19 integrity of the c abl e?

20 A Yes, I do.

21 BY MR. HULIN:

22 Q A little change of subject here for a minute. Have 9

  • f e

. 21

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1 you ever attended a Quality First orientation program?

2 A I don't believe so.

Do you know what the Quality First program is?

3 Q ,

4 A Here on this site?

5 Q Yes. Could you explain it to me, what you think the 6 Quality First program is?

7 . A What I understand of it is as a guidance for all of 8 quality as a need of -- if we have any problems at all that 9 can't be dissolved with them, we are to go to Guidance First, 10 or Quality First, excuse me.

. 11 Q That sort of makes it sound like they are just -

12 another level of the supervision chain. Do you see them as 13 being just another step in the supervision chain, or is it 14 something outside that you could go to?

15 A How do you see it?

16 Q I'm not supposed to answer these questions. Okay.

17 Do you feel completely free to take any quality 18 concerns you have to Quality First or the NRC?

19 A Yes, I do.

20 Q Have you ever done it?

21 A No, I haven't, but I wouldn't be afraid to if I did.

22 Q What might keep you from doing it. You say you

- _ . . , - , . . . - - - - - _ ~ _ . - - -e

22 1 would be perfectly willing to do it. What set of 2 circumstances could keep you from going to them.

3 A What set would keep me from going? -

4 Q Yes. Let's say you had a concern about a cable out 5 there, there was a band radius problem, and you can't get any 6 satisfaction from your lead or your supervisor.

7 A. If"I can't get it resolved on site through my 8 company, I will ask my lead, my supervisor, I will take it on 9 through the chain of command here. If I can't get any 10 satisfaction at all, then it's time to go someplace else.

11 Q And there is very little that would -- is there '

12 anything that would keep you from doing it?

13 A No.

14 Q Do you think that Quality First and the NRC are 15 responsive to concerns that are brought to their attention?

16 A Yes, I do.

17 Q Have you ever taken anything to th'em?

18 A No.

19 Q Do you have any examples where they have responded 20 to a concern that was brought to them?

21 A The newspapers are full of them. They are 22 responding.

6

23 1 Q Is it the Quality First and the NRC that are 2 responding or is it the parties to the hearing that are

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3 responding? .

4 A The name I see the most in the papers is the NRC.

5 Q of any of the people you know well out at the site, 6 have they taken any concerns to Quality First or the NRC?

7 A I have no idea.

8 Q Do you think you will be kept anonymous and 9 confidential if you took a concern to Quality First?

10 A I don't know what the fear would be or why such

, 11 concern should be there to be anonymous. >

12 Q My first question is do you think you would remain 13 anonymous if you went to them?

14 A I doubt it.

15 Q The second question, then, is would this lack of 16 anonymity keep you from going to them?

17 A No.

18 Q You don't have any worries or fears about what would

[

19 happen to you if you went to them with quality concerns?

20 A No.

i l

21 Q Do you know of any inspectors that have received 22 what you might call bad treatment back on the site because o

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1 they did go to them?

2 A No.

3 Q Do you think you would be terminated if you took ,

4 concerns to them?

5 A No.

6 BY MR. GALLO: ,

7 Q Do you know of any inspectors who got to Quality B First?

9 A No; I don't.

10 BY MR. MARCUS:

11 Q Why do you think it would not be kept confidential? -

12 What is the basis for your saying that, if you went to the NRC 13 or Quality First?

14 'A Why do I think it would not be?

15 Q Yes. You indicated that you felt that it would not 16 be kept confidential.

17 A No. I didn't indicate that. I was asked the 18 question, if it would be kept confidential. I couldn't see 19 any reason why it should or it shouldn't.

20 BY DR. HULIN:

l 21 Q I asked you in a follow-up question, I said do you l 22 think it would be confidential, and you said no.

l l

l l

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25 1 A I'm sorry. I misunderstood the question.

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2 BY MR. MARCUS:

3 Q You think it would be kept confidential? -

4 A Yes; I do. I'm sorry. I misunderstood the 5 question.

- 6 BY MR. GALLO: -

9 7 Q Do you know Rick Martin?

8 A No, sir. I don't. I have heard his name but I do 9 not know him.

10 Q You know Greg Archambeault; right?

11 A Yes; I know Greg. '

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12 Q Do you know whether or not he went to Quality First 13 with a matter?

14 A I have no idea whether he went to Quality First or 15 not; none whatsoever.

16 Q Do you sit around with the other inspectors on the 17 second shift and' kind of swap stories and discuss what is 18 going L.4 at the job?

19 A I don't like the questioning there.

l

! 20 BY DR. HULIN:

21 Q People take breaks. People eat lunch. You can sit 22 around with them then.

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, 26 1 A Right.

2 Q During that time, when you are sitting around, do 3 you tell war stories to each other?

4 A I stay pretty much to myself, basically.

5 Q Let me summarize this section. Essentially, you 6 have not been to a Quality First program meeting. You know 7 what the program is.

8 A I've read it.

9 Q You feel like you would be perfectly free to take 10 any concerns that you have there or to the NRC?

11 A Yes. .

12 Q You think you would remain anonymous but it doesn't

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, 13 bother you if you weren't; is that correct?

s

14 A I think I would remain anonymous, but it wouldn't 15 both'er me. It wouldn't bother me. I don't think I would be

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16 anonymous. If I had a problem, why should it remain 17 anonymous.

18 BY MR. MARCUS:

19 Q Are you saying that you don't feel there is a need 20 for things that you would bring up to be kept confidential?

21 A Right. I don't see why anything should have to get 22 that far to get resolved to start with.

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1 BY MR. GALLO: -

2 Q Have"you ever had to take a question beyond Harry 3 Revels?

4 A No.

5 Q Have you taken questions to him?

6 A Yes; many times.

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7 Q Did you have occasions to take questions to him 8 because you couldn't get an answer from the lead?

9 A No. The lead just wasn't available at the time.

10 Even at times when I do ask my lead, which sometimes I ask r

11 other inspectors and they say, I don't know, let's ask Don. -

12 If Don doesn't come up with a clear clarification, he will 13 say, let me get with Harry. I do get an answer. I'm never 14 left'out in the cold.

15 BY DR. HULIN:

16 Q Have you ever been unable to perform a proper 17 inspection because of pressure from Production?

18 A No.

19 Q Have you ever felt rushed during an inspection?

20 A No. A lot of times, people do get in a hurry. Time 21 prevails. I'm going to take my time to do my inspection.

22 Q Have you ever approved or accepted an inspection e

4

16 .

, 28

, 1 that should not have been accepted?

2 A No.'

3 C Have you ever known of any inspections that were ,

4 accepted that shouldn't have been?

5 A No. ,

6 Q Have you ever walked through the plant and seen some 7 cable -- .

8 A In reference to your question, I sort of thought you 9 were going to ask that question, because of the way I 10 answered. The inspectors that I knew, no. The answer would 11 be no. Yes. I have seen things out there that have been -

12 accepted, but it's not right. When you run across them, you 13 write an ICR, an NCR, whatever the case may be to get it 4

14 resolved.

15 BY MR. GALLO:

16 Q Have you ever done that?

17 A Yes; I have.

18 Q Was it an NCR or ICR situation?

19 A NCR.

20 Q Can you describe the circumstance?

21 A Not right off hand.

22 Q What was the nature of the non-conforming condition?

O e

A .

29

~

1 A I just can't think of it right now.

2 Q When you noticed this, it was a non-conforming

.f

, 3 condition; right?

4 A Yes.

5 Q When you noticed this non-conforming condition, what

. 6- action did you take as soon as you saw it?

7 A I went to the front office to find out if there was

. 8 any paperwork turned in on these. I'm assuming it was 4

9 cables. Were there any other previous reports, should there 10 have been a hold tag here, is it just missing.

11 Q I take it there was no hold tag. ,

. 12 A No.

13 Q You went to the front office. Do you mean to the

14 vault?

15 A Yes. ~

16 Q What did you find out?

l 17 A I really don't recall a whole lot about it. I 18 really don't.

l 1

i l

19 Q Did you write the NCR yourself?

20 A Yes; I did.

21 Q Is it fair to assume there was no documentation on 22 the problem in the Vault, otherwise you wouldn't have written e

9

+

30 I the NCR7 2 A That's true.

3

Q Can you recall the circumstances under which you .

4 wrote the NCR7 5 A I can't even recall what day it was or what it was 6 about. I do know I wrote one. N 7 Q Did you seek the advice of anyone about writing it 8 before you wrote it?

9 A Not that I know of.

10 Q Did you go to your lead and say, look at this -

11 situation, what should I do? '

12 A

. I believe if I would have said, what should I do, it 13 would have probably meant through the course of the next step 14 of paper flow, not what should I do.

, 15 Q I guess all I an asking is whether you issued the 16 NCR on your own initiative --

17 A Yes.

18 Q -- or did you ask Revels whether you should do it or 19 not.

20 A No; my own.

21 BY DR. HULIN:

22 Q Do you ever have the feeling when you are on a pull 9

e e

O h _ _ _ . _ _ . _ _ _ _ _ _

. 31

~

1 or otherwise, that cost and schedule override quality?

.. 2 A No; I don't.

3 Q If you can walk through the plant and see examples .

4 of work that should not have been accepted, doesn't that give 5 you the impression.that schedule may be overriding quality?

6 A It does leave that impression. In my mind, I 7 believe quality should come first.

8 Q Do you think the management feels that way? Let's 9

9 start with your lead and your supervisor. Do you think they 10 feel that way? '

. 11 A Yes. .

t 12 Q Do you think management feels that way?

13 A They should.

14 MR. GALID: Which management are you referring to?

15 DR HULIN:- DeWald.

16 MR. BOX: Quality management; yes.

17 18 BY MR. GALLO:

19 Q You say they should. Do you think they do?

20 A For the most part; yes. I don't know what the hell 21 they do up there.

22 BY DR. HULIN:

O e

G

C - .

32 1 -Q Have they ever communicated anything to you that 2 made you think that production was more important than

, 3 quality? -

4 A No.

5 Q Have they been consistent in their communications to N6 "you that quality is more important than production?

I i "7 A No; they. haven't.

i 8 BY MR. MARCUS:

f' i

9 Q You don't h, ave that much interface with those 10 people. ,

11 A Not I don't. ~

12 Q You are not really saying that -- you don't want to

!s 13 give the impression that they are not communicating something l'

14 to you that they should.

( 13 A That's true.

I 16 BY MR. GALLO:

1 17 Q What causes you to believe that maybe they are not 18 as concerned in all aspects with quality?

1:

19 A I don't have an answer for that.

20 Q Just a gut feeling you have?

21 A It could very well be. Like I said a while ago, I 22 don't knov what they do up there. I deal with the people e

e S

33 1 closest to me.

2 Q Do y~ou feel that they ought to involve themselves 3 more in what the second shift does, meaning Simile, DeWald?

4 A I think they should.

5 Q How about Seltmann?

6 A I believe he should. I don't even know the guy, but 7 I believe he should. -

8 Q You think they ought to come around and see what you 9 guys are doing?

10 A That would be fine with me.

I 11 Q I take it they don't. .

12 A Simile, he has been around. He comes around from 13 time to time.

t 14 Q Since you have been working here the last five 15 months?

16 A Yes.

17 Q DeWald doesn't come?

18 A It's kind of hard for me to say yes, if I hadn't 19 been here.

20 Q I take it DeWald doesn't come to the second shift?

21 A I haven't seen him.

22 Q The same with Seltmann?

o G

r . i

.. l

. 34 1 A I don't know him.

2 Q Does this lack of appearance perhaps cause an 3 irritation, and cause you to say that you don't know whether .

4 they have quality concerns or not, you don't ever see them?

1 5 A You sort of answered your own question.

6 Q I just framed it. What do you think?

7 A I don't know what to think of it.

4 8 Q You just have this unexplainable feeling that maybe t

,' 9 they are not totally concerned with safety concerns?

10 A I'm sure they are very much concerned. If they are.

11 not, they shouldn't be there. -

+

12 BY DR. NULIN:

13 Q Have you ever been instructed or discouraged from 14 documenting a non-conforming condition on the proper paperwork 15 forms?

i 16 A No.

17 Q Do you do that very often?

18 A No; not very often.

19 Q I guess you are telling me that you don't see enough 20 violations of safety regulations.

1 l

21 A I don't; no.

1 22 Q You have never been instructed to, well, don't write 4

8 e

4

35' 1 that up, everybody knows about it?

2 A No.

3 Q Have you ever been instructed to write a memo rather .

4 than file an NCR or an ICR?

5 A No.

6 Q Are the inspection procedures sufficiently clear to 7 you for you to perform your job?  ;

=

8 A Yes; they are.

9 Q Do you know the difference between acceptable dust 10 and debris in a tray? -

11 A I believe I would; yes. *

\

12 Q What would be acceptable?

13 A Dust is dust. If you had debris with sharp edges, I 14 woul'd call that unacceptable.

15 Q How about protectors on the trays?

16 A Cable protectors.

17 Q Again,'the procedures are clear on that, when they 18 are to be there and when they are not to be there? Are they 19 supposed to be on all trays?

20 A Any time that cable goes over the edge.

21 Q How about 4.8.8 and 4.3.8 procedures, are you 22 sufficiently clear on where they apply and where they don't O

e

. - - . _ - . -- - . _ ,_ _. _ _ . - _ _ _ . ~._

36 1 apply?

1 2 A Yes, si'. r

~

3 Q Can you tell me the difference between the two sets .'

4 of procedures?

5 A Yes, sir. One is for the installation and one is 6 for the inspection.

7 Q 4.8.8 is for the inspection?

8 A Yes, sir.

9 Q One of them outlines the procedures that you are a

10 supposed to go through, and the other one outlines the 11 procedures that the craft crews are supposed to go through?

  • 12 A Yes.

l'"r 13 Q 4.8.8 governs. Suppose you see a crew violating 4

l 14 4.3.8, what do you do?

L 15 A First of all, I would stop and ask. An example i

l 16 would be like taking a cable off a reel, you never have a back 17 real. The cable comes over the top. I have seen guys pull 18 the cable and get ahead and it would bend back. Before it t

19 would go beyond that, I would stop the cable and say, 20 gentlemen, you are going to have a reverse bend here and 21 according to your procedures, you are in violation if it does, 22 and when it does, you will have to be written up. We didn't 9

e 6

r- .,,_ ,mm.--n.w._,_m-r-..%.~ . ,.,,mem__w-,,,,,,m..-___,-,_., ,,,..-m,...,,m,,m,,_--_--w___- - - - - - . - - - _

. 37 We didn't know 1 know that. I hear this time and time again.

2 that. As far as I'm concerned, I believe that the craft 3 should have more training on their procedures. I really do. .

. 4 I believe that.

5 BY MR. GALLO:

6 Q From the circumstance you described, when the cable .

7 begins to wind back on the reel, you just stop the unrealing i

8 at that point and point it out?

9 A Yes. I have done that beforet yes.

10 Q They correct it?

11 1 A Rather than ha.ve the cable go ahead and go through

  • 12 the band, why not. I don't see anything wrong with that.

13 Q I am not suggesting there is.

I 14 The installation procedure indicates that -- can you 15 tell me what the installation procedure says on that point?

l l

16 Just your general understanding.

17 A I believe it says that should the cable be in a l

[ 18 reverse band, that it shall be written up as the footage 19 marker, to where the bend was, the cable can be presumed to be 20 pulled, notification of the Engineering Department, so they 21 can resolve how much was bent, as in terms of the radii of the 22 cable and the footage marker and let Engineering resolve it.

9 O

O

-~.

38 ,

1 Q This is an instruction to the foreman; right?

f .

2 A Right.

3 Q It is the foreman that is supposed to do the writing .

4 4 up of the problem if it occurs, under 4.3.8?

f' 5 A We can write it up, if that thing should reverse 1

6 band. We would write it up. They would be in violation.

,, 7 That is the craft's procedure.

8 Q They work against that procedures right?

,6 j 9 A Yes. I don't think they have enough training in f 10 that procedure.

l 11 Q I understand. In the circumstance you described, in' 12 this installation procedure, if it happens , nobody saw it l

13 ahead of time, it just happened, isn't that an instruction, at

! 14 least in the first instance, to the foreman, to write it up 15 and get advice from Engineering?

16 A It should be; yes.

17 Q That's who is supposed to adsinister the procedure; 18 right?

19 A That's true.

20 & If he doesn't do it and misses it, then you take it 21 up?

22 A That's true.

9 6

-..----ny,,,--, m_.,.,,..w,- - - . . . ,

. 39 1 Q You wouldn't hesitate to write it up if you had to?

, 2 A No; I wouldn't.

3 Q Have you ever done it?

2 4 A No.

5 Q Do you normally -- ,

6 A That is a good prime example to start with.

7 Q A prine example of? .

8 A What we were discussing, the situation where it

. 9 would happen.

10 BY DR. HULIN:

11 Q Is there any confusion or has there been any since .

i 12 you have been here about 4.3.8 and 4.8.8, about what you were 13 supposed to do in terms of your job?

14 A No.

, 15 BY MR. GALLO:

16 Q Did you haar about the circumstance involving Bob 17 Tuite and Greg Archambeault, when they were unrealing cable

( 18 from the real, footage markers were inconsistent and in error, 1

19 they were marked improperly? .

l 20 A Yes; I have heard about that. That was brought up 1

21 in one of our meetings.

22 Q What was your understanding as to what Tuite told O

4

, 40 1 Archambeault at thht instance?

t 2 A I don't recall.

. 3 Q Did you hear that Tuite said something to the effect .

4 that we work against 4.8.8 and not 4.3.87 5 A I don't recall.

6 Q You said that was the subject of one of your

7 meetings?

, 8 A Yes; it was.

$ 9 Q How was the subject discussed?

10 A It was brought to our attention as this is what has.

11 happened and in concurrence to, how can we refrain from this

  • 12 happening. That is the way it was brought up.

I 13 Q What did they explain was the nature of the 14 problem? Who conducted the meeting?

15 A Harry Revels.

16 Q What did he explain was the problem?

17 A I really don't have total recall on the meeting 18 itself. I an aware it was in one of our meetings.

19 BY DR. HULIN:

20 Q What do you think you should do if you saw that 21 happening on a pull you were inspecting?

22 A That your footage markers became the same? You are m

9 e iumsu ummum um is - i

, 41 1 going to have to stop the pull at some point and get 2 verification from someone as to the cable itself. You are

.. 3 going to have to start with some kind of footage marker ,

4 someplace or put it on a meter to get your foo'tage. You can't 5 juqt go blind.

6 Q Would it be acceptable to put it on a meter?

7 A I believe it would; yes. Meters don't lie.

8 BY MR. GALLO:

9 Q Getting back to this meeting, you don't recall 10 whether or not the subject of the meeting was to explain 11 inspectors were supposed to hold the craft to their own ,

j 12 installation procedures? -

13 A No; I don't.

14 Q Tuite had said essentially you work against 4.8.8 j 15 and we don't work against the installation procedures, so 16 don't worry about this footage marker problem?

17 A I have no idea what he said.

l 18 Q You don't remember this subject being discussed at l

19 the meeting?

20 A I do remember the situation of the cable itself as 21 to the footage marker. Who was involved in it, I have no 22 idea.

e e

.+--,------,,.yy. -

_.. , - - - - - y,%- mm m, , v-. ,m--r-e---,,y,m--...---- , - - - + , - . . . - . .

. 42 i

1 Q Do you remember approximately when that meeting was?

2 A No,' sir; I don't.

. 3 Q since you were certified on this job, have you .

4 always held the view that essentially if craft violated its 5 procedures, you would have to write them up? -

6 A In violation; yes.

7 Q Was there ever any doubt in your mind about that 8 while you were on this job?

9 A Why should there be doubt?

10 Q I'm asking that question.

11 A No.

  • 12 Q It was clear to you?

13 A It's clear to me, if I see something wrong; yes.

14 ~Q Where did you get that understanding?

15 A From my procedures.

16 Q From your inspection procedures?

17 A Yes, sir.

18 Q What in your inspection procedures would tell you 19 this? I don't want you to quote me chapter and verse, but if 20 you can, can you generally tell me what there is in your 21 procedures?

22 A It is either a non-conforming item, you write an 9

O e

b 9

43 1 NCR, or an ICR. If it doesn't conform, you write it up, no 2 matter what. *You have to get the paperwork flowing in order j; 3 to get something repaired.

4 Q It doesn't make any difference whether it doesn't l

5 conform --

l 6 A If you don't write it down, nobody is going to know i

7 about it. . .

1 8 Q Right. In your view, it doesn't make any difference

9 whether it is the inspection procedure or the installation 10 procedure?

11 A It doesn't to met no. -

12 Q I guess that is my point. Some other inspectors 1

13 have not been able to make that distinction. They view that 14 you treat one differently than the other.

l 15 A I don't. I work to these procedures. That is the i

16 two I carry around with me all night. That's what I go by.

17 BY DR. NULIN:

18 Q How do you handle quality concerns, either safety 19 related or non-safety related, that are not directly related 1 20 to what you are doing, but you may see when you are doing your 21 job?

22 A Do you have an example? I l

~

l Q You are inspecting a cable pull and you see some 2 cables that l'ook like they are not properly trained, they have 3 been up there for six months to a year, but they look like ,

4 they are violating the bend radius.

t 5 A If it is a violation of the band radius, I will 6 write it up. If it is not properly trained, I will ask the 7 crew that I am with if they will train that properly, if at,

  • 8 all possible. I ask the crew. I don't go running off to 9 foremen here, foremen there. I will ask the guys.

10 As an example, coming down on the riser, and the 11 riser would come down, like 45 in, and come back down again. .

12 It was in free air during this ber.d. Even though the cable is 13 in its grip, it is still in free air here. We have asked the i

14 guys if they would tie wrap that, to keep the pressure off the 15 cables as they go over that band. That's happened.

16 BY MR. GALLO:

17 Q If they didn't do that, what would you have to do at 18 that point?

19 A I would go ask their foreman, let him be the first 20 to know, if I couldn't get anything resolved with them.

21 Q What if he didn't help you either?

22 A Then I would go to my lead, say what can we do to 9

l G

~

45 1 get this done, I have talked to the men, I hav4 talked to 2 their foreman", what would be the step to go to. That would be 3 sy question.

4 Q Would you write en NCR in that circumstance?

., 5 A No; an ICR.

6 Q At what point would you just do that, seek asking

7. advice? I should say stop asking advice.

S A After the men, the foreman, and my lead, if he

.: 9 didn't show any concern.

l '.

/r  ; 10 Q You would ask your lead to try to prevail upon the -

11 foreman to do something? .

12- A I don't know what my lead would do. I am not in his

13 position. I don't know if he would go to the foreman or 14 someplace else. I have no idea.

15 Q You would give him an opportunity to do something?

16 A Sure. Yes; I would.

17 BY DR. HULIN:

18 Q Has the procedure for handling these sort of 19 unrelated safety or quality concerns ever been explained to 20 you?

21 A The procedure?

22 Q What do you do when you are supervising or e

i I

. 46 1 inspecting a cable pull and you see something like what we 2 have just been talking about. Have they ever explained the

3 procedure that you should go through when you see that? .

,, 4 A No.

l 5 Q You just work out a procedure, that you try to get 6 the men to do it and then you try to get the foreman --

7 A. I'would try to work it out very comfortably; yes.

  • l

,' 8 Q Do you know how other people handle it?

!i 9 A I have no idea. I would like to know. I think that 10 would be something that in the interface on-site that could

11 use more training, something that could be brought out. -

12 BY MR. GALIO:

13 Q Do you need training or do you really need advice as 14 to how to handle the situation?

15 A I would call it training, not advice. I wouldn't

, 16 call it advice at all.

17 Q What would the training encompass? First of all, 18 who would you train?

19 A All the inspectors, to be aware of the situations.

20 You are speaking of advice. Sure, you are going to hear 21 advice. You are going to hear that all the way around the 22 room once you sit down and talk.

e G

.- . . . _ __ - ~ _ . . -

, 47 l 1 Q It is my perception that the inspectors generally 2 are pretty go'od at observing these non-conforming or problem

/ 3 conditions in areas that they are not pulling cable in. It is ,

4 my perception that the problem they have, if they have any , is 5 they don't know what to do at that point.

6 A Whose perception?

7 Q Mine. '

8 A You are speaking for the supervision?

f'. 9 Q No. I am speaking from my experience in talking to t

10 a number of inspectors, including yourself.

11 A The inspectors. When you reach that point, what -

12 else can you do. '

13 Q My point is that the question asked here was you 14 need some assistance in trying to deal with that circumstance, 15 because there seems to be some uncertainty as to what i 16 inspectors should do. It seems to me the uncertainty is they 17 don't know whether to write it up or get somebody to fix it or 18 just what to do.

1 19 Would you agree with that characterization?

20 A Yes; I would.

21 Q Do you still feel training would be necessary?

22 A Yes; I do.

9 1

. 48 a .

1 Q Train them to be alert to look for these conditions?

2 A Awareness; yes.

3 Q Do you have a feeling that not all inspectors are as 4 alert as they should be?

5 A No; I don't. I feel that is a qualification, a lack 6 of communication. I think that would be a good term.

, 7 Q In other words, the uncertainty that exists between 8 supervision and the inspectors as to what they should do in l 9 those circumstances? '

10 A Yes.

11 Q Do you think training would take care of that? ,

12 A I think it would certainly bring out a lot of --

13 Q You would have to train the supervisors; wouldn't ll 14 you?.

.l 15 A Well, if they need it, they should be trained. I do 16 know inspectors ask questions and somehow they always come up i

17 with answers.

18 Q Isn't it your perception that people observe things, 19 they just don't know whether they should write NCR's or ICR's 20 or tell supervision about the problem first?

21 A I don't know whether or not they don't know the 22 difference.

o O

. 49 1 Q How about in your case?

2 A I believe I know the difference.

t 3 Q You indicated that you wrote an NCR, you saw a .

4 non-conforming condition and wrote the NCR.

5 A Yes.

6 Q You did it on your own initia,tive. .

7 A Yes; I did.

8 Q In the ICR situation, you seemed to be more 9 lenient. Why is that?

10 A It's not being more lenient. It's the situation.

11 Q What is there about the situation that would cause 12 you to treat it differently than the NCR situation?

13 A An ICR, like the band radii on a cable,.for example, 14 against the gouge in a cable, one would be an ICR and an NCR.

15 Q I understand that. I don't think you and I are 16 communicating.

17 A That's what we are talking about here, lack of 18 communication.

19 Q What I am trying to point out is you are not the 20 only one, there are a number of other inspectors I have talked 21 to. When an ICR situation presents itself on a condition that 22 is not connected with the pull they are on, but during the e

4

- - --v .. mv- - ---_, , , . . . , _ _ _ - - - - -

. , - - . . . ~ , , __t 5 .___ _ -_

4

. 50 e

1 course of the pull, they notice an ICR situation, untrayed 2 cables. Instead of writing the ICR, they try to get the craft 3 to fix it, or they may not try that, they may go to their 4 lead, or they may go to the supervisor and ask the question, j 5 what should I do.

6 ,

A They could very well do that.

7 Q In the case you described, you would first try to 8 get the crew to do it. You would try to get the foreman to do -

9 it, if the crew wouldn't do it. That is, re-train the cable.

10 If the foreman wouldn't agree, then you would go to the lead 11 and tell him about it. If he sat on his hands and did -

i 12 nothing, you would write the ICR; right?

? 13 A Right. ,

14 'Q Why do all that? Why not just write the ICR to 15 start with? That's what I'm driving at.

16 A It could be done. I believe I could get it done the very first time, without going to the foreman.

17 All I have to 18 do is ask. Not putting anybody out of anything.

19 Q I guess I can understand going to the foreman. I 20 guess I don't understand going to the lead.

21 A You asked me what the next step would be. That's 22 the way I looked at it. I couldn't see getting past the e

e

!. 51 t

l 1 foreman. I was projecting. -

l 2 Q When'you answered that question, I assumed you were 3 serious in going to the lead. The other alternative would '

l 4 have been if the foreman turned you down, you would have 5 written an ICR. I am trying to find out what you would do.

6 I'm not able to penetrate that.

7 I am not talking about abstract, hypothetical 8 situations. I am talking about what you would do. If you 9 told me you would have written the ICR, we wouldn't have had 10 this ten minute conversation.

11 A I enjoyed it. .

12 Q What would you do?

13 A First of all, I would ask the men, which I am 14 certain they would do it. Therefore --

l 15 Q If they didn't do it,'you would go to the foreman?

16 A Yes.

[

17 Q If he wouldn't do anything, what would you do at 18 that point?

l 19 A I would most likely write it up. I'm sorry.

l 20 Q There's nothing to be sorry about.

l 21 A I'm sure I have wasted time here.

22 BY DR. KULIN:

l

i -

52 1 Q You seem to have a motivation -- I take it you would 2 rather get the situation corrected without all the paperwork, 3 by going to the men and then to the foreman, rather than 4 writing up an ICR first, which you could do.

5 A Yes. .

'6 BY MR. GALLO:

7 Q Are you aware of the circumstance when Greg 4

8 Archambeault went up into the upper cable spreading room and 9 noticed during the course of a pull that he was working on, 10 that a bunch of cables were laying loose and out of their 11 trays and had band radii problems, and Kellum grip cuts in .

j 12 them, things like that?

13 A No; I'm not.

14 'Q You are not aware of that?

15 A No. In fact, I don't know a whole lot about this 16 case. I really don't.

17 Q The shop talk wasn't -- I understand it was fairly

, 18 well known that this problem in the upper cable spreading room 19 existed for some time.

l 20 A Not to my knowledge.

21 Q Have you ever been up in the upper cable spreading 22 room yourself?

l l

4

, , . . . . . . _ . - --,-,,:-.-y_,----,y- - - - , , ,- -www ,------ -y- -- - . , - - - - - - -

t 53

. 1 A Yes; I have.

2 Q In the April or May timeframe, can you recall?

3 A The latter part of May; first of June. ,

4 Q Do you recall seeing this situation where these 5 cables were out of the tray?

6 A I have no recall of that at all.

', 7 Do you know who Diederich is?

Q 4 8 A Yes; Mark Diederich.

9 Q Have you ever had occasion to talk to him, just ask 10 him questions about the work?

11 A I've talked with Mark, yes; several times. -

+

12 Q Asked him questions about the work?

13 A Not really; no.

14 ~Q Just casual conversations?

l, -

15 A Yes.

l 16 Q Are you aware of a separation conflict problem that 17 Archambeault flagged down in the remote shutdown panel area?

18 A No, I'm not.

19 Q Do you recall about a week ago or ten days ago, Greg 20 discussing with the inspectors the interpretation of the l 21 separation critarion involving the one-inch clearance?

22 A I recall Greg speaking to some of the inspectors.

9

. . - . _ _ _ _ _ _ - . _ , . _ _ . . _ . . _ _ _ _ _ _ _ _ - _ ~ . __ _ .- .. . __ _ _ _ _ _ ._

t ,

~

. 54

. 1 He didn't talk to me personally, no.

. 2 Q You weren't one of them?

t 3 A No. .

4 Q Let me ask you a question about the application of 5 the separation criterion, the one-inch criterion. If you have 6 an open tray with safety cables in it and you hdve a tray of 1

7 nonsafety-related cables passing overhead, and ' cables are 8 coming out of the end of the nonsafety-related tray and coming l downward towards the safety tray and passing overhead over the 9

10 top of the safety tray and then going down the side to a piece 11 of equipment, and as the cable comes out of the upper tray and- '

12 kind of swoops over the top of the lower tray which has the i

13 safety cables in it, and there is no cover on this lower tray, 14 what is the separation criteria that applies in that 15 circumstance?

16 A Well, you have a 12-inch free air, but he is also in 17 violation. If that cable went the other way, it would be free 18 air, but as it's crossing over cable, it's within violation.

19 Q What criterion applies?

I 20 A The one-inch.

21 Q I'm sorry?

22 A The one-inch.

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^

! , 55 1 Q The one-inch applies?

2 A Yes.

3 Q Do I understand the cable could swoop down as close .

4 as one inch to the cables in the open tray?

5 A No. You have 12 inch free air.

6 Q They have to be at least 12 inches away?

7 A Right.

8 Q Are you aware that Archambeault passed out a f

9 questionnaire to some of the inspectors? I'm going to ask you 10 if you filled one out, but you. don't have to answer this 11 question. I will give you some prior warning. If you prefer -

1 12 not to answer it, you can just say "I don't want to answer the 13 question."

i 14 Did you fill one out?

15 A Yes, I did.

16 Would you mind if I dig it out and ask you to Q

17 identify it?

18 A Sure.

19 Q There are seven here. Just find yours.

20 A Mine's not here. Yes, it is.

21 Q This is yours?

22 A Yes, sir.

4 o

J

, 56 s

1 Q I want to discuss with these two fellows what 2 questions I should ask or shouldn't ask. Can you just step 3 out for a moment? .

4 A Sure.

5 (Recess.]

x. 6 MR. GALLO: Let's go back on the record.

t -

7 BY MR. GAILO:

8 Q Have you ever experienced any problems getting help 9 when you needed it,on pulls?

10 A No.

11 Q Have you had occasion to ask for help? "

- 12 A Yes, I have.

4 13 Q Which lead were you working with at the time?

14 A Which lead?

15 Q Well, let me ask the question differently. Did you 16 ask Schirmer for help from time to time?

17 A No. Usually I just go back to the office and ask 18 for another inspector.

19 Q I see. You don't have to consult first with your 20 lead on the question?

21 A No.

22 Q You just do it.

e h

E 57 1 A I just do it.

2 Q How sany --

e 3 A I have had a time, an occasion where everybody would .

4 be out on a pull, and when I did contact my lead, he would ask 5 me if anyone is available, and I would say no, and he would 6 say, well, I will be right out, and he would come out and 7 assist me. ,

8 Q The lead went out.

9 9 A The lead, yes.

10 Q How many assistants have you had on a pull? More 11 than one? .

12 A Just one.

13 Q Do you know that there was an NCR inspector that 14 cama'around to ask questions by the name of Westberg? Do you 15 know who he is?

16 A No, sir, I don't.

17 Q I take it he didn't ask you any questions. <

18 A I guess not. I don't recall his name.

19 MR. GALLO: That's all the questions I have.

20 MR. MARCUS
No questions.

l 21 MR. GALLO: I want to thank you for your time- and 22 effort. If you have any other questions or comments you would e

e b

s, o - 58 1 like to make or something that you forgot to mention, I think

" ~

, 2 that --

3 DR.'HULIN: You can get in touch with me, and my -

4 home phone is on the back. You can call collect. Or you can 5 call George Marcus.

6 MR. MARCUS: I'm on 2633, if you want to note it i

7 down there. I will be right on the site.

8 DR. HULIN: Quite often you will get back and think, I

, 9 Oh, I wish I had told them that, you know, whatever that is.

10 MR. BOX: I just hope that I have helped in 11 answering your questions. .

. 12 DR. HULIN: It helps. We appreciate your

, 13 cooperation very much.

14 MR. BOX: It's my pleasure.

t 15 (Whereupon, at 7:33 p.m. the interview was concluded.]

6 16 17 18 .

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