ML20214R603
| ML20214R603 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 12/06/1985 |
| From: | Puckett W COMMONWEALTH EDISON CO. |
| To: | |
| References | |
| CON-#386-877 OL, TRAM-851206, NUDOCS 8609290222 | |
| Download: ML20214R603 (173) | |
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OR GINAL w 1 1 UNITED STATES OF At1 ERICA '86 SEP 26 P4 :49 2 NUCLEAR REGULATORY COrlf1ISETph y n, z_,
DOCHETIm,G,...'.
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'l 3 BEFORE THE ATOMIC SAFETY & LICENSING BOARD '
4 5 - - - - - - - - - - - - - - - - - -x 6 In the matter of: :
7 COMMONWEALTH EDISON COf1PANY : Docke t No . 50-456 8 [Braidwood Nuclear Power Station, : 50-457 9 Units 1 and 2] :
10 - - - - - - - - - - - - - - - - - -x bi
/ 1 11 Isham, Lincoln & Beale V 12 Three First National Plaza 13 Sist Floor 14 Ch ic ag o , Illinois 15 Friday, December 6, 1985 16 !
17 Deposition of: WORLEY PUCKETT, 18 called for examination by counsel for the Licensee, pursuant 19 to no t ic e , taken before Ann Riley, a Notary Public 20 --------------------------------------------------------------
21 ANN RILEY & ASSOC IATE S , LT D.
22 1625 I Street, N.W. 293-3950 Washington, D.C.
D' 8609290222 860206 6 PDR ADOCK 0500 l
l 2
- 1 in and for the District of Columbia, when were present on 2 behalf of the respective parties
3
, 4 APPEARANCES:
1
! 5 For the Licensee Commonwealth Edison Company:
1 6 MICHAE L I. MILLER, ESO.
7 REBECCA LAUER, ESO.
I 8 ELENA KEZELIS 1
9 Isham, Lincoln & Beale f
10 Three First National Plaza 11 Ch ic ag o , Illinois 60602
@ 12 13 For the NRC Staff:
! 14 GREGORY BERRY, ESO.
. 15 United States Nuclear Regulatory Commission l 16 Office of the Executive Legal Direc tor I
i 17 Washington, D.C. 20555 18 19 For the Intervonor BPI, et al.:
20 ROBERT GUILD, ESQ.
i 21 109 North
Dearborn,
Suite 1300 22 Ch ic ag o , Illinois 60602
- O 1
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!O 1 Also Present:
1 1
2 LEONARD McGREGOR, NRC l
l 3 RAN DALL KURTZ, Sargent & Lundy l
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CONTENTS I
2 Witness: Examination by: Page:
3 WORLEY O. PUCKEIT M . Miller 7, 39 4 Mr. Berry (Voir Dire) 37 i
5 l o'
EXHIBITS i i
7 Exhibit No. Description Page: !
8 Puckett Exhibit No. 1 Subpoena issued by the Nuclear i j
Pegulatory Comnission 7 l'
9 Puckett Exhibit Ib. 2 Document that is undated, firts ;
three pages are handwritten, next '
10 page is typed, and remaining seven pages are handwritten 21 11 O 12 Puckett Exhibit No. 3 Document entitled " Structural Welding Code", second page is I
{
identified as AWSDl.1-75 46 !
L3 Puckett Exhibit No. 4 Page 9 of Inspection Report 85-09 53 l4 Puckett Exhibit Nc. 5 Three-page document entitled "Pesume, Worley L. Puckett" 57 15 Puckett Exhibit No. 6 Memorandum from Mr. DeWald to 16 Mr. Mennecke and Mr. Quakie, dated May 12, 1984 67 17 Puckett Exnibit No. 7 Handwritten memorandum from Mr. Puckett to Mr. DeWald, 18 dated August 9, 1984 80 19 Puckett Exhibit No. 8 " Procedure Tracking Sheet, Procedure No. 4.3.3, Pcvision 20 D", dated August 29, 1984 83 21 Puckett Exhibit No. 9 Menorandum from Mr. Puckett to Mr. DeWald, dated August 10, 1984 99 22 Puckett Exhibit No. 10 Menorandum to Mr. DeWald from Mr. Puckett dated August 13, 1984 104 J
f m-,---
I O e 1 C O N T E N T S.[ continued]
2 Exhibit No. Description Page:
3 Puckett Exhibit No. 11 T m page memorandum from Mr. DeWald to Mr. Iblan, dated August 15, 1984 4 showing a copy to Mr. Puckett 106 5
Puckett Exhibit No. 12 Four page document identified as "L. K. Ocastock NCR 3099" dated August 17, 1984 107 6
Puckett Exhibit No. 13 n:morandum from Mr. Iblan to 7 LKC Supervision dated August 17, 1984 109 8 Puckett Exhibit No. 14 Minutes of a meeting which took place on August 22, 1984 signed by Mr. DeWald 112 Puckett Exhibit No. 15 Speed letter from Mr. Gieseker to Mr. Bolan, dated August 22, 1984 119 Puckett Exhibit No. 16 Meno from Mr. Puckett to Mr. DeWald 11 dated August 22, 1984 122 12 Puckett Exhibit No. 17 " Procedure Tracking Sheet" for Procedure No. 4.3.3, Bevision F, dated December 5,1984 136 13 Puckett Exhibit No. 18 Memo from Mr. Puckett to Mr. DeWald 14 dated August 24, 1984 144 15 Puckett Exhibit No. 19 Memo frcm Mr. Puckett to Mr. Dewald dated August 24, 1984 with return 16 message from Mr. DeWald 144 17 Puckett Exhibit No. 20 Undated five-page document with six columns: name, position, c h ss, M ass n h , s # ,
18 and discrepancy 160 19 Puckett Exhibit No. 21 Four-page document. First page bearing signature, George G. Nometh, 20 dated July 6, 1984 166 21 22 O
1 PROCEE DI NGS 2
[10: 00 A.M. }
3 MR. MILLER:
This is the deposition of Mr. Worley 4 0.
Puckett, taken at this time and place, pursuant to a 5
subpoena and agreement of the parties and the witness.
6 Mr. Puckett, my name is Mike Miller. I am one of 7
the attorneys for Commonwealth Edison in its operating 8
license proc eed ing .
I am going to be asking you a series of 9
questions about your employment at the Braidwood Station, and 10 if for any reason you do not understand my questions, please 11 tell me and I will re phra se it.
O 12 If you want to take a break at any point in time, just let me know, and we will do that, 13 too.
14 It's my plan to go to about 1:00 p.m. this 15 afternoon, and then take a lunch break and resume a f ter about 16 an hour.
17 Whereupon, 18 WORLE Y 0. PUCKETT, 19 having been called for examination by Applicant, and having 20 been first duly sworn, was examined and testified as follows:
21 9
22 O
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1 EXAMINATION 2 BY MR. MIL LE R :
3 0 Mr. Puckett, would you state your name for the 4 record, please?
5 A Worley O. Puckett.
6 0 What is your present address?
7 A 3672 Spring Grove Road, Bethel, Ohio 45106, j i 8 0 Mr. Puckett, I am going to show you a subpoena 9 issued by the Nuclear Regulatory Commission, which I would I
10 like marked as Puckett De po s i t ion Exhibit No. I for l l
l l
11 identification. I 12 [Puckett Deposition Exhibit No. 1 l 13 was marked for iden ti f ic at ion. ]
14 BY MR. MILLER: l 15 0 I would ask you if you received a copy of that 16 s ub po en a ? It must have been about a month aqo. ,
l 17 A Yes; I d id .
)
18 0 The second page of the subpoena asks that you bring 19 with you to this deposition certain documents, if you had them i
20 in your possession. Do you have any such documents?
21 A Yes, j l
22 0 May I see them, please? l
O) i V e 8
1 [ Witness complying.]
2 MR. MILLER: I would like the record to reflect that 3 Mr. Puckett has handed me the following documents; a j 4 transcript of U.S. Department of Labor proceedings, in the 5 matter of Worley O. Puckett, Case No. 85 ERA-4; a memorandum 6 from Mr. DeWald to the File, dated September 17, 1984; a 7 personnel instruct ion log , one sheet dated July 10, 1934, a 8 second one also dated July 10, 1984, with a number of 9 attachments; a document handwritten entitled " Practical 10 Examination," which has a date of examination of July 19, 11 1984 A
U 12 A letter from Comstock Engineering to Mr. Puckett 13 dated May 29, 1984; a personnel instruction log dated June 14, i
14 1984; a similar document dated June 15, 1984; and another 15 dated June 25, 1984; a typed document entitled "Weldments 16 Visual Inspection Test," dated June 27, 1984; a personnel 17 instruction log dated June 29, 1984; a test for QA 18 comprehension dated June 29, 1984; a test cover sheet relating i
19 to a practical examination, which is dated July 3, 1984; what l l
l 20 appears to be the results of a practical examination with t h '-
l 21 signature of George G. Nemeth, dated July 6, 1984; a series at 22 documents, the cover sheet of which is Comstock NCR 3099, and O
I there are a number of attachments.
2 A document which is entitled " A Familiarization 3 Log," date started 5/29/84; personnel instruction log dated 4 June 1, 1984; another dated June 5, 1984, another dated June 5 6, 1984; a vision aculty test form for Mr. Puckett; a 6 personnel instruction log dated June 11, 1984; another dated 7 June 13, 1984; a handwritten memorandum from Mr. Dominique to 8 Mr. DeWald dated August 25, 1984; a memorandum from 9 Mr. Simmely to Mr. DeWald dated September 13, 1984; a copy of ,
10 an NRC Inspection Report dated August 7, 1984; a memorandum 11 from Mr. Puckett to Mr. Saklac dated August 17, 1984;
' O 12 memorandum f rom Mr. Puckett to M r . Saklac dated April 15, 13 1984, and I believe that should be August, 1984.
14 Is that r ig ht , sir?
15 THE WITNESS: Yes.
16 MR. MILLER: A memorandum f rom Mr. Puckett to 17 Mr. DeWald dated August 22, 1984; a memorandum -- a speedy 18 memo f orm , from Mr. Puckett to Mr. DeWald dated August 24, 19 1984; another handwritten memorandum dated August 10, 1984; 20 another memorandum dated August 13, 1984, from Mr. Puckett to
, 21 Mr. DeWald; a memorandum from F. Rolan to LKC Supervision 22 dated August 17, 1984; a memorandum f rom Mr. DeWald to O
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1 Mr. Rolan dated August 15, 1984; minutes of a meeting held 2 August 27, 1984 signed by Mr. DeWald .
3 Another memo dated August 27, 1984 signed by 4 Mr. DeWald and Mr. Seese ; a letter from Glenn Smith to 5 Administrative Law Judge McKenna, which does not appear to be 6 dated. A personnel instruction log dated July 9, 1984; a work 7 clearance form dated May 29, 1984 8 MR. BERRY: Excuse me, Mike. Could you slow down a 9 little bit?
10 MR. MILLER: I just want to record these for the 11 record, and then I am going to ask to get copies of all of 12 them. I will be happy to make copies for however many people 13 want them.
14 What appears to be a practical examination with 15 Mr. Pucke tt's name da ted August 22, 1984; a document entitled 16 "W.O. Puckett History," which appears to be undated; a letter 17 from Mr. Guild to Lee Hornberger, dated July 11, 1985, to 18 which is attached a number of documents, the first of which is 19 the Complainan t's Pre-Hearing exchange in Mr. Pucke t t's 20 Department of Labor proceeding; a resume of Mr. Puckett; an 21 employee performance appraisal and development plan for the 22 period August 1, 1979 to July 1, 1980 O
1 Am I correct, this is Kaiser Engineering?
2 THE WITNESS: Yes.
3 PtR. MILLER: By Kaiser Engineering; a similar 4 employee performance appraisal and development plan for the 5 period July 1, 1980 to Play 1, 1981; there are then five 6 documents from the tietals Engineering Institute, which appear 7 to be course naterials that Mr. Puckett took; a performance 8 evaluation for the period of April 15, 1982 to April 1, 1983 9 for Mr. Puckett; another Metals Engineering Institute -- lot 10 me back up.
i l 11 tietals Engineering Institute course material 12 documents; a certificate of completion by the American Helding 13 Society and the American Society of Metals given to 14 Mr. Puckett; another copy of the letter f rom L. K. Comstock to 1 a
15 fir Pucke tt dated May 29, 1984; some rules of the
]
16 L. K. Comstock te st f acility; a memorandum from a Mr. Tier to 17 ti r . Pucke tt da ted July 12, 1984; a memorandum f rom tir. Tier to 18 Mr. DeWald dated July 26, 1984.
$ 19 A handwritten memo from fir. Puckett to tir . DeWald 20 dated August 9, l!l84; a similar handwritten memo dated August
) 21 10, 1984; another copy of the same document; a memorandum 22 dated August 13, 1984 from Mr. Puckett to Mr. DeWald; a CE)
12 j 1 memorandum from Mr. DeWald to Mr. Rolan dated August 15, 1984;
! 2 another copy of the memorancum from fir. Puckett to Mr. Saklac ,
3 which carries the date of April 15, 1984; a copy of a j 4 memorandum f rom Mr. Puckett to Mr. Saklac dated August 17, 5 1984; another copy of L. K. Comstock NCR 3099 6 A speed letter from fir. Gieseker to Mr. Rolan dated
) 7 August 22, 1984; a similar speed letter from Mr. Gieseker to i 8 fir . Rolan dated August 23, 1984; memorandum from Mr. Puckett
/
9 to Mr. DeWald dated August 22, 1984; what appear to be nctes
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10 of a meeting held August 22, 1984, signed by Mr. DeWald; a 11 document which appears to be a part of an NCR form dated O 12 August 23, 1984, that has a signature of David W. Bradef ute ; a 13 memorandum from Mr. Puckett to Mr. DeWald dated August 24, l 14 1984.
l i 15 A handwritten letter f rom tir. Puckett to the
! 16 Depar tment of Labor dated September 5th or 8th, 1984; a 17 Department of Labor form in Mr. Puckett's Department of Labor 18 proceeding dated September 28, 1934; a notice by the I
19 Department of Labor that a request for reconsideration has i
j 20 been filed dated Octouer 9, 1984; the administrator's
) 21 reconsideration decision dated November 6, 1984; a letter f rom
]
, 22 Daniel P. Newe, Area Director of the U.S. Depar tment of Labor 9
1 4
- O 13 1 to Mr. T. Trumbull of Comstock Engineering, Inc., dated 2 November 6, 1984.
3 A Western Union Mail-gram to the Administrative Law 4 Judge, Depar tment of Labor, from Mr. Trumbull, apparen tly 5 dated November 12, 1984; a two page document which appears to
.l 6 be undated, that has the handwritten number "41" in the lower 7 righthand corner of the first page, and appears to be signed i
] 8 by R. Wyzguski, a Compliance Officer; a memorandum from 1
9 Mr. DeWald to Mr. Mennecke and Mr. Quaka, dated May 12, 1984
- 10 BY 1R. ftILLER
11 O Other than these documents, Mr. Puckett, do you have i 3
12 any documents that are responsive to the subpoena?
13 A I didn' t bring any with me, if I did. I just i 14 qathered up what I had.
l
) 15 0 tiay we take these for just a period of time and get 16 them copied and then I will return the copies to you?
, 17 A Sure.
l 18 [ Discussion off the record.)
19 BY ttR. MILLER:
20 0 fir. Puckett, in a document that the Intervenors 21 filed in this proceeding on July 12, 1985, they refnered to 22 certain documents that we just discussed on the record that O
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14 1 you brought with you.
2 At page four of the pleading, there are two 3 sentences that say as f ollows "During the course of 4 his..." meaning your employment, "...with Comstock, 5 Mr. Puckett was shocked by the widespread deficiencies in 6 procedures, qualifications and workmanship. He identified j 7 numerous instances of improper construction procedures, I
i 8 impropec qualification of welders and material traceability 9 de f ic ie nc ie s . "
10 You were kind enough to begin reading Inspection 11 Re por t 85-09 prior to the time this deposition started.
12 My question to you is whether the allegations that 13 are recorded in that Inspection Repor t are all of the 4
14 instances of improper construction, improper qualification of 15 welders, and material traceability deficiencies that you l l 16 observed when you were an employee of Comstock at the i
17 Braidwood site? i l
18 A To the best of my knowledge, it is.
19 0 IIad you noon inapection Roport 85-09 prior to tho 20 time that I gave it to you?
l
! 21 A No, I hadn't. l l 22 MR. GUILD: That was this morning before the
i I
i 1 deposition began.
2 MR. MILLER: Correct.
3 BY ttR. MILLER:
I 4 0 To the best of your recollection, when did you first 5 communicate with the NRC staf f regarding what you observed at 6 Braidwood while you were an employee of L. K. Comstock?
7 A The day a f ter my termination, I received a call from l 8 the Resident Inspector at Braidwood, at my home address, after I l 9 I had returned. I got fired in the afternoon. I returned to l 10 my home address that night in Ohio. I received a phone call 11 the following morning f rom the Resident Inspector. I I
1 12 0 was it Mr. Schutz or ttr. ricGregor?
I 1 13 A Mr. PicGreqor, I believe. )
i
- 14 0 What did Mr. McGregor say to you?
i 15 A He said that one of the other OC Inspectors had come
- 16 to him and told him that he thought he should call me and talk i
17 to me.
j 18 0 Did tir. McGregor identify that other OC Inspector by 19 name?
i 20 A He d id. Off the top of my head, I don' t remember 21 what it' was now.
l 22 0 Was it Ftr. Soeders?
lO
16 1 A No.
2 0 was it Mr. Bossong?
3 A No.
4 0 There are a lot of inspectors and I don't want to 5 run down the entire list.
6 A I'm trying to tie names back to faces.
7 0 Mr. Stoute?
8 A I don't think so.
9 0 Mr. Snyder?
10 A I don't think so.
11 0 Did you then have a conversation with Mr. McGregor O 12 about your termination by Comstock?
13 A Yes; I did.
14 0 About how long did the conversation take?
15 A I'd say 10 or 15 minutes.
16 0 To the best of your recollection, what did --
17 (Discussion off the record.]
18 BY MR. MILLER:
19 0 To the best of your recollection, what did 20 Mr. McGregor say to you and what did you say to him?
21 A fle re ferenced me to the Regional Of fico in Glen
?2 Ellyn. I think he wrote a report to them about our O
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1 conversation.
2 MR. MILLER: fir. Berry, has that report been made 3 available in discovery?
4 ftR. BERRY: I don' t know. >
3 5 ftR. MILLER: If it has not been, I am requesting 6 it. Mr. Guild, have you seen it?
1 j 7 ftR. GUILD: No, not that I recall.
8 MR. BERRY: I'll look into it.
l 9 BY ttR. PtILLER:
10 0 When you said he referred you to the Regional Office
, 11 in Glen Ellyn, did he name an ind iv idual there that you should 12 contact?
13 A lie may have, but I can't remember if he gave a 14 particular name.
15 0 Did you sketch out for him your view of what had 16 taken place in terms of your termination at Comstock?
! 17 A Yes. I told him what I thought led up to my 18 termination at Comstock. ,
19 O Did Mr. AtcGregor say in offect that the !!RC Rogional f 20 Staff would be looking into it and they would contact you 21 further, or something like that?
- 22 A Yes.
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l 18 I
1 0 Did that in fact occur? Did somebody contact you?
2 A Yes.
3 0 Who?
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4 A The name I can' t rem em be r .
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! 5 0 Was it Mr. Schapker?
6 A I really don' t know. I can't remember. Its been 7 quite some time ago.
8 0 It was shortly after your termination that you were 4
9 contacted again by the NRC?
i 10 A Yes.
11 0 Did they visit you personally or was this on the O 12 telephone?
j 13 A On the telephone. They made arrangements for me to l 14 come to Glen Ellyn to make a statement.
l 15 0 Did you then go to Glen Ellyn at some point?
16 A Yes; I d id.
17 0 Do you remember the approximate date?
18 A No; I don't.
19 0 Was it still in calendar year 19847 20 A I'm sure that it was.
21 0 How much time did you spend in Glen Ellyn?
22 A A couple of hours, I guess.
O
19 1
1 Q Do you remember the name of the NRC individual who 2 interviewed you at that point?
, 3 A No; I do not.
4 0 Was Mr. McGregor present?
5 A No; I don't think he was.
6 0 Was Mr. Schulz present?
7 A No; I don't think he was .
8 Q Do you know Mr. Schapker? He's the gentleman who 9 wrote 85-09, 10 A No, I don' t believe I do.
11 Did you have any dealings with Mr. Schapker when you n
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12 Q
were employed at the Cincinnati Gas & Electric Zimmer plant?
13 A I really don't know. There was a lot of NRC 14 Inspectors there. I run into quite a few of them.
15 Mr. Schapker, it's very possible, if he worked there -- there 16 was one gentleman, an NRC Inspector, that had been over at
- 17 Marble Hill and he called me at my home and asked if he could 18 come over and clarify some of the allegations that I had 19 made. He came to my house. We went over those allegations 20 that were not clear to him. This could have been il Mr. Schapker.
22 O I represent to you that in the Inspection Report, he
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i iO 1 refers to certain clarifications that he sought from you on 2 tiarch 12, 1985. Is that the time when he came to your home?
3 A Yes, but this was quite some time after I had been 4 to Glen Ellyn.
5 0 You said you gave a statement. Was there a Court 6 Reporter present?
7 A For the NRC In spec to r ?
i 8 O For this interview that took place at Glen Ellyn.
9 Was there a tape recording going?
10 A It appears to me that there was, but I can't 11 remember. I really don't know.
O 12 O After you had this interview in Glen Ellyn, 13 Mr. Puckett, did the NRC send you a memorandum or a transcript 14 of the interview and ask you if it was substantially correct?
15 A They sent me a copy of the allegations that I had 16 made. They sent me a copy of that. I looked for it while I 17 was home, fly lawyer might still have it. I don' t know. I 18 had to go to my lawyer to pick up all those papers. Ele had 19 all of my papers. He gave me what ho had at that timo.
20 0 That is Mr. Hornberger?
21 A Yes.
22 f tR. f1 ILLER: Ag ain , M r. Berry, if the NRC has a copy 1
_-_A
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x_.
1 of the document that was sent to Mr. Puckett, I would like to 2 see a copy, please.
3 MR. BERRY: I will look into it.
4 MR. GUILD: I guess for the record I would make a 5 similar request for any documents that Mr. Miller might 6 identify, if I could have the courtesy of a copy of those as 7 well.
8 BY MR. MILLER:
9 0 Between the time you went to Glen Ellyn and the time 10 Mr. Schapker came to see you at your home, did you have any 11 further contact with the NRC, with respect to the Comstock
- O' 12 matter?
13 A None that I can recall.
14 O After Mr. Schapker came to see you at your home in 15 Bethel, Ohio, did you have any further contact with the NRC 16 with respect to your employment by Comstock?
17 A No; I did not.
18 MR. MILLER: I would like the Reporter to mark as 19 Puckett Deposition Exhibit No. 2 for identif ication a document 20 that is undated. The first three pages are handwritten. The 21 next page is typed. The remaining seven pages are again 22 handwritten.
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2 1 [Puckett Deposition Exhibit No. 2 2 was marked for identification.]
3 BY MR. MILLER:
4 0 fir . Puckett, I show you a document which has been 5 marked Puckett Deposit ion Exhibit No. 2 for identification, 6 and ask you first of all if you have ever seen this document 7 before today.
8 A Yes.
9 O That is in fact your handwriting, is it not, sir?
10 A Yes, it is.
s 11 0 Can you tell me approximately when the handwritten
(_ 12 portions of that document were prepared?
13 A It was two or three days before my termination, I 14 started this review. That was an assignment that was g iven to 15 me, and I had started this review and I had worked on it a 16 Thursday, a Friday, a Saturday, and then I think it was on a 17 Monday that I was working on it again, when I was terminated.
18 0 When you were terminated, did you leave a copy of 19 this document with anybody at L. K. Comstock or Commonwealth 20 Edison Compary?
21 A No; I did not.
22 t1R. GUILD: Could I examine it? Did you reduce O
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23 d
1 that?
2 t1R. MILLER: Yes, I believe so. The first large 3 page after the typing, the first few lines, an earlier test 4 was given on 1/2 inch A-36 plate. It also reflects unlimited 5 thickness.
6 f1R. GUILD: Your exhibit copy is on 8 1/2 by 14 j 7 MR. MILLER: Yes. At the bottom of that page, the 8 words "PTL test number 4885 GWO 125." I believe they are 9 identical.
10 BY ftR. PtILLER:
- 11 0 As I said, the fourth page of the document that I v
12 have marked as Exhibit No. 2 is typed. Was that also prepared 13 by you prior to the time that you left Comstock?
de"T ":n -86 14 A It was prepared -- I d idn ' t 44d- the typing. I was 15 the one that wrote the in f o rm at ion that is reflected there.
16 The best I can recall is when I started this review, I started 17 it with the current welders, welders that were on the project 18 at this time. This reflected the current welders, the ones 19 that I found proble:ns with their test records. The 20 handwritten was started at a later date and I hadn't had time 21 to have it typed.
22 0 So I understand the typed page there, does that O
n
('N 24 1 represent all of the then current welders of Comstock at 2 Braidwood whose files, in your judgment, contained some 3 discrepancy with respect to their qualifications?
4 A At that time; yes.
5 0 The handwritten ones were welders who were no longer 6 employed?
7 A They were welders in a hold file. That was welders w o P. t- W s
8 that possibly had been terminated.nr rarminated. Some of them 9 had been there more than once.
10 0 I know you have not had a chance to complete your
- 11 review of 85-09, the Inspection Report. How f ar did you get
'- 12 into it, Mr. Puckett?
13 A Let's see; page 11 l 14 Q As far as you have looked, do you agree or disagree 15 with any of the conclusions that were reached by fir. Schapker l l
16 with respect to your allegations as they are recorded there?
17 A Well, I won't say that I disagree uith them. I 18 think that some of them were belittled, made to seem smaller 19 than what I personally think they are.
20 0 Could you identify those for us at this time?
21 Obviously, you will have to refer back to --
22 A If I go back to them and look at them, some of the v
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! I problems that I submitted as being problems and they say they 2 don't seem to be much of a problem. At the closing of the 3 Zimmer power plant, they were as serious as a heart attack.
4 That's what closed us, the very same type things I reported L 5 here . -
6 0 Could you identify for us which ones of the
- 7 allegations were similar to the things you say caused the 1
8 closure of Zimmer?
t 9 A The welding material, inasmuch as the A-446 to A-36, l 10 I noticed also in here that some of these problems they said i
1
, 11 that I was wrong, that they had been taken care of, and they 12 had in fact been taken care of, but this was two months after 4
13 I had left the project.
14 Welder qualifications were always a problem. Some 15 of the papers that we had in here referencing to welders' i
16 qualification test forms and the typographical errors that 17 were in these, that they're calling typographical errors, we 18 had the same type of typographical errors on some of our 19 welder qualification test papers at the Zimmer nuclear power 20 plant, and we had to requal -- recall quite a number of 21 welders to retest, because their welder's qualification was 22 considered indeterminate.
O 4
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1 And we called welders from all over the United 2 States, and one particular welder all the way back from Korea, 3 just to retest to the new procedures.
4 0 That was at the Zimmer plant?
5 A Yes. And the problems that they had there with the 6 welders' qualification test records is the very same type of 7 problems that I presented to NRC with this document.
8 O And when you say "this document," you are referring 9 to what we've marked as Puckett Deposition Exhibit 2, correct?
10 A Yes.
11 O And this one allegation, Allegation 2 on the NRC O 12 finding on random samples of weld filler material withdrawal 13 forms --
14 MR. GUILD: What page are you on, Mr. Puckett?
15 THE WITNESS: Page 7 And when I talked to NRC, I 16 gave them specific heat numbers, that we could not find these 17 heat numbers listed in any of the documentation that we had 18 there at Braidwood. He says he took a random sample, 19 according to this, and that he found most of the heat 20 numbers. There was one, I think, that he said had a number 21 inverted in it or an S that looked like a 5, whatever the case 22 might be.
O
- . ~ .. . . - . - -. -_ . . . . ._.
4 9
1 BY MR. MILLER:
2 O Yes, sir?
1 3 A I don' t think that these are even the same numbers 4 that I mentioned, that we could not find in any documentation.
J 5 0 Well, we'll.come back to that later in the 6 deposition, and perhaps we can get out the original i
1 7 documentation and see how they match up, l
I 8 B u';. a s I say, I understand that you haven't gone 9 beyond page 11. Are there any others that come to mind? ;
i 10 A On page 9, G. An allegation I made was that welds l 11 were made without the required preheat. A procedure was l 12 developed that did not require weld preheat, that Quality
- 13 Control did not participate by observing the making of the j 14 weld coupon qualifying the procedure.
15 Now the allegation that I made when I made it was j 16 that I requested that a procedure be qualified. I talked to 17 the engineer in Comstock and told him the type of materials 18 and the thickness of the materials that would be needed.
19 The next contact I had with him was when he took me 4
1 20 into the electrical fab shop and presented four test plates to 1-21 me that had been welded out without any OA supervision 22 whatsoever.
O
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1 On the NRC review here at the bottom, it says: "The 2 NRC inspector interviewed the OC inspector who was responsible I
3 for surveillance of the PORs. The QC inspector attested that 4 he witnessed the welding of the test coupons throughout the 1
5 process."
6 This could be very well so,.but note up here at the 1 7 top a date of October the 12th, 1984, after my termination.
8 0 Can you identify the QC inspector for us?
9 A No, I cannot. I wasn't there at the time. It just 1
'l 10 says "0C inspector." I don't know who may have witnessed 11 this.
O 12 O Okay. Who was the weld engineer who presented you 13 with the four coupons that had been welded?
14 A They did not have a weld engineer, per se, there at 15 B ra idwood , lie was an electrical engineer.
l 16 0 I'm sorry. And.what was his name; do you recall?
17 A I do not remember. .
18 0 Was he employed on the production side?
19 A Yes. He was in supervision. I think he was the 20 number two man in charge, in fact. He was a young guy, but I 21 can't think of his name off the top of my head. I didn' t l l
' 22 really have too much dealings with him.
4 O
e
f'~h 29
(~
1 Q One more question on this preheat issue.
2 Approximately when did you raise that issue at Comstock?
3 A I would say it was in the middle part of July. On 4 page 5, Item C, a procedure we used to make bimetallic welds, 5 but the procedure is not a bimetallic procedure. Bimetallic 6 welds have been made, but L.K. Comstock does not have a 7 procedure to qualify its welders for bimetallic welds.
8 Therefore, welders are not qualified to make bimetallic welds.
9 The NRC inspectors in terv iewed , it goes on to say 10 down here, that there was no bimetallic welds made. However, s 11 on page 7, at the bottom on "NRC Findings," where he's
) 12 checking weld filler material control slips, weld rod slips, 13 he has listed there, "E-309-16 weld filler material," which is 14 used for making bimetallic welds.
15 O Does it have any other application besides 16 bimetallic welds?
17 A It could be used to weld stainless to stainless, but 18 I was the project weld engineer at Zimmer nuclear power plant, 19 and 309 is what we used for making all our bimetallic welds --
20 that is, stainless to carbon.
21 0 Yes, sir. Did you personally observe any bimetallic 22 welds at Braidwood?
V<O
l i
4 30 I
1 A No, I did not. And when I made the statement, I i
2 said that in talking to other OC inspectors there, I asked 3 them,'because I didn't really do that much inspection myself
.f 4 in the field. Were they aware of any welds that were being 5 made in the field that were bimetallic, stainless to carbon?
I 6 And they said yes.
4 7 O Okay, sir. When did you have your first
- 8 conversation in which someone identified bimetallic welds?
9 A I really don' t remember any dates. I would say that 4 .
10 it was in June or early July. There was one particular i
1 11 inspector that came to me that was supposed to inspect a weld j 12 that was bimetallic. He had the papers to inspect the weld.
l j 13 And he come to me and asked me about the procedure. I told I
14 him at that time that we did not have a procedure for making a 15 bimetallic weld. And in turn, he says, "Well, I'll just write l 16 a nonconformance report rather than inspect the weld."
i
! 17 Now whether he did or not, I don't know.
l.
18 0 Okay. Can you identify any of these inspectors by j 19 name?
4 j 20 A I think I can remember this one's name if I think l
, 21 just a-minute.
! 1 22 O Okay. Take your time, g I 9
1 i
31 3 1 A I've got a lot running through my mind, so -- there i
2 was one of the inspectors that I qualified to run the test i 3 facility while I was there, and I can't -- the name just isn't
! 4 coming to me right now.
5 If we have copies of the NRs in here, he signed -- I i
6 requested that he write a nonconformance report for me, a '
i 7 because at that time I wasn' t qualified myself to write it.
8 0 Well, I have some of the NCRs. I have NCR-3099. It 9 doesn't relate to the bimetallic issue.
10 A John A. Miner, that's him.
i ,
11 MR. GUILD: What was that NCR number, Mike?
1 i 12 MR. MILLER: 3099.
- 13 MR. GUI LD: I was just going to suggest that if you l
j 14 had a roster of Comstock OC inspectors, it might prove usef ul I
15 in refreshing his recollection.
l 16 MR. MILLER: Off the record.
17 [ Discussion off the record.]
I i 18 BY MR. MILLER:
I 19 0 On this bimetallic weld issue, there were other OC 20 inspectors, to your recollection, besides Mr. Miner,-who i
4 l 21 raised a question about it? .
l 22 A They did not raise questions. I just asked some of i
f .
l
32 1 the individual weld inspectors there. They had different i
2 types of inspectors. They had those inspectors that inspected
- 3 con f ig urat ions , those that inspected cable pulls, and the weld I
4 inspectors.
5 I asked some of the other weld inspectors if they
]
1 6 were aware of any bimetallic welds, and they said yes.
- 7 O Did they identify locations?
8 A No, other than what's listed in the paperwork here. ,
! 9 -
0 Well, going back to page 5 of Inspection Report
)
10 85-09, apparently -- or at least Mr. Schapker reports that on
\'
l 11 tiarch 12, 1985, you informed Mr. Schapker that the welds you
- O i 12 were referring to were stainless steel junction boxes within ;
13 the reactor building. !s that accurate?
t I
14 A I know that the junction boxes had been mentioned to l
15 me, but one of the inspectors, he said he thought there was f' 16 bimetallic welds being done there. I asked for a location on dr **9.26-66 j 17 onef tham. I don't remember which one.
18 O Okay. Looking at page 5 of Inspection Report 85-09, 19 does that help ref resh your recollection as to whether there -
20 were any other locations besides these junction boxes where ;
1 1 21 the bimetallic welds might have been installed?
22 A I had an inspector to say that he felt that there iO 1
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,-m I 33 (V
1 were some in some of the cable runs in the horizontal devices 2 that holds the weight of the cable.
3 Q The cable pans?
4 A Yes. It's the bracketing material that holds the --
5 they have a sleeve type affair that fits on the cable that 6 holds the weight of the cable. The sleeve is attached to a 7 bracket inside of a horizontal cable run. And I was told that 8 some of these were, in fact, bimetallic.
9 Q Going further down on page 5 under Allegation C, is 10 that the CS conduit attachment to the junction box that's
.- 11 referred to there?
V 12 A No, it is not.
13 O Did you tell Mr. Schapker about this second possible 14 location of bimetallic welds when you were with him on March 15 12, 1985? '
16 A I don' t remember if I did or not.
17 O Is there a specific location in the power plant 18 where these welds that might be bimetallic occur, or are they 19 just random throughout the plant?
20 A No. In the junction boxes, as mentioned, sometimes 21 they have those welds in your fuel pools, for the fuel pool -- ;
22 well, not the fuel pool cooling, but they have fuel handling (v
l l
l
4 34 l
2 i 1 racks, and I think they're making a lot of them out of a
j l 2 aluminum now, but I think at one time some of them was made of i
3 stainless. I don't know if the ones there are or not.
4 4 0 Well, but the fabrication of the fuel pool racks i 5 would not be within Comstock's scope of work, would it?
! 6 A Probably not, no.
j 7 Oh, in Comstock's.
8 0 Yes.
9 A Oh, I'm sorry. No, none that I could think of.
10 Q Uell, Mr. Puckett, I know you got up to page 11, but l 11 I would ask you if you would take the time now to review the 5
i l 12 rest of Inspection Report 85-09, and then I want to go back i
j 13 and ask you some additional questions about it. I realize i
j 14 that 's ' going to take some time, but I think it ultimately will '
i r
! 15 shorten the overall process if you do that.
1 I '16 So we can go off the record now.
l l 17 MR. GUILD: I guess before you do that, that seems i
18 to be a useful thing to do, and I think the record should just i 19 reflect that, given the fact that the witness has only seen 20 the document this morning, that whatever we get from him by 4
21 asking him today may not be a complete response to what-would, i
22 for any reasonable person, require a somewhat in-depth review 4
I \
i I
I i
1
. _ _ , . _ _ , _ , . , , . _ , , ,, _ , _ . . . _ _ . . _ __._,._,__,,_m -, , _ _ _ _ _ _ - - . _ _ . . _ _ , , ,-.,,___m_.,_
l l
. i 4 x i
35 1 and study.
t 2 MR. MILLER: All he can do is tell us what he can l 3 recollect on the basis of the review that he's done, and he's 1,
4 already testified that he just got it shortly before this l
5 deposition.
6 [ Discussion off the record.]
l i
j 7 (Whereupon, at 11:00 o' clock, a.m., a brief recess 8 was taken, with the deposition reconvening at 11:25 o' clock, I 9 a.m.]
I ,
1 10 MR. FiILLER: Mr. Berry, you said you wished to make ,
11 a statement for the record when we resumed.
. 12 MR. BERRY: Yes. During the recess, I consulted i
13 with Mr. McGregor. He is present with me here today as the 14 Staff's technical advisor. And I had asked him about a l
l 15 memorandum that Mr. Puckett testified that he had written and j 16 sent to the Reg ion, summarizing the conversation that he had 3
17 with Mr. Puckett on August 28th.
]
18 Mr. McGregor indicated to me that, yes, he did meet 19 with Mr. Puckett, that there was a memorandum generated ,
20 summarizing that meeting, and that he has in his possession
],
21 today a copy of that memorandum.
4 22 The only question about disclosure of that
36 ,
l 1 memorandum at this time that the Staff has is whether it would !
2 impinge or compromise any confidentiality which Mr. Puckett 3 may claim. And so before disclosing that memorandum to the 4 other parties, I would like the opportunity to ask Mr. Puckett 5 a few questions.
6 MR. ?! ILLER: All right, fine. I'll interrupt my 7 examination. Go right ahead.
8 9
10 11 12 4 13 14 15 16 17 18 19 20 21 22 O
3 i
.. 37 i
k 1 VOIR DIRE EXAMINATION 1
j 2 BY MR. BERRY:
3 O Mr. Puckett, are you seeking cc,nfidential treatment
! 4 in this proceeding?
.i 4
l 5 A For myself, no.
i 6 0 For yourself, you are not.
i 7 A If there's any other names mentioned, any other QA
! 8 inspector's name or OC inspectors' names mentioned, I wouldn't 9 want their names mentioned.
10 0 All right. When you spoke with Mr. McGregor, I 11 believe on August 28, 1984, did you indicate to him that you i
l 12 desired confidential treatment?
., 13 A No.
1 i 14 0 When you spoke with anyone else from the NRC , if you 15 did, did you make such a request of them?
I j 16 A No, not for myself.
I l j 17 O Do you have any objections to the Staff making i 18 available to the other parties in this proceeding a copy of a 19 memorandum written by Mr. McGregor, summarizing your
- 20 conversation with him, the conversation of August 28th that j 21 you testified to this morning?
22 A Not if Mr. McGregor hasn't.
O i
I t
1 7 38 N) 1 MR. BERRY: I represent that Mr. McGregor does not.
2 Well, in that case, the Staff, looking at the 3 memorandum itself, there's no indication in there that 4 confidentiality was requested or desired by Mr. Puckett, and 5 all indications and actions by Mr. Puckett subsequent to that 6 date would indicate that there is no desire for 7 confidentiality.
8 For that reason, the Staff -- and this document 9 appears to be relevant to his testimony and to the Contentions 10 in this case, and for that reason, the Staff would make 11 available a copy of a memorandum dated August 28th from 7-s
'%.)
12 Mr. McGregor through Mr. Warnick, who is Chief of the Projects 13 Branch, and the memorandum is intended for Mr. C. Weil, who is 14 an Investigation Coordinator.
15 This document was -- I obtained this from 16 Mr. McGregor. I understand this is his personal copy.
17 [ Discussion off the record.]
18 19 20 21 22
(~%
\~-)
1 1
b)
\J 39 1 l
1 EXAMINATION (RESUttED) ,
l i
2 BY f1R. 4 ILLER: l f
3 0 ti r . Puc <e tt , you have now examined the memorandum 4 that's been tendered to you by Mr. Berry, and on behalf of
! 5 Mr. McGregor.
6 Do you have any objection to its disclosure?
7 A No.
8 MR. MILLER: Okay. We'll get copies made.
9 !!r . Berry, for the record, the Applicant has 10 refrained from any direct discovery against the Staff in the 11 expectation that responses to Intervenors' discovery requests U,3 12 would yield any documents that we were interested in, since 13 they are quite <:omprehensive ones.
14 I req 2est on behalf of Commonwealth Edison, however, 15 that documents re s pon s iv e to the Contention items, most i
16 specifically tr ose dealing with the allegations of harassment 17 and intimidation, including fir. Puckett and the other OC 18 inspectors, be turned over for our copying and review.
19 BY MR. f-TILLER: l l
20 0 Now, Mr. Puckett, I know that you had about a half 21 hour2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br /> or so in which you went through the remainder of 22 Inspection Recort 85-09. I understand that it was a somewhat
('~N
40 1 cursory review, but let me ask you, with respect to the 2 balance of the document that you've just reviewed, are you 3 generally satisfied with Mr. Schapker's disposition of the 4 allegations that are found in that inspection report?
5 A Generally so. Hovever, on page 14, Allegation 1 --
6 that's underneath K. Willard's qualifications inconsistencies 7 --
"The alleger believes there are many instances of record 8 falsification. For example, an unidentified welder took three 9 test coupons and got the results all in one day. The alleger 10 stated that this was administrative 1y impossible."
11 And the NRC review, I notice here that the NRC b
O 12 inspector was reviewing a procedure dated November the 26th, 13 1984 That wasn't the procedure that the test was made to.
14 This was a procedure that was evidently changed or revised 15 after I was terminated in August of '84.
16 [ Discussion off the record.]
17 BY MR. MILLER:
! 18 0 Mr. Puckett, Mr. Guild has handed you a document 19 that bears on the first page the identification, " Procedure 20 Tracking Sheet for Procedure 4.7.1." It's identified as 21 Revision C with a date of November 26, 1984. That is the samo 22 revision that is identified in page 14 of Inspection Report
1 41
())
m 1 85-09.
2 Can you help us, and if you recall, can you point to 3 the paragraph of Procedure 4.7.1 that dealt with the welder 4 qualifications at issue in --
5 A Well, the allegation I made was that according to 6 the welder's qualification test record, the dates that were on 7 these records reflected that he completed three one-inch test 8 plates in one day. He welded these out, had them taken to 9 PTL, and had them bent.
10 I qualified welders myself while I was there, and I s 11 know that a good welder will finish one plate and maybe get it 12 cut up and bent the same day. But there's no way that he 13 could do three.
14 Now again, as he said here, there's the possibility 15 that he may have welded these plates over a period of time, 16 cut these plates and submitted them all the same day, and they 17 dated the records accordingly. But the record should reflect 18 the date that a man completes a test coupon, and then there 19 will be another record that reflects the day that it was bent.
20 0 The allegation is identified as an example of 21 falsification. Were there any other examples that you know 22 of?
- O
42 )
1 A Well, this was just -- again, I had done just a 2 quick review on these welder's qualifications test records.
3 When I said it was a falsification of records, I'm saying if 4 the records, if they wanted to take them verbatim as they were S written, it would have to be falsification, because there's no 6 way that a man could complete three test coupons and get them 7 bent the same day.
8 Q Physically impossible?
9 A Now the explanation that the inspector had here on 10 his findings is satisfactory to me. But this is the type of 11 things that needs to be found at Braidwood and identified.
^
12 0 Well, my question to you, sir, was, was there any 13 other instance, other than this one situation where apparently 14 three test coupons were completed on the same date according 15 to the records, which, in your judgment, could have 16 constituted record falsification?
17 A No, not that I can think of, that you can actually 18 call falsification -- that is, you know, intentional 19 falsification of a record. Maybe unintentional, which is 20 mentioned in some of the other items in here, where they had a 21 clerk to go in and pull a certain numoer of weld papers and 22 make some changes to the base material there.
O
/^\ 43 b
1 0 Would that be unintentional or intentional?
2 A I don' t know where it was intentional or 3 unintentional, but I know that a clerk isn't supposed to make 4 changes on quality documents.
5 0 I see. Well, are there any others besides this 6 instance on page 14 that you have some comment on?
7 A Well, I have no problems with these findings. If 8 that's the way that they want to look at them, that's 9 perfectly all right with me. I just wanted to make known my 10 concerns, and if they don' t considar these as being concerns, 11 that's their prerogative.
O 12 O Well, let me ask you this, fir. Puckett: You talked 13 earlier about the typographical errors that had appeared on i 14 some welder qualifications documents, and I think you said i 15 this was the same sort of thing that caused Zimmer to have a 16 heart attack and in actuality led to the shutdown of the job.
17 That's a paraphrase, but is that right?
18 A That is part of the reasoning. Of course, there was 19 a lot of reasoning, but that was one of the big things there 20 at the end that they were really pounding on.
21 O Okay. Based on your evaluation -- I'm sorry; I 22 didn't mean to cut you off. Did you finish?
44 1 A I was just saying that most of the things that I 2 reported in my allegations were the exact types of things that
?m,rn uso f' s . 2 6 - G G 3 NRC was so concerned at at Zimmer.
4 0 Well, focusing just on the welder qualification 5 records first for a second, the typographical errors and so 6 on, in your own judgment, do those types of errors and 7 inconsistencies in the records create a concern for the actual 8 qualification of the ind iv idual , or is it really just adhering 9 very, very strictly to procedures that was your concern?
10 A I would say that probably most of the discrepancies 11 there were procedure violations. In other words, more than i
O 12 likely, the welder made a good test, but the paper just did 13 not reflect what it should have reflected.
l 14 0 Okay. You've looked at a lot of welder '
15 qualification records in your career, I'm sure.
16 A Yes, I have.
17 0 And typographical errors do happen, do they not?
18 A Yes.
19 0 And the fact that the typographical error takes 20 place really doesn't mean that the welder is not qualified to 21 do his job; isn't that rig ht?
22 A Well, yes. But NRC was so concerned at Zimmer that i
/~'i 45 1 we had to bring back approximately 18 or 19 welders because of 2 typographical errors. Their qualifications was considered 3 indeterminate, because there was a wrong date, a wrong type of 4 material listed, or a wrong position or a wrong type of filler 5 material.
6 0 I think you said that welder qualification records 7 were a large part of the problem at Zimmer. But were there 8 other welding discrepancies at Zimmer that had been identified 9 prior to the time that project was shut down?
10 A Oh, yes. We had problems with the same things that 11 I've mentioned here. Joint designs, filler material control, 12 and lost documentation, which I never got a chance to check 13 into there.
14 I do know that I've tried to do'some traceability on 15 some weld rod slips by taking the welders' names and the dates 16 and going back to the work log that they have there, showing 17 what welders were assigned to particular jobs on a particular 18 day, and I could not trace these rod slips back to the actual i
19 paperwork in the vault, reflecting what these rod slips had l l
20 been used for, the rod slips being the weld filler material 21 control slip.
22 O Was that an allegation that's reflected in --
' ' 'S 46 J
1 A No, not really. They mentioned something in there 2 about the traceability of filler material. But when this was '
3 brought up, the bit on the traceability of filler material and 4 the heat numbers for the electrode, that's when I was trying 5 to run down these heat numbers for this electrode and find out 6 what kind of components that they were used on, and I could 7 not do this.
8 Q Do you believe, Mr. Puckett, that the type of 9 traceability that you've just described is required by either 10 the AWS code or Comstock procedures at Braidwood?
s 11 A Yes.
12 O All right. I'm sorry. I asked you two questions 13 there.
14 Is it required by the AWS code?
15 A Yes.
16 MR. MILLER: I aould like the Reporter to mark as 17 Puckett Deposition Exhibit No. 3 for identification, a 18 document entitled " Structural Welding Code." On the second 19 oage, it is identified as AUSDl.1-75.
20 THE WITNESS: Can I rephrase that?
21 MR. MILLER: Certainly.
i 22 THE WITNESS: When you mentioned the AWS Code, I was O
} %
(d i 47 1 thinking of that actually. It is 10 CPR 50, Appendix B, that 2 requires that you maintain traceability on all materials up 3 and until time of installation. I think it is Appendix 18, 4 BY MR. MILLER:
5 0 Criterion 18?
6 A Yes; I think so. I think it's 18; I'm not sure.
7 O Let me understand precisely what aspect of 8 traceability you believed was required with respect to ASW 9 welding by 10 CFR 50, Appendix B. You have described it 10 before and I just didn't jot it down. What aspect of cs 11 traceability are we talking about here?
d 12 A Well, I'm concerned within the recordkeeping. They 13 should be able to go into the vault and pull a weld filler acPs.24-BL 14 material rod slip and take -any-information f rom that filler 15 material rod slip. They should be able to trace it back to 16 the component which it was used on. I'm not at all sure that 17 can be done.
l 18 0 Isn't that a requirement of ASME welding procedures, 19 the ASME Welding Code?
20 A It is also a requirement of 10 CFR 50, Appendix B.
21 I would assume that your filler material would fall in the 22 same categories as base materials that you might use. It just u
l
~'
i 48 (G
1 says that your materials - you will maintain traceability on 2 the materials up until the time of installation.
3 MR. MILLER: Perhaps Mr. McGregor will share his 10 4 CFR with me for just one second.
5 BY MR. MILLER:
6 0 Can we agree it is Criterion 8 rather than Criterion 7 IS?
8 A Eight. I knew it had an eight in there soaewhere, 9 that deals with traceability.
10 [ Perusing document.]
- 11 MR. GUILD: We have all been guessing, and guessed b 12 wrong, perhaps.
13 BY MR. MILLER:
14 0 With respect to materials that are used by Comstock, 15 isn't it right that all that is required is that the material 16 as a whole, weld filler material as a whole must be traceable 17 to certified material test reports and so on, and that it need 18 not be traced from there to a specific joint?
19 A I think Comstock's procedure requires that you have 20 heat numbers, that this be traced to a certification of 21 compliance heat numbers.
22 O Does the procedure go on and require that those heat
I l
l l
l l
fh v
49 1 numbers then be traceable to a specific joint where the weld 2 filler material is used?
3 A I would assume so, yes. I don't know the exact 4 location. I know in my experiences, you have always had to be 5 accountable if you used filler material, for where it is being 6 used at, because some of the procedures call for one type of 7 grade of material and other procedures call for another type 8 grade of material. Your rod slips, weld filler material i
9 control slips, should reflect a heat number for the joints it 10 was used on. It should correspond with the type of material 11 that was supposed to be used for the joint.
O t f
- 12 This was a digression, but a useful one from my O
13 earlier question, with respect to the welder qualifications at 14 Zimmer, as being a part of what caused the plant ultimately to 15 be shut down. I think you said there were other issues at 16 Zimmer that were similar to the ones --
17 A Yes.
18 0 -- at Braidwood. Going back to the traceability of 19 material, do you regard the traceability issue that was 20 identified at Braidwood as one that was again a procedural 21 problem or one that raised questions about the safety of the 22 installation?
O V
50 1 A Uell, I would say if they had a procedure that was 4 2 correctly written, it could have alleviated a lot of the 3 problems they had.
4 O There was an issue, was there not, on traceability 5 or on weld rod control with respect to the use of -- let me 6 get my numbers -- the interchangeability of E7018 and E6010?
7 Indeed, you followed that issue, did you not, while you were 8 at Braidwood?
9 A Yes.
10 0 Do you know what the disposition of that issue was?
g 11 A I'm trying to think on that now. I believe they 12 didn't really get a disposition on that until after I left. I 13 know I worked on it myself for quite a while. That got me 14 into some of the other things there. I pulled the same rod 15 slips during the same period of time that the NRC Inspector 16 had pulled. He had found these problems. I went in and tried 1
l 17 to find the same problems that he found, to be able to give '
18 him an answer when he asked for it, as to what the problem 19 was.
20 In order to do that, I had to tie them back to the 21 actual work that the rod had been used on. In other words, if 22 a weld required that you use E6010 rod on it, and the rod slip O
51 s~e 1 reflected they used E7018, I wanted to find out what type of 2 rod they actually used, and what procedure they actually 3 used. I never did get this satisfactorily completed.
4 0 Is that because the records didn't enable you to 5 determine what rod had actually been used?
6 A You could only go with what was on the rod slip. I 7 tried to tie the rod slip back to the record that it was used 8 on, and I could not do this.
9 0 I think you said earlier that you had qualified 10 welders at Braidwood. Is that correct?
x 11 A I had witnessed the qualification of welders at n
12 Braidwood.
13 O Sir, how many and on how many occasions did you do 14 that?
15 A tiaybe 10, 12 16 0 Until you were certified as a Level 3, you yourself 17 could not qualify those welders, is that correct?
18 A I could not qualify a welder, no QA Inspector we had 19 could qualify a welder. There is no reason why he could not 20 witness that, because the ultimate and the final inspection 21 was done by PTL. They either accepted or rejected a welder's 22 test coupon.
v
1 1
l m
1 O I think we were up to page 14 in Inspection Report 2 85-09. Are there any others that you have identified as 3 something you wish to comment on?
4 A Not really. Evidently, the NRC Inspector that 5 checked the allegations that I made done a little more I 3 0 - B
Tne c 3p:
6 in-depth study on them t-hen I mysel f . Of course, I was pushed 7 for time while I was there. I was told to complete an 8 inspection in a week, that a half a dozen men could not 9 complete in three weeks.
10 0 Which inspection were you told to complete in a
,e w 11 week?
' s)
\
12 A I was told to do a complete review of all of our 13 procedures and make necessary changes. I was told to do a 14 complete review of all welders' qualification test records, 15 past and present, and come up with a conclusion stating any 16 problems we had there. I was told to do a complete review of 17 all weld filler material control rod slips that had been 18 initiated on the Braidwood Project.
19 0 You were to accomplish all of this in a week?
20 A Yes.
21 O What was the start date for this review?
22 A A Thursday. I had to have it completed by the next
\
. -~~ . - - .. - . _ . - . _. .. - . - _ _ _ _ _ -
53 1 Thursday, but they terminated me on the Monday prior to that 2 Thursday. I worked on it for three days; Thursday, Friday and 3 Saturday.
4 0 Who was the individual who told you to complete this I 5 review within a week?
! 6 A Bob Seltmann. He is the QA Manager at Braidwood, or 4
7 was when I was there. DeWald was present at the time. He was 8 the QC Manager.
9 O Anybody else present besides Mr. DeWald and 10 Mr. Seltmann?
11 A No.
iO G 12 O I would like to go back, if you would, to page 9 of i
13 Inspection Report 85-09. I think we probably ought to mark 14 thet as Puckett Deposition Exhibit.No. 4 for identification, i
15 (Puckett Deposition Exhibit No. 4 16 was marked for identification.]
17 MR. GUILD: I'm sorry. What page are you on, Mike?
i 1
18 MR. MILLER: Page nine of what we have now marked as j
19 Puckett Deposition Exhibit No. 4 for identification.-
20 BY MR. MILLER:
)
21 O Under the allegation G cn that page, there is a i r 22 sentence under the heading "NRC Review" that reads "The welds O
4 a
- O '4
! I to members in the plant in excess of three inches in thickness 2 were removed and replaced utilizing the required pre-heat."
l 3 Did that take place, tir. Puckett, that activity,
! 4 while you were present at the site?
5 A To the best I can recall on this, I-had a QC i
6 Inspector come to me and told me that he was required to I
7 inspect a weld. This was a. post-inspection. This was after i
8 the weld had been completed for quite some time. He was to
{
t 9 inspect this weld in accordance with, at that time, the l 10 present revision of the inspection procedure.
i 11 He said that the weld was-in excess of one and a i
i %.
4 12 half inches. He said that he could not verify that pre-heat 1
13 was used, as required by the D.l.1 Code.
14 I told him that if he was concerned with it, if he i
15 could not verify it, that he should write something to the 16 effect that he could not verify the pre-heat on this weld,
! 17 that it was in fact pre-heated.
i 18 I think a Non-Conformance Report may have been 19 written regarding this. -The engineer that received the i
! 20 Nonconformance Report and had to make a disposition on it, 21 came to me and asked me, what can we do to make this right. I 22 told him at that time, that if they could not verify that a 1
/ 1 55
(_/
1 weld had been pre-heated prior to and during welding, that 2 they should qualify a procedure without the pre-heat to show 3 that a weld could be made without pre-heating and still be a 4 good weld, that the welds that are already installed should 5 have further inspections, such as a mag particle inspection or 6 an ultrasonic inspection, to show that they were sound.
7 It was at this time that the engineer told me, okay, 8 I'll make a disposition on the Nonconformance Report that we 9 will qualify a procedure for welding without the pre-heat. He 10 asked me to get him a list of the materials that would be 7-~g 11 involved. I got him a list of these materials and gave them
(\~) 12 to him. As I stated earlier, I gave his this list the next W #; p,-aI, 13 time I seen him.
14 He was presenting me with four test plates that were 15 supposedly welded in our test lab, completed, and he wanted to 16 have them tested. I told him at that time that's not the way 17 we do it. We don't have anybody that witnessed the actual 18 welding on these test caupons, the fit-ups, the tacks, the 19 completed weld, so forth and so on. He said, I didn't know 20 they had to. I told him to order some more material, we are 21 g7ing to have to re qualify the procedure.
22 I'm not at all sure whether the procedure was s
v
56
(_-
1 requalified after that or not. Evidently, it was, as they 2 have an October 12th date up here, two months after I left.
3 Q Do you remember the name of the engineer? You have 4 described the instance in some detail.
5 A I know what he looks like, but I can't think of his 6 name.
7 MR. GUILD: Again it might be helpful if we had a 8 list.
9 THE WITNESS: lie had a name that ordinarily I would 10 recall, but --
11 MR. MILLER: Hold on for just one second and let me
(~'\
~
12 see if I can refresh your recollection.
13 (Discussion off the record.]
14 BY MR. MILLER:
15 0 fir . Puckett, I show you what has been supplied by 16 Commonwealth Edison as the answer to Intervenor's 17 Interrogatory --
18 A You've got to be kidding. That's Baker. I worked 19 with him at Zimmer. Ile was our Level 3.
20 0 This is Attachment 2 to Edison's answer to 21 Interrogatory 19 of Ir.Lervenor's first set of 22 interrogatories. If you might just take a quick run through
[G
m 57 1 that, and perhaps the name of the engineer we've been 2 discussing with respect to this lack of procedure with respect 3 to preheat will come to mind.
4 t1R . GUILD: Did Engineering make that list?
5 f1R. MILLER: Pardon?
6 MR. GUILD: Did engineers make that list? I thought 7 they were only QC inspectors.
8 THE WITNESS: All I see so far is QC.
9 f tR . f1 ILLER: Tha t 's r ig ht . Okay, you're right.
10 It's not going to list engineers, and I don't know that I have 11 a roster.
12 MR. GUILD: Off the record.
13 (Discussion off the record.]
14 t1R . MILLER: I would like the reporter to mark as 15 Puckett Deposition Exhibit 5 a three page document which is o, s c P. 9 7.t;-80 16 entitled " Resume, Worley 4n Puckett."
17 [Puckett Deposition Exhibit No. 5 18 was marked for identification.] l 19 BY ttR. MILLER:
20 Q t-t r . Puckett, I show you a document that has been 21 marked Puckett Deposition Exhibit 5 for identification and ask 22 you if that is an accurate depiction of your work experience
58
(
v 1 up to the time that you joined Comstock?
2 A Yes.
3 Q All right. Since your termination by Comstock, by 4 whom have you been employed, sir?
5 A tiobody.
6 O Are you presently employed?
7 A No, I'm not. I can' t get a job.
8 0 Where have you applied?
9 A Oh, Ma r t i n-fla r ie t t a , General Dynamics, any of the 10 larger companies. They all find some reason that they don't 11 need me.
12 O Have you applied to any utilities?
13 A Yes, several down South. I've sent resumes in, that 14 is, to job shops that hire for the power plants.
15 0 I see. Job shops are, in effect, employment 16 agencies, are they not?
17 A Yes.
18 O Could you identify those for us?
19 A Off the top of my head, I couldn't. I might have 20 some of the stuff in here, or I may have taken it out before I 21 left, places that I've applied for employment and been turned 22 down.
O t_-
t 59 1 I've applied to such places as Webster, Stone &
2 Webster, Daniels, Carolina Power & Light. Like I say, I've 3 got one here from General Dynamics. These are all "
==Dear
,==
4 Johns."
5 Q When you say "
Dear Johns,
" they're --
6 A Schneider Power Corporation, General Electric. This 7 is just a few of them that I left on the side here. There's a 8 lot more than that.
9 Q I really don' t want to go into the details of this 10 at all, except to ask whether in any of our correspondence g-~g 11 with these applicants, whether any reference has been made to U 12 what happened with your employment at Comstock at Braidwood?
13 A By myself or --
14 Q I assume you'tc told your prospective employers that 15 you were employed by Comstock.
16 A No, I did not.
i 17 Q I see. Well, have any of them inquired or mentioned 18 Comstock or Braidwood to you?
19 A No. A lot of them seem interested right up to the 20 last there, and then it seems like for some reason all of a 21 sudden they didn't need me after all. I 22 O But up to and including that poinc, you, at least, 4
\
l 1
f I
i
(~
N 60 1 had not disclosed that you had been employed for a three-month 2 period at the Braidwood site.
3 A No. I only felt it would be a detriment.
4 0 Mr. Puckett, how did you learn of the availability 5 of a position with Comstock in the spring of 1984?
6 A My son-in-law, who was also a weld engineer and had 7 worked with me at the Zimmer power plant, had applied for a 8 job there, and they were going to call him up for an 9 interview. I called them and gave them a brier a description j 10 of my qualifications and asked them if I could also come up 11 for a, interview, and they said, "Sure," you know, and they 7-~
u 12 invited me up for an interview.
i 13 0 Who did you call; do you remember?
14 A I believe it was Mr. Siess that I talked to.
15 0 Okay. So both you and your son-in-law went together 16 to apply for positions with Comstock; is that correct?
17 A Yes.
18 0 Did your son-in-law get a job?
19 A tio , he did not.
20 0 In this first trip up for the interview, who did you 21 talk to?
22 A I talked to Irv DeWald, and I had a few words with I
l
61 o
1 Mr. Marino. He happened to be on the site at the time. And 2 Mr. Paserba, who was on the site at the time.
3 0 Okay. You have identified Mr. DeWald as the QC 4 supervisor. What was Mr. Marino's position at that time, if 5 you know?
6 A He was the Corporate OC Manager.
7 O And Mr. Paserba?
8 A I think he's Regional Manager.
9 0 All right. Were Mr. Marino and Mr. Paserba on site 10 specifically to talk to you?
11 A No. They just happened to be there at the time, and 12 I interviewed with Mr. DeWald, and he showed them a copy of my 13 resume. He told them what my salary requirements were, and 14 Mr. Marino said, "Can we meet his requirements? Does his 15 qualifications meet our requirements?" And Mr. DeWald said, 16 "Yes, we can meet his salary requirements, and he does have i 17 the qualifications, according to his resume."
18 Q Okay. What was Mr. Paserba's involvement in this, 19 if any?
20 A He just happened to be there. You might note that 1
1 21 Mr. Marino's name is mentioned several times and Mr. DeWald's 22 name is mentioned several times, but Mr. Paserba's name is not
62 1 mentioned anywhere. He managed to stay there in the 2 background. I've often wondered about that.
3 O Okay. How long was your interview with Mr. DeWald?
4 A Approximately 30 minutes.
5 0 And what, if anything, did he tell you about the 6 position you would be asked to fill?
7 A He told me I'd be filling a Level 3 QC inspector's 8 position. .
9 0 Had you previously been qualified as a Level 3?
10 A Not as a Level 3, no. I had been qualified as a 11 Level 2 mechanical inspector and as the lead mechanical 12 inspector, Level 2.
13 0 This would be a Level 3 weld inspector, correct?
14 A Yes.
15 O Had yeu been qualifisd prior to this time as a Level 16 2 weld inspector?
17 A Yes.
18 0 So you had had both tne Level 2 weld inspector and a 19 Level 2 mechanical inspector certification, correct?
20 A Yes, r ig h t . Mechanical inspector, they just inspect 21 -- well, at the Zimmer plant where I was qualified, I was 22 qualified as a Level 2 mechanical inspector. We inspected all l
0
O 63 1 the piping and all the structural welding other than 2 electrical.
3 0 So let me make sure I understand. At Zimmer, did 4 you have any responsibility for inspecting electrical -- or 5 welding within the' electrical scope of work?
6 A No.
7 0 Did Mr. DeWald ack you whether you had had that 8 prior experience with respect to the electrical scope of work?
9 A No, 10 0 Did you tell him?
11 A No. But weld inspection, a weld is either good or ca "> ' 7.C3.. - e (,
12 bad, whether it's doneIan elec trical component or whether it's
, 13 done or. a structural component or piping. You have your 14 procedures that you go by, and you inspect in accordance with 15 the procedures that are written.
16 0 Was the structural welding at Zimmer AUS code 17 welding?
18 A Yos.
19 0 And was that AWS D.l.1 that would be the applicable 20 code?
! 21 A Yes.
l 22 0 Okay. Do you remember which edition?
(
s_-
l l
I/~'l 64
\m/
1 A I think it was the '73 edition. It might have been 2 the '71, though. I'm not really sure. '71 maybe it was.
3 0 Okay. At Zimmer, had you had any experience with 4 welding of what I'll call -- and I hope you understand to be 5 -- light gauge material in the structural or mechanical scope 6 of work there?
7 A Yes.
8 0 In other words, the materials that you had 9 experience with at Zimmer were roughly comparable to the ones i
10 that you were going to be involved with at Braidwood, correct?
11 A Yes.
(
\~ 12 What else, if anything, did fir. DeWald tell you O
13 about your duties as a Level 3?
14 A Basically what he told me was that my job would be 15 to work closely with the other weld inspectors, the Level 2s, 16 and that in some cases I may be called on if they had a l
17 conflict in the field with an inspection, such as a weld 18 inspector thinking a weld might be rejectable, the welder 19 thinking that the weld might be acceptable, that I might be 20 called on to go out and look at the weld and make a final 21 disposition on whether it was an acceptable or a rejectable 22 weld.
O
O 65 V
1 O Is this something that you had -- that sort of 2 activity -- something you had done at Zimmer as well?
3 A Oh, yes.
4 0 And this is common in the industry, is it not, to 5 use a Level 3 or a very experienced Level 2 to make these 6 tough judgment calls about the acceptability of a weld?
7 A Yes.
8 0 All right. Anything else that he told you about 9 your duties?
10 A No, not really, other than the fact that I would be 11 responsible for all weld-related activities.
O 12 O Mr. Puckett, to your knowledge, had Comstock 13 employed a Level 3 weld inspector prior to the time that you 1
14 were hired?
15 A No, not for the position that I was filling. I 4 16 think both Mr. DeWald and Mr. Siess is classified as a Level 17 3, but I think it's a classification that they gave him that 18 they didn't necessarily test for.
19 0 Okay. What makes you believe that they didn't test 20 for the Level 3?
. 21 A Well, that is part of the industry. I think that
] 22 there's a requirement that before a person can be the OA O
9
66 1 inspector in some of the projects, before they can be the OA 2 Manager or Assistant Manager, that they have got to have 3 qualifications exceeding the people that work under them, you
- 4 know, so it's just general practice that usually your QA 5 Manager is also classified as a Level 3.
l I
6 0 Did Mr. DeWald tell you why at this point in time 7 they were filling the position of a Level 3 to perform the i 8 duties that you've just described?
9 A No. Just that they needed a Level 3 to perform i
10 these particular duties.
1 11 0 Okay. And at the end of the interview after your 12 talk with Mr. Marino, you were offered the job, correct?
13 A well, yes, in a sense I was offered the job. I told 14 Mr. DeWald that I would like to go back and discuss it with my 15 wife before I made a decision, and that I would call him with 16 that decision. And I went back to my home in Ohio and 17 discussed it with my wife, and we agreed that I would take the 18 position, and I called him and told him as much.
I 19 0 Okay. And in that telephone call, was there any 1
20 other conversation about the substance of your duties, or was 21 it just pleasantries about how glad he was to have you coming 22 aboard and that sort of stuff?
l 1 A Well, that kind of thing, because he's retired Navy 2 as well as myself.
3 MR. MILLER: I would like the reporter to mark this 4 Puckett Deposition Exhibit 6 for identification, a memorandum 5 from Mr. Dewald to tir. tiennecke and tir. Quakie, dated May 4
6 12, 1984.
! 7 [Puckett Deposition Exhibit No. 6
! 8 was marked for identification.1 i
9 BY ttR. MILLER:
! 10 0 tir. Puckett, during your interview with fir. DeWald, i 11 did he show you the document that we have now marked as 12 Puckett Deposition Exhibit No. 6 for identification?
13 A Would you ask the question again, please?
14 0 Sure. During your interview with fir. DeWald, were 15 you shown that document that we have just marked as Exhibit 6?
16 A No, I was not. I was shown this document after I 17 was hired on.
18 0 I see. So can we fix a date, approximately, as to 19 when this interview was?
20 A Well, I was hired on the last part of May. I would 21 say it was the early part of June.
22 0 When you say the document for the first time?
T i
- , . - _ ~, _ _ _ _ _ _ _ _ _ _ _ _ __ _
s 1 A Yes.
2 0 Let's just back up in the chronology. You called i 3 Mr. DeWald, told him you'd take the job, and you'd be there 4 about the 29th of May, is that correct?
5 A Yes.
6 0 All right. And after you processed in as an 7 employee of Comstock, was this document, Exhibit 6, one of the 8 first documents that you were given as background?
1 9 A Well, when you process in, part of your i
10 qualifications is that you've got procedures that you have to 11 review or to read. It's mandatory, required reading.
l
!( 12 In the process of reading some of these procedures l
t 13 and in the process of making little tours in the fabcication 14 shops and in the field during this process of qualification, I i
15 had brought up a few things that I had found in the procedures 16 that I thought were incorrect or not clear.
17 And some of the things that -- the cuestions that I 18 raised -- evidently had been previously raised by someone
- 19 else. fi r . DeWald gave me this to clarif y some of the things I
20 that I was talking about. Some of the things -- the concerns i
l 21 that I had are also concerns that had been addressed earlier.
i 22 0 I see. So when you say "this," Exhibit 6 is what O
69
! l you are referring to?
2 A Yes.
3 0 All right. Can you recall what some of these early 1
4 observations were that you made as you processed in, what some 5 of the procedural problems that you observed were?
6 A I could probably look at this and point out some of 7 them.
8 0 That would be helpful.
9 A Let me see.
10 (Witness reviewing document.]
i 11 Yes. On this background that they have here, I 12 brought up the fact there that they were welding the 13 galvanized steel, the unistrut and cable pans, to structural
-: 14 steel, and they were using a procedure that was qualified in i
15 accordance with D.l.l. And in D.L.1, the material listed, the 16 A-446 wasn't listed in there. And the thickness requirements
, I 17 of the cable pans that they were welding, that procedure 18 should have been qualified in accordance with D. l.3.
t i
19 I can see here, too, that this had been addressed 1
20 previously. This was one of the concerns that I had.
! 21 0 okay. Any others?
22 A I think that's the only one that I had addressed in
, 1 1
I 1 here that I can see, i
2 0 Okay.
l 3 A Some of these are pretty well clear.
4 0 Notwithstanding whether the concern is expressed in 5 Exhibit 6, is your recollection refreshed as to any other
] 6 procedural issues that you identified as you were processing
! 7 in as a Comstock employee?
t 8 A Well, I just -- I brought up several clerical errors 9 that they had in the procedures.
i 10 0 What sort of clerical errors?
11 A well, just small clerical errors like misspelled
) 12 words, fractions that were incorrect, and they had statements j 13 in the procedures that just wasn't pertinent to the type of i
14 materials that was being used. But most of those are listed 15 in one place or the other.
16 0 And when you say they are listed in here, you are 17 referring now to Exhibit 4, which is Inspection Report 85-097 18 A Yes, r ig ht , the allegations that I made.
19 0 Okay. When you made these observations -- well, I 20 take it that for the first few days, you were simply given all 21 the welding procedures and kind of told to or asked to read 1
22 them cover-to-cover and to f amiliarize yourself generally with
}
4
1 71 1 the Comstock procedures?
2 A Yes. The weld procedures and the S&L qualifications
! 3 for the project.
1 4 0 The S&L qualifications?
5 A The Sargent & Lundy L-2790.
6 0 That's the specification?
) 7 A Yes.
8 0 Okay. And, of course, Sargent & Lundy was the 9 architect engineer at Zimmer also.
I 10 A Yes.
11 0 Was there a similarity in format, at least, in terms 12 of the specification?
i 13 A There was similarity inasmuch as I found that S&L j 14 was making some of the same mistakes here that they were l
15 making at Zimmer, and there at the end, they had to say, 16 " Yeah, well, maybe we sere wrong."
17 0 What were those mistakes?
18 A Well, they were just little things, you know, verbal l
i i 19 things that was given over a telephone instead of memos being 20 written and things like that.
21 0 Well, you didn't learn that from looking at the 22 specification.
'O 4
)
72 1 A No.
2 0 Okay. Who were you to report to? Was it to 3 Mr. DeWald? Was he your immediate superior?
4 A Well, no. The Inspection Supervisor was Mr. Saklac, 5 and it was my understanding that I would be reporting to him.
6 0 And that was for all of your activities, including 7 these procedural reviews?
8 A Well, yes. I reported to Mr. Saklac when he was 9 present. Ilowev e r , there was times when he wasn't present; he 10 was tied up somewhere else, and I might be talking to 11 Mr. DeWald or, in some cases, to Mr. Seltmann, who was the OA 12 Manager.
1 l 13 0 Was Mr. Saklac qualified as a weld inspector?
14 A He was qualified, I think, as a Level 2 weld
[
t 15 inspector. I had very little dealings to do with Mr. Saklac, 1 16 though.
17 0 Did you just generally deal directly with 10 Mr. DeWald?
19 A In most cases, I would -- I would go to Mr. Saklac 20 about something, and he'd shrug his shoulders and say, "Well, 21 maybe yod'd better talk to Irv about it."
22 0 And that's Mr. DeWa ld . So you'd just go directly to
73 O 1 him.
- 2 A Yes.
3 O After this initial familiarization process, what was 4 the next step in your employment at Comstock? You read the 5 procedures, and then what did you do? What did you begin i 6 doing?
7 A Well, I was asked on several occasions to help with i
1 8 audits and to do reviews, like the review where the Resident l
l 9 NRC Inspector had found some weld rod slips that he thought l
10 were in noncompliance. I was doing some footwork on that, i
l 11 trying to run down the information that he needed, and running (O ,/ 12 the test facility more or less, and qualifying other weld 13 inspectors to the weld test facility, qualify them to run it.
14 0 Okay.
15 A It seemed that I was qualified to qualify these 16 other inspectors to run the test facility, but I was not i
} 17 qualified myself to do it, or so they told me.
18 0 To do what, sir?
19 A I had to teach them the procedures. I had to go 20 over the procedures with them and tell them what their job i
j 21 would be in the test facility, how to fill out the papers and i
j 22 the forms that were required for weld testing and sign their
_-____._ _ -. . _ _ . - . - - _ _ . _ _ _ . _ . . . _ .~ - _ - - . . ~ - - _ . . . _ _ - - _ - - . _ - . _- _ _._. --.__ __
, 74 1 qualification records, saying that they had, in fact, 2 qualified to run the test facility.
3 0 Okay, but I think you said that you couldn't do it 4 yourself.
5 A well, one of their complaints was that I signed 6 welder's qualification test records as accepting their weld.
7 All I did was sign that I had witnessed a test. By no means 8 did I accept anybody's weld, i 9 And this was not a problem up until right there at 10 the last couple of weeks before they decided to terminate, and 11 then all of a sudden, they started coming up with any kind of 12 issue that they could.
13 I don't think there's any kind of a code requirement 14 anywhere or even -- well, in their procedure, it says that a G c. ~;* Q s n 15 OA~ inspector will witness a test. And at this time, they said 16 that I wasn't qualified.
co~0>p vW' 17 However, we had -(FN inspectors there that were not 18 weld inspectors. They were conduit inspectors, termination 19 inspectors, and configuration inspectors. According to that 20 procedure, they could inspect wolds.
21 0 According to which procedure?
22 A To the procedure for the test facility. I don't
\
l 1
I
75 1 remember the number on it.
2 O The one we were looking at before, 4.7.l?
3 A That might be it, yes. " Welder Performance 4 Qualification Test," yes. That's the one that was changed 5 after I left, j 6 The one that they had when I was there wasn't near 7 as complete as I can see that one is.
8 0 You can tell just by the thickness of the procedure?
9 A Yes. It doesn't seem to be, anyway.
10 0 Were you also doing whatever was necessary, so that 11 you could obtain your certiftt:ation as a Level 3 in this time j 12 period?
13 A Yes, I was going in the field and doing examinations
.l t
14 on welds that had previously not been inspected, and I would l
15 write a report on these welds, either accepting or rejecting 16 the weld, the reasoning for it, and that would be -- I would 17 write up all the paperwork that was required, and then they 18 would have another reinspector to inspect the paperwork and go 19 and actually inspect the same weld that I had inspected and 1
20 see if our findings were the same or somehow different.
21 0 And that's what is called a practical examination?
l 22 A Yes.
O 4
l 0 In addition, you had some classroom work and written 2 tests, did you not?
3 A Yes.
4 0 During the month of June into July, were you 5 spending most of your time on these training activities?
6 A Yes. That and in the test facility.
7 0 Now you had made this initial pass through the 8 procedures in the first few days you were onsite. Did there i 9 come a time when you began a detailed r3 view of the weld i
!, 10 procedures?
11 A Well, there was a time there at the end that I was
! 12 to do a detailed review of the procedures, and I had just qot 13 on the welder qualification test records, worked on it for 14 three days, when I was terminated. That was one of the things 15 that I was supposed to do within the week.
1 16 0 Well, was it a part of your normal duties as a Level 17 3 inspector in training, if you will, in the months of June l 18 and July, to review the Comstock weld procedures, as well as 4
a 1
19 the wolder qualification records?
i 20 A Hell, yes. I reviewed the procedures inasmuch as if 21 a man was going to take a particular test in the weld test
! 22 facility -- that is, he was going to be taking the test in 1
l l
I
77 j 1 accordance with the welder's qualification test procedure, 2 that the welding that he was going to be doing in the field 3 would be done under another procedure, and I would check that 4 procedure to see, you know, that the welding he was doing in 5 the test facility would, in fact, qualify him to do the j 6 welding in the field.
7 0 Okay. So in the course of running the test 8 facility, then, did you have occasion to review -- -
9 A Yes.
10 0 -- all o f the Comstock weld procedures that were in l 11 use in the field?
12 A Yes, I did.
I 13 0 Okay. And did you draw any conclusions about --
14 A Yes. He made some changes to the procedure. They 4
15 had a gentleman who was the Corporate Weld Engineer that dould 16 come out to the site occasionally, and him and I collaborated 17 in writing a procedure, one procedure that would take in all 18 the welding that we done there. But that was still under 19 review when I left. I don't know if it was over accepted or 20 not.
21 0 This was fir. Vogt?
22 A Vogt, clqht.
i
)
- 78 1 0 How many times did you visit with Mr. Vogt during 2 your -- or how many times --
! 3 A I guess I seen him two or three times during the 4 period of time that I was there. He may have been out there i
5 three times.
6 O And he was the corporate Level 3 for Comstock?
7 A Ile was the Corporate Weld Engineer. Ile was their i
8 Wold Engineer.
f 9 0 Do you know what ANSI certification level he was at?
10 A No, I do not.
11 0 Okay. Did fir. DeWald tell you that fir. Vogt would 12 be coming out and that you should be working with him on these 13 procedural changes?
14 A Yes.
15 0 All right. Were there any specific procedural 16 changes that you discussed with 'tr. Vogt the first time that i 17 he was out there?
18 A !!ostly the procedure changes that I discussed with ;
I 19 him was ones where they had clerical errors and things of this 20 nature. And then, of course, the changes wher.o we were 21 incorporating our procedure to where we were going to have one j i 22 procedure qualified -- that is, one qualified procedure that s
I
I j 79 1 you could do all welding to, whether you'd be welding using 2 the E-7018 electrode or using an E-6010 electrode or your 3 E-308 electrode for stainless.
4 And again, like I say, we made some drastic changes 5 there, incorporating all of our weld procedures into the one 6 procedure. But up until the time I left there, they hadn't 7 approved this procedure.
! 8 0 Okay. Were your dealings with fir. Vogt cordial?
9 A Yes.
10 0 Did you believe that he was a knowledgeable weld 11 engineer?
12 A Yes. Mediocre.
13 0 tied io c re . In other words, you felt that you knew i 14 more than !!r. Vogt about some of these issues?
15 A No, not really. But I had been a weld engineer.
16 And for his position, I think that he should have had a few 17 more qualifications than what he reflected to me.
18 0 I see.
I 19 A He might have been a lot smarter than I thought he 20 was.
21 0 Did you ever have a disagreement with fir. Vogt about 22 any technical welding matters that you were discussing?
O l -
80
{'}
'%)
1 A No. In most cases, if I brought something up, he 2 agreed with it.
3 In fact, I wrote a memo, I think, to Mr. Saklac. It 4 was in that group of papers there. It was reflecting the weld 5 filler material that we were doing some checking on. I wrote 6 a memo saying that the welders that used the material were 7 qualified to use the material, so forth and so on.
8 After I left the project up there, he came out and 9 he wrote a memo on the same thing, and it was almost word for 10 word from what I had written.
11 0 That was Mr. Vogt that wrote this?
x 12 A Yes.
13 0 Would you see Mr. DeWald on kind of a daily basis?
14 A Yes.
15 MR. MILLER: I would like the Reporter to mark as 16 Puckett Deposition Exhibit No. 7, a handwritten memorandum
)
17 from Mr. Puckett to f1r. DeWald, dated August 9, 1984, 18 [Puckett Deposition Exhibit No. 7 19 was marked for identification.]
20 BY f1R. MILLER:
21 0 fir . Puckett, I show you a document that has been 22 marked Puckett Deposition Exhibit No. 7 for identification,
81 f's V
1 and ask if that is in your handwriting.
2 A Yes; it is.
3 0 What were the circumstances that led you to make the 4 recommendation that all welding be stopped, that involved A-36 5 to A-446, using the 7018 electrode?
6 A In reviewing the weld procedures that we had, I 7 could not see any procedure that we had that reflected a weld 8 made from A-36 to A-446 material, which is your common 9 structural steel, your A-36, A-446 being your galvanized 10 unistrut and sheet steel that they used for cable trays.
11 0 Is the significance of your recommendation the 12 welding of the two materials or the welding of the two 13 materials using the 7018 electrode?
14 A Uelding the two materials.
15 0 Am I correct that a weld procedure should either 16 directly or by reference indicate the materials for which it 17 is qualified?
18 A Yes.
19 0 That is under the AWS Code; correct?
20 A Yes.
21 0 You gave this to Mr. DeHald on August 9th.
22 A That was under the prccedure - pardon me. The O
~' 82 1 procedure tells you what material can be used with it. They 2 had a procedure. They had technique sheets on the back of the 3 procedure. These technique sheets is what was assigned to a 4 weld paper, telling them to use this technique sheet to weld 5 this type of material. We had no technique sheet that 6 reflected the A-36 to A-446.
7 Q When you sent this memo to Mr. DeWald -- I take it 8 this is a fairly common weldment that was taking place, that 9 is, there was a lot of this kind of welding going on; right?
10 A Yes. In the electrical Comstock, I would say 75 11 percent.
12 O What did Mr. DeWald say, if anything, when he got 13 this memo from you?
14 A He went and looked at our procedures and he agreed 15 with me. I think he sent one of the memos back that I sent.
16 I don't know if it was this one or not. He said he needed 17 more information. He wanted me to tell him what we should do 18 about it. I recommended that we qualify the procedure.
19 We had a procedure in the book, a technique sheet on 20 the back of the procedure, that reflected a lot of the welds 21 that we were doing using this A-36 to A-446, but it was a 22 rejected procedure. The procedure had been rejected by Fr&L.
l f h U
q 83 LJ l Yet, it was in the book and they were using that procedure to 2 do a lot of these welds with.
3 O When you say it was in the back of the book, is this 4 the procedure book?
5 A Yes; it is the technique sheet that goes with the 6 procedure.
7 O Let 's get the procedure out here and make sure we 8 are talking about the same thing.
9 MR. MILLER: I would like the Reporter to mark as 10 Puckett Deposition Exhibit No. 8 for identification a document 11 that on the first page has " Procedure Tracking Sheet, O(_/ 12 Procedure No. 4.3.3, Revision D." Underneath is the date of 13 August 29, 1984.
14 BY MR. MILLER:
15 Q Mr. Puckett, I represent to you this is a procedure 16 that was implemented on or shortly after you were terminated.
17 My own review, which is very inexpert, I'm a rookie in weld 18 procedures, I promise you, suggests to me that Revision D 19 involves some minor changes which are readily discernable from 20 the difference in type face that appears there, but I may be 21 wrong.
22 First of all, I would like you to take a look at it
, ,)
t :
\_/ j I
. . . .. - - -- . ._- - _ .. . . - - . - _-. - -- ~
i 1 and-I have clipped a couple of pages which I will get to 2 later, j 3 Is this generally in the format, the wold procedure l 4 that was in use while you were an employee of Comstock?
5 A [ Perusing document.] Yes. You might note that this t
i 6 technique sheet that they have here, ASTri A-446 to A-500, 1
j 7 Grade B, the A-500 being essentially the same thing as A-36, i
8 it has my initials on it and the date of 7/15/84. This is a e
i 9 procedure-that I changed. The one they had in there before, 4
10 they had submitted these weld tests as a flare bevel groove
- 11 weld, and they were rejected.
12 The same coupons were re-submitted by myself as i
.l 13 fillet walds, and were ultimately accepted.
4 14 O I want to identify the page that we are at, because 4
15 this is a very thick document. Am I correct this is
! 16 Attachment O?
I 17 A Yes, i
i l 18 O That is found in the lower quarter of the page.
t 19 These pages are not numbered. It is about halfway through the i
l 20 document. It is a procedure that has in the originating date j 21 block the letter "C" and' January 17, 1984,'and in the revision 4
22 date block, it has the letter "D" and August 29, 1984, and i
a t l I
i
?
l
< 85 1 next to it, it says "page 10 of 11."
2 You have indicated, Mr. Puckett, that on the fourth 3 line down, on the line that says " Position of welding...,"
4 that your initials and the date of July 15, 1984 appear?
5 A Yes. This was one of the changes that I made when I 6 got there. I found that the procedure they were using that 7 was in the book was essentially the same thing we had, the a
8 same materials, the same test coupons and all, but they had 9 submitted it as a flare bevel weld, and it had been rej'cted.
10 My instruction was to re-submit this as a fillet 4
11 weld, which I did. As a fillet weld, it was accepted.
O
-I 12 O Is this the rejected procedure you referred to?
j 13 A No, that's the accepted procedure.
14 0 In an earlier answer, you referred to a rejected 15 procedure that they were using. Is this the one?
i 16 A A rejected technique sheet. That's part of the 17 procedure. This particular one only deals.with one particular i 18 type of weld using a particular type of material. This 19 particular one is A-446 to A-500, Grade B. The other !
20 technique sheets they have in there are for other types of 21 materials that might be used in construction.
22 O I want to ask you what a technique sheet is. This
] ,
- O
4 l 86 >
t 1 page we have been looking at is identified as Attachment O.
2 is Attachment 0-1 a technique sheet?
3 A Yes. This just shows the different positions of the 4 weld. This gives you --
j 5 0 When you say "this one," we have to be specific or i 6 the record will be a mess. We are looking at the page that is 7 identified as Attachment 0 itself.
i l 8 A That being a vertical weld. It should tell you up 1
i
! 9 here at the top the type of weld that it is , vertical, upward ,
i 10 on about the fourth line from the bottom.
11 O tir . Puckett has been referring to a diagram in a j -
12 block here.
i 2
13 A Yes.
14 0 The next sheet after that is identified as 15 Attachment 0-1. '
i 16 A Rig h t.
17 0 Is that a technique sheet?
18 A That is a technique sheet showing another position.
19 This particular one is also a vertical.
20 0 Let's go on to Attachment 0-2, 21 A This is just a different position.
22 O This is the horizontal position?
i i
. , . . _ . , . . . . . . . , . _ . .. , . . . - - - - - - . _ , . _ . . _ . , , _ - - . _ - . - - - - - _ , . - - _ - _. , ~ - - . - - -
87
\j 1 A Yes, horizontal or overhead.
2 0 Overhead. I'm sorry. The aext one is Attachment 3 0-3 4 A That is the horizontal.
5 0 Attachment 0-4.
6 A The flat position. That ends that particular O 7 series.
8 O Are these welding proc 9 dure specifications and the 9 associated technique sheets, which the title for them is 10 " Welding Procedure Qualification Test Record," are these ones 11 that we have been looking at, Attachment O and 0-1 through O)
'ss , 12 0-4, welds that are commonly made at Braidwood?
13 A Yes. I think this is actually a procedure 14 qualification record. A welder's qualification test record is 15 entirely different.
16 0 If I said " welder," I beg your pardon. I meant to 17 say welding procedure qualification test record.
18 A Yes.
19 0 In an earlier answer, fir. Puckett, I think you said 20 A-500 B material is virtually identical to A-36?
21 A Yes. The problem here was the A-446 This 22 procedure was qualified in accordance with AWS D.l.l.
O i >
G
88
(~')
Iv/
1 According to AWS D.l.1, they give you a list of materials in 2 there that you can qualify. A-446 did not appear in D.l.l.
3 It, however, did appear in AWS D.l.3. fly question to them . nd 4 my concern was why they did not qualify some of these 5 procedures in accordance with D.l.3, as required by the Code.
6 0 Was AWS D.l.3 a part of the Sargent & Lundy 7 specification?
8 A They have it mentioned, I think, in their 9 specifications. In fact, I think this was addressed to 10 Sargent & Lundy in one of the letters we were looking at here 11 earlier. They may have -- I think it might be in ,there, it
,a k-m 12 was addressed to Sargent & Lundy. They were going to make a 13 disposition on it.
14 fly problem wasn' t that Sargent & Lundy was going to 15 make a disposition on it. It was just the fact that welding 16 was being continued on these components before any procedural 17 changes were made. What I wanted was to stop work on it, make 18 all the paper right, let 's make the procedures right, and 19 let's make the welder's qualification eight, and then contir'ue 20 the work.
21 O I understand that. I am trying to work my way 22 through this materials issue, if I could.
V
N 89 1 MR. MILLER: It is 1:05 p.m. I think this is 2 probably going to involve a rather prolonged educational 3 process for me. Why don't we break for lunch and come back.
4 What is a reasonable time? Why don't we come back in 45 5 minutes.
6 (Whereupon, at 1:05 p.m., the deposition recessed 7 for lunch, to reconvene this same day at 1: 50 p.m. ]
8 9
10 11 12 13 14 15 16 17 18 19 20 21 22
fT 90 V
1 AFT ERN 00N SESSION 2 [2:00 P.M.]
3 Whereupon, 4 WORLEY O. PUCKETT, 5 having been called for examination, and having been previously 6 duly sworn, resumed the stand, and was further examined and 7 testified as follows:
8 EXAMINATION 9 BY MR. MILLER: [ Resuming}
10 0 Mr. Puckett, if you turn to Section 5.5.1.2 of the 11 AWS Code. That is the paragraph which gives direction on how
(~x
\w- 12 weld procedures are qualitied with respect to the materials 13 that are used; is it not?
14 A Yes.
15 0 Am I correct that there are certain materials under 16 the ASW Code that are in a sense pre qualified?
17 A Yes; that'.a all these paragraphs, all these diagrams 18 you see over here, all this is pre qualified, all those 19 procedures.
20 Q There are certain materials as well that are 21 pre qualified, are there not?
22 A Yes.
1 a
t i
1 91 I 1 0 There is reference in paragraph 5.5.1.1 to Section l
) 2 10.2, as giving you a reference list of base metals that are i
i 3 prequalified; right?
f 4 A Yes.
4 5 0 Would you turn to that for just a second? That is 6 Section 10.2.
7 A 10.2, page 107, i
j 8 0 Right. In that table of materials, both ASTM A-36 9 and ASTM A-500 are listed, are they not? j
! 10 A Yes.
, 11 0 Do you know whether ASTM A-36 has a tensile strength
! /'
12 that is equal to or less than the tensile strength of A-500 ,
j 13 material - yield strength?
14 A I would say that the A-36 is probably pretty close 15 to the same as the A-500.
I 16 0 Is it then correct that under Section 5.5.1.1, that l
I 17 qualification of ASTM A-446 with A-500 also serves to qualify l~
18 A-446 with A-36?
19 A Well, it depends on how you look at it. Look down
} 20 here [ indicating), this is limitation of variables. This is
, 21 the-variables that you have to meet. 5.5.1.3 on page 45, it 22 says " qualification of a weld procedure established with the r
1 4
i 1-_.__ _ _ . , ,_ ----_ __. _. _ , . _ . . . - _ -
92 I
1 base metal included in 10.2 having a minimum specific yield !
1 i 2 strength greater than 50,000 psi shall qualify the procedure i 3 for welding only base metals of the same material i
4 specification, grade or type." j 5 0 May I have that back for just one second, please.
- 6 Am I correct that the distinction between 5.5.1.1 7 and 5.5.1.3 is whether the yield strength of the material is
, 8 greater or less than 50,000?
, 9 A Greater than, i
j 10 0 5. 5.1.1 deals with 50,000 psi yield strength or i.
l 11 less; correct?
12 A It's mentioned in 10.2, the materials that are 13 listed in 10.2. My contention was at the time when we had i
i 14 this out there at Braidwood, in 10.2, it did not list A-446 1
i
} 15 material. There was some materials there, I'm sure, that had *
- 16 yield strength that were greater than A-446 I wasn't i
i 17 arguing that. I was just going by the note down here that i
i
, 18 says if you- change a type or a grade, this is saying that a }
! 19 procedure has got to oa re qualified, if you change a grade or i
j 20 type of material, other than those listed in 10.2 That tells 21 me that you cannot substitute A-500 for A-446, 22 0 The substitution would have been A-36 for A-500; 4
!O
(~] 93 V
1 correct? That's what we are talking about.
2 A Yes. My problem was the A-446, that was the sheet 3 steel.
4 0 That had been qualified for use --
5 A In accordance with D.1.1.
6 O To weld the A-500; right?
7 A Yes.
8 O As I understood your concern, this --
9 A I was the one who had this change made, because of 10 the problem we had there. I had this change made. This was 11 not in effect when I was there. It was just being finished t
g-'s
\m- 12 and just being accepted, 8/29/84 13 O This indicates that Revision C, which is the 14 revision before this, is dated January 17, 1984, and we have 15 already discussed your note, which is dated July 15, 1984 To 16 your knowledge, were there other changes made in the procedure 17 between January 17, 1984 and July 15, 1984?
18 A Not that I know of.
19 O For the record, we are referring again to 4ttachment l
20 0 in Puckett Deposition Exhibit No. 8. You will have to help 21 me, because I really have a difficult time understanding this.
22 To your knowledge, does A-36 material have a yield Q
i ,
'O
m 94 kv )
1 strength greater or lesser than 50,000 pounds per square inch?
2 A I'm trying to think. A lot of this stuff is behind 3 me a long time. I would say that is has greater than. It 4 would be greater than; yes. I get the filler material messed 5 up with the actual base materials.
6 Yes; it has a greater yield strength than 50,000 7 psi.
8 [ Discussion off the record.]
9 BY MR. P1 ILLER:
10 0 fir . Puckett, I would like to return briefly to 11 Puckett Deposition Exhibit No. 4 for identification, which I
(_sl 12 believe is the Inspection Report 85-09 I draw your attention 13 to page three and onto page four. As I say, I know this is 14 the first time you have seen this document.
15 Can you tell from looking at the write-up on that 16 allegation, whether the Inspection Report concludes that 4-36 17 material has a yield point of greater or less than 50,000 psi?
18 A Well, there was a Nonconformance written on this.
19 The electrical contractor, LKC, issued a Nonconformance 20 Report, NRC 3099 I was instrumental in this Nonconformance 21 Report that was written on this. It was in fact written off 22 " accept as is" or "use as is."
/~
d
's 95 1 They said that if you had a procedure where you had 2 your A-446 welded to A-500, that is the same as having A-446 3 welded to A-36, which I said is fine, and they said, we have a 4 procedure, Attachment H of this.
5 O That is the other clip I have.
6 A They said we can use Attachment H. I brought to 7 their attention at that time, even though they accepted it, if 8 you will note this note on here, it says "3/8 minimum size 9 fillet weld." In other words, the minimum size weld you can 10 make using th a t technique sheet is 3/8. Ninety percent of the 11 welds that were being done to the sheet steel was quarter
{}
k- / 12 inch. That technique sheet would not be suitable for doing a 13 weld, A-446 to A-36 or A-500, 14 O That is a separate issue about the minimum weld 15 size, was it not?
16 A Section 5.5, A-36 is also qualified for use with 17 welding procedure specification Attachment H. The 18 Nonconformance Report said use H to do the welding. I told 1
19 them at that time you can't use H because you are doing a 1 l
l 20 quarter inch fillet weld, and th is is for 3/8 minimum. 1 1
21 O Is there any limitation on the size of the fillet 22 weld that can be used under Attachment O?
l r
96 1 A No, not at that time. They didn't have that -- this 2 technique was not there at the time. The weld they had there 3 previously to that, the same thing you can see there, that is 4 the variables are almost all the same, the positions, and the 5 only change that was made, it was changed from a flare bevel 6 to a fillet.
7 0 That occurred on July 15th, as you previously 8 testified; correct?
9 A Well, close to that date. This was brought up on 10 8/29/84. It looks like two days after I was terminated. They 11 finally accepted this. I made this change so this would be k 12 acceptable to use. I made the allegations originally when the 13 Nonconformance Report was written. We had nothing to weld 14 this steel with that was acceptable.
15 0 What I am trying to understand is the sequence of 16 events, Mr. Puckett. I know you are attempting to help me and 17 this is a technical area.
18 As I understand it, when you came to the Braidwood 19 site, Attachment O was qualified as a flare bevel groove weld?
20 A Yes.
21 O It had failed, as far as FTL was concerned?
22 A Yes.
/-
Uy
97 1 0 It was not available for use by welders?
2 A Yes, it was available. It was in the procedure just 3 as that is.
i 4 0 In that case, they were using a rejected procedure?
I i
5 A Yes. t 6 0 At your initiative, it was re-submitted as:a fillet 7 weld procedure on or about July 15th?
i 8 A That is when I made this change up here j 9 lindicating). It was submitted probably around that date. It j 10 was finally accepted 8/29/84 I just made a change up there
$ 11 in the positions.
("
- 12 O When we say the position, 1-F, 2-F, 3-F, 4-F, "F" J
13 means fillet weld; does it not?
14 A Right. I think when the girl typed it and submitted l 15 it originally, she had_l-G, 2-G, 3-G there.
16 0 Those are flare bevel groove welds?
17 A Groove welds, i
l 18 O Mr. Puckett, I am looking at Attachment 0-1, are a
19 those your initials up there also, and is the date July 5th on I 20 that one?
1 l 21 A That's what it looks like. '
e
\ l l 22 MR. GUILD: It looked like the 5th on the other one, i
t 4
t
_ _ _ . . . - - . , , _ _ _ - . , _ _ . _ . . _ _ _ _ _ _ _ _ _ _ = _ _ . . . .,_ _ _ _ - - -
I
! l l
j.
O 1 too. You said the 15th.
2 BY MR. MILLER:
l 3 0 I did say the 15th, and the witness agreed with me.
i 4 A I never really looked at it real close. It is J
5 customary any time you make a change to a document like that 6 that you initial and date it.
7 0 After it was re-submitted as a fillet weld
(
8 procedure, do you recall how long it took before it was 9 finally approved?
8 f
10 A They lost the papers first. I had to go run them i 11 down. They had part of them. PT&L was supposed to have l s_/ 12 returned the papers to me and I would take them to the vault.
j 13 It seems that they sent Sargent & Lundy two of the technique i
j 14 sheets, two of the four, and the other two went to our vault.
i ,
j 15 Uhen we starting having problems with this, this is 4
16 when I went back to Fr&L and started a tracer on all this 17 stuff and finally ended up with all the papers that we needed j 18 for the procedure.
i i 19 0 Let me go back, if I may, to Exhibit No. 4 I'm not j 20 certain that you really answered a question I asked, as to 21 whether or not you can tell from looking at this, just i
) 22 focusing on the yield strength of the material, whether the I
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i i
a i
. , . , _ _ _ - , - . , . _ - , , . . . . . . - - - , _ . . . . . . - , , - . , , . . . ~ . ~ - - , _ - . , - . ,,. ,,, -, , , . , . . . . . - , _ , . . - - - . . . - ~ ., , _ _ ,,
C\ 99 kj 1 NRC Inspector who wrote up this Inspection Report believed 2 that A-36 material had a yield point of greater or less than 3 50,000 psi.
4 A I would say that he knew it was greater than, 4-36 5 is greater than.
6 MR. MILLER: I would like the Reporter to mark as 7 Puckett Deposition No. 9, a memorandum from Mr. Puckett to 8 Mr. DeWald. I am going to represent that the date is August 9 10, 1984, because Mr. DeWald's reply is dated August 11, 10 1984 The dates are not very clear.
11 [Puckett Depos it ion Exhibit No. 9 x- 12 was marked for identification.]
13 BY MR. MILLER:
14 0 We have already looked at'Puckett Deposition Exhibit 15 No. 6, which is a handwritten memo dated August 9th. Now I am 16 going to show you Puckett Deposition Exhibit No. 9, and ask 17 you if you sent the top half of that memo to Mr. DeWald on or 18 about August 10, 1984?
l 19 A [ Perusing document.] Yes, I wrote it.
1 20 0 Then you received the reply back from Mr. DeWald the 1
21 following day or so; is that correct?
22 A Yes, the same day, it looks like, 8/11. His date rs O
-J--
100
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'm l and my date is the same.
2 O Is it the lith? It looked like the 10th up here.
3 It actually looks like the 16th, but I know that is not 4 right. It is either the 10th or the lith that you sent it to 5 him; right?
6 A Yes.
7 Q I guess my question is why on the next day did you 8 send another memo?
9 A This was on a different procedure.
10 0 were you still doing your research on August 9th on 11 the stainless steel?
\~' 12 A Yes. I was aware that it had problems, but I wanted 13 to dig into it and make sure there wasn't some other documents 14 somewhere that reflected they had a better procedure than what 15 was in the book at the time.
16 O After you sent Mr. DeWald the August 9th memo, did 17 he say anything to you to the effect of, if you have any other 18 problems, let's hear about them quick so we can get them all 19 resolved, or anything like that?
20 A I don't really recall what the conversation was at 21 ~ the time. I know at the time I sent him this memo, he called l
22 me down to the office. He went into the procedure manual, ts
(
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101 U(N 1 which you have. I showed him in there the rejected procedure 2 that we had, which was item O in the back, and I told him that 3 would have to be changed and to come up with a good procedure.
4 Later on was when I wrote the one on the stainless steel weld 5 procedure.
6 O Had you not identified to Mr. DeHald the 7 re-submission of the Attachment O procedure as a fillet weld 8 procedure in July when you did it?
9 A I had submitted it to PT& L f or testing.
10 Q You hadn't told Mr. DeWald?
11 A Yes. He was aware of it. I told him I was waiting (g
N/
)
12 for the results. I kept waiting for the results and never got 13 them. That's when I went to PT&L and said, where are they?
14 When they send out anything from PT&L, they had a sheet saying 15 "we sent this to". Meanwhile, I had two of these technique 16 sheets O returned to me by an employee of S&L. They said 17 somehow they got over to our place. I later found the other 18 two in our own vault, that had gotten by me without my seeing 19 them.
20 Q Did you consult with Mr. Vogt about either of these 21 procedural problems? ,
i 22 A I may have just in talking, I might have mentioned ,
1
fg 102
\~J l we had problems; yes.
2 O Did you discuss it with anybody else?
3 A No, not really, other than other inspectors that 4 would come up and ask me about it. They did that quite 5 frequently there, before I was terminated. If they saw 6 something in a procedure that they were not sure about, they 7 would come and ask me about it. I would say it was about 8 75/25 in favor of the company, in favor of the procedures.
9 0 You mean 75 percent of the time they thought -- what 10 do you mean?
11 A About 75 percent of the time, the procedure was okay
('%
(s,) 12 for what they wanted to do. They sometimes had genuine 13 concerns, maybe something in the procedure wasn't exactly 14 right or wasn't explanatory enough for the average OC 15 inspector.
16 O Then there must have been 25 percent of the time 17 when there was a problem?
18 A When there was a problem, r ig ht . Different 19 inspectors came up with the same problems. They found the -
20 same things in the procedures that I did.
21 0 Do you include this ASTit A-36 to A-446 welding 22 issue, did other inspectors raise that?
r'~s 103 C 1 A Yes. One of them asked me about could he use the 2 Attachment O back there. I told him no, it was still in the 3 procedure book, and I told him no, you can' t use it, because 4 it is a rejected procedure.
5 Q Was this before or after you re-submitted it as a 6 fillet weld?
7 A It had been re-submitted, but we hadn't received any 8 results on it. Until such time as you receive'results, it's 9 like not having one at all.
10 Q Do you know when the results were ultimately 11 received? Was it while you were on-site?
f\
\-
m 12 A Yes. I got the completed papers together maybe a 13 week !>efore I left the site, where I had all the papers 14 there. After you receive something like that, it still has to 15 be submitted to the client, you know, and get him to okay it.
16 That would be a revision to the procedure and they have to 17 look at revisions to proceduras and say, yes, it is all right.
18 Q Other than these two procedures, that is the 19 stainless steel welding and the A-36 to A-446, can you 20 remember any other procedures that inspectors specifically 21 questioned you about that were in your judgment discrepant 22 procedures?
m
p 104
%.)
1 A Not procedures per se; maybe in the wording in the 2 body of th e procedure. Basically what we are talking about 3 here is the technique sheets and the back-up procedure. There 4 were some things in there that they would sometimes ask me 5 about.
6 0 Can you recall any specifics as to ones that were 7 discrepant?
8 A No, not specific.
9 MR. MILLER: I would like the Reporter to mark as 10 Puckett Deposition Exhibit No. 10 a memorandum to Mr. DaWald 11 from Mr. Puckett dated August 13, 1984 rh
, s- 12 (Puckett Deposition Exhibit No. 10 13 was marked for identification.)
14 BY MR. MILLER:
15 0 Mr. Puckett, I show you a document that has been 16 marked as Puckett Deposition Exhibit No. 10 for 17 identification, and ask if you sent that to Mr. DeWald on or 18 about August 13, 1984 19 A Yes.
20 Q 'Had you had any conversation -- first of all, I take 21 it this is in response to the bottom portion of the document 22 we have marked as Exhibit No. 9; correct?
i
(~%
, V
105
(_ /
1 g Yes.
2 O Between August 10th and August 13th, did you have 3 any conversations with --
4 A August lith to August 13th 5 0 Did you talk to Mr. DeWald or anyone else about 6 whether a stop-work should be ordered?
7 A I don't really recall whether I talked to anyone 8 else about it or not other than maybe John Saklac, I might 9 have mentioned something to him. He was the Inspection 10 Supervisor.
11 O Is that the same fellow as Rick Saklac?
O
-) 12 A Rick Saklac. I keep saying John, and I don't know 13 why.
14 0 Did Mr. Saklac say anything to you about --
15 A No, just shrugged his shoulders and said, you better 16 talk to Irv.
17 O The usual. .Did you have any conversation with 18 Pir. DeWald about this, other than this exchange of written 19 memoranda?
20 A No, other than I wrote these. He told me to come up 21 with a solution for them. fly solution that these procedures 22 ought to be re qualified and we ought to hold up on the A-446 O
i e
106 l
I 1 to A-36 until such time as we received the test results back l
2 f rom FI& L, the Attachment O we were talking about. Meanwhile, 3 work was being continued. That's when I wrote the letter to 4 Irv DeWald, recommending a stop cf welding on all the welds, f 5 until we could get our procedures in shape.
i 1 6 0 In fact, there was a stop-work order issued on both l
l 7 stainless steel welding and the ASTM A-36 to A-446 material 8 shortly after the 13th, wasn't there?
I 9 A Yes, not because of these memos but because of a 10 Nonconformance Report, where it almost makes it mandatory 11 that you do something about it rather than say, well, you
-l
' 12 know, maybe it will go away.
l j 13 0 Let's get these on the table, if we can.
I 14 MR. MILLER: I would like the Reporter to mark as
- 15 Puckett Deposition Exhibit No. 11, a two-page memorandum from j
16 Mr. DeHald to Mr. Rolan, dated August 15, 1984 It shows a j 17 copy to Mr. Puckett.
i 18 [Puckett Deposition Exhibit No. 11 l
- 19 was marked for identification.)
i
! 20 BY MR. MILLER:
i i
21 O Mr. Puckett, did you receive a copy of th a t l;
! 22 memorandum on or about the date it bears?
I 4
t a
107
(}
\_/
1 A Yes, I received a copy of this. Basically Irv 2 DeWald is saying that everything I have said in the memos and 3 the Nonconformance Report is true.
4 MR. MILLER: Let's mark as Puckett Deposition 5 Exhibit No. 12 a four page document, the first is identified 6 as " L. K. Comstock NCR 3099," dated August 17, 1984.
7 (Puckett Deposition Exhibit No. 12 8 was marked for identification.]
9 BY MR. MILLER:
10 0 Mr. Puckett, I show you a document that has been 11 marked Puckett Deposition Exhibit No. 12, and ask you whether
,r\
(_ / 12 that is the NCR which was initiated with respect to the 13 welding of ASTM A-36 to A-446 material?
- 14 A Yes.
15 O That NCR was initiated by Mr. Miner at your request; 16 is that right?
17 A Yes.
18 Q Did you discuss the initiation of that NCR with 19 anybody else prior to the time you had Mr. Miner sign that for 20 you, other than him?
l l
21 A Irv DeWald, I may have mentioned to him that I !
22 thought a Nonconformance Report was -- I may have; I'm not
-~ 108 U 1 sure. Miner is the one who worked with me in the test lab. I 2 was qualifying him down there. He was dealing with welders' 3 qualification at the time. I explained the situation to him.
j 4 I showed him the procedure. I requested that he write this l
5 NR. I wasn't qualified. They wouldn't accept an NR from me.
6 0 In effect Mr. Miner acted as your proxy for this 7 NCR?
i 8 A Yes. May I say something about this?
a 9 O Certainly.
i j 10 A We discussed this with David E. Brandt. I'm not 11 sure of the name here. He made the disposition on the i
i .
12 Nonconformance Report. He said "Per attached speed letter i
) 13 from PCD..." --
1 14 0 We will get to the speed letter. I will have all 15 the documentation.
{
i i 16 A I was just going here on the explanation and 17 j1stification. Welding of A-36 to A-466 may proceed per 18 parameters specified in WPS H and O. You might notice on the i
j 19 Nonconformance Report here, that O is the one in the back i
l 20 that I had to remind them at the time was a rejected i 21 procedure, they couldn't use it. H, you might note, is the l 22 one I showed you a minute ago, that could not he used for a i
l l- l i
1 .
i 109 I weld under 3/8 in size. '
l 2 In essence, this disposition was also incorrect. It i
3 still violated the procedures.
4 MR. MILLER: I would like the Reporter to mark as i1 5 Puckett Deposition Exhibit No. 13, a memorandum from Mr. Rolan
) 6 to LKC Supervision, dated August 17, 1984, at 1:45 p.m.
I 7 [Puckett Deposition Exhibit No. 13 i
8 was marked for identification.]
9 BY MR. MILLER:
10 0 I show you a document that has been marked as l 11 Puckett Deposition Exhibit No. 13. Did you see the document i
j 12 on or about August 17, 1984, the day it was issued?
13 A Pretty close to that time; I did see the document.
14 0 That references, does it not, as the authority for
- . 15 the stop-work, the 'lonconf ormance Repor t 3099, Exhibit l 16 No. 12, which you initiated; correct?
4
! 17 A Yes, the same day the Nonconformance Report was j 18 written. The Nonconformance Report initiated this reaction 19 from Mr. Rolan.
4 20 0 Of course, Mr. Rolan had some advance warning of 21 this from the memo Mr. DeWald sent him two days earlier, which 22 was also based on concerns you expressed; correct?
4 4
J n- . . . . , - - , -, - e v - , ~ ~r - ww - , e, g--,V -
, - . ,- , ,~ , . - -
t 110 i
l 1 A Yes.
i
, 2 0 Is it fair to say up to that point, Comstock was 3 responding to the concerns you expressed and following the 4 recommendations you made?
, 5 A Not the type of response they should have had. I 6 wrote the memos. The memos should have stopped it. We 7 shouldn't have had to go to an NR, where they were forced to l
j 8 stop work.
9 0 In other words, the memoranda that you are referring l
10 to are the August 9th --
, 11 A He kept sending them back and saying explain a 4 / 12 little more, meanwhile, work was still being performed in the l
13 field using these procedures that were doing no good. To stop 14 the work, a Nonconformance had to be initiated.
15 O Mr. Puckett, did you have a concern about the safety i
16 significance of the welding that was taking place in the field 17 during this interval between August 9th and August 17th?
18 A No, not really. It's just that I knew, being in 19 the position I was in, as a Level 3, and a professional, that l
20 there would come a time when I would be held accountabl e f or 21 all weld related activities from the time I was on the site.
22 O Therefore, you wanted to make certain that the f
1
-m._ . _ _ _ . , _ . ._, _,- .._,. . ,__,,__ . _ _ _ _ . . _ _ _ _ .
'h 111
{d 1 procedures were just right in accordance with --
2 A I had been down that road before with the NRC at 3 Zimmer, and I knew eventually they would be coming back to me 4 and say, why did you let this happen, you know, you and your 5 regime.
6 0 Had you ever talked with Mr. DeWald about your 7 experience at Zimmer as a basis --
8 A Yes; quite often. I told him the reason I am 9 reporting this to you is this is one of the things that we 10 were dinged with at Zimmer. It was one of their concerns 11 there, there is no reason why it shouldn't be a concern here
(- 12 as well.
13 0 In order to disposition this, to talk about the 14 technical solution to this NCR, there was a meeting convened, 15 was there not?
16 A Yes.
17 0 You attended that meeting?
18 A Yes, I did.
19 MR. MILLER: I ask the Reporter to mark as Puckett 20 Deposition Exhibit No. 14 what appears to be minutes of a 21 meeting which took place on August 22, 1984, and signed by l i
l 22 Mr. DeWald. I
(
uj j
112
(N
\ )
1 [Puckett Deposition Exhibit No. 14 2 was marked for identification.1 3 BY MR. fiILLER:
4 O Mr. Puckett, I show you a document that has been 5 marked as Puckett Deposition Exhibit No. 14, and did you get a 6 copy of these minutes on or shortly after the 22nd of August?
7 A Yes; I did.
8 O Some of the people -- is there somebody from Sargent 9 & Lundy who was pot forward as a welding expert?
10 A tir . Laudon and Stu Clavins was there.
11 O Had you met !!r . Loudon before?
O)
(v 12 A Yes.
13 Q Had you met Mr. Clavins before?
14 A Yes.
15 0 In what connection?
16 A Mr. Loudon, I have known him quite some time. I 17 knew him from Zimmer.
18 O Does he have a level certification as a weld 19 inspector?
20 A I think he is a weld engineer, is he not? I think 21 he is a weld engineer.
22 O It's just not the protocol in these depositions to O
v
eN 113 t \
V 1 ask people who are not under oath to respond.
2 A I'm sorry.
3 0 That's okay. Had you met Mr. Loudon at Zimmer?
S aniowood Y-:;t.v8C 4 A The first time I saw him at -44mmer- was at this 5 meeting. Wo 9 gg,y a woo 3 i - >. g -8C 6 0 You hadn't actually met him at &immer-?
7 A No, not prior to this meeting.
8 0 Had you heard about him by reputation at Zimmer, as 9 being a qualified individual?
10 A Yes. I dealt with him quite extensively as the weld 11 engineer there.
p k> 12 O Do you believe he was a competent and qualified 13 professional, as far as welding matters go?
14 A Yes.
15 0 Mr. Seltmann is also shown as being present from 16 Comstock. Did you have any conversation with Mr. Seltmann 17 prior to the time this meeting tock place?
18 A Concerning this, not that I recall.
19 Q Do you recall a conversation in which Mr. Seltmann 20 said to you that if you had a professional opinion that the 21 work needed to be stopped or some other corrective action 22 needed to be taken, that you ought to in effect stick to your I
r^N I
( )
/
I
- -c- .-w-
114
(]
N j' 1 guns and take a hard stand at the meeting?
2 A I don't recall him saying that. I know Mr. Seltmann 3 was responsible if the procedures were going to be changed, 4 the people he had working for him actually made the changes.
5 He made recommendations saying this needs to be changed, but 6 they actually made the changes in the bodies of the 7 procedures. Him and I may have had some conversations wherein 8 I may point out something in a procedure that was incorrect, 9 or maybe it was just a typographical error. He would have his 10 people make these changes, 11 O Do you recall any conversation about this specific
(
%.s' 12 --
13 A I don't recall a conversation.
14 Q Puckett Deposition Exhibit No. 14 indicates that 15 Mr. Gieseker opened the meeting by saying what the subject 16 matter was, but I guess everybody knew that. Is this an 17 accurate reflection of what was discussed at the meeting?
18 A Pretty much so.
19 O This indicates, does it not, that A-36 is to be 20 added to the POR, the Procedure Qualification Record?
21 A Right.
22 O It was to be ready for the Review Board the very A
/~N 115
\v) 1 next day. Do you know whether that was in t'act revised and 2 ready for the Review Board by August 23?
3 A I don't think it was done the next day. The 4 Attachment O was part of that, and we hadn't come up with all 5 the paperwork on it at that time. Some of it was missing.
6 Q NCR 3099 was to be dispositioned, to use only 7 Procedure H; correct?
8 A Yes.
9 O Limiting it to certain weld sizes?
10 A Yes.
11 Q Not to include small welds; correct? Isn't that A) 6
\- ' 12 item D on Mr. DeWald's note?
13 A Yes. They limited it.
14 Q Let's go to E. E on this memo - perhaps you can 15 tell me what your understanding of item E is.
16 A What is the question again?
17 0 Was there going to be another NCR initiated?
18 A According to this, there was. If they initiated 19 another NCR, I am not aware of it. I'm not sure if there was 20 or was not. I don't think there was another one issued. At 21 the time we had this meeting, I disagreed with the disposition 22 of the Nonconformance Report and it is not reflected in here.
f O'
l 116 1 It says it was agreed by all parties involved.
2 O That A-36 would be added to the POR in the next 3 re. vision of -- that much you agreed to, did you not?
4 A Well, I can't really say, just invariably going and 5 changing a procedure that had been qualified months before and 6 adding another material to it -- the way I read the Code, you 7 change a type or grade of material, you have to re qualify the 8 procedure.
9 I disagreed with the disposition of the 10 Nonconformance Report. Had I to do it over again, I would 11 disagree again.
(N/ I 12 0 Did Mr. Loudon suggest or did he make any comment 13 about whether or not this was an appropriate disposition of 14 the NCR?
15 A They asked fir. Loudon about it. I forget the exact 16 question that was asked. Gieseker asked Str. Loudon something 17 about what he thought about it. fir . Loudon kind of mumbled.
18 I'm not even sure of what he said. Mr. Gieseker took it as 19 yeah, it's okay, and they went on that.
20 0 As I understand it, there was one issue that had led 21 to the stop-work, and it was your concern about the welding of 22 A-36 to A-446 material.
)
v
117
(~"3 Qil 1 A Yes, on that particular NR, in that meeting.
2 Q Was that issue, the welding of those two materials 3 together, satisfactorily resolved, as far as you were 4 concerned, at the meeting ? Let's not talk about weld size 5 yet, just the question of whether there was a valid procedure 6 which under a permissible interpretation of the ASW Code, 7 permitted the welding of those two metals?
8 A To my satisfaction, no. The fact of Mr. Gieseker's 9 dispositioning the NR and putting his name on it, that removed 10 me of the responsibility of this weld at a later date, and 11 that's what I was concerned with, along with the procedure
)
/ 12 itself. I did not want to be held responsible for them using 13 a procedure that I still thought was not qualified.
14 Q Did you tell Mr. Gieseker in substance, look, the 15 monkey is on your back now, it is not my responsibility 16 any more?
17 A No, I just told him I disagreed with his 18 disposition of the NR. He made a comment like, I don't care 19 what you disagree with.
20 Q Did he ask Mr. Loudon whether he agreed or 21 disagreed?
22 A It's like I said, he asked Mr. Loudon about the ID V
N 118 (G 1 situation, and something was said. I would not have accepted 2 it as a "yes" or "no." I don't remember exactly the words 3 said. He mumbled something and they asked whether he agreed 4 that these procedures could be used.
5 0 Mr. Gieseker did in fact suggest or followed through 6 on adding A-36 to the PQRs, did he not?
7 A It was done, evidently. I see some changes made.
8 However, nobody initialed them and dated them. To look at the l 9 procedure, that could have been there from day one. The 10 thange was made without an initial and date.
11 0 Don't you understand that a revision to a procedure
(_) 12 is indicated by a bracket in the margin?
13 A Yes.
14 0 Can we agree that in Puckett Deposition Exhibit 15 No. 8, Attachment H, the line which talks about material 16 specification, which is shown as Revision D of the procedure 17 effective August 29, 1984, in fact shows a bracket on that
! 18 first line in the righthand margin, and the words "or A-36" 19 seem to be added in a different type face?
20 A It shows here that a change was made, but it doesn't 21 reflect what the change was. Of course, it was the "or 22 A-36." It's pretty plain. However, whoever made that should A
i l
/~N 119 1 have initialed and dated it.
i 2 O Did you consider requesting that there be an 3 engineering evaluation of the disposition of this NCR 3099 by 4 Sargent & Lundy, before you would be satisfied?
5 A No. Once Mr. Gieseker dispositioned it, he said 6 something to the effect, I don' t want to hear no more about 7 it, I've dispositioned it, this is the disposition.
8 f1R . MILLER: I would like to mark as Puckett 9 Deposition Exhibit No. 15 a speed letter from fir. Gieseker to 10 St r . Rolan, dated August 22, 1984.
11 (Puckett Deposition Exhibit No. 15
)
\~/ 12 was marked for identification.)
13 BY MR. f1 ILLER:
14 Q Did you receive a copy of that on or shortly after 15 its date?
16 A Yes, I received a copy of this.
17 Q Let's go back to Puckett Deposition Exhibit No. 12, 18 and the disposition or the client concurrence, if I am reading l
19 this right, is dated August 23, 1984, "Per meetino on Auqust 20 23, 1984, field is to continue to weld to Attachment H for the 21 weld sizes indicated in Attachment H. Attachment 0 is not to 22 be walded to until approved by CECO in Rev. D of 4.3.3."
/\ 120
\ )
v 1 Doesn't that indicate to you that the ultimate 2 disposition of 3099 was in exact conformance with your 3 recommendation?
4 A This note was added after we had the meeting we 5 discussed. I brought it to their attention that O was not 6 approved, it was a rejected procedure. He marked through 7 that. I mentioned the fact that technique sheet H was for a 8 3/8 inch minimum size fillet weld, and they mention here they 9 are not to use it for anything smaller than 3/8. If they did 10 that, they would be going against the drawings they had that i 11 said a quarter inch weld would be used. You have to go by the I
~/ 12 drawings as well as these type of dispositions.
13 This NR, not everybody sees it. The individual RY 14 inspector in the field doesn't see this NR. He inspects Eer $,* &
15 the procedure and by the drawings. If the drawings say use a 16 quarter inch fillet weld, he inspects a quarter inch fillet 17 weld.
18 0 Wouldn't any weld that was made after August 17, 19 1984, which is the date of the stop-work order, which was 20 outside the sizes that were permitted by Attachment H to weld 21 procedure 4.3.3., be contrary to the disposition of the NCR?
22 A Yes, it would.
O
,-~.,
/ \ 121 V
1 Q Mr. Puckett, do you know whether or not any such 2 welds were made?
3 A No.
4 Q After August 17th?
5 A No.
6 What I was going by is the NR says to use Attachment 7 H. The Engineering Department at that time would stipulate 8 for any weld, use A-446 to A-36 or A-500, that they should use 9 Attachment H. Attachment H then stipulated that you use a 3/8 10 minimum size fillet weld.
11 The only thing that tells them, the individual b)
\. /
12 inspector, any weld you do using Attachment H, it has to be 13 minimum of 3/8, and the only thing that tells them th a t is 14 that NR. The inspector don't get that NR. The procedure
\
15 never changed to reflect what the NR says. All it did was add 16 the A-36 at the top of the page. It did not change the 17 minimum size of the fillet weld.
1 18 0 It was always a 3/8 inch minimum size fillet weld. l l
19 I am looking at Attachment H. l l
l 20 A The welds they were doing using A-446 to A-36 or 21 A-500 was never greater than a quarter inch.
22 0 There was no weld that was 3/8?
(O.)
p 122 O 1 A There was some, but on other components. Ninety 2 percent of the work they had done was a quarter inch fillet 3 weld or smaller.
4 0 As you sit here today, you don't know whether there 5 were any welds made after the stop-work order that were 6 smaller than 3/8 inches?
7 A I don't know for a fact that they were.
8 MR. MILLER: I would like the Reporter to mark as 9 Puckett Deposition Exhibit No. 16, a memo from Mr. Puckett to 10 Mr. DeWald dated August 22, 1984 11 (Puckett Deposition Exhibit No. 16 12 was marked for identification.)
13 BY f1R. f1 ILLER:
14 0 I show you a document that has been marked as 15 Puckett Deposition Exhibit No. 16 for identification. I ask 16 if you sent that memo to Mr. DeWald on or about August 22, 17 1984.
18 A Yes; I did. It was not to be used as an of5icial 19 memo. This was more or less a letter between Irv and myself, 20 as two individuals. He kind of took it a different way. I 21 was just bringing a problem to his attention. I guess he went 22 a little overboard with it.
(m)
%/
123
("s
\,_
1 Q Even though it was just a personal memo, it does say 2 "I strongly recommend that all weldings be stopped."
3 A Yes. I could not stop it at that time myself. I 4 wasn't qualified. He could.
5 O We have a number of documents that we have 6 identified that are dated August 22nd. There was a meeting 7 that took place on August 22nd, and that is Puckett Deposition 8 Exhibit No. 14. There is Mr. Gieseker's memo, speed memo, to 9 Mr. Rolan. That is Puckett Deposition Exhibit No. 15. Now we 10 have your memo dated August 22nd. It sounds like it was a 11 busy day.
d
(> 12 Can you remember the sequence of whether you had the 13 meeting first and then you gave Mr. DeHald this memo, or 14 whether you gave him the memo --
15 A I don't remember the sequence. More than likely, I 16 would have wrote that after we had been to this meeting, and 17 they had made this disposition on the Monconformance Report 4
18 that I disagreed with.
19 0 Why did you send this to Mr. DeWald as k ind of an 20 informal memo, rather than one of the earlier recommendations 21 for a stop-work that were in a speed memo form? Is there any 22 significance?
O
s'% 124
( )
w/
1 A I didn't really mean for it to be part of the 2 record. I didn't mean for it to be filed away as a record, 3 This was just an informal discussion between Irv and myself.
4 Quite often he would be busy, tied up, and I wouldn't be able 5 to go in and sit down and discuss it with him. I could write 6 a letter and get it to him and he could find time to read the 7 letter. I had other things to do at the time, too. I 8 couldn't stand around and wait until he was free for a 9 conversation.
10 0 Prior to the time you sent this memo, did you 11 discuss your concerns with respect to the weld procedures you O
1
(-sl 12 used, galvanized ASTM A-446, with fir. DeWald or anyone at 13 Comstock?
14 A On the tJonconformance Reports, they were addressed.
15 On the memos, they were addressed.
16 0 I'm a little confused. The second sentence of this 17 refers to - you have already recommended a stop-work on all 18 stainless. A-36 to A-446, and then the next category of 19 procedures that you questioned are those that involve 20 galvanized ASTM A-446, 21 A It's the same material, galvanized, A-446, as far as 22 I know, it is all galvanized. That is the materials that we
p
%s 2s l
1 work with there.
2 O Had you raised this overall concern with the 3 application of AWS D.l.1 to this galvanized material, A-446 4 material, prior to that?
5 A Yes. I had talked to Irv before about it. I asked 6 him why they had qualified that procedure in accordance with 7 AWS D.l.1 with A-446 material, when A-446 material is not 8 listed in D.l.l. It was supposed to have been qualified in 9 accordance with AWS D.l.3. He told me that S&L was looking 10 into it, that a memo that had been sent out to them quite some 11 time ago and they were looking into it, and they hadn't A- 12 dispositioned yet just exactly what they were going to do with 13 it.
14 fly concern was work was being done then, using these 15 procedures.
16 0 Prior to the time you discussed this with 17 ftr. DeWald, had you discussed it with anyone else, fi r . Vogt, 18 for example?
19 A I may have, but I can't really recall.
20 0 Did you discuss it with anyone else, to your 21 recollection?
22 A Not that I can recall. Maybe one of the inspectors
126 V
1 was in there and might have asked me a question about one of 2 the procedures related to this.
3 0 Am I correct that the AWS D.l.1 Code is a structural 4 code and generally contemplates the use of thick materials?
5 A Yes.
6 0 AWS D.l.3 is specifically adapted for lighter gauge 7 materials?
i 8 A Yes, they have a completely different set of 9 criteria. The test criteria is different. They have 10 different types of test and the essential variables are 11 different with the D.l.3 Code and the D.l.1 Code.
/~
kNl 12 0 In your professional judgment, Mr. Puckett, is the 13 D.1.3 Code more or less stringent than the D.l.1 Code as 14 applied to these lighter gauge materials?
15 A In some cases, more stringent; in other cases, less 16 stringent, it depends on what you are dealing with.
17 0 What was the first year that the D.l.3 Code was 1 18 issued?
19 A I'm really not sure.
20 0 Do you know whether it was before or after 1975?
21 A I really don' t know.
22 O Do you know whether the use of the D.1.3 Code is i
-s,
\~-]
i
I 127
('~
l mandatory when' welding these lighter gauge materials?
! 2 A I would probably say it isn't mandatory, that the 3 engineer, which would have been S&L, they could have said, 4 qualify it in accordance with D.l.l.
5 O In fact, that is what the weld procedure, Puckett 6 Deposition Exhibit No. 8, references, right on page -- it is 7 the fourth page of the exhibit; correct?
8 A Yes, it references all materials in D.l.1, 1975 9 A-446 isn't listed in D.l.1, 1975.
10 0 The only welding code that is referenced in Section 11 1.0 is the AWS D.L.1, 1975?
12 A Yes.
13 0 In order for any weld procedure to be qualified 14 under D.1.3, that would have to be an acceptable reference 15 under the Comstock procedure; correct?
16 A No, I think it pretty well clarifies it here, saying 17 applicable base metals specified in D.l.1, any material that 18 is specified in D.l.1, you can weld.
19 0 I guess I am not making myself clear. If the 20 Comstock procedure, welding procedure, had purported to 21 qualify specific welding procedures to AWS D.1.3, that 22 reference would have to be included in the list of references?
)
i 128 1 A Right, if they had qualified anything in accordance 2 with D.l.3, it would have been listed as well.
3 Q Your memo of August 22nd says "AWS D.l.1 criteria 4 was never intended to be used to weld materials less than 1/8 5 inch thickness." I would like you to show me where in the AWS 6 D.l.1, 1975, that statement is supported?
4 7 A I don't know if I can find it. I'll give it a try.
8 [Whereupon, at 3:15 p.m., the hearing was recessed, j 9 to reconvene this same day at 3:30 p.m.]
10
< 11 12 13 l 14 15 16 I
17
. 18 1
19 ,
I 1
20 21 !
22 t
1 1
l
! 129 1 BY MR. MILLER:
i j 2 O Now, Mr. Puckett, let me just restate the question.
l 3 The question was: Can you point me to a provision of AWS l
4 D.l.1-1975 which indicates that it was never intended to be 1
t
! 5 used to weld materials less than one-eighth inch thickness?
6 A I can't offhand find it in D.l.l., but I would
- 7 assume that the reason they came out with D.l.3 is to deal 8 with the lighter materials, because that's all it does deal 9 with, is the lighter materials. I a
- 10 MR. GUILD
- Mike, did you say one quarter inch or i 11 one-eighth inch when you asked the question the first time?
I
! 12 MR. MILLER: I thought I said one-eighth inch the i
13 first time as well, because that's what's in the document.
14 It's a one-eighth inch.
15 BY MR. MILLER:
16 0 Your August 22nd memo goes on to say, "In addition i
l!
i 17 to these procedures that I can assure you are not qualified,
- 18 there are so many inconsistencies in the remaining procedures 19 that we are using, that I'm sure their qualification would be
) 20 considered indeterminate."
i j 21 Now earlier today, Mr. Puckett, I asked you whether 22 the list of allegations that are found in Inspection Report 4
i 4
i
0 1 130 85-09, Puckett Deposition Exhibit 4, was a complete catalogue, 2 if you will, of the concerns that you had identified with the 3 welding procedures, and I am going to repeat the question to 4 you again.
5 Is it correct that all of the concerns that you had 6 with the welding procedures, including the many 7 inconsistencies that are referred to in Puckett Deposition 8 Exhibit 16, are reflected in Inspection Report 85-09?
9 A I'm not completely sure. There's one other thing 10 that I noticed in the procedure that has not been changed. I 11 don't know if I listed it on anything or not. I know I did
\") 12 bring it to the attention of a lot of people at one time I was 13 there.
14 Let me see what series it's in.
15 (Pause.)
4 16 It's in the G series. Okay, in the G series, in 17 Procedure 4.3.3. In the attachments, what I refer to as a 18 technique sheet, a procedure qualification test record, by all 19 rights there should be four PORs back there, procedure 20 qualification test records. That is, one reflecting the flat 21 position, one reflecting the horizontal position, one
, 22 reflecting the vertical position, and one reflecting the
'O
O G 131 1 overhead position.
2 I see back here Attachment G.1 through G.10, which 3 gives them ten back there. Some of these are duplicated, 4 which would give the inspector in the field an option. The 5 figures aren't the same on the duplicated forms.
6 0 Are they all --
7 A In other words, tnis one says " flat position," and 8 it gives you a range of essential variables that was used to 9 qualify this procedure. That is on G.I.
10 On G.4, you have another flat position, the same 11 position, different essential variables. This procedure is
~'
12 what the inspector inspects by. So here they're giving him an 13 option: "If you don' t like these heats, use the ones on this 14 paper."
15 0 Well, Mr. Puckett, is there anything to indicate --
16 let me strike the question and start over again.
17 Were both the technique sheets properly approved by 18 Comstock, PTL, and so on?
19 A According to the s ignatures, they were all properly 20 approved by those people who are to approve these. Ilowever, 21 in reviewing the procedure, I don't know why they let these 22 stay in here like this. You hava a revision that is outdated O
4
132 1 that is still in the book that they can use.
2 0 Oh, I see. One of these technique sheets is a 3 revision of another?
4 A Well, it doesn't say as much, but it pretty much has
- 5 to be. You wouldn't hava two of the same thing. You have the i
6 test records over here from PTL on this one flat position.
7 0 Hould you identify the sheet, if you would?
l
- 8 A Okay. This is on Sheet G.4 You have your test 9 criteria there for the -- it looks like it might be a groove 10 weld. That gives you your test requirements. It says that 11 Section 1 was one quarter inch; Section 2 was one quarter 12 inch; Section 3 was 5/16ths inch. Your heat range for welding 13 is 106.25 to 143.75 14 Now you have another sheet over here that says you 15 can weld from 110.5 to 149.5 16 MR. GUILD
- What sheet is that, Mr. Puckett?
17 THE WITNESS: That is G.I. And you have a different 18 set of test requirements up here, which would make me think 19 that maybe these coupons was the same coupons, was submitted 20 twice. The information is incorrect on it. One or the other.
4 21 Now if I was the inspector, I'd say, "Which one do I 22 inspect by? I'm inspecting a flat weld. Do I use G.1, or do
133 1 I use G.4?" There is nothing in the body of the procedures 2 that tells them. And you shouldn't have an option. A QC 3 inspector is supposed to inspect by the procedure. With this 4 procedure being like this, I don't know how he could do a 5 valid inspection.
6 BY t1R. ftILLER:
7 0 Because he had a choice of which technique sheet to 8 use?
9 A Sure.
10 0 Let me ask you a question, Mr. Puckett, along these 11 lines.
b k- 12 The purpose of these technique sheets is to provide 13 the welder, if you will, with sort of a cookbook approach to 14 each individual weld that he's called on to make -- that is, 15 if he follows the instructions and the technigt s that are 16 shown on the sheet, he will wind up with a weld that has the 17 necessary structural integrity; is that correct?
18 A What these are, when the procedure was qualified, 19 this is the procedure qualification. It gives you a list of 20 variables. It says that if you use these variables with this 21 type of filler material, this type of materials, using this 22 heat, using a single pess weld, you should come out with a O
-~ 134 V 1 satisfactory weld.
,, ,, e i - 2 6 - O
2 We have demonstrated that by an inspection ever-by 3 PTL, and they've accepted it.
4 0 Okay. Bear with me for just a second.
5 Let's assume -- well, we don't have to assume --
6 maybe we do.
7 Let's assume that a weld is made using the voltages 8 specified in Technique Sheet G.I. As I understand your prior 9 answer, that would, if everything else was done according to 10 the technique sheet, lead to a satisfactory weld, correct?
11 A Yes.
12 O All right. Let's assume again that a weld is made 13 in accordance with Technique Sheet Attachment G.4, and again 14 all this is followed and the voltages are different, wouldn't 15 that also lead to a satisfactory weld?
16 A It may, depending on the engineer that fills out the 17 paper to do the welding. If he puts on there, "Use Attachment 18 G." You take the position that the weld is in; you go to the 19 technique sheet that 19 involved for that position.
20 In this case, we have two, which gives the inspector 21 an option, okay. If he don't meet the criteria of 106.25 to 22 143.75, does he noot the other criteria? And I'm saying that O
V
)
i i
i
!l I 135 i
1 the inspector should not have to make that kind of decision.
l 1 2 0 Is this a question of the inspector making a 3 decision or the welder himself?
4 l 4 A I'm talking about -- the procedure _could very well 4
l 5 be qualified. According to this and the signature and
.i I
j 6 everything, it is qualified. What I'm saying is, the I
7 procedure in all, as a whole, okay, I would be concerned with I
8 giving an inspector the option of which technique sheet he 1
l 9 could use for the inspecting of a weld in the field.
1 10 0 Did you ever raise this concern with Mr. DeWald?
l 1
i 11 A I spoke to him about it and Mr. Seltmann as well. I i t
t 12 showed him. They said, "Well, let's make some changes in it.
i.
j 13 I spoke to you once before when I was talking to Mr. Vogt, and i
- 14 we were making a change to procedure." All of these changes j 15 were going to be taken care of in the one procedure.
i l 16 I don't think it was ever accepted, not while I was I
! 17 there anyway.
I
] 18 Incidentally, we have three flat out of that G I
19 series. There's three of them that's in the flat position, l
j 20 So he has three set of criteria that he can inspect to. l l
21 MR. MILLER: I would like the reporter to mark as I l
f 22 Deposition Exhibit 17 a document the first page of which is
! i f
l
.- . . . _- . - _ .- .~ . _.- -- _ . . . .-
i
. 136 1 entitled " Procedure Tracking Sheet" for Procedure No. 4.3.3, i'
2 Revision F, and right under there is the date, December 5, 3 1984, i
- 4 [Puckett Deposition Exhibit No. 17 5 was marked for identification.]
j 6 BY MR. MILLER:
7 0 Now I kind of assume, Mr. Puckett, that you haven't i
J 8 seen this document before, and I represent to you that it is a 9 later version of the basic welding procedure.
- 10 A Is this an acceptable procedure? Is this the one
- 11 they're using now?
12 0 I'm inf ormed that it is, and I represent to you --
13 well, I don't know -- it certainly was in use~for a period of 14 time. There may have been subsequent revisions of which I am 15 unaware. But it was in use after its effective date.
? 16 Just looking at it quickly, can you tell whether or 17 not this is the type of format and reorganization that you 1
i j 18 suggested to the wold procedure while you were a Comstock l
l 19 employee?
i 20 [ Witness examining document.]
1 i 21 A Some of this does look familiar. It looks like the q
22 procedure that Mr. Vogt and myself was working on at one time, I, l 1
1 i
a l
s ,
J
)
j i
137 f
1 but I'm not sure that all this here was what we were looking 2 for, i
j 3 0 Well, I understand that you are seeing this for the 4
) 4 first time, and again, it's a thick document.
l
- 5 A Yes, this is the first time I've seen this
( ,
j 6 particular procedure.
s j 7 O Okay. But it does have some elements, at least --
1 l 8 A Some of the stuff in there does look familiar. It i !
9 looks like some of the changes that I recommended be made i
l; 10 were, in fact, made.
1 11 O Now I'd like to go back to the chronology of events l
12 that took place in August, and I think one of the 1
4 j 13 recommendations you made was a stop-work with respect to the
- 14 stainless steel procedure, the stainless steel welding because
. 15 of the lack of a qualified procedure.
4 4
- 16 A Yes, I
17 Q How much, as a percentage of the job, stainless 18 steel welding was going on?
) 19 A I would say a very small percent, maybe three to d
20 five percent max.
21 Q And do you recall how many welders were qualified to i
l 22 that procedure?
4 i
. . . _ . - - , _ . __ - -. . . - ~ ._ __ - ._. . . . - _ . _ . -. ._.
('x 138 V
1 A No, I do not.
2 O Was it every welder onsite?
3 A No.
4 Q Just a few of them who specialized in the stainless 5 steel?
6 A Yes.
7 Q Do you know what the ultimate disposition of the 8 stop-work with respect to the stainless steel welding was?
9 A They were going to requalify the procedure. They 10 were going to qualify the additional position required to 11 qualify the procedure, which was the 2-G position.
-- 12 O All right. And again, G indicates --
13 A Groove.
14 0 -- a groove weld, and various positions are 15 indicated by the numbers i, 2, 3, 4, 5, 6, I auess; is that 16 correct?
17 A well, 1, 2, 3, 4-G is your plate welding. When you 18 get into your 6-G and 5-G positions, you're talking about pipe 19 welding.
20 0 I see. Do you know what the disposition was of the 21 welds that had been actually performed when there was not a 22 qualified procedure?
f% i e
LJ
i 139 1 A No, I do not.
2 O Okay. Now after you-sent the memorandum of August i ,
3 22nd that we've marked as Puckett Deposition Exhibit 16 to 4 Mr. DeWald, did he respond to you?
5 A No, not really on this. He kind of seemed a little 6 displeased to get it. ,
- 7 0 How did he exhibit that displeasure?
8 A well, I mean, just by his attitude. He never really 9 said anything to me about this particular thing. He took it. .
10 The only thing that I heard -- and this was a couple of days i
i 11 later -- I was called into the office, and that's when I i
i 12 talked to Mr. Seltmann. .
13 0 Okay. You sent a copy of this to Mr. Seltmann?
! 14 A Yes.
j 15 O Do you know whether or not he got it?
4 16 A I don't know if'he did or not.
17 0 You say Mr. Seltmann called you into his otfice a 18 few days after this memo?
19 A He was in Irv's office. He called me into Irv's i
20 office. And Irv was my supervisor, and it kind of threw me 21 off there, because Mr. Seltmann was doing the talking, and Irv 22 just more or less stood there, and Bob was doing the talking, 1
3
- - - - . . - - . - - , ,. 7 y , , , _ _ , , _ . y _ ,
t i .
140 I.
I and he said that Mr. Marino was very displeased with me
! 2 writing this letter, and that's when they gave me the j 3 assignment, on that Thursday, to -- the following Thursday, to i
t 4 do all this document research, which I said was physically 1
5 impossible. That was on a Thursday, and I was terminated 6 Monday.
i 7 0 Okay. When this assignment was given to you, did 8 e you tell them it was impossible to do? i 9 A Yes.
10 0 And what was the answer?
i 11 A They said, "Well, you best get started." I asked ;
12 for support, okay. I said, "Am I going to get anybody to help 13 me on this, to help do this research?" And they said, N o 14 support." They had everybody inspecting.
15 And at that time, like I say, they were pushing for
, 16 numbers, t
17 0 When you say " pushing for numbers," what do you j 18 mean, sir?
i 19 A Quantity rather than quality. That was my j 20 impression. They had people working overtime, coming in on 21 the weekends, so f orth and so on. They had schedules to meet
-22 on inspection.
O
l 141 1 O Were these schedules written out?
2 A Well, they just set the schedule. They'd tell 1
3 people, "Come in on the weekend. We're going to be working."
4 4 Yes, they had schedules, they had charts made up on what they
- 5 expected to accomplish over a period of time.
6 They were doing post-inspections in the field, 7 trying to catch up to the current work log. That is, these is
! 8 work that had been performed, in some cases, months prior to, 9 and they were just now catching up on the inspection of this 10 work.
I
~
11 O I see. There was an inspection backlog.
12 A Yes.
l.
13 0 Was that an inspection backlog with respect to welds i 14 or other inspection activities as well?
i 15 A Welds, welding configuration, the whole bit.
16 Everything. Terminations.
I 17 0 Were you ever present when the inspectors were told l
18 that they had a certain quota of inspections to perform in a ;
i 19 set period -- a day, a week, a month?
20 A Not an individual inspector. He had meetings where 21 they sa'id, "Okay, we want to get this done this week," and'
- 22 they would lay out a schedule of what they wanted to get done I
i i
i 142 1 during that week.
) 2 O You mean for the inspection force as a whole?
i 3 A Right. And I mean, everybody was pretty well 4 4 hopping. Everybody was putting in overtime. Some of them i I 5 were working seven days a week.
! 6 Q Did individuals object to working seven days a week?
7 A Some of them did. I mean, you know, some of them 8 wanted more time with their family. Others -- it was 9 mandatory; I mean, you had to have a real good excuse to say, 10 "No, I'm not coming in this weekend." You had to have a good 11 reason, or they expected you to be there.
O 12 O Did anyone in your presence object to coming in?
13 A Yes. You know, guys talking in the office after i
14 work, you know; I heard them mention, you know, "I'd like to I
15 spend a little more time with the family," you know, or in 16- some cases some of the people were comniuting and just going I
17 home for the weekends. They wanted their weekends at home, 18 and in some cases they couldn' t get them. They had to stay in 1
19 town, because they said, "We're going to be working both l
20 Saturday and Sunday."
l- 21 I see nothing wrong with that. I mean, you know, I
- 22 just want to make it clear. I see nothing wrong with it, you l
I 1
i 143 1 know, they had schedules they wanted to meet. All companies 2 do that.
1 3 0 In your judgment, Mr. Puckett, was there ever a I
4 situation in which a quality control inspector was asked to
]
i
} 5 sacrifice the quality of his inspection in order to get the
' 6 numbers --
l 7 A I never witnessed that. I never witnessed any of i
j 8 that.
I 9 0 Based on your observations while you were out there, i
10 was there ever a situation in which, for whatever reason, an
- % 11 inspector compromised that quality of his inspection in order 12 to get it done and move on to something else?
13 A There was an inspector that said that he was. I
]
14 never witnessed it. Mr. Seeders, he wrote a letter. I guess 15 you have a copy of it.
16 0 Yes, we've talked about that with Mr. Seeders at 17 some length.
18 A And he said that he was, but that had nothing to do i
- 19 with me.
20 0 Mr. Puckett, did you turn in weekly or daily status 21 reports to Mr. DeWald?
22 A No.
{.
J 144 j
O 1 0 Did you keep track of your time in some sort of a
[ 2 diary or other timesheets that indicated what you were doing 1
j 3 on each day?
j 4 A Just the pay records. No, nothing to say what I was
- 5 doing each day. Just when we filled out our timesheet, the
- 6 fact that I was there and that I'd put in so many hours.
I j 7 MR. MILLER: I would like the reporter to mark as l 8 Puckett Deposition Exhibit 18 a memo from Mr. Puckett to j
9 Mr. DeWald, dated August 24, 1984 j 10 [Puckett Deposition Exhibit No. 18 j
11 was marked for identification.]
9 12 MR. MILLER: And then as Exhibit 19, it's the same 13 memo with a return message apparently from Mr. DeWald.
14 [Puckett Dep0sition Exhibit No. 19 1
! 15 was marked for identification.]
16 BY MR. MILLER:
17 O Mr. Puckett, I show you two documents that have been 18 marked as Puckett Deposition Exhibits 18 and 19 I represent j 19 that the top half of both of them is identical. It's just 20 illegible on the one because of the quality of the copy.
3 21 But is the top half a memo that you sent to 22 Mr. DeWald on August 24th, asking permission to get into the
145 1 vault?
2 A Yes.
3 0 Okay. And the bottom half of the memo, Exh'ibit 19, 4 is his response which gives you permission to get in there, 1 5 does it not?
l 6 A I may have seen a copy of this after this was filled 7 in. I don't recall. I do remember. sending this. I don't 8 remember getting a copy back that had this on there, but I did 9 have access to the vault.
10 0 All right. Mr. DeWald's memo was addressed to some 11 other person. I couldn't really make it out.
12 A That was Jim. That was the boy at the time that was 13 in charge of the vault.
14 0 I see. All right. And so this conversation with 15 Mr. Seltmann in which he expressed Mr. Marino's displeasure j 16 with your memo of August 22nd, was that on August 23rd?
17 A Well, it was on a Thursday, because I worked the 18 rest of that day, that afternoon. It was about 2:00 o' clock
- 19 in the afternoon when we had this meeting. I worked the rest i
20 of that day, which was a Thursday. Then I worked Friday, and 21 I worked Saturday, and I come back in to work Monday, and it 22 was Monday afternoon when I was called up and terminated.
t
, . _ ..r_, .,w.- , ,,w _ c, , - - , _ . . , .- ,y e _ -- ,m .-,
146 1 0 When Mr. Seltmann told you that Mr. Marino was 2 displeased with your memo, what was your response?
j 3 A I said, "
Any reaction is better than no reaction.'"
i 4 It didn't bother me that he was displeased, as long as we were 5 going to have something done about it.
6 O So in that sense, the research project was, I guess,
! 7 a positive reaction, that they at least wanted to learn about J
8 the problem, correct?
4 9 A Yes, but the time limits given to me with no
- 10 support, that kind of upset me. fly first reaction when we had I 11 this talk and they gave me this time limit, something I knew 1
O 12 would be impossible, vas, "I'm going to quit." That was my 13 first reaction.
14 And then I thought, "That's probably what they want 15 me to do. That way they won't have to terminate me."
i j 16 0 I see. So you just regarded this as a ploy to get 17 you to quit?
18 A I think they wanted me to quit. I mean, that's my 19 own personal feeling. Nobody told me this, okay. But that J
20 would have solved a lot of problems had I quit. But I said, 21 "No, I'll finish this review, if they give me time to do'the
{ 22 review. I'll finish this review. Once I've got the review i
i
_ - - - . _ . . . _e ..
l l
J 147 i l done, then I'll resign." But I was going to complete the i
j 2 review first.
I 3 0 Okay. At this point in time, why had you decided to 4
4 resign?
. 5 A Because the concerns that I had there, they wanted i
6 to just shove them aside and belittle them, make them littler 7 than what they were. And I know someday tha* if I stayed 8 there as their Level 3, the NRC was going to beat me over the t
9 head with those concerns, if they weren't taken care of, i
10 because I had been through this previously.
11 O And once again -- I know I've come back to this a ;
O 12 number of times -- are those the concerns that you expressed
- 13 and that are discussed in that Inspection Report 85-09, 14 Pi r . Schapker's inspection report that we looked at first thing i 15 this morning?
i 16 A Those were the type of concerns that I had, yes.
17 0 Ue have identified a lot of documents today, 18 Mr. Puckett, and I guess what I'd like to know is whether you 4
! 19 can recall any other documents that you authored while you l
20 were a Comstock employee that described the concerns you had l l
21 about welding procedures or welder qualifications?
22 I exclude weld rod control, because there are some iO i
t i f
148 1 documents, and we just haven' t gotten to them yet.
4 2 A Not off the top of my head. I can't remember. I 2
3 initiated a lot of forms, a lot of paper. Mostly they were 4 the read-and-reply type things. I just wanted an answer to 5 these concerns that I had.
i 6 There may have been some others that was issued that
-l 7 didn't really have anything to do with quality, but off the 8 top of my head, I don't really know.
1 9 [ Discussion off the record.}
1 10 BY f1R. MILLER: '
11 O Mr. Puckett, your assignment from fir. Seltmann was i O 12 to do a complete research of the weld procedure, welder 13 qualification records, and the filler metal documentation; is
]
q 14 that correct?
l t 15 A Yes.
16 0 And did they want a -- were you requested to have a l
j 17 written report on that?
j j 18 A Well, I'm sure that's what they'd want. The 1
l 19 procedures themselves, I think they wanted a recommendation ;
l 20 for the changes that was required, any findings that I might j i
21 have in the welders' qualification test records, and any 22 findings that I might have for weld rod filler material
- O f
i I
r~~T 149
'\_/)
1 control slips that were involved.
2 O All right. Now prior to this date, you had already 3 identified two specific procedures that needed to be changed, 4 and, in fact, as early as July 5th, had recommended some 5 changes to weld procedures; is that correct?
6 A Yes.
7 Q All right. When you were given this assignment, 8 which of the three parts to the assignment did you first turn 9 to?
10 A Welders' qualification test records.
r- 11 O Was that because you had already taken a look at J
12 some of the weld procedures and --
13 A I had already started. I had already started this 14 on my own. I had already started a review of these, just a 15 general review, and I thought I would continue it out as I'd 16 already started this.
17 0 Uhen you say "this," is --
18 A The review on welders' qualification test records.
19 0 Oh, okay. With respect to the procedures, did you 20 feel that that would be the second piece of this that you 21 would get to, or were you going to go to the weld rod --
22 A I was going to go to the procedures next.
(D N)
i i
t 1
l- 150 1 0 All right. And did you ever get started on the l
2 procedural aspect of it before you were terminated?
l 3 A No.
t i 4 0 Just to jump ahead of ourselves a little bit --
! 5 [ Discussion off the record.]
6 BY MR. MILLER:
7 O Let me strike the fragment of the question I had 8 pending.
9 At the bottom of the stack, Puckett Deposition 10 Exhibit No. 2, the-handwritten notes and the one typed sheet i
11 that I think you said you completed in terms of your review of t
12 welder qualifications prior to your termination, when you left i 13 on that Monday, did you tell anybody that you completed that i
j 14 much of your review?
15 A No.
I 16 0 You didn't volunteer to make the information j 17 available to Comstock?
18 A No, I did not. They asked me if I wanted to sign an 19 exit statement and make an exit statement, and I said, i SI
! 20 make an exit statement, I would like to have NRC present, a 21 representative. They did not call NRC, so I didn't sign a l
22 statement.
l i
4 i
. . , - , , . . . , _ _ . , , , . . . - . _ . - , _ . - . . . _ . . _ _ m._ . . ~ , , ._,. -,- .,_, _
_ . . . . . . .m -.,,,_m .-
. .. . =.. . _ _ _ - . . . _ - . . -
151 l 0 llow long did it take you to prepare the information
- 2 that is found in Puckett Deposition Exhibit No. 2?
! 3 A The handwritten part, that was from Thursday, when I 4 was requested to do a review, until Monday, when I was 5 terminated.
6 0 The typed sheet headed " Current Welder Qualification 7 Test Records"?
I 8 A I had mentioned to you prior that I had already 9 started a review on this. This had been done approximately 10 three or four days prior to this.
~% 11 O Just in the normal course, you were getting to this 12 review?
1 13 A Yes. Like I say, I had already started a review, i
l 14 These were current welders. Those are the ones I was most i
l- 15 concerned with because they were on the project and they were 16 welding at this time. I was more concerned with those than 17 welders that were no longer there.
18 0 Is this typed list every welder -- maybe I have
) 19 asked you this before, and if I have, I apologize -- is this 20 every welder that was then on Comstock's roster?
21 A Those were current welders on the project during l 22 this period of time currently qualified. I found problems s
l 1
1
,I 4
a 15'2 1 with their welder qualification test records. There was a lot 2 of other welders, but their test records were satisfactory.
3 0 I see. Do you remember what percentage of then 4 current welders this reflects?
! 5 A No, I do not.
6 O Are each of the deficiencies that you observed in 7 the current welders' test records reflected in Mr. Schapker's 8 Inspection Report 85-09, Exhibit No. 5?
9 A I'm not sure all of them are or not. He mentioned 10 that he checked some of these. He never gave a run down by 11 name or anything.
12 O The first name is Richard Cobb, Brass number 525
! 13 Is that the employee identification number or the welder's j 14 stamp?
l 15 A Same. Pardon me. That is the employee's i
i 16 identification number. They have a different stamp or symbol, i
17 whatever.
I l 18 0 The next line reads "WQTR reflects test was A-6G, l 19 pipe test material."
20 A Yes, a 6-G pipe test, materials specs reflect A-36 1
, 22 on the WOTR. "VT" is a visual test. If you do an inspection
\
_ _ _ _ _ _ __. _ _ =- -__ _ __.._ -- _ . _ . _ _ _ _ _._ ___
i-
- 153 i
' on a pipe, there is supposed to be a final. visual inspection.
1 j 2 If he in fact did a test on the pipe, there was no final
]
3 visual inspection performed.
j 4 0 Is this your handwriting up here, the word j 5 " changed?"
i 6 A No.
j 7 MR. GUILD: Where is that?
8 MR. MILLER: On the typed sheet.
- l j 9 THE WITNESS
- 6-G reflects just pipe that is pipe 10 welded. A-36 is plate. It reflected both. It said the test
~
11 was a 6-G position, which could only be pipe. The material 12 they had listed was A-36 to A-36, which was plate. Your pipe P
! 13 would have been A-106.
1 i 14 BY MR. MILLER:
i j 15 O There was an inconsistency between the type of weld 1
! 16 which he tested and the type of material he was supposed to 17 weld for the test; is that right?
18 A There was an inconsistency on the test record 19 inasmuch as I could not determine by looking at the test
!~
20 record what type of test he really ran and what type of 21 materials he used, and if in fact all the tests and 22 inspections were performed on it. The welder's qualification
(
i i
( 154 1 test record should reflect all of that.
4 2 0 The next one says for W. Cobb, same conditions as 3 Richard Cobb, in addition entries made with red ink. What is i
i 4 the significance of that?
i 5 A It goes without saying, it is common practice, 6 especially in the nuclear industry, that you use black ink for i 7 any changes or any forms. You don' t use red ink or green ink 8 or blue ink. It has a tendency to fade with time. These l
9 documents are supposed to be retainable for a good period of 10 time after they are filled out. It is just general practice.
1 11 0 The next one is Charles Capin, corrections made to O
i V 12 WOTR. Can you tell from looking at this what the corrections j 13 were?
14 A I don't remember off the top of my head. If I had 15 the paper, I could look at it and I could show you where the
]
16 corrections were made. Any time you make a correction on a 17 WOTR or any other quality document, you are supposed to 18 initial and date it. There were changes made without initials
! 19 and dates on these records.
- 20 0 I think that also covers Mr. Richard Demel, who is I
t j 21 next. Mr. Eller, the WOTR reflects a six inch Schedule 80 t
22 pipe test. Should the period be after the word " test" and O
V
C') 155 V
1 then a new sentence beginning " material specs reflect A-36 2 pipe?"
3 A Basically, the problem with this is the same we had 4 with item number one. Item number one had some additional 5 things. Mr. Eller said he ran the test in the 6-G position, 6 and yet it reflects plate, which there is no way to get it in 7 a 6-G position. 6-G refers only to pipe.
8 Q The next one says WOTR for aluminum reflects that it 9 was made with consumable insert. What is the deficiency?
10 A We did not have a procedure to do aluminum pipe with 11 a consumable insert. It was an open butt weld over the t
'~' 12 vacuum ring.
13 0 All aluminum welding at the site was non-safety 14 related; correct?
15 A That's what they say. I don' t know one way or the 16 other.
17 0 He qualified only 5-G positions but the form 18 reflects he is qualified in all positions. Was that for the 19 aluminum welding or some other?
20 A Same procedure.
21 0 The next one is Mr. Kempes, qualified in only 5-G 22 positions, WOTR reflects he is qualified in all positions. Is Oi U
156
\_)
1 that for aluminum or stainless steel? Can you tell from 2 looking at this?
3 A I can't tell unless I looked at his welder 4 qualification test record.
5 0 Mr. Kensel, a bend test change from a root and face 6 bend to side bends. What is the significance?
7 A [ Perusing document.] Depending on the type of test 8 you do, it depends on what type of tests are made. You would 9 do a root bend and a face bend if you were working with a 10 small gauge pipe, a large gauge pipe, such as 3/8 inches
(~x 11 thick. If you get to one inch or something like that, ,you 12 can't do a root bend and a face bend.
13 The report had reflected that one type of bend had 14 been performed on the test. Later on, it was changed. It was 15 initialed but there was no date there reflecting when it had 16 been changed.
17 Q The next one is Mr. Manus. WOTR reflects 5-G, 18 qualifies all position. Three inch Schedule 40 reflecting 19 unlimited thickness.
20 A Which means he ran his test in the 5-G position on a 21 three inch Schedule 40 pipe. A three inch Schedule 40, I'm 22 not exactly sure of the thickness, but it is like 3/8 of an
<m N,/l j 1
l
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i 157 1 inch. It would not give him unlimited thickness. It would 2 have to be over three quarters of a inch in thickness to give 3 him unlimited thickness.
4 0 Would this be for pipe welding, plate welding or i
i 5 both?
i j 6 A Both. He could do fillet welds but he could not do
! 7 a partial penetration or a full penetration.
l 8 0 He could --
i i
9 A He would qualify for all size fillets. The 5-G I
l 10 position that he supposedly ran the test in, that only 11 qualifies him in the flat, vertical, and overhead position.
1 12 It does not qualify him in the horizontal position to do 13 welding.
i
! 14 0 To do groove welds or fillet welds or either one?
15 A Groove welds or fillets. The test he took was on a i
- 16 groove weld. He only ran it in the 5-G position. He would I
l
! 17 need the additional 2-G position to qualify him in all 4
18 positions to weld, or had he ran the test in the 6-G position,
! I
! 19 that would qualified him in all positions.
i I j 20 0 The fact that he had taken a groove weld test on 21 three inch Schedule 40 pipe, that did qualify him for j 22 unlimited thickness on plate; correct?
O 1
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.. _ -. .- .._=_. . . . . . -_- . . -- ,_ __ _ _
4 1 A No; for fillet welds.
2 O I'm sorry. I keep saying for plate, and I really 3 mean to say it gives him -- a test in the 5-G position on pipe
) 4 gives him the qualifications to perform fillet welds on 5 unlimited thickness material; correct?
6 A All fillets, all sizes and shapes, with the 7 exception of the 2-G position, which he did not have.
8 0 I think we have it, s
, 9 There is one where there must be a typo on your 4
10 notes. The second name from the bottom, the test was given on 11 three foot Schi --
' O 12 A It is supposed to be Schedule 80 pipe.
13 O Schedule 80 pipe is approximately what thickness, 14 sir?
! 15 A It's not three quarters of an inch thick. It would 16 have to be three quarters of an inch thick or greater to 17 qualify him for unlimited thickness.
18 0 To your knowledge, did Comstock do any pipe welding
) 19 as such in the course of its scope of work?
l i 20 A No, they didn' t do any pipe welding. However, GRn)dSb G.Qs-sc j
21 E. C. Aree44 did qualify some of their welders on pipe in the
!, 22 6-G position, a single position, on three quarter inch wall 4
O
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_ . . . _ . . _ _ _ _ . . . _ _ . ~ _ . . _ _. , , . . . . _ - . _ , ,
I i
l 159
) 1 pipe. It would qualify all thicknesses of structural steel, 2 either full penetration weld, partial penetration weld or all
+ 3 fillets.
4 0 To your knowledge, was there any groove welds that j
l 5 were qualified in the Comstock weld procedure?
3 1 6 A Groove welds, yes. They qualified welders.
l 7 0 I am asking whether there were any weld procedures 8 that were qualified, that contemplated the use of a groove
! 9 weld?
10 A They used mostly pre qualified weld procedures for i 11 that. You did have to have a procedure written up and qualify i 12 your welders to that procedure.
I 13 0 Okay. ,
I 14 A That's with the exception of your flare bevel i
15 welds. Of course, they had to qualify those separately. They
! 16 were considered a partial' penetration weld.
17 0 I guess I'm having some difficulty in matching ;
i 18 the welder qualification to the qualified procedure, and maybe
! 19 there is no match there.
i j 20 If the welder is qualified in the 6-G position on 21 pipe, can he then perform all the welds that are qualified by I
j 22 Comstock weld procedures?
i 1
i l
l i ;
[3 160 U
i 1 [ Pause.]
2 If I've asked a silly question, just tell me, and i
3 I'll try again.
! 4 A No, it's a good question. But it would depend o,n 5 the thickness of the pipe in the 6-G position that he I
l 6 qualified on.
7 O All right.
l 8 A It would have to be three-quarter inch or greater to l 1
9 give him unlimited thickness on any other procedure -- that 10 is, any A-36 or A-106 carbon steel materials.
1 i 11 O Would he be qualified on fillet welds?
i 12 A All fillets.
13 0 Regardless of thickness?
14 A Regardless of thickness, j 15 0 Okay. I've got it.
i
- 16 MR. MILLER: I'd like the reporter to mark as 17 Puckett Deposition Exhibit 20 an undated five page document.
l 18 It's got six columns: Name, Position, Thickness, Brass j
19 Number, Symbol, and Discrepancy. j
! 20 [Puckett Deposition Exhibit No. 20 l l
i
! 21 was marked for identification.]
\
! 22 BY MR. MILLER:
i i
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i . _ _ . _ , _ _ _ _ ._. _. . _ _ - . _ - _ _ . , . . _ . . . ..- - , _ _
(}
kJ 161 l Q Mr. Puckett, I show you a document that's been 2 marked Puckett Deposition Exhibit 20 and ask you if you have 3 ever seen that before?
4 [ Witness examining document.]
5 A I cannot recall ever seeing this document.
6 0 So it wasn't prepared by you or by somebody working 7 for you, then?
8 A No, not that I know of.
9 0 Can we agree, just by looking at it, that it appears 10 to be a roster of welders at Comstock?
11 A It could be. Sometimes it's pretty hard to tell on m.
ws 12 this, though, because where these brass numbers are concerned, l 13 they're used as part of the identification of the welder on i
14 his welder's qualification test form. However, every time a 15 welder terminates and rehires, they change that number. So 16 you could possibly have a welder there that has four or five 17 different identification numbers, brass numbers, and those are 18 listed under the welder qualification test record as an 19 identification.
20 0 I see. They also have their symbol number on those?
21 A No. They did not, prior to me hiring on at 22 Braidwood. I started putting the symbols in there, because O
4
+
162 1
1 that was the correct identifying thing. It doesn't change; it 2 stays the same regardless. A welder can hire on a dozen f 3 times, and he retains the same symbol. It's not used again.
I j 4 Q Did you make this suggestion fairly early in the 5 time that you were at the Braidwood site?
- 6 A Yes, I did.
I 7 0 And who did you suggest it to? Mr. DeWald? .
- 8 A Yes, I suggested it to Mr. DeWald, and then I i 9 started using it myself.
l 10 0 okay.
11 A There was nothing in the procedure that addressed it
[
12 either way.
. 13 O No one objected to your doing so, I take it?
14 A No, j 15 But had I started doing it, and there was something
! 16 in the procedure that said that it was supposed to have been j 17 done a different way, even though that way might have been j
18 incorrect, I would have been incorrect in implementing it. I
- 19 made sure there was nothing in the procedure that says we i 20 could not change it.
21 Q Okay, Mr. Puckett, we talked a little bit earlier 22 today about the practical exams that you took. Some of those j l I
1 i
4
i 163 1 examinations were examinations of actual welds in the field, 2 were they not?
4 3 A Yes.
4 O And you would go out and make your inspection, write 5 it up, and then it would be checked by another Comstock OC
- 6 inspector, correct?
f
- 7 A Yes.
8 0 How was the Comstock OC inspector who would check j 9 your work chosen, if you know?
i 10 A I really don't know.
j 11 O Would you just show up one day and be told, "Well, 12 today you'll take a practical examination, tir. Puckett?"
i l 13 A Well, you had a certain amount of practical that you j 14 had to take, and until you got it all taken, you continued on 15 it, you know. Of course, I was helping with audits and some ,
- 16 other things, and I got this in between time, you.know. When j 17 I had a little bit of time, I'd go in the field and do a 1
18 practical. I would go to one of the Leads and I'd say, "Do 19 you have something that I can inspect out there that hasn't 20 previously been inspected?" And if he had something, he would l! 21 give me the f orm, just as he would an inspector that was going 22 in the field to do an actual inspection.
]
1
4
( 164 I 1 I would go out and inspect the weld and accept it or j 2 reject it and write up the required paper. And then at a i
3 later date, maybe the following day, he would have a qualified 4 inspector to go out and inspect the same weld. And then he 5 would compare the two sets of documentation to see if we both 4
] 6 had accepted it, both rejected it, or one of us had accepted 7 it and one of us had rejected it.
( 8 0 You were on your way to being qualified as a Level J 9 3 I take it there were -- you said that Mr. DeWald and 10 Mr. Seese were Level 3s also, but every other inspector was a 4
Level 2.
p 11 I
12 A Yes.
j
! 13 0 If you disagreed with your examiner's evaluation of 14 the weld, could you discuss it with anybody?
15 A No. I mean, I wasn't qualified as a Level 3 at that 16 time. I wasn't qualified even as a Level 2. I was hired on 17 as a Level 3, and when I completed my qualification, then I 18 would have been a Level 3.
19 O All right. So the judgment of the certified Level 2 20 -- that is, whoever looked at the weld after you had done your 21 inspection ---was dispositive. No appeals, no review of that 22 determination by anyone else?
1 1
d J
165 1 A Well, I might ask him about it, you know. If.his 2 disposition was different than my own, I might ask him about 3 it, but that's all. I mean, you know, what he said, that was 4 law. I can go with that.
5 O I want to just pick up on another point. I think 6 this is the second time you mentioned it, that you were 4 7 involved in audits.
8 Which audits were you involved with?
9 A Mr. Seltmann asked me to help one of the gentlemen 10 that worked for him. I can't at this time remember the name, 11 He was going to perform an audit on welders' qualification and 12 the procedure that was involved with welders' qualification.
13 He didn't know a whole lot about it, so Mr. Seltmann asked me 4
1 14 to help him with this audit.
-i 15 HiM 9 &
So I walked 4* through the test facility and the l
16 paperwork and procedures that we used in order to qualify a l
I 17 welder.
18 O And was that ac*tv.ty - do you remember when that i 19 activity took place?
t 20 A No, not really. It was probably sometime in early i
21 August, the best I can recall.
22 O Was this an opportunity for you to familiarize O
v
l 1
166 0
1 yourself with the welder qualification records?
2 A No . - We didn't look at the welders' qualification 3 records themselves. We were looking at the welder 4 4 qualification procedure that was used for testing welders and 5 those forms that were required to_be filled out when we tested 6 a welder.
7 0 About how much of your time did you take on this I
8 activity?
9 A Well, off and on, with the different things that I d
10 was doing, the reviews of the procedures and the writing of 11 procedures and this particular audit, this particular audit O 12 that you're talking about took most of a day.
13 MR. MILLER: I'd like the reporter to mark as 14 Puckett Deposition Exhibit 21 a four page document. On the 15 first page, there's a signature, George G. Nemeth, date, July 16 6, 1984.
17 [Puckett Deposition Exhibit No. 21 18 was marked for identification.] !
i
~
19 BY MR. MILLER:
20 0 Mr. Puckett, I show you a document that has been
~
21 marked Puckett Deposition Exhibit 21 and ask you if you've t
22 seen it before? ,
rO y -
,, ~ ,-r-- ,,,-,- - , . , - . , , w- -- u -,~. .--,.e ,
e- pe-e .,wa,e nr..m ,
1 167 1 [ Witness examining document.]
2 A I wrote up this part of it [ indicating].
3 -
0 Referring to the second page of the exhibit?
4 A Yes. I wrote this part, the third page, and the I 5 last page is what was given to me to do this inspection.
6 This part evidently was written up with tir. Nemeth.
7 0 Referring to the first page?
8 A Right. Which was grading what I had done on 7/5.
9 This was done on 7/6
- 10 Q Okay. Did he show you his little write-up, the 11 first page of that?
12 A No. To the best of my knowledge, this is the first 13 time I have seen this. I may have seen it; I don't know. I 14 do know that there was a verbal discussion about this, because 15 this particular veld, this one particular weld, I had 16 rejected, because I could not find a welder's stamp on the 17 weld, which is identification markings, okay, saying which i
i 18 welder done the weld.
I 19 At the time I did this inspection, there was two 1
20 other QA inspectors, qualified inspectors, in the same area 21 inspecting. I called them over, and I asked them to look at s
. f y - , -- ->m+- --e- a em , . ,
--9u-- - , - , - .rym-- - w y n w-g-,, 9y., g pgg- -wr e- , 9 97w-g---y=- -*
4 i- 168 1 welder's stamp on this weld anywhere?" Both of them said, no, 2 they could not see a welder's stamp cn it. They looked at it, 3 they inspected the same weld that I did.
4 Both of these inspectors were Level 2s, the same as i 5 Mr. Nemeth. Later, he went back out, and he found welder's 1
6 stamps on the welds, or so he said.
7 0 You never went back and had him show you the stamp?
s 8 A No.
9 O Now on this first page, there is some handwriting 10 that looks different on the bottom half of the page from that 11 on the top half of the page.
12 A I don't know who made that. What was the date on 13 that?
I 4
14 0 Well, it's July 6, 1984 15 A Can I see that again.
16 [ Witness examining document.)
17 Basically what this note means that you have here.--
18 0 On the lefthand side.
19 A --
the way that I would read it is, I would have an 20 additional twenty hours in the field to do inspections,-doing 21 other inspections, you know, and fill the paper out correctly, i 22 O In other words, you would need an additional twenty i vn i .
1
i l
i l
l r~% '
( j)
~~.
169 1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of on-the-job training before you could take the test 2 again?
3 A Yes. Well, no. What it meant - yeah, basically 4 that's what it did mean.
5 Q Okay. Now the other discrepancy that Mr. Nemeth 6 identified was that a DV-2 connection was incorrectly listed 7 as a DV-120, 8 A That was a clerical error. I caught the error 9 before the man got the paper, but he had it in his hand to do 10 the inspection, and I said, "Here, I made a clerical error gs 11 there." He said, "It's too late now."
\.
'~'
)
12 O tir. Nemeth is just a Level 2 inspector?
13 A Yes. It makes you wonder.
14 Q Did you discuss this with anyone else? Did you --
15 A No.
16 Q Did you ever go back to the weld that you had 17 inspected and see whether --
18 A Not this particular one; no, I did not.
19 0 -- and see if you could find this welder ID stamp, i
20 130? l l
21 A No. I did talk to the other QC inspectors that had 22 been there at the time I inspected it, and they inspected it v) 1
170 1 as well. And I told them that he had gone back and inspected, t
1 2 and he said that there was a welder's identification stamp 3 there. And their comment was, " Bullshit."
i
! 4 0 When these stamps are put on, are they done with a 5 punch and a hammer?
1
! 6 A Yes. Low-stress stamps. They usually consist of a i
i l
7 three-digit number. The low-stress stamps are welded 8 together, and a welder has a handle welded.to that, and he
, 9 puts them on or near the weld and strikes them with another 10 hammer.
t 11 0 Had you had any contact with Mr. Nemeth prior to 12 this?
13 A No. I can't recall now. Usually I've got a pretty i
{
14 good recall on faces, but I can't even tie his face to the 15 name anymore.
16 0 Did you understand that you were expected to get a 17 perfect score on this examination to avoid having to take j 18 another twenty hours of OJT and then another test?
i I
19 A No. I kind of got the impression at a later date i
l 20 that I was expected to have a perfect score.
21 0 How did you get that impression?
! l l 22 A Well, I was told that I was expected to do better i k I
i
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1 i
171 !
i I 1 than all the Level 2s, because I was going to be the Level 3 2 And yet there was no criteria that outlined just exactly how l
3 well'I was supposed to do.
4 0 Who told you that, that you were expected to do I 5 better?
5 1 6 A It was in one of the transcripts. I think it was by 7 Mr. DeWald or Mr. Seese during a hearing that I had with the 8 Labor Department.
i i 9 MR. MILLER: All right. It's now two minutes to I
10 5:00. We'll call it a day. He will contact you and try to
]
j 11 arrange something close to your home the next time.
12 [Uhereupon, at 5:00 o' clock, p.m., the taking of the i
l 13 deposition was recessed, to reconvene sine die.)
1
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i 16 l 17 i
! 18 i
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22 i
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( 172 ;
y .
1 CERTIFICATE OF DEPONENT 2
3 I, WORLEY L. PUCKETT, do hereby certify that I have read 4 the foregoing transcript of my deposition testimony and, with 5 the exception of additions and corrections, if any, hereto, 6 find it to be a true and accurate transcription thereof.
7 8 Oo c . PM
- o. ag s-wSU 9 WORLEY 4. PUCKETT 10 l
q 11
.] 12 DATE 13 ***
14 CERTIFICATE OF NOTARY PUBLIC 15 Sworn and subscribed to before me, this the d 16 day of 1/>/u 4/} , 19 [d .
17 18 19 .h A }. )MJh-20 NOTARY PUBLIC IN AN D FOR '//h d"""#^ e 21 My commission expires: fjf,//
22 us'
-4 A *-
g \
[w.J ] 173 l CERTIFICATE OF NOTARY PUBLIC 2
3 I, Ann Riley, the officer before whom the foregoing 4 deposition was taken, do hereby certify that the witness whose 5 testimony appears in the foregoing deposition was duly sworn 6 by me ; that the testimony of said witness was taken by me and 7 thereafter reduced to typewriting by me or under my direction; 8 that said deposition is a true record of the testimony given 9 by the witness; that I am neither counsel for, related to, nor 10 employed by any of the parties to the action in which this
-~s 11 deposition was taken; and further, that I am not a relative or 12 employee of any attorney or counsel employed by the parties 13 hereto, nor financially or otherwise interested in the outcome 14 of the action.
15 16 17 ANN RILEY 18 Notary Public in and for the 19 District of Columbia 20 21 fly commission expires: November 30, 1989 22 O