ML20215J933
| ML20215J933 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/03/1984 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML20215J867 | List: |
| References | |
| FOIA-84-779, FOIA-86-A-219 NUDOCS 8705080339 | |
| Download: ML20215J933 (147) | |
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f BEFORE THE UNY.Yht '3TATES j NUCLEAR RF.UULATORi COMMISSION
(
IN THE MATTER OF: )
} h COMANCHE PEAK. ) .
I THE SWORN STATEMENT OF MR. WILLIAM A. DUNHAM, taken by MR. FRANK HAWKINS, Reactor Inspector, Region 3, and MR. VINCENT LETTIERI, NRC Consultant, on Saturday, the 3rd day of March, A.D. 1984, at the hour of 11:00 o ' clo: k A.M. , in Bay City, Texas.
PRESENT:
MR. FRANK HAWKINS, Reactor Inspector.
l i
MR. VINCENT LETTIERI, NRC Consultant MS. GLORIA APOSTOLOS, Certified Shorthand Reporter.
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1 EXAMINATION 2 By: Mr. Hawkins
, 3 4 C. Why don't we enter the record Bill's 5 address? It's ,
6 is that correct?
7 A. Correct.
8 Q. The purpose of our interview and the getting 9 together with you today is that we understand you hava 10 some concerns and that's based on my discussions with 11 you on the phone and some previous statements that you 12 hcVe provided to th? M.R.C. Office Investigations.
13 And after our review of all that, we have identified 14 several technical issues that we wanted to discuss 15 with you. .
16 What we are trying to accomplish is that 17 we want to clearly define each technical concern as it 18 relates to Conanche Peak.
19 Do you have any open I remarks you 20 would like to make of any sort?
21 A. No.
22 C. Chay.
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4 1 that he wrote as a result of his three-day site visit?
2 A. I have read the report, yes.
3 O. But you have no personal knowledge of how the 4 thing was -- how the report was written or what's 5 contained in it?
6 A. Only that I have read it. That's as --
7 0 All right.
8 Why don't we get on to the specific 9 areas that we are concerned about?
10 One of them is insufficient zine primer 11 cure. Could you tell me a little bit more about that 12 problem?
13 A. Well, it's been my experience in.close to O
14 five years of nuclear that zinc just does not cure in 15 two hours. ..
16 I believe it's possible under the right 17 forced heat conditions to cure it in two hours, but at 18 Comanche Peak it wasn't cured.
19 0. Do you recall what the procedure said as far i
20 as cure of the zinc? !
21 A. Cure will be in accordance with the nickel 22 test and the chart.
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5 1 0. And the chart?
2 A. Yes.
3 Q. What's the chart?
4 A. There was a chart included which gave hours -
5 and temperature.
6 Q. Yes.
7 A. And above a certain point, the nickel test 8 could stand alone, above the dotted line.
9 Well, the nickel test was -- I mean 10 everyone knows how to take a nickel test, every 11 inspector. I mean it's just very basic. ,
12 But we had supervisors telling us that 13 two hours was good enough. They didn't care what we 14 thought. And I took them and I showed them cured zine 15 and I took them and then I showed them uncured zinc, 16 that they were trying to make me buy and, their reply 17 was, "I don't care if it's two hours old and they 18 pissed on it, it's cured." And I said fine.
19 0. But did it pass the nickel test after two 20 hours?
21 A. No.
22 I-took my finger and dug down to the i
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6 1 substrate like that with my fingernail and exposed 2 substrate and he says, " Keep your fingernails out of 3 it."
4 He took me by the hand and he took my 5 hand and applied pressure and he said, "I want you to 6 hold it just this tight, with just enough pressure so 7 the nickel doesn't fall out." And he took his hand 8 and put it on mine in front of the paint department 9 and they are all snickering over there, and he made me 10 buy it.
11 Q. You made a statement prior to this that you 12 felt that the nickel test wasn't being performed 13 properly.
14 A. No.
15 Cured zinc rings like a bell. You can 16 take a nickel, a knife, any metal object and just 17 scrape the hell out of it and it doesn't come off.
18 But they changed their specification to 19 tell you just how to rub the nickel, to lay it fist 20 and slight amounts of zine may be removed, you know.
21 That's not the nickel test.
22 Q. Who was your supervisor that put his hand on COUNTY COURT REPORTER 9, INC.
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7 1 yours and said I want you to apply this amount of 2 pressure? -
7 A. Yes.
8 0. Hou widespread was the problem of 9 insufficient zine primer cure? Was it all surface 10 level one work, or did it occur just in certain 3ress, 11 or was it more widespread than that?
12 A. Well, level two stuff, -- only level one was 13 inspected. NCR because he 14 saw them painting in the rain on level two, and that 15 was invalidated. ..
16 0. Service level two? Is that what you are 17 referring to?
18 A. Right.
19 0. All right.
20 A. I mean, they were water curing it while they 21 were putting it on, you know.
22 0. So you didn't really answer my question, PAf1MTV P A f1 D
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8 1 though. Did the insufficient zine cure, or cure, did 2' that occur -- was that a widespread problem, or'was it 3 something that was isolated?
4 A. That was widespread.
5 Q. And was it the way they typically did 6 business?
7 A. Yes.
8 Q. To your -- what's been your experience as far 9 as on what happens when you have this insufficient 10 cure?
11 A. Loss of adhesion. Your solvent from your top 12 coat penetrates the soft zine and they just separate.
13 Q. All right.
14 A. And you have zine on the back of your top 15 coat and you have zine still on your metal. .
4 If Q. Okay.
17 So'we should then be able to go out into 18 some of the service level one areas, particularly on 1
19 the liner plate, and find some areas where they ere 20 inter-coat adhesion failures or just a separation of 21 the zine from the substrate?
i 22 A. Well, it's been failing before I left and COUNTY COURT DEPORTERS, INC.
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9 1 it's been failing ever since. And they might have it 2 dressed up when you get there, but I'm sure something 3 will fail while you are there.
4 0 Is it actually sheeting off the wall, or is 5 it --
6 A. Yes.
7
- Q. It is coTing off of hard sheets,oor is it 9 more localized type area failures? ,
9 A. Well, I can tell you one time they removed 10 about, I would say over 100 feet of coating because 11 they couldn't feather it in. They would sand it back 12 and it would just fall off. And they woul'd sand it 13 back and it would fall off. And they ended up taking 14 it all off.
15 O. If an area like that had been final inspe,et.ed ,
4 16 how did you all identify that there was in fact a 17 problem with the cure, or that there was a problem 18 with the adhesion?
19 A. Well, if you wanted to keep your job an3 stay 20 out of trouble, you would not identify it.
21 C. How were you supposed to do it?
22 A. In the latter days, they told us that that i
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10 1 was supposed to be addressed on an unsatisfactory 2 document.
3 Q. Which would have been an inspection report or 4 an IR?
5 A. Right.
6 0. And you would have marked it unsatisfactory?
7 A. Right.
8 Q. Even though the area had been already finally 9 inspected?
10 A. Yes.
1 11 C. But you arc saying that didn't normally 12 happen, because of this factor of harassment or 13 intimidation by supervision?
14 A. Right.
15 If you reported problems, you weren',t, 16 viewed vary --
you weren't cooperative.
17 C. So you p c- r s o n a l l y observed some failed 7reas 18 in the reactor building?
19 A. Yes.
20 Q. Can you remember any specific locations,
, 21 elevations, azimuths, anything like that? 1 1
22 A. Behind every IIVAC duct work. Because see, l COUNTY COURT REPORTERS, INC.
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':h o cro you amplcyod by right now? I 2 A. Ebsseo Services, Inc. i 3 C. Fhen 4id you '-i c r k at Ocmanche Peak?
4 A. From 1:o v e m b t r of '31 until August of '23.
5 C. And Si' you work for Ebasco while you uc re 6 there, also?
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': c , I worked for Crown an' Foct.
O C. All right.
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h s t terc your responsibilitics, if you 10 could stcrt at the beginning and kind of work through?
11 i'- s are :":y - angei as timc ic n t by.
12 A.
I was hires as a coatings inspector, and ir 13 .l i n u a r of '03 bce:-r 1 cad inspector of tha bec4 fit 14 group. That's it.
15 O. 7.11 right.
16 Do you know( -
17 A. :: o .
10 C. You don't have any sort of relationship with '
19 him at all?
23 A. 1: o . I have never met him.
21 Q. Okay.
22 Are you f c.m i l i a r with the trip report i
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11 1 this harassment and pressure, it went with the 2 schedule. The HVAC ducts were going up, so they w e r :-
3 in a real sweat, and that's why the zine was two hours 4 old. It was cured --
After the HVAC ducts were up, i t-5 ws back in seven hours or something like that and 6 then test it to see if it was cured.
7 But there's been plenty of failures 8 behind the HVAC ducts and they are probably still 9 going on.
10 C. Let's see if I understand exactly what your 11 concern was on the nickel test.
12 A. Check out the the polar crane. That was a 13 hot area.
14 0. What do you mean hot?
15 A. Kell, that was the buy word.
16 'lh e n
. told you it was hot, that 17 meant you were supposed to accept it.
19 C. This is_ -
19 A. Yes. l
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20 Q. [He was your supervisor? (-
21 T. Right.
20 s my superv.isor on nicht y COUPTY COURT REPORTEPS, INC.
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was my supervisor from then on.
2( ~ J 3 0. Tell me more about the polar crane problem.
4 A. Well, it was one of those hot areas, you know, 5 and they just threw quality to the wind and --
6 0. Were you one of the inspectors that was 7 assigned to it' 8 A. At times. -
9 0. At times? That's a pretty large job, is n ' t-10 it? Are you all assigned just pieces of the polar 11 crane? ,
12 A. Right. l 13 0. There was l 14 A.
15 O. _Did have some problems ,
16 with the work that was going on there?
17 A. Well, one day % L called me over and said, 18 "It looks like is going to reject that. Why don't 19 you go up there and lean on and make buy it."
20 And I went over to and the 21 general foreman and the foreman and the Paint 22 Superintendent were all standing there making
13 1 nervous --
2 BY MR. LETTIERI:
3 Q. Excuse me. Could you tell us the names, if 4 you know them?
5 A. The Paint Superintendent was 6 The general foreman was 7 and I don't recall the foreman.
8 But I said, I just told 9 you know, make your inspection and do what you want to 10 do, but you see over there? He just told me to 11 get over here and lean on you and make you buy this.
12 I never heard of such stuff in my life. I said, don't 13 feel like I am trying to influence you.
14 So when came down for lunch, he 15 asked well, what's taking so long up there?
16 said well, I'm finding a lot of defects and they uill 17 have to repair as we go.
18 See, they had a deal they would repair 19 defects as you go and with no reinspection of these 20 defects. So they got a satisfactory every time they 21 called for a final.
22 BY MR. HAWKINS:
14 1 Q. But was the final coating as it was applied, 2 was that acceptable quality, even though they were 3 doing it as they were --
they were repairing it as you 4 were inspecting it and identifying defects, doesn't 5 that still result in an acceptable quality of coatings 6 A. Not at all.
7 Q. In what respect?
8 A. Contamination, mostly.
9 What used to take them four or five 10 attempts was now taking them one. And when they made 11 that deal, I mean they quit trying.
12 So it started out, they were making 13 minor defect repairs and pretty soon they were 14 repairing, you know, the four and five-foot holidays.
15 That's' not to be reinspected.
- 16 But anyway, --
17 Q. Wait a minute.
h 18 A. Back to 19 Q. Yes. He are talking about doing --
let me 20 rephrase that.
21 You are talking about a problem of 22 contaminatio.n. What sort of contamination were you i
15 !
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2 A. Imbedded contaminants.
3 Q. And that's what originally caused the area to 4 be unacceptable?
5 A. No. Generally, --
6 Q. Are we talking about the polar crane still?
7 . A. Right.
8 Q. Tell me, can you be more specific about 4
9 imbedded contaminants? I guess I am not following you 10 there.
11 A. Okay.
12 Uhen they repair something with wet 13 paint and you don't go back and reinspect it and 14 somebody else comes along and walks in that wet paint, 15 you have accepted that ares as satisfactory with ,
16 footprints and all; contamination, sand.
17 Q. And all that happened after you had inspected 18 the wet paint?
19 A. Right.
4 20 Q. Okay.
21 A. Because repairs were not to be reinspected.
22 And if you saw it happening, repairs were'not to be COUNTY COURT REPORTERS, INC.
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16 1 reinspected and you couldn't say a thing about it.
2 Q. In other words, you are saying you were not 3 to go back and reinspect the area after the paint had 4' dried or the repair had dried?
5 A. Correct.
6 Q. I see.
7 So that's what you mean when you say 8 that you couldn't reinspect repairs. In other words, 9 you watched them apply the repair and everything, but 10 then you bought off on it at that point?
11 A. Right.
12 Q. And then you didn't go back to do a final 13 inspection of the type that you would have done had it 14 been a regular production type job?
15 A. Right.
16 And evcn when you saw that the repair 17 was unsatisfactory, you still could not' reinspect.
18 Q. In your mind, how are the coatings on the 19 polar crane today?
20 A. Falling off.
21 Q. Which unit?
22 A. One.
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17 1 Q. So if we were to go look at the polar crane, 2 that is an area that you believe that there probably 3 are some standard coatings applied?
4 A. Well, they have been falling off since I left, 5 That's a pretty good way to represent it, I believe.
6 -Q. We will get into some more specifics later on.
7 but I wanted to discuss that one with you while we 8 were here.
9 Why don't we move on to the backfit 10 program a little bit? You know something about that.
11 A. All right.
l 12 MR. HAWKINS: I'm sorry. Do you have a question 13 to ask?
14 MR. LETTIERI: Yes I do.
15 BY MR. LETTIERI: ..
16 Q. What is the proper way to perform the nickel, 17 just so we have it recorded?
18 A. Well, I will demonstrate it.
19 Q. Would you tell it verbally as you are 20 demonstrating it?
21 A. The way I was trained to do it is to hold the 22 nickel, take the edge and rake.
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The way I was instructed to do it at 2 Comanche Peak was to lightly rub the nickel, as 3
lightly as I could, to keep, you know, enough pressure 4
to keep the nickel from falling out from under your 5 hand. That's what they said.
6 Q. When you scraped the nickel across the 7 surface, what would you expect to see?
8 A. Adherent zinc.
9 Q. Okay.
10 Adherent zine in the form of a burner 11 surface? Is that the proper terminology?
12 A. Yes.
13 Q. And you would not expect to see the zine come 14 off in a peel?
15 A. Exactly.
16 Q. And that's basically the test?
17 A. Yes, sir.
18 Q. Okay.
19 If you already gave it and you know what 20 the answer is, then please excuse me, but could you 21 give any elevations, any specific areas that you feel 22 we ought to go look at to find zine that was not cured COUNTY COURT REPORTERS, INC.
19 1 properly?
2 A. It's all over in patches.
3 Q. Okay.
4 So from the top of the dome to the 5 bcttom of the reactor containment, anywhere that we 6 would look, we would find them?
7 I know that it's been a while since you 8 have been there and you might not be able to remember.
9 But if you could tell us, for example, elevation 905 10 around by the pressurizer, anything like that would 11 make our life a little bit easier.
12 A. The first one I was forced to buy off sticks 12 in my mind the best. That was in unit two, behind the 14 HVAC duct. I am trying to think of the azimuth. Okay 15 1 can figure it up. Okay. It would have been over 16 around zero azimuth behind the HVAC ducts.
17 Q. And that would be a good example, as far as 18 you could remember, of a place to look,?
19 A. Right. There is a couple of ducts over there, t
20 I'm not sure which one it is, but that was one of the 21 first areas that I was ever told to buy uncured zinc.
22 Q. Could you give us another example, msybe r. o t i
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20 1 behind a duct?
2 A. Well, these ducts, you can look behind them.
3 0. Okay.
4 A. Not behind a duct. It would just bc 5 different repairs on the liner. It would be --
6 documentation would be more help than anything.
7 C. Okay.
8 If we go back and perform the elchomatar 9
adhesion tests, do you think those results could be 10 used to Take a comment one vcy or the other on the 11 acceptability of the zine cure?
12 A. Well, I really can't tell you.
12 C.
If I understood your statements acrlier, th 14 concern is that the zinc didn't cure properly; IF thcreferc, whrn the top coat was applied, it woci d , ,
15 ru n .- en interco ting failura, cnd in .: y ?.i n d , th;t 17 should be ossy to see through an c1chemcter test sn' lt in .:Jh sion _ull. ,
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2^ A. Light.
21 C. And I would just like your opinion on wheth:r 22 that would be areentable and if it wouldn't, why OCUMTY COUPT FEPORTER", I ::C .
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-21 1 wouldn't that be acceptable?
2 A. An elchometer gives you one square inch.
2 That coating is acceptable on that one square inch, I 4 agree. But --
S c. So the concern then is that all you can do is 6 look at one small area?
7 i A. I really don't have concern with that, see.
8 I work for construction now and I disposition all my 9 nonconform.ances with adhesion testing, because it's 10 about the only tool I have. But QC hates it, you see.
11 0 Okay.
12 Well, if I understand you correct, if we 13 take five areas in 100 square feet and get five 14 readings that are acceptable, the standard practice is 15 to say that area is in fact acceptable. ,,
16 I would like to know if you have any 17 reason to say why that isn't an acceptable way of.
18 approving an area.
19 A. No, I have no reason-to.
20 Q. Okay.
21 Your comments in general, were they 22 about both unit one and two?
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22 1 A. Yes.
2 Q. Okay.
3 So we could go to either place and look 4 for problems?
5 A. Yes.
6 Q. Okay.
7 You mentioned, and I don't remember 8
exactly where it was, but I think you said that there 9
was approximately 100 square feet of costings that 10 were removed and they were removed because they were 11 feathering and it fell off.
12 Did they hand sand the whole 100 square 13 feet? Did they use any other tools, is what I am 14 getting at?
15 A. Yes.
They eventua,lly stripped it because.
16 they couldn't feather it in.
17 Q. But they didn't come in with a sand blaster 18 or power tools? They were just attempting to feather 19 it and -- 1 l
20 A. Right. i I
1 21 Q. So very slowly they were coming off?
22 A. Right. Until they got about ten feet !
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33 1 stripped. Then they decided this whole thing was like 2
2 this and they power tooled it.
3 Q. What tool did they use if you can remember?
4 A. 3-M Strip-N-Clean.
5 Q. That isn't used to provide a profile? That 6 is used to strip the coatings?
7 A. It will give you a modest profile.
8 Q. Do you remember what they might have used to 9 go back to profile that area?
10 A. No.
11 Q. There was no profile put on before they put 12 the primer on?
13 A. Know. The specification said that the 14 Strip-N-Clean was adequate, provided adequate profile.
15 O. Do you think it's adequate? ,,
16 A. You know, at times it is; at times it's not.
17 It depends on the man behind the Strip-N-Clean.
18 Q. Okay.
19 Here you given any tools to determine 20 profile?
21 A. At times.
22 Q. ?! e a n i n g that today you could have a tool and COUNTY COURT REPORTERS, INC.
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24 1 tomorrow you wouldn't, or that the procedures --
2 A. No. Meaning the first year I was there, no, 3 no tools. And later we got some new inspectors who 4 just would not accept the areas without a tool and 5 they gave us Stewart depth gauges.
6 Q. Those are the dial gauges?
7 A. Yes.
8 C. And you were using those?-
9 A. Later on, yes.
10 Q. Do you remember what type of profiles you-11 were obtaining, roughly?
12 A. No. 3y that time I was in the backfit. I 13 went into the backfit group in June and was very glad 14 to be out of the ongoing inspection.
15 Q. Do you have an opinion as to what the profi.lc 16 should have been for that surface to be properly 17 prepared for a coating application repair?
18 3. I think as a minimum, one mil should have 19 been required.
20 Q. You mentioned that, and I unfortunately 21 didn't take a good note here, but you were talking 22 about IR's with Frank, and what I would like to know COUNTY COURT REFORTERS, INC.
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is in the context of an IR, were you allowed to put 2 anything in the remark section?
3 A. You could put it in there, but that didn't i
- 4 mean it would stay. They would make you rewrite it if 5 you wrote something they didn't like.
6 0. If you found an area that did not have on the 4
7 IR itself a block where you could mark satisfactory or 8 unsatisfactory, which is the context I think you were 9 discussing at the time; you see a gauge hole in the a
10 concrete wall and your IR doesn't tell you to say i 11 satisfactory or unsatisfactory-without the hole, could 12 you make that remark in the remark section?
13 A. If you wanted to be considered a rebel O
, 14 inspector. If you wanted to make waves and you had 15 the courage, you could do what you wanted to, but th,at 16 didn't mean you would stay.
17 Many times they have made inspectors 4
18 rewrite documents because they didn't like the 19 comments.
20 Q. Okay.
21 A document where you personally might
- 22 have written in the remark section, do you remember 1
I 3
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26 1 any?
2 A. My first inspection, I was not certified. I 3 was on on-the-job training. I went to the vault, 4 service prep satisfactory pe They 5 called me out. I inspected a very small concrete ite.9 6 that hadn't even been touched, surface prep wise.
7 Still had the form lines. It just was untouched. It 8 had all the fine dusty powder.
9 Q. Laitence?
10 A. Right. And they wanted to put llS on it and 11 I told the guy who was giving me on-the-job training, 12 I said well, that's not touched. What do you want to l 13 do about it? So he rejected it and lEE come up and 14 made him buy it.
15 Q. Did that ever show up on the J R , though?
16 A. Yes. It went to the vault. Surface prep one 17 year previous per 18 Q. And that one was accepted?
19 A. Right.
20 C. That never got kicked back to you and -- I em 21 trying to find an instance where an inspector 22 attempted to inform management through the IR that !
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I there was a problem that he could not identify per the 2 form and they did nor allow you to do that. Can you 3 help me a little in identifying something like that?
4 A. I would just have to say talk to
}
5 He had some documents sent back to him.
6 The other inspectors --
I tried not to 7 mcke wcVes. You know, I didn't record that stuff on 8 my documents. He had an NCR, for instance, beccuse ws 9 5:d no method to determine profile, anchor profile.
10 And it was because about two inspectors wrote on their 11 i o c u r.e n t s ne comparator evailable.
12 So they had an NOR and identified thes-13 dccuments that those two inspectors had written doun, 14 but there wasn't any comparator available to any 15 inspector at any time. So what made those documents, l
16 unique?
17 C. Okay.
18 But if I understood you earlier, as far '
l 19 as profile was concerned, by the time profile was in 20 the procedures, you were not working with those 21 procedures, so you don't feel comfortable about 22 commenting about the measurement of profile as far as l
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1 procedure required?
2 A. I feel comfortable about it. See, I tr o r k ed 3 ongoing on call. Certain days they would say well, we 4 need you over here worse. You know, forget backfit.
5 O. And you just don't remember, though, if the 6 procedure gave you a minimum substrate profile, 7 meaning that you could have one, two, three, four mile 8 or zero mils profile?
9 A. Yes, it did.
10 Q. Do you r e m e r.b e r when it was?
11 A. No, sir.
12 C. And th? tools that you had were the dini 13 gauges?
14 A. About a year or so later we sterted using[
15 those. Prior to that time we had nothing. ,,
s 16 0. You didn't have the --
I forget the nane.
17 A. We didn't have a thing. No comparator, i
18 Q. The errors behind the HVAC ducts, if those 19 errors were to be put on the exemption log, would that 20 be acceptable? Do you know what the exemption log is?
21 A. Yes.
22 Well, it just depends. It's not COUNTY COURT REPORTERS, INC.
?1c y.na .,411e ca iw e..-- ,, ense- ,3,,. ce, rea
- 29 1 acceptable to me. It might be to the N.R.C.
2 You're talking about pretty huge sh.eets 3 behind the HVAC duct. They are not no little thing.
4 0. Okay.
5 But physically, unless you removed the 6 duct, you couldn't get back there and work on those?
7 You could see them, but a man could not repair --
8 A. Sure you can. You can get behind them.
9 0. How far were they off the wall?
10 A. Well now, I got stuck one time coming out 11 from behind one of them. But all the rest of them you 12 can get behind really easily.
13 C. So a man could get between the wall and the 14 duct and work?
15 A. Yes. ..
16 0. Getting back to repairs that were done during 17 coating application that were unacceptable, I wasn't 18 following exactly why they were unacceptable. I 19 envisioned you talking about an area such as a floor 20 space. There was a defective area. They went, they 21 repaired it, but it wasn't cordoned off? They didn't 22 keep people out of that area?
(
I l l l COUNTY COURT REPORTERS, INC. j i _
. 4
30 1 A. Right.
2 Q. And that was the standard procedure?
3 A. Yes.
4 Q. Did they ever get to the point where they did 5 in fact cordon off areas where the paint was still wet 6 while you were there?
7 A. At times'they would. You know, different 8 foremen.
9 C. And that was not a QC problem. That was a 10 production problem, keeping people out of the area?
11 A. Yes.
12 MR. LETTIERI: Okay.
13 BY MR. !!M KI NS :
14 0. Okay. Now 1ct's get on to the backfit 15 program for a minute.
16 You mentioned that there were instances 17 when the areas were excluded from the backfit program 18 because someone in management made the determination 19 of adequate documentation?
20 A. Yes.
21 We were given a hand-drawn map and it 22 says these areas have adequate primer documentation.
COUNTY COURT REPORTERS, INC.
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31 1 So when we came to those areas, we did our adhesion 2 test and left off the tooke test. And wrote on our 3 document --
let me see --
adequate primer document 4 takes exists for this area.
5 Q. But you still didn't do the elchometer 6 adhesion test, but it was excluded from the tooke 7 gauge test?
8 A. Yes.
9 Later these areas that had satisfactory 10 primer documentation ended up having ten mils of 11 primer on them.
12 Q. Why did they have ten mils of primer on them?
13 A. Well, we didn't even know they had ten mils 14 until they were sanding down the top coat to try to 15 meet the milage criteria there --
16 Q. For total systems?
17 A. Yes. And exposed primer and still couldn't 18 get down to their total system requirement.
19 Q. So in certain areas, you found that just the 20 zine primer by itself had been applied --
21 A. Over ten mils.
22 Q. --
over ten mils, which was already two or COUNTY COURT REPORTERS, I N C ., __ ,,_,
32 i
i 1 three mils over the maximum allowed for the total 2 system? -
3 A. I think they had 11.5 for the total system.
4 But this brought a question into my mind 5 about well, just how adequate is tha' .ocumentation?
6 And besides that, the guy that was keeping the maps, 7 none of his other maps were right, not one. So I 8 wouldn't --
9 C. Who is that?
10 A. >
So I don't see how that one 11 could be adequate.
12 C. Who made the decision that the documentation 13 was acceptable?
14 A.
15 O. Was ever involved in that? ..
16 A. In making decisions or --
17 0. In this problem with --
18 A. kept demanding to see this J
19 adequate documentation before he would put it on his 20 document, and he never could.
21 But through the books and the maps, he 22 obtained the number of one of the documents and he l
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1 C O U t1 T Y COURT REPORTERS, INC. '
33 1 went to the vault to see it and it wasn't at all 2 adequate. It was, in my opinion, forged and falsifief, 3 the way a lot of that documentation I believe is.
4 Q. So was the one who made the 5 decision?
6 A. Yes.
7 . Q. And you obviously didn't agree, based on your 9 observation of some unacceptable work in the field?
9 A. Yes.
10 Q. Do you remember exact 1'y where that was?
11 A. Liner plate.
12 Q. Again, elevation and azimuth?
13 A. Okay.
14 Well, the elevation would be just below 15 the polar crane rail and just above it. The azimuth ,,
16 would be --
I will have to figure it up here. From 17 270 to zero. That's a big area, but there is a lot of 18 areas up there like that.
19 Q. It's right above and right below the polar 20 crane area?
21 A. Yes.
22 I recall that I discovered some more of COUNTY COURT REPORTERS, INC.
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34 1 this one day. Well, one day found some and he d
2 wrote an NCR on it, and I discovered some the next day 3 or so, because I asked him to bring me a light.
4 And so the next day or so adequate 5 lighting became the minimum light output of a two-cell 6 flashlight, because I requested a drop light, a 7 60-watt bulb, and I saw this gray primer through --
8 There is about 14 mils, you know, total 9 system, and you can see primer through your top coat.
10 So that means your top coat is about three mils 11 maximum. So that's giving you about 11 mils primer.
12 So I rejected this area.
13 Q. That was around the polar crane rail also?
14 A. That was just below the polar crane also, 15 right. And that would have been about azimuth, right' 16 around zero.
17 BY MR. LETTIERI:
18 Q. Excuse'me. How did you know it was 14 mils?
19 Dry film?
20 A. I had a dry film thickness gauge and I was 21 taking a reading.
22 C. The other question I have is when you speak of COUNTY COURT REPORTERS, INC.
h . . _ __
35 1 rail, is that the traction that the wheels of the 2 polar crane were on?
3 A. Yes.
4 MR. LETTIERI: Okay. .
5 BY MR. HAWKINS:
6 Q. Do you have any examples of th3t 7 documentation, by any chance? Did you :etain any of 8 that?
9 A. No. -
10 When they fired me, they were prethy 11 particular about what they let me take out, and I just 12 had never thought, you know, had never planned 'to use 13 it against them or anything. So I don't have any.
14 0. Do you recall the time period when this took 15 place, the instances when would identify 16 an area that yes, we do have adequate documentation?
17 What time period was that occurring in?
18 A. Jllfwas researching all that documentation 19 from about November of '81 probably until February of 20 '82.
21 C. Was the program, the backfit program 22 redefined at any point on down the road and did they l
l
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-36 1 say we don't feel that this documentation is credible 2
enough that we can rely on it and in fact, maybe we 3 should reinspect everything? Was that decision ever 4 made?
5 A. The backfit NCR was constantly revised and it 6 was just constantly revised.
7 I mean one time they would want 20 8
percent; then they would want 50 percent; then they 9 would want 100 percent.
10 Q. 100 percent of what?
11 A. Oh, for instance cable tray hangers. T.h e y i
12 would start out with 20 percent and then 50 percent.
13 But then after we inspected them, for a while there 14 they repaired the effective areas, but later they just, 15 they forgot about backfit. After I left, they just, 16 abandoned it.
17 C. But to your knowledge, was the backfit le program ever redefined to the point that they wrrr-19 required to inspect 100 percent of everything? And I 20 am talking specifically the linor plate.
21 A. The liner plate was to be 100 percent 22 inspected.
,3 - . . . . . . .,,
C O U S* T Y COUPT ?EPORTTPS, INC.
37 1 0 Therc werc then samples probably taken :f 2 T.iscellaneous steal sh, pes such as cable tray hing rs,
? supports, thirk like t't i t ; ic that correct, an I 4 understani it?
5
.. Th.y wart bac% fitting all cf ther, tco.
6 0. Oksy.
7 But they only did a certain percentcg:
E of ther, or dii they do cl1 of them? Do you recall?
9 A. Eventually they h a :' t '.1 e m all en the list to 10 do.
11 0. c o :n the finc] 2nalysis, they did de 12 everything, as far as you know?
12 A. I: c . They discontinued it. They did a trend 14 analysis on it and they said well, we have only got 15 eight percent bcd hangers here, so that's good enough. ,.
16 0. In other words, you said they develop a 17 statistical basis to give them a reason not to proceed 18 with the inspection of the rest of the itens?
19 A. Yes.
20 0. But as far as the liner plate goes then, the 21 concrete surfaces within the containment, they were 22 100 percent reinspected?
COUNTY COURT REPORTERS, INC. ~
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1 A. Right.
2 Q. So there was no documentation that existed 3 that they took credit for on the liner plate or the 4 concrete surfaces that was a basis for them to exclude 5 some of the liner plate or the concrete surfaces from 6 the backfit program?
7 A. Quite to the contrary. Now they had adequate 8 primer documentation, they say.
9 0 So did they exclude part of the liner plate 10 because they had adequate documentation?
11 A. Yes. They excluded it from the tooke test.
12 0. I see.
13 Then what you said earlier and what I 14 said is maybe incorrect. I asked you did they do 100 15 percent reinspection of all the liner plate, and you 16 said yes.
17 A. On paper. Forgive me. See, you've got paper 18 for 100 percent of the liner plate.
19 C. h' hen I say reinspection, I mean out on the 20 wall looking at it and doing the tests that were 21 required.
22 That's not true then? To your knowledge, COUNTY COURT REPORTERS, INC.
who.*n, 71o yanneuf11. o4 Tr snio7 tot s Amt1A??
39 1 they didn't do 100 percent reinspection of the liner 2 plate?
3 A. No.
4 Certain areas were excluded.
5 O. Based on this documentation that we discussed' 6 A. Right.
7 . O. What tests were required by the backfit '
8 program?
9 A. The teake test and adhesion test.
10 Q. How often were you supposed to do the tests?
11 In what square foot was the liner plate and the 12 concrete surfaces? Were they subdivided into certain 13 square foot areas and did you do these tests in those 14 areas?
15 1. . Right.
16 Now you are going on my memory here 1
17 which we have got a whole new bunch of standards down 18 here now, so I have got to try to remember'them.
19 If I am not mistaken, it was three 20 adhesion tests and five tooke scratches for I guess 21 500 feet. That could have been 1,000 feet. I just 22 really don't remember.
COUNTY COURT REPORTERS, INC.
93o .smo..411a od . Wha =*nn. TL 60187 (312) 653-1622
40 1 BY MR. LETTIERI:
2 Q. Could you remember what time period that vas?
3 was that June of '82 or January of '84 o r --
4 A. For those sizes and all that?
5 O. Yes. The numbers you just gave us.
6 A. That was throughout.
7 Q. Okay. They didn't change a thing.
8 A. The frequency didn't change, no.
9 0. So up until the time you left the plant, as 10 best your memory serves you, those were roughly the 11 areas?
12 A. Right.
13 BY MR. HAWKINS:
14 0. And that was the same for concrete and liner 15 plate? ,
16 A. Concrete was a little different. I just 17 really can't recall the requirements now, i
18 0. That's okay. I was just trying to get an !
1 1
19 idea.
20 Do you recall what they did on the .
l 21 miscellaneous steel pieces, such as the hangers and i 22 supports and that sort of thing?
COUNTY COURT REPORTERS, INC.
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41 1 A. Right.
2 I think they had three tookes and~one 3 adhesion on miscellaneous supports.
4 0. What if an area had adequate documentation:
5 what would you do?
6 Let's talk about the liner plate again.
7 What inspection would be performed on the liner plate 8 under the backfit program if adequate documentation 9 existed?
10 A. Strictly adhesion test.
11 Q. Just adhesion? They wouldn't do the tooke at 12 all?
13 A. Right.
14 BY MR. LETTIERI:
15 Q. Is that because the dry film thickness gauge 16 would give you the rest of the documentation?
17 A. Supposedly, right.
18 0. Why do you say supposedly?
19 A. Because they had adequate documentation 20 saying that primer was three to five mils, and that 21 primer was 11 mils.
22 0. But given that the primer was identified, COUNTY COURT REPORTERS, INC.
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42 l
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then all you would need is a dry film thickness gauge 2
reading to give you the total system and then the 3
adhesion test to tell you the perameter?
4 A. Right, 4 5 BY MR. HAWKINS:
I 6 O. How was it ever 11 mils to begin with? Was 7 one of the areas inspected?
8 A.
The areas had documentation, maybe, but they 9 weren't inspected.
1 10 At the time that dome was painted, the 11 guy 12 13 14 So they dismissed him for that, 15 16 Q. What was his~name?
l 17 A. His name w 18 o, 19 A. Right.
l i .
43 1 Q. So you are saying he ascepted substandard 2 work, at least from the dome work?
3 A. And didn't even inspect it.
4 Q. Oh, didn't even inspect it?
5 A. Right.
6 Q. What did he do, dry lab documentation?
7 A. They called him up, told him what they had 6 and he said okay, point it, ard they wrote it down.
. 9 Q. So in effect he did dry lab results?
10 A. I don't understand dry lab, but --
11 Q. In other words, wrote it up without ever 12 naving done the work?
13 A. Yes. Right.
14 Day shift was wondcring how night shift 15 was getting so much done, you know, when they weren'.t. .
16 doing that much, or that good of work on day shift. I l
17 But that's how they were doing it.
18 Q. Ilo w long a period did that occur?
19 A. Well, that happened just before I got there l
20 and I was just told this by '~
21 A hen I first arrived at Comanche Peak.
22 And they got rid of him pr'etty quick 3,o . .....,,.
COUNTY COURT REPORTERS, INC.
- e. .. .. ..... . . . - .-- .---
44 l
1 because he tried to go by the book, and they just l
2 Sidn't allow that.
3 eY MR. LrTTIEPI:
4 0 ent quickly?
l 5 A. Right.
6 like I say, he tried to go by the book and so they :
7 terminated him beccuse he didn't want to make this 5 2 l the(rotating platform rail.
8 inspection on , {
9 Once you get there and see it, you might 10 know why, because the only rope they had to tie off to 11 was below their fect, and the thing is only about this 12 wide and but yet, when I came on on night shift, they 13 gave me the us2 of the platform, because I wouldn't 14 walk it either.
15 You can't even lean up against the we11. ,,
16 That's how far away it is. So you have no support to 17 steady yourself. You have just got to be a monkey.
18 Eo when I came on, they gave me the use 19 of the platform, but they wouldn't let them use it.
20 So e wouldn't make the inspection and they fired him.
21 But they kept the old boy out of the shop who would 22 not climb six feet, not six feet. He would not put.o9 000P;Y COURT R E; P O R T E R S , INC.
w _ _ - _ . __ _ - _ - . _ _ _ _ . . - _ _ . ._
45 1 a safety belt.
2 C. Okay. Let's stay with the backfit program.
3 You had some concerns about the tooke 4 gauge tests that were performed, in that you 5 personally observed what you perceived to be rust or 6 grease or other contaminants on the steel of the 7 concrete surfaces.
8 Could you give me some more details on 9 what you saw?
10 A. Just about a mile of dirt.
11 C. Dirt?
12 A. Yes.
13 0. Dirt dirt?
14 7. . Ground in grime.
15 0 This is on steel? ,,
16 A. Concrete.
17 0. This i r. on concrete?
18 A. On steel generally, what was always rust 19 instead of primer.
20 BY MR. LETTIERI:
J 21 C. This was a standard tooke gauge reading? '
22 A. Yes.
l COUNTY COURT REPORTERS, INC. i a$ n .......:,,- os ...s...-- ,e enio, asini ccm.,co9 l
46 1 BY MR. HAWKINS:
2 0 That was performed during the --
3 A. During the backfit operations, I detected 4 grease, filth and rust.
5 0 Which building were you in when you 6 identified this?
7 A. Reactor one was the biggest problem area.
8 0. Do you recall any specific instances of when 9 it happened or where it was located?
10 A. Steam generator compartment, I would say 11 compartment number four. And in unit two, compartment 12 two.
13 0. Were the deficiencies corrected after you 14 identified them?
15 A. No. ,,
16 0. Why?
17 A. That just wasn't the status quo out there.
i 18 0. Did you identify them on documentation, on 19 the backfit documentation?
20 A. No. I was actually afraid to. They didn't 21 want anything like that reported.
22 0. Where would you have identified it, had you l
l i
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COUNTY COURT REPORTERS, INC. !
. . -,n ........e,. -3 ..s..... ,, en,n, ,3$os ces , coa
47 1 I had the wherewithal to do it?
l
, 2 A. If I would have had the nerve, I would'heve I l
3 wrote a nonconformance report. ;
I 4 Q. Did you specifically do the testing that -
4 5 identified these contaminants?
6 A. Yes. And not just myself.
7 Q. Did you bring it up to someone else's 8 attention? i 9 A. Yes.
l 10 Q. Who did you tell about it? l 11 A. Well, I always told my boss.
l 12 0. Which one? l 0
15 A. And one time identified some
- 16 rust on the A-frame in the seal table room. And 17 6 He wouldn't take no for an answer.
- le 18 wouldn't shut up. So they took it all the way up to 19 1 the QE level three, never 20 had a paintbrush in his hand, but knows all about it.
21 They determined that was D6 residue.
22 0. Based on what?
COUNTY COUPT REPORTERS, INC.
48 1 A. Nothing. Just they said --
1 2 0. This was on the steel surface, on the 3 substrate you exposed what you perceived to be rust 4 and then they said no, we think it's 06 residue?
5 A. Exactly. But when they went to paint it, 6 they were blowing off the dust with their quarter inch 7 air line and blew the paint off and oh, there is that 8 rust. It just happened to be rust.
9 Q. And these were in the two compartments that 10 you mentioned earlier in the steam generator; right?
11 A. ti o . This is in the seal table room. ,
12 C. This is the A-frame seal table room?
13 A. Yes.
O 14 BY MR. LETTIERI:
15 0. What elevation is that? ..
16 A. 230, something tells me.
17 Q. Seal is s-e-a-1?
18 A. Yes.
19 C. Seal table room?
j 20 A. Right.
j 21 C. Do you know of any other way that you might 22 call that room? It's unfamiliar to me and it may be COUNTY COURT REPORTERS, INC.
219 Nanarvilla Rd.. Wha =*nn. 7 t, 60187 (312) 653-1622
49 1 easy to find, but is there any other way of 2 identifying it so then we can find the A-frame?
3 A. Welle --
4 0 Is there a room --
5 A. It's the third floor on the elevator.
6 0 Third floor on the elevator? Is it adjacent 7 to any other area that you could identify for us?
8 A. I think it's an incore instrumentation room 9 or a --
10 I believe that's -- you could enter it 11 on 832 also. That's the second floor. There is a 12 room that goes in there. That's all I know about the 13 seal table room.
14 0 In another instance you identified grease or 15 imbedded wood, that sort of thing, concrete. ,,
16 What did supervision tell you when you 17 brought that to their attention? I mean that doesn't 18 look like anything normally that you would expect to 19 find imbedded. What did they say in those instances?
20 A. Well, when I identified it t 21 he says, "Well, what the hell do you want me to do l l
22 about it?" l COUNTY COURT REPORTERS, INC.
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50 1 0. And these were in the steam generator areas?
2 A. Yes.
3 0 Okay.
4 Are they, to your knowledge, still there 5 in that shape?
6 A. As far as I know, yes.
7 0 How did they typically prepare concrete for S the seal coat? Did they sandblast it? Did they rub 9 it down? What did they do exactly?
10 A. That was their normal surface trim on 11 concrete.
12 0. What if you had pieces of form work still 13 left in it?
O 14 A. Oh, that was allowed.
15 O. Was that typical?
- 16 A. When I got there, there wasn't that much raw 17 concrete left. But I always wondered what they 18 thought they were accomplishing making mud holes out 19 of concrete before they put on the 11S.
20 You know, a solvent wipe or water wipe 21 doesn't do anything but make a muddy surface on 22 concrete.
COUNTY COURT REPORTERS, INO.
9to e,-r..43to na wwo.*aa T r. An1p? t117) 691-1A77
51 1 You know, I mean if they had rinsed it 2 or really gotten after it, just taken an old rag here 3 and three swipes and it's filthy, and they just keep 4 on wiping and all they did was muddy it up.
5 MR. HAWKINS: I don't have any more, Vince. Do 6 you want to ask him anything?
7 BY MR. LETTIERI:
8 0 Do you remember any elchometer adhesion tests 9 being performed inside electrical boxes at Comanche 10 Peak as part of the backfit program?
11 A. Inside?
12 C. Inside the electrical compartments?
13 A. I remember some on the outsides, but not on 14 the inside.
)
15 0. Do you have any recollection of say, 25 ,,
16 elchomoter adhesion tests being performed on a single i
17 Hangar? Did you ever run across that being done?
18 A. Yes, I recall that now. They had a
.i 19 requirement to --
if you had a failure, you would test 20 it. You tested out a certain area, you test it again.
21 If it failed again, you were supposed to strip the l
22 item. That was the requirement.
J COUNTY COURT REPORTERS, INC.
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52 1 But on some, on some hangers, 2 installation hangers for the steam generators, they 3 didn't want to strip the whole item, because it was a
- 4 big item.
5 And so in violation of a written 6 instruction, we were instructed to go ahead and glue 7 on some more, and they just kept failing.
8 0 Did you document the failures per procedurc 9 or -- If I were to look up the documentation, would I 3
10 find 25 test results document, or would I only find j 11 say five good results and 20 failures to be ignored?
12 A. Okay. Now, that wasn't in the realm of 13 backfit. That was an ongoing inspection.
O i 14 0. That was ongoing, not backfit?
4 15 A. Right. ,,
16 Q. Okay.
]
17 A. They had kind of integrated it there, too, 18 where on the primer, for some reason, they were taking 19 tasts.
20 C. Frank, correct me if you have already gone 21 over this, but it doesn't seem to me that we have 22 gotten any data on where the areas of insufficient i
i I COUNTY COURT REPORTERS, INC.
91o *.ne..411.
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An197 (117) 441-1672
53 1 documentation are.
2 What can you tell us to help us go back 3 and look at documentation packages that would turn up 4 to be deficient? Anything at all? I know you didn't
- 5 keep copics; they wouldn't let you take copies, but 6 anything you can tell us?
7 A. Well, if you look at the backfit 8 documentation and if it doesn't --
just try liner. I 9 mean to me, all the rest is insignificant.
10 But you look at the liner and if it 11 doesn't have tooke readings, then it will say at th-12 bottom, "Adecuate documentation for primer exists for 13 this area."
14 0 In the liner, do you know of any specific 15 elevation or failure? I understand it's been a whi,1,9 16 and --
17 -
A. Hell, there was quite a bit of it, see, that 18 supposedly had adequate documentation. So it was all 19 over.
20 0. Okay.
21 Cotting back to the primer being too 22 thick, if my understanding is correct, what happenef ,
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1 CO U t!T Y COURT REPORTER 9, I t:C .
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E4 1 was no one inspected the prir.er initially, se it was 2 applied too thick and approved. Is that a fair 3 statsment?
4 t. . Yes.
5 C. If y memory serves mc correct, thcre wr s ' s 6 period of time when no documentation was written down; 7 cr if it uss uritt:n f09n, it wac in a f or , nct the 8 way th: procedures callei for. Is that correct?
9
. .. c 1 1 , they had shout tuo years cf missing lo dicerspant and i n a :' e q u a t e documentation.
l '. C. In : .- -
- t '. : log book titcframe? In t h s,t when 12 they vert using seppesedly a " log book" and you logg:3 17- it in? Oces thtt tarr s o u n t' familiar?
14 t. . t!c .
15 C. Okay.
16 If t. n inspector wasn't documenting the i 17 inspection, did he follow any procedure to actually i
~
lt perfor- the inspection where there was no -- ! know l 19 you sai3 that there was one inspector that didn't i 23 inspect at r11. You just told them to go ahead and l
21 they went.
22 A. Pight.
i f
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COUNTY COURT REPORTERS, INC.
91o_ _r. 6 pr!. _.N,h _a m e n n ._ ,T_ r, 6 019 7 _ .(_312 ) __.53_1622
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55 1 0 But the other inspectors, the day inspectors 2 during that timeframe, what procedure were they using; 3 do you know?
4 A. Uc11, they had there 01, OP's, you know 5 quality instruction quality procedures.
6 0 Those procedures, do you have any reason to 7 believe were insufficient?
8 A. No, but the book is meaningless if you don't 9 go by the book. You know, it's just what they want 10 people to think it was really like.
11 Q. So if we were to go to that timeframe and 12 nistorically locate the procedure that was in place at 13 that time, we could read through it and see that the 14 procedure was adequate; and if I heard you correctly, 15 what you are saying is yes, that's great, but nobody 16 did it that way?
17 A. Exactly.
18 0. You were talking to 4EEE [about the area of 19 the rotating platform.
20 Did I understand you to say that no 21 inspection has been performed up there? Is that what 22 was going on during that phase of the conversation?
COUNTY COURT REPORTERS. INC.
56 1 A. The dome in that area up there, the upper 2
liner plate, was the area that was the guy sleeping 3 through night shift.
4 Q. But you were saying something about I guess 5 it was %ywas it?
6 A. Right.
7 Q. Was fired due to the fact that hc would not 8
perform the inspection in that area; is that correct?
9 A. Right. He wanted some kind of safety 10 precaution and they saw their chance to get rid of him, 11 so they said no, get up there and make that inspection.
12 Q. Why did they have --
do you know why they had 13 him doing the inspection if the night inspector 14 already approved that area?
15 A. Okay. Now the night inspector, he had d o n e,.
16 been fired for months.
17 0. Oh, I see. This is later inspection?
18 A. Right.
19 0.
And now they repaired the area and they were 20 going to --
21 :
A.
Heeded another inspection for another paint l 22 job.
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57 1 Q. For some reason, the area that had been 2 previously inspected and found acceptable was worked 3 on again. It was time for a new inspection and this 4 gentleman refused, refused to inspect it 5 and he was fired?
6 A. Yes.
7 '
O. And at that time, in that timeframe when you 8 did inspections in that crea, you also refused to do 9 what he did and you used the rotating platform?
10 A. Right.
11 0. And there was no problem?
12 A. Right.
13 C. In areas where --
i 14 A. Because I was a more lenient inspector.
15 O. I see. ,,
16 They liked you at that time?
17 A. Exactly.
18 0. They didn't lik 19 A. Exactly.
20 C. In the areas where there was dirt underlining 21 the coatings, there were other unacceptable items in 22 the coatings, if we were to go back to those areas and COUNTY COUP.T REPORTERS. TN*.
55 1 do an adhesion pole test, do you think we would have a 2 failure, in your opinion?
3 A. t: o .
4 Q. 1:e would not have a failure?
5 A. No.
6 0 In the event we do not hsve a failure, would 7 it be acceptable -- would the coatings be acceptable, 8 provided they pass the pole test?
9 A. That's not up --
you know, that's not really 10 in my scopc. .
11 Q. You don't feel comfortable commenting about 12 that?
13 A. In my opinion, adhesion right now at 200 14 pounds isn't necessarily what you are going to have if 15 you've got a lot of high temperature in there and ..
16 you've got grease in between coats, no. You are going 17 to have some failures.
18 Q. If I understand you correctly then, you are 19 saying as the temperature were to increase in the 20 containment, the adhesion pole results would change 21 and --
22 A. I believe the coatings adhesion would change.
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l COUNTY COURT REPORTERS, INC.
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59 1 C. Even though an ambient temperature, you do 2 n o 'c have a " failure" using the 200 PSI criteria?
3 A. Right. That's my opinion. I don't --
4 Q. Well, the reason I ask is if we go back and -
5 do an adhesion pole test and find out it passes the 6 200 PSI, I would like your opinion whether that would 7 be valid or not. Right now you are saying it may not 8 be?
9 A. See, I have no opinion about that place any 10 more. They have addressed the problems that I brought 11 up. I trust your judgment, you know. If your company 12 goes in there and says they are adequate, I believe 13 you.
14 Q. Okay.
15 And we are using an individual such a s.
16 yourself to help us look in the right areas to find 17 inadequate coatings, and we are going to use 18 individuals with your expertise to give us some 19 guidance as to what you think should be acceptabic, 20 and we will use that in conjunction with our own 21 expertise.
22 A. Well, the only reason that the thought came COUNTY COURT REPORTERS, INC.
1 l
60 l 1
1 1 up is because we have experienced it out here. 1-: e hai 2 some surfacer . contaminated by hydraulic oil.
3 My disposition was clean it to the best 4 extent, you know, that you can and paint a 5 representative sample and then take adhesion tests.
6 And we did and they were satisfactory, and I thought 7 everything was great.
8 But the Design Engineer in Houston came 9 down with that decision that that may be fine and 10 that's, you know, its justification to go ahead and 11 work with this, but that doesn't mean that during an3 12 ESA you are going to have adhesion then.
13 That's what he told me, so that's the 14 only reason that I would question it.
15 Q. You were mentioning that in the beginning..
16 when you first cane on the site, there was still raw 17 concrete that had not been prepared at all, and there 18 was some amount of wood in that concrete.
19 A. Right.
20 C. Procedure-uise, do you remember about that 21 wood at all?
22 ?. . Yes. It said s slight am.ount of wooc fuz:
C O U t? T Y COUET REPOFTERS, I !! C .
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61 1 ani splinters are acceptable.
2 Q. In your opinion, what would be wood fuzz and 3 s all amount of splinters?
4 P. Nell, you know, small chips remaining after 5 they jerk off the forms. You are going to have a 6 littic splinter here. And when you have a splinter 7 that goes in this way, you can't remove it. So hey, 9 it's going to fuzz up on the end rather than --
9 0, tiell, what I was getting ,at is a splinter say 10 of a quarter of an inch in length, and if it was 11 laying horizontal to the surface, maybc the size of -
12 hair, or is that too small?
13 A. That's too small. I would scy about the 14 neasure of your little finger, that size.
15 O. The size of my little finger, say ,,
16 three-cights to a half-inch long or wide and maybe --
17 7. . Pight. I sau that left in there. I myself 18 didn't allow it, but it was in the book.
19 0. That it could be accepted?
20 A. Yes.
21 Q. As best you can tell, what would be the uppcr 22 limit that the inspecting staff would accept in the
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62 l
1 wood, if you would? What was your upper limit, and 2 then what would be the QC inspection staff's upoer l
3 lit.it?
4 4. !iell see, in the latter days we got some real 5 inspectors in. And when I first got there, after they 6 got rid of I didn't say anything. I bought 7 everything and continued to, until I got(fired)
% J And ,,
B there was no upper limit.
9 Q. For you, personally, there was no upper limiti 10 Is it facetious to say a piece of 11 four-by-four stuck in the concrete would be acceptable 1 12 A. No. That wouldn't be allowed.
13 Q. By anybody at the plant, that you know of?
14 A. Not that I know of. But now if they come and 15 swing a 1411 over it where you couldn't see it, - , ,
16 Q. Okay. But in the inspection of the raw 17 concrete, the inspector should identify something of 18 the border of a four-by-four?
19 A. Right.
20 Q. He would find that unacceptable and they 21 would have to rework that concrete?
22 A. Right.
COUNTY COURT REPORTERS, INC.
63 1 Q. How about a two-by-four? I am just trying to 2 find --
3 A. No. There would be no full-sized boards Icft 4 in it.
5 Q. So it was something then under one inch by 6 one inch?
7 ' A. Right.
8 Q. But it could be, say, that big and be 9 acceptable?
10 A. I don't recall what th'e spec says, but --
11 Q. The spec doesn't give a limit. I.am trying 12 to gct a feel from while you were there if'you could 13 remember back --
14 A. Just my estimate, I would say finger size.
I 15 Q. Finger size being we will say a half-inch, 16 wide by two or three inches long?
17 A. That sounds about right.
18 Q. In your experience, that could be acceptable l 19 by procedure? j 20 A. I don't recall what procedures say, really.
21 Q. How would the wood be removed; or it would l 22 just be left?
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64 1 A. Right.
2 Q. They didn't hit it with a water blast?
3 A. No. Mostly the service prep I saw was hand 4 rock and water wipe.
5 Q. Hand rock?
6 A. Yes.
7 Q. What is a hand rock?
8 A. It's e Carborundum stone with a handle on it.
9 And they use it to grind down the form lines and --
10 0 By hand?
11 A. Yes.
12 Q. They wouldn't use a needle gun? They 13 wouldn't use a wire brush?
14 A. No, not in general.
15 Q. Wood in concrete is one example of a foreign 16 material embedded in the concrete. Can you tell us 17 anything else about foreign material embedded in 18 concrete besides wood? Rebar chairs maybe, or 19 plastics sticking up?
20 A. Sure, all the time.
21 We had a lot of problem with that. When 22 they did their hot functional, everywhere the rebar r
COUNTY COURT REPORTERS, INC.
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65 1 chairs were exposed, you know, and they coated over 2 blister, you know. So you had about a thousand 1.ittle 3 failures about this big. (Indicating.)
4 Q. Could you tell me roughly what area that ~
5 might have been in?
6 A. Main steam penetration area.
7 O. Were there any other areas?
8 A. No. I believe that was it. You know, pretty 9 localized, because it was so hot in there.
10 0. Would you feel comfortable if I used that 11 number of thousand literally?
12 A. It would be best to talk to 13 He wrote a nonconformance on it and l
i 14 closed the nonconformance. He wrote the 15 nonconformance because there was blisters everywhere, 16 and he went in here and fixed some down on the lower 17 four feet of the wall and closed the 11C R . So he 18 rewrote another NCR.
19 So I don't recall what happened then. I 20 think management shut him down.
21 0. Okay.
1 22 The concrete coatings blister in the l
l
66 1 area of the rebar chair, was that because the rebar 2 chair was penetrating out of the concrete, do you 3 remember?
4 A. Yes.
5 C. By procedure, would the trade sand it down or 6 grind it down before they applied the coating?
7 A. Yes.
8 Q. So these were areas that they missed for some 9 reason?
10 A. Right.
11 See, these coctings were applied years 12 before I got there and it was all reapplied when I got 12 there.
14 0 So you don't know whether or not they ground 15 down the protrusions in the procedure? .
16 A. Right. We investigated it and saw little 17 blicters and cracks here, so we whipped out the pocket la knife and dug, rebar chair. Then you noticed, you can 19 just count the chairs as you go down; blister, blister, 20 blister.
21 Q. Did you personally see the area that was 22 repaired?
CO U !!T Y COURT REPORTERS, INC.
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67 1 A. The one that was repaired to close the NCE?
2 Q. Yes.
3 A. Yes.
4 Q. If my memory serves me correctly, there is a 5 repeir done in elevation --
it was in elevation 905.
6 It was underneath the floor of elevation 905 in the 7 ceiling where the main steam lines are. Does that 8 seem familiar to you?
9 A. Right.
10 Q. It was like two rows of rebar chairs that had 11 been ground down. Do you know what I'm saying?
12 A. Yes.
13 Q. Is that an acceptable way of repairing an 14 area such as that, to go in and grind down the 15 concrete and the rebar chair? ,,
16 A. And reapply coatings?
17 Q. Yes.
18 A. As far as I know it is.
19 Q. And do you know of any reason why we would 20 expect that to fail in the future?
21 A. No, but they didn't repair them all when I 22 was there.
l COUNTY COURT REPORTERS, INC.
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6E 1 0 Okay.
2 Do you believe it was a time-dependent 3 failure, or was it because of the temperature gradient 4 created by the hot function?
5 A. I feel it was the temperature.
6 0. So when they go up to the operating 7 temperature of the plant, if it's ever allowed, they 8 should have those areas occurring again?
9 A. Yes.
10 0. Another foreign material that could be in the 11 wood -- concrete, is metal. What types of foreign 12 estal objects did you see in the concrete?
13 A. Well, wire, nails, just standard stuff.
O 14 C. Wire and nails to me are normally -- were 15 they sticking on end, or would they be in any --
16 A. Generally the only ones that were left were 17 sticking out, you know.
18 0. So we are talking about an area say of an 19 eighth of an inch in diameter, something along those 20 lines?
I i
21 A. Well, they had a criteria for priming metal 1 22 objects in the concrete that were over I guess half c r.
COUNTY COURT REPORTERS, INC.
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69 1 inch, it seems like, and it was acceptable to coat 2 over.
3 Q. When yca primed them, did you do any surface 4 prep on the metal prior to the trades personnel? Did 5 you inspect the metal that the metal objects were in 6 fact prepared and had some sort of profile to them?
7 '
A. I believe that was part of the inspection, 8 yes.
9 Q. So as far as you know, you don't remember cny 10 influences where there was a polished surface that 11 they came and applied a primer to and then went on it 12 and coded?
13 A. A polished surface was pretty standard, if 14 you could get them to clean it up that good.
15 Q. Okay. .
16 But a polished surface didn't give you 17 that profile the way you di cussed earlier?
18 A. Right. Profile, .1ke I said earlier, we had 19 no way to determine profile for a year.
20 Q. And from your experienec, would you be able 21 to comment that there was no profile, or minimal 22 profile, or --
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l COUNTY COURT REPORTERS, INC. !
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70 1 A. I would say minimal.
2 0 And minimal is less than one mil, in your 3 opinion?
4 A. Yes.
5 O. So we have talked about wood in the concrete, 6 metal in the concrete, plastic in the concrete. In 7 your experience, were there any other foreign-objects 8 that you ever saw in the concrete? Old rubber boot?
9 A. Yes. Outside containment, they found duct 10 tape, duct tape covering voids; they found rubber 11 hoses.
12 2. Eut these were non-service level one?
13 A. They were in the fuel building, in a pretty 14 critical area.
15 O. Could you give us any details so that as ,
16 could go back to that area?
17 MR. HAUKIMS: It's non-strvice level o n -2 .
19 MR. LETTIERI: You don't want to pursue that?
l? *! F . H P. '.: K I t: 3 : Uc can't pursue it.
20 A. It was in our specifications that ue ucre to 21 inspcet high level service such cs the vault. 'ut n i
2^ nav er cin.
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C3UPTY COUPT REPOPTEFS, I i10 . !
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r 1 !Y R. LITTIEPI:
2 0 "ut in your expcricnca, did you ever insp:c*
2 fuel such as wood, pl:,stic or tapc?
? .. Ta,rc. ' lot of tape. -
5 Q. The tape that wts erbe4 dei in the concrete, 6 or was it covered?
7 A. It was covered.
F 2 This was a void i r. the concrete?
i 9 A. Generally this tape was apnlied by craft to 10 cover cit 5er a void that we had rejected and they say 11 okay, we will block it out. So they would block it 12 out, all right, and cover right over it.
13 0 So they would put a piece of duct tape d own --
14 5 Meaning they are not supposed to coat.that 15 area.
16 C. But trey would inspect --
17 A. Coat the area, right.
18 0. With 11/120l?
19 . A. Right. You wouldn't know anything about it 20 until you investigate the cause of these cracks here.
21 Duct tape, again.
22 Q. Ilo w about if there was a Richmond insert in COUNTY COURT PEPORTERS, INC.
?1o vane.uilio na -wo.*m- vr en,en ,, ins ce2 5cm,
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1 the wall? How would they handle that?
2 A. Smear right over it. Sometimes they would 3 paint it. Sometimes they wouldn't.
l 4 Q. Would they duct tape over that and paint over
. 5 it with 11/1201?
6- A. Yes.
7 Q. Did they ever tape inside the threads so that i
q 8 you could in fact remove the tape at a later date and 9 use the Richmond insert as it was intended?
j 10 A. No.
11 Q. So if I understood you correctly, that .t h e 1
12 four items that you would have experienced at the d
13 plant in concrete was wood, steel, plastic, in general 14 and also tape, duct tape over the hose?
15 A. Right. Foam rubber inside the Richmond ,,
16 inserts, a lot of them had foam rubber I guess 17 protecting the threads. And also --
18 Q. They would not be removed?
19 A. Right. And they coated a lot of seismic 20 joints, you know. They are filled with foam. They 21 are not to be coated, but they coated over them.
. 22 Q. I am not familiar with that. You are saying 1
i COUNTY COURT REPORTERS, INC.
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73 1 that there are. places in the plant where due to 2 seismic criteria, you put the foam and by procedure, 3 you are not to coat those?
4 A. Right.
5 Q. Do you remember what coating procedure that 6 would have been?
7 A. That tells you not to coat it?
8 Q. Yes.
9 A. It would be in your specification, surfaces 10 not to be coated. Machine surfaces. Seismic joints.
11 Q. That's the title of a procedure, areas not to 12 be coated?
13 A. That's a paragraph in specification.
14 Q. Oh, Specification AS317 15 A. Yes. ,
16 Q. Does call out what areas are not to be coated' 17 A. Yes.
', 18 Q. Yet the paint procedures in and of themselves 19 don't reference that criteria?
20 A. Yes, they do. The paint procedures are 21 supposed to be taken directly from the specifications.
j 22 Q. I realize that. But what I am'saying, though, I
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74 1 is if I followed my paint procedure exactly the way it 2 was written, it never goes back and references --
3 A. The items not to be coated?
4 Q. Right.
5 A. I really can't remember that procedure. I 6 have got four new ones out here and two new specs.
7 Q. You are doing much better than I would do if 8 I had to try to remember two sets of jobs at the same 9 time. But for example, CCP 30, does that ring a bell 10 to you?
11 A. Yes.
12 0. That's the steel procedure?
13 A. Right.
, 11 Q. And then C,C P 40 is the basic concrete 15 procedure? -
16 A. That sounds right.
17 Q. If I were to go through those procedures, 18 would I expect to find something in there that tells 19 me not to coat certain areas?
20 A. I don't think it's in the procedure, but I 21 believe it is in the specification.
22 C. What I am trying to get at is would the l
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1 trades know not to coat that area if they read there 1
2 procedures?
3 A. The craftsmen, probably not, because ;
4 knowledge is kind of jealously guarded up there.
5 They don't educate their craftspeople as 6 to what's required and all that. Do it like I say, 7 and that's good enough.
8 0 And who is talking when they say that?
9 A. The foreman. You don't need to know what's 10 in the book. I will tell you what to do.
11 O. But the foreman, if he follows the procedure, 12 would he know?
13 A. Yes.
14 C. So if I went and tried to go through the 15 procedure, as far as you can tell, it should tell ge 16 in there these areas not to go in?
17 A. Yes.
18 Q. But you are not sure?
19 A. In specification, I don't believe the 20 procedure is mentioned. I can't be for sure.
21 C. I would like to go next to something that 22 came out of your OI statement t And in COUNTY COURT REPORTERS, INC.
91o o=, v,.i11. e4 vw..+nn tr ento 7 t ,1' ? ) An1 ic??
76 1 there you stated, I believe,.that the procedures 01, 2 OP 1123 and 1124 are very vague. Do you remember 3 doing that?
4 A. I remember saying that.
5 O. Can you tell me anything at all about'why you 6 would make that statement?
7 A. Well, the brevity of them, for one thing.
8 There were only about two or three pages in each.
l 9 And see, backfit got watered down a lot.
10 It started out visual examination. I mean this and 11 that. And then they would leave off the visual and 12 then they would leave off this. And then finally they' '
13 left off that.
14 C. So if I went to the historical file, I would 15 see that even though the procedure is briefed te begin ,,
16 with, it gets even briefer with time?
17 A. Yes.
18 0 Do you remember the procedure requiring you 19 te remember DCA's and not having a reference to the 20 DCA?
21 A. The specification was about this thick and i
1 22 the DCA's were about that thick. (Indicating.) l l
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77 i
1 Q. A little bit of an exaggeration?
2 A. I don't know. It was a book, three-inch 3 binder. And --
4 Q. Before we go any further, DCA stands for 5 design change authorization?
6 A. Yes.
7 Q. And those are attached to the back of 8 Specification 7.S31?
9 A. Only those that are incorporated.
a 10 Q. Those that are incorporated.
11 So we could say in a three-inch binder, 12 the specification is roughly one inch and the DCA's 13 T. a h e up the remaining two inches?
14 A. If you count the unincorporated ones, it 15 would be well over two points. ,,
16 Q. Why would you use an unincorporated QA?
17 Procedure requires that you -- not procedure, but the lE specification would require you to?
19 A. No. I never could understand it, except that, 20 you know, I had a boss saying it's good; you've got to 21 go by it.
22 Q. 3 DCA is issued?
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79 1 A. Pight.
2 0. And approved by all the proper authorities.
3 Somr of them are incorporated to the specification.
4 '7 hen you used the specification, did it refercnce b a c k.
5 to the DCA; do you remember?
6 A. 1:e didn't have ? specification. Uc :c r o 7 supposed to use the procedures, and we had an info 8 copy of the specification, and when they found out 9 that, they took it away.
10 0. So when you were working there, you did not 11 oven have an info copy of the specification?
12 A. Fight.
13 C. Yet ycu were required to know about DCA's 14 that were in the specification?
15 A. Right. , ,
16 Construction had all these, see. And QC 17 didn't even know about it until they tried to turn 18 something down, and they said well, we have got DCA on 19 that. It's just a piece of paper. It doesn't say 20 incorporated. It doesn't say approved, control or 21 anything. You've got a xerox copy of a piece of paper 22 and --
COUNTY COUPT EEPORTERS, I ll C .
79 1 0. And that was the justification that you were 2 recuired to live with?
3 A. Yes.
4 C. So if you were to find a defect in th=
5 coatings, they produced'a DCA th'a t you may never'have 6 seen before, you would say to yourself, if to no one 7 else, due to this DCA, I will accept that?
? A. Yes.
9 Q. Facity area.
10 Did you ever use the DCA's to justify?
11 Were you recuired to?
12 A. Yes.
13 0 Chat I am saying is did you document that per 14 DCA so-and-so, I'm excepting this area?
15 A. No. You just wrote satisfactory. ,
16 0. So a satisfactery area could be an area that 17 had no problems or had problems that were --
there 18 were DCA's that said that you were allowed to accept 19 it and off you would go?
20 A. Exactly.
21 Q. And in your mind, there was no difference 22 between an incorporated and an unincorporated DCA?
i COUNTY COURT REPORTERS, INC.
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@C 1 A. In my mind there is; but in their mind, 2 management's mind, there was not.
3 Q. Did. .
4 And any DCA that covered the area given 5 to you was accepted?
6 A. Yes.
7 Q. Now, vague is a very subjective term, and I 8 am trying to put some objectivity into it.
. 9 From listening to o u t. discussion here, I i
10 would say that because you had to use DCA's that~were 11 not part of the procedure, that was one example of how 12 it was vague.
13 Can you give me any other examples that 14 I could use where you were trying to.use your 15 procedure, you came to an area where you didn't know 16 what to do and somehow you got instruction, yet it 17 wasn't in the form of the procedure?
18 A. Well, --
i
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19 Q. DCA's were one?
, 20 A. We had meetings twice a day and those 21 meetings and their policy carried'far more weight than
)
! 22 the specification, the procedure or anything.
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COUNTY COURT REPORTERS, INC.
219 Nacerville Rd., Wheaton. IL 601R7 (312) '653-1622
61 1 would get up there and 2 say okay, boys. This is how we are going to do'it.
3 0. Where would you have those meetings?
4 A. In the office.
5 0. Okay.
6 So when you would go into that area all 7 gf the.0C Inspectors would sit down roughly what, 7:30 8 in the morning, 8:00?
9 A. Twice a day, usually.
10 0 But what time of the day were these, usually?
11 A. 7:00 in the morning and usually either right 12 after lunch or at 4:30.
13 C. And he would dictate what the policy should 14 be for the day, so to speak?
15 A. Right.
16 0. And if that didn't meet the procedure, --
17 A. My way or the highway.
18 0 My way or the highway?
19 A. Exactly.
20 0. Meaning that if you didn't do what he said, 21 even though it violated your procedure, you would be l 22 fired?
COUNTY COURT REPORTERS, INC.
219 Faperville Rd., Wheaton, IL 60187 ( 31' 2 ) 653-1622
l 22 1 A. Exactly. '
2 Q. So we have gotten examples now of how the 3 procedures were vague, in that you were receiving 4 verbal communications from telling you 5 how to do the procedures, even though they violated 6 the procedures?
7 A. Right.
8 0. You were using DCA's to accept areas that the 9 procedure told you not to accept?
10 A. Yes.
11 O. Do you feel that that was really the two 12 areas? Is there anything else that I should look into:
13 E. . Well, to me, the specification is the mother 14 document, the ruling document. But you look through 15 the historical file and you'll find that constructi,o.n i
16 procedures deviate wildly from the specification. And l l
17 our OP's, quality procedures, referenced construction 18 procedures.
19 So, if you don't have a controlled spec 20 around --
if you don't have a spec around, period, 21 you've got to go by what the construction procedures 22 say. And they were totally different from what the l
l l
8 1 specifications say.
2 0. I have heard this before and I still don't 3 understand it.
4 What you are saying is the first section-5 of procedure referenced a number of documents, roughly?
6 Somewhere the procedure references a CCP 30 or CCP 40 7 or some construction procedure?
8 A. 1o. The QP said inspect per CCP 30, 9 paragraph so-and-so. Anchor profile, inspect per.
10 CCP 30 paragraph so-and-so.
11 0. So you needed then the construction 12 orocedures to perform your own inspection?
13 A. Yes.
14 0. Did you have those procedures?
15 A. Yes. Not controlled. ,
16 0. Net controlled?
17 A. Right. We didn't have a lot of control IE documents.
1 l
19 0 So do you know of any times where you were 1 20 using procedure that would -- a construction procedure 21 that was in error because they hadn't given you s 22 control copy of the latest revision?
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04 1 A. I can't recall right now any specific 2 instances, but I do recall a number of discrepancies 3 between the construction procedure and the 4 specification.
5 C. There were discrepancies then between the 6 construction procedure and the specification and you 7 were using the construction procedure because'that's 8 what your procedure told you to?
9 A. Yes. And every time they found out we had a 10 copy of the specification, they searched every drawer, 11 every box, everything in the whole building until they 12 found it and removed it.
13 0. They meaning 14 A. Yes.
15 O. The fact that you had to jump from a QC 16 inspection procedure to an operating procedure, in 17 your opinion, would that hinder your ability to do 18 that procedure or --
19 A. Yes, it did.
l l 20 0. Why did it hinder your ability?
l 21 A. Well, your inspection; it should never change, 22 You know, an SP 10 is an SP 10.
COUNTY COURT REPORTERS, INC.
, - . _ = _ _ _
8 1 0 You are talking about service work now?
2 A. I'm talking about inspection in general.
3 0 I know. But when you say SP 10, you are 4 talking about the profile or the blast surface is now 5 an SP 10?
6 A. Right.
7 0 Okay.
8 How does it change, for example, if you 9 go from the QC document to the construction document?
. 10 A. Okay. For one thing, profile. You used to 11 have a one mil minimum profile. Rev 85 says 12 Strip-N-Clean gives adequate profile, period.
13 0. So if I understand it right now, the 14 procedures make you jump around, and that could 15 inhibit your ability to do an inspection?
16 A. Sure.
17 We weren't made aware of any revisions 18 or changes, so the construction liked to keep this 19 stuff under their hats, see, and so you turn it down 20 for no profile, and we got you here, look here.
21 0. It was a game between construction and OC?
22 A. Construction was winning all of them, I'll l
i 1
l l
COUNTY COURT REPORTERS, INC. '
9 t o . e . n o . . 4 1 1 .- ca vwo.*n- vr enio, ,,ios cet_1c07 '
86 1 tell you.
2 Q. They had the upper hand?
3 A. By far.
-4 0. Did you find that the QC procedures were 5 confusing because when you look at a procedure, it 6 incorporates repairs, application of primer.,
7 application of top coat; the procedure was all 8 inclusive for say steel?
9 Everything that you needed to do with 10 steel was in construction procedure CCP 30, and then 11 there was an associate quality control procedure, but 12 that one procedure included everything? Did you find 13 that?
14 A. No, not really.
15 0 It was the fact that you had to jump out o f, 16 your own procedure into somebody else's procedure that 17 wasn't current? That was the problem?
18 A. You are ispected to CCP 30, paragraph 11.4, 19 and you remember what it said yesterday, you know, and 20 what it's been saying. But if they have had a 21 revision, you don't know about it.
22 0. And since you don't know about it --
COUNTY COURT REPORTERS, INC.
9,e . - - o ..,4 13n ea -,-.-- vr Anic, r,19s Ace.1A?;
E7 1 A. You are still inspecting Rev 4. You .ight be 2 on Rev 7.
3 f: P . H AW K I !; 5 : Let's take a five-minute break.
4 (Whereupon, .there was a break 5 taken, after which the Statement 6 was resumed as follows:)
+
7 EY MR. LETTIERI:
8 Q. Would you then proceed with that exaT.ple on o how the procedures were?
10 . . . 1:e l l , for instance, you are sent out to 11 examine a concrete wall and it's got cracks throughout 12 the surface. It can pass th; 25hesion tcst and rhe 1- tooke test rev als the z.i l e. g e is all right, but it'.c 14 still cracked and th refore unsstisfactory. But '5at 1E wasn't part cf the procedure, so you wrot? a ,
1: r-tisfactory backfit d ecu ent fcr that.
17 0 Okay.
1? I could like to go on now to th?
19 1'h&sion tests thorsnives. In the OI s t a t c .r. t n t , y e t: ,
20 I bili'v:, st t:f that they usre not properly i i
21 7 rfor :f. Ocul' ycu give ne any examples? l 2: .. ~. : ] 3 , t '. s spreificatien said that we voul?
i COUNTY COURT FEPORTERS, I t:0.
21c "ancrviii- n'.. .er. ?? Ae' (ii?) A t ' 1 e r j
C*
1 fellow the T.anufacturer's r e c o T.m e n d a t i o n s , which is :c 2 cut aroun? the adhesion dellies, and we weren't.
3 And everybody that_had ever messei with 4 sn cdhesion tester had been trying to cut around the 5 icilies. So when they c a r.e te work for Cornnche Peak, 6 they had to be retrained that you don't have to. cut.
7 around dollies, because we say so.
8 And also, the manufacturer's 9 recommendations say when you reach a thousand pounds 10 pull, you have damaged the integrity of your machine 11 and you have to rebuild it. 'They didn't do that 12 either.
13 ;;h e n you have got your machine and it's 14 brand new, you've got failures, adhesion failures.
15 But I don't know if those things were designed to b e.
16 used ten hours a day or not, but after you got a few 17 miles on them, you didn't get any more failures.
18 And by the time you put your machine on 19 there and snugged it up tight on the dolly, it would 20 be on 200 pounds which is your minimum, and you could 21 still slide the machine around the dolly.
22 And before we ever got a set of COUNTY COURT REPORTERS, INC.
nio .,- - - . .. 3 3- e .u--.-- ,e case, ,,$ ,i ces icne
89 1 manufacturer's recommendations, we didn't know that a 2 thousand pound pull damaged the integrity of t h'e 3 machine.
4 And we reached thousand pound pulls -
! 5 pretty often on all the machines. And you know, it's
{ 6 just been -- that's just because we didn't know. He 7 hadn't read the manufacturer's instructions.
1 8 All this was kept from us until one day 9 a machine came in and had the instructions with it and 10 really opened our eyes a lot.
11 Q. Were you properly trained in the use of the 12 c1chometer adhesion testing?
13 A. It's a pretty simple operation. They gave me '
14 on-the-job training for it.
15 Q. Did you ever certify that you could properl,y 16 use the instrumentation?
17 A. Yes.
18 Q. You did?
19 A. Yes.
20 Q. After the on-the-job training? ,
21 A. Yes.
22 Q. Can you give us any_other examples of how the COUNTY COURT REPORTERS, INC.
719 Nanarville Pi.. Whaaton. f t. 60187 (112) 653-1622
9C 1 t ests were not performed properly, such as the example 2 y ou gave me where you get a 200 PSI reading and still 3 be able to move the base? Can you think of anything 4 e lse we ought to look into as far as how those 5 i nstruments were not properly used?
6 A. Well, I don't know what their calibration 7 p rocedure was, but for instance, I had a machine blow 8 up on me one day.
9 I guess I stripped out something, but 10 about half of the washers inside of it fell down the 11 d rain. And so I took it over to calibration. They 12 s aid oh, man. We will have to send this back to the 13 co.moany. It will be a month before it comes back.
14 The very next day they checked it out, this is ll 15 EEk and it blew up on him.
16 Q. You are saying that they improperly 17 reconstructed them and calibrated them?
18 A. I don't know what they did. I know they told 19 me it was going to be a month before it was back in 20 service, and the next day it was back in service doing 21 the same thing.
22 Q. Do you know this by serial number that it uns COUNTY COURT REPORTERS, INC.
91o v . m o ri,4 1 1 o oa ..n--.-- ,, enie- ,34 as re, 'e a
91 1 the s me?
2 A. Yes. And I saw half of it fall down the 3 drain and never retrieved; these washers inside of it.
4 Q. Would you happen to-remember that number, or 5 anything that could identify it?
6 A. Mo, sir. I'm sorry.
7 Q. Okay. Unless you have anything else to tell S us about the adhesion tests, I think we ought to go 9 back to --
10 3Y MR. HAWKINS:
11 C. Let mc ask him, are you familiar with the 12 calibration curve for the elchometer?
13 A. Yes.
14 Q. Did they develop a curve for each machine and 15 did they use them? ,
16 A. No, because they never read the 17 manufacturer's recommendations either. And when we 18 read them and tried to convince them of it, that was 19 all considered anti-production static and it just 20 wasn't looked on very favorably.
21 BY MP. HAUKINS:
22 C. All right.
l COUNTY COURT REPORTERS, INC.
71Q *enorvillo DA. . t?bom6ma . T f. An197 ( 1 1' ? ) 691 1677
@2 1 You mentioned that you had a concern 2 about overspray into areas that had previously been 3 inspected?
4 A. Right.
5 Q. Was this on concrete or steel?
6 A. Steel.
7 Q. It must have been steel, right.
8 Did you personally observe it?
9 A. Yes.
10 0. Do you recall any specific areas where it 11 took place, or was it commonplace?
12 a. . Commonplace.
13 0. In your own mind, what's the significance of 14 overspraying?
15 A. Well, I just know that it wasn't allowed b y. .
16 the specification. I believe that it could 17 potentially trap contaminants, radioactive 18 contaminants.
19 It's just not good paint practice. It's 20 not allowed by the specification.
21 0. Do the procedures require removal of the 22 older spray?
i l
l COUNTY COURT REPORTERS, IHC.
71o : 3 n e. , ,. i 1 1 r, na vwo,- Tr en1on r119s Ac1.1A?7
93 1 A. Yes.
2 Q. Why didn't you all remove it?
3 A. Because our boss, said that's 4 good enough. That ain't overspray. That's tightly 5 adhering.
6 Q. This was typically on the top coat?
7 . A. Yes.
e Q. Your concern then is one of that the 9 overspray is not tightening the area; that in your own 10 mind it can trap radioactive pa'rticles and that --
11 A. That's what I believe. I believe the wholc 12 purpose is to have a smooth, decontaminable surface 13 with plenty of gloss to aid in this removal of 14 contaminants. But you don't have any gloss out there.
15 When I was there they would paint up, 16 about 20 mils and then grind it down with 60 grit 1
1 17 sanding wheels and you would just have a lot of i l
18 scratched up top coat.
19 BY MR. LETTIERI: l 20 Q. Is that why you feel that the contaminants 21 would get into the coatings, because the surface hai 22 scratches in it? I am trying to understand your COUNTY URT REPOPTERS, INC.
pio :u n n v o i 1 1,, e4 w_,..-- tr en,e7 st i9s res_sco,
94 1 concern about the contaminants being trapped.
2 A. On a smooth, slick surface like glass, it's 3 just a lot easier to wash it off than if you have got 4 a scuffed, rough surface.
5 1:h e n I first went there, you had to 6 inspect for everything, you know; gloss, color, 7 everything. But later, gloss went out the window.
E And they put it right in the procedurc 9 and everything, it's permissible to pour sand down to 10 acceptable milage.
11 C. Okay.
12 In the overspray area, would they 13 f :- a t h e r back when they went in to tie that into the 14 r.= x t ;res?
15 A. No.
16 C. Co uhat you are ssying is the overspray was 17 left. It's the ragged edges caused by the overspray 15 that could in fact be trapped particles?
19 A. Right.
20 0. And that's where you are concerned, because 21 you have this big area?
22 A. Right.
COUNTY COURT REPORTERS, I t!C .
219 !!acerville Fd., Wheaton, IL 60187 (312) E53-162:
95
, 1 EY tm . P. A U K I !! S :
2 C. You said-it was very widespread. You are 3 implying by that that we would be able to go out in 4 the field almost anywhere and ses it?
5 A. Right. They just would not mask. They just 6 weuld not mask, bccouse 00 wanted them to mask, and by 7 G06, they wasn't going to mask.
2 0 2.11 right.
9 You mentioned a concern about your 10 inspection of high level radiation areas.- We 11 discusse6 briefly before the fact that those are s 12 vcre probably not servicc service _ level one. Is that IT true?
14 A. Eight.
1 15 C. Rc:1 quickly then, what types --
could you 4
1A giv? me a little history of what types of p r o b l e r.s 17 ri r e cecurrin- in those areas and hev the inspections 10 changed as t i t.e went by?
19 . . . Uell, tre specification required all r. l o n g 20 that high redi: tion levels outside containment woula 21 be inspectad. ?ut just because the specifiention s,id 22 tnat, it didn't mean that they would do it.
COUNTY COURT REP 0eTERS, I t: 0 .
710 tanarvilla Rd.. Whea+or. IL 60187 (312) 652-1622
DE 1
So then they decided verbally that they 2 would have a final inspection after it was all over 3 with. So was doing all the final 4 inspections and he is buying them off about two to 5 five a day.
6 And so they called some night shift 7 inspectors to go out and look. The first time anyone s ~-
8 other than jEEE Lhad inspected outside, there they 9 found the rubber hose and the whole floor buckling and 10 cracking and non-adherent and duct tape over voids in 11 the concrete. And generally, coatings way in excess 12 of the required thickness.
13 C. You mentioned, though, in your discussions 14 with lll that some of those problems that you just 15 said occurred in the high level radiation non-service ,
16 level one areas. That those problems also occurred in 17 service level one areas; is that correct?
18 A. Pardon me?
19 C. You had the same type of problems occurring 20 inside containment as these areas we just had 21 discussed?
22 A. Right, but --
97 1 C. In the high level radiation areas?
2 A. Right. We found these things a. piece at a
-3 time.
i 4 You know, you see the walls crack and 5 you wonder why. You whip out your knife and dig down 6 and find duct tape.. Or you find that they have coated i
i 7 a seismic joint. And you know, there is a reason for t
j .
8 mest all cracks.
9 Q. All right.
1 10 Because it's non-service level one, I i 11 should have to tell you that we don't have the
!l
! 12 responsibility to carry it. But I wanted to get the 13- feeling of the prevailing attitude of the type of 4
14 quality work they wanted to do. And I think we h ve 15 got that.
16 MR. LETTIERI: Are we still on concern number 17 three, or did we jump?
18 .v R . HAUKI"S: We are on five.
19 MP. LETTIERI: We skipped four, or we covered four 20 through other discussions?
21 MR. HAWKINS: De discussed the tooke gauge during 22 tne backfit program.
i
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1 !
COUNTY COURT REPORTERS, INC.
91o .,-...43 1- ca w..... ,, ense, , 3 3' m s ce3.sc,-
9E 1 If you don't have any questions on five, 2 5: e will go en to six.
3 MR. LETTIEPI: Question five was asked just for l
4 attitude?
5 '! P . HAWKINS: Yes.
6 MR. LETTIERI: I have no questions.
i 7 BY !! P . HAWKINS:
l 8 c. We wanted to discuss with you the 9 identification of non-conforming conditions. What e r '.
10 your concerns in that area?
11 A. Uc11, it's been my cxperience that if you I
12 identify them, they identified you and usherei you ;
23 right on out. Your attitude was look past them. !
~ 1 14 I had a rrecting with on it l 15 one time. He says, "I don't know why you guys want te 16 get out here and make trouble for yourselves. Now we i
! 17 don't want to get nobody hurt, but that's what it's 18 moving towards. You all are supposed to enjoy this
! 19 job. You are supposed to get out here and have fun.
20 Den't be so serious." That's 21 BY MR. LETTIERI:
22 C. That was e quote?
,_.__--,__----r - - - - . - - , - - * - - - - - - " " " - - ' " ~ ~ ' ' ' " - - - - - ' - - - ' - ' ' " - - ' ' ~ ~ " " ' ' " " ' ' * - ~ ~ ~ - ' " ' ~ ~ '
90 1
1 A. Yes. That was recorded on tape and 2 transcribed and sworn to by me. And I remember a lot i
- 3 that thav conidn't get transcribed onto the tape.
3 4 BY MR. HAUKINS:
5 c. Il o w are non-conforming conditions typically 1
6 identified?
7 A. The book said any time a situation arose 8 where you did not have a standard repair, it would be 9 identified on a nonconformance report.
i 10 Now, for the first couple of years, you i
li know, I just floated downstream. I looked past them 12 like everybody else did, like I was meant to do. And j 13 then we got some T. ore aggressive inspectors in, you 4 14 know, that hadn't been already cued. .a nd so they set
) 15 3 bout writing UCR's. Well, we were told verbally this ,
16 group will not write any more NOR's. And --
1 17 0. Did he give you an alternative method instead 12 of writing the NCR's?
}
19 A. Well, not at first. Later on they decided I i
20 guess they had used a little too strong innguage.
- 21 Then tney decided to tell us, "Well, now, we are in 22 the nidst of revamping all these specs and everythin]
l f
COU"TY COUPT REPORTERS, IUC.
i eso .---..411e ea ,'.w . . . n - tr Anie7 rif?) 65'-Ir29
l 100 i
1 ar.d well, you've got to read between the lines, Bill. 1 2 Ycu've got to read between the lines. What is it in l
3 this specification? I mean what is it that makes ther 1 1
4 think that they have got the right to write NCR's?" l 5 "Well, I guess, the fact l
6 that you referenced the NCR procedure makes them think !
I 7 that." )
8 But I strayed from the question again.
9 I'm sorry. What was the --
10 C. What types -- could y o'u give me some exampics 11 of conditions that were not identified or should have 12 been identified on NOR's or an IR, unsatisfactory IP? ;
I 13 A. Uell, for instance, things would just apoear l 14 painted.
15 O. What do you mean appear painted?
16 A. Well, you would walk in one day and here is 17 scmething that's painted and you say oh, that must )
18 have been painted on night shift. But you talk to all 19 the night shift inspectors; no, we didn't paint that.
20 We didn't allow it.
21 So to me, that's a non-conforming I 22 condition. Painted without inspection.
l l
l
^^"V' "' *?
- O * ? " * : IW* - _ ,
10]
1 C. You had no documentation on it; is that 2 correct? 1 l
1 3 A. Right. Just here, paint it. It happened a I l
4 lot. l i
5 For instance, you would go up to do a 6 final inspection and the last document you've got is 7 seven days prior. You are inspecting after full curc 8 of seven days, and fresh paint. Just a little last 9 minute dob there. You know, robody will know. A n d.
10 they wouldn't say anything if they find out.
11 0. Well, you are implying through this that work 12 was done without the benefit of quality control 13 inspection and outside the program that's been defined 14 for work to have been satisfactory?
1 15 ?. . It was. 1 16 C. Was that a typical thing and did you all 17 identify it or say anything to management about it?
18 A. Management was Harry. And one time I went
-. I 19 and complained to 'and I ended up in 20 office and I found out that(EEEhwas nothing but c 21 mouthpiece and that he was merely echoing 22 commands. And so I certainly never brought it in to COUNTY COURT REPORTERS, INC.
l 10; l
1 management again. I 2 0. If there are in fact a lot of areas you say 2 tha t were not inspected by CC, then wouldn't we be 4 abl e to go into the site and find that there was just ,
5 fla t out missing documentation on the areas?
6 1. . 1: o . Everything has bcen paintei five times.
7 *ha t's one more coat?
6 C. So what are you saying?
9 A. I'm saying you've got five top coat documents 10 on this hangar. There might have been seven paint 11 jobs performed on it. They are just missing two of 12 the m. You never know.
13 Q. Do you have any examples of areas where work 14 was done without the benefit of quality control 15 ins pection?
16 A. Yes. Down in the botoom, I don't know if 17 it' s in the core instrumentation room. It's that area, 18 and doun below it they have some guards posted saying -
19 That I didn't find on flC P , so I don't 20 know if that's really --
21 I You might ask him about that.
22 C. Do you knov of any instances where that COUNTY COUPT REPORTERS, I !J C .
nic ,-c...., $ na .w...., , en,e- ,3 , ce-
l' 4
4 1 happened and that wasn't identified and subsequently i
2 c e r r r- c t e d ?
4 4
4 A. res. I will try to r e m e t. b e r it. Let e 4 think. I guess it was on a hangar attached to the 5 liner plete.
l C Soe, you were allowed a errtain nu?ber i
7 of fiscontinuitics, you knew. So I had been un and i 5 inspectei this thing the night- beforo and id(ntified 4
^ s e i.e defectc.
1r .i n i so thcy .cre c:lling this guy i- ths 11 n:xt d:y to r. inspect it, and there was ne evid:nce cf I' :: ccu tntatier :r nything. ': c cn: .5 crilt' ::
1? fnse:ct it.
14 'ut anyway,
. h c '.- he get up there, w.-
1! ,m : i n t . ?n' so you k n t .' , ani the fercman, he ab ut l' su s110 ::' nin tsetn, "ut 5:t coul' . - - say! "h:t 17 :: 19 he 10 but lech th ?c pi sh and swaar he wcu13 nc..:
l' ': it : s i *. 7 II "ut it's ju:t t ' . ng:r. 7 don't knou if 20 there is any big uficspread coating or net.
j 21 -
"'. * " *t I ' ' : Oc you have ny questions, V i n c ., 2 i
! 22 'G . LTTTIEti: Yes.
i
- 1 i
I i ,
1 f.
1 0 0 0 !; T i' OCUFT'ETPOPTEPS, I t'O .
s,- . . . . ...: , , - ~> vu.,.n- 1 cenen r~ ins ce,_sen-
. l '- d 1 RY "R.
. LTTTITPI:
2 Q. If I unicrsrooi what you .:c r e saying, 2C
- . 3 would coma to sn area that hid to be inspected say for 4 top coat . application. So if it was inspected for the 5 primer, the substrate was okay, but nobody d o e u r.~c n t e d 6 that the priner was applicJ preperly, wouldn't -hat 7 jump out at you? Wouldn't the procedures keep you e from allowing them to accept an --
wouldn't the 9 procedures keep you from accepting an area that hafn't 10 been QC?
5 11 A. Well sce, when you you've got five coats on, 12 you've got, likt I say, plenty of records to look back 13 through and you say oh, well, this must be it. And so
~
i 14 how a. you going to knew if it's been QC's?
i 15 C. When you wcre there were they using the tern 16 thread?
17 A. No.
1E Q. Could you explain to me then how a repair 19 would be performed? If they damaged the coatings on 20 the steel head, then you have to prep the substratc, 21 you prime-it, you top coat it and QC looks at it ofter 22 the primer.
COUNTY COURT REPORTERS, INC.
219 !?arerville Rd.. Whaa*nn. tr eni:7 r119s cc' -
l 105 1 After the substrate is prepared, that's 2 the whole point. 00 says okay, go. They prime it.
3 CC comes back; primer is okay, go.
4 Don't you have to check as you go 5 through the procedure that it says that the last step 6 was done?
7 A. See, the things changed a lot in the two 8 years I was there. They have gone all the way fron 9 107 percent discontinuity testing to the traveler.
10 You know. That's a pretty big leap.
11 I really didn't understand the question.
12 One more time.
13 2 Okay.
14 If you were going to inspect for top 15 coat application, meaning that the primer was donc ,
16 satisfactorily, wouldn't you have to find a document 17 that says for that repair, the primer was in fact le inspected properly before you would allow them to do 19 the top coat?
20 A. No. The documentation was never in that good 21 a shape where you could look back and find the 22 document.
l COUNTY COUPT REPORTERS, INC.
oso e,en..411e e ,-i v. - . . . - - tr cnio, sofoi cc1_1rea l
l i
10 (
1 BY MR. HAWKINS:
2 C. Isn't that why the backfit. program was 3 instituted? !
4 A. Pight. And the documentation had never got 5 in that good a shape, either.
6 BY t:R . LETTIERI:
7 i C. But after the backfit program was instituted, 8 did you ever run into an occasion where you were --
9 A. You still couldn't look back and find 10 anything because you might spend half a day 11 rescarching the 6 o c u m e r. t a t i o n at one hangar and they 12 just would not let you spend that much time.
13 You went out there and you documented 14 whrt you allowed, w h a.t operation happened while you 15 were there. Uhst happened before, no concern.
16 C. What is the discontinuity test that you were 17 referring to?
16 A. The beep test.
19 C. Do you understand that?
20 A. Right. If you run a little current through 21 whatever you're testing and you run a sponge over it, 22 and where you have a pinhole, mechanical damage, 1
m,o .g COUNTY COURT REPORTERS, !!N .
a......t . m * ..e .. ..... ..* *** ***
.- , . _--,-.-_m -
. - . . . __ _ _ _ - . - . - - . . ...m.
101 1 holiday, it beeps. It's a noliday detector.
2 C. Was this a big area?
? A. All 3reas.
i 4 MR. HAWKINS: It's a standard test.
! 5 A. *:e were testing anything from shims that big 6 to a liner plate.
7 DY MR. LETTIERI:
E 2 Eut you didn't find a holiday that was four
- 9 square feet, did you, during this test? You found 10 pinholes a n .' --
11 '.. Uell, you could find large, yes, large crers 12 en the liner platc.
13 C. When you say large, what do you mean? Uhat 14 w 1d you consider a large area?
15 A. Uell, for instance, ten square feet wherc
{ .
16 they had power ground their top coat down to 60 grit 17 paper, they brokc the film back to the primer and so lE you just beep beep beep beep beep, you know, as far as 19 you wanted all over the whole thing.
20 C. So roughly, that ten square feet was to reach 4
21 all tnc way down to the substrate of the coating?
l 22 A. It would be te the next coat, not the COUNTY COURT REPORTERS, INC.
,,e .......4 ,s. a4 ..u..... ,, en,,, ,3i%. ce- a r+-
10 E 1 substrate. It would be through the top coat to the 2 zinc.
3 O. You worked at Comanche Peak through most of 4 1983?
1 5 A. Yes.
6 C. If I were to tell you looking at the records 7 I saw a large number of NCR's written in the 6 protective coatings for 1983, --
9 A. Right.
10 0. --
would that be what your recollection was?
11 A. Well, that's where all the trouble started.
12 Like I say, we got some diligent 13 inspectors and they just would not be shut up. And
~
14 every time they wrote one, they would counsel them and 15 tell them you know, hey, you'll get your ass run off 16 if you keep writing these. But they kept on writing 17 them.
18 You didn't see my name on many of them, 19 did you?
{ ,
20 Q. No, I am just looking at the gross numbers.
21 It appears to me prior to 1983, the numbers slowly 22 rose and then suddenly in 1983, there is like four COUNTY COURT REPORTERS, INC.
219 y 3 e,.. . ,,i i i ,, na ew.s,. . t, case- ,* a. -- --
- ~ . . - - - . _ , . , . - - - - . - , , . _ - . . _ . _ . . . _ _ - - . , . . - . - . , - - _ - . - - - .
10 0 1 pages on an eight-by-eleven sheet, four columns?
2 A. Well, thst's because us old hens, we knew 3 what the program was. We knew we weren't supposed tc 4 identify them and and we would suffer if we did.
5 These new guys, they just didn't care. They was goint 6 by the book and they didn't care.
7 C. Eere they fired, these guys that were writing E the --
9 A. :: o , but tneir supervisor was, and you(rc 10 looking at him. .
11 C. khey w o r t: e ? for you?
12 A. Yes.
13 C. Th?y were writing the NCR's -- Because tbGy, 14 wrote the PCR's, you were fired? ,
15 .T .
t: e l l , I was called down several times and,hrd 16 discussions with on, you know, why my guys 17 thought they ht$ the right to write an NCP.
18 0. And you discussed that earlier?
19 A. Yes.
20 C. Okay.
, 21 4. And at one time I discussed it with them for 22 three hours. They were trying to fire
- , ------- ,,___,y.-. -
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1 1 (-
1 for writing NCR's on blistered coatings in the main 2 steam penetretion area, and that was right before they s
me. / {
3
}ctr.inated ,
4 "B. LETTIERI: I don't think I nnve anything tis?.
5 PY "P. H a.E-[: I ;i c :
6 C. ?ncth:r it?r that we hcvc touched on beftrc, 7 but it was inspection methods that were dictnted to E tN insp;ctors by Ubst precisely scsin 9 was his pcsition on inspection techniques to be used?
1 r-
. " i *. e n you people are dowr thers ahing 3 11 final inspection, don't get right up on it. Etani 12 'c : : shout t:n f c- e t , you know. ' hart ain't ne prrfect 13 paint jobs."
14 You know, "You guys are getting 15 concerned abcut a lot of things that don't really ,
16 matter, pinholes an$ big contaminants. You just don't 17 have to worry about it. Just stand back a littic bit.
16 Lighten up. I'm tir:d of all this nit-picking."
19 C. Here you personally instructed with that 20 policy?
21 7. Yes.
22 ?. You have rentioned a couple of instances C O U t' T Y COURT REPORTERS, INC.
11' i
1 'hcre th t policy resulted in substandard work; is 2 that correct?
1 3 .r. . Yes.
4 C. You m.ight be thinking in the back of your 5 -ind sore other examples. When we get to the end, I j 6 will a s '. you te give ?. e locations and instanc-s whtn 7 that h a n. .c e n e d .
I C 5. . All rignt.
. 9 "n. HM:EIUS: Vince, do you have anything?
)
- 10 MP. LETTITRI: Fe are on number seven now?
I 11 P . M ' " r'I M E :
. T'-,t's correct. I i
i 12 MR. LETTIEPI: 1: c , I don't.
.i 13 OY "P. " '
- 3 : ': S :
I couple 14 '.. Uc discusse$ ever the telephonc ,
15 w ? c ). s age paint cuality, the issue of thinner.
I 11 '. . Pight.
t l 17 C. Usuld you give .a some more details on t'r r t ?
4 lE A. " ell, one of your more desirable effects of r
l 19 spoxy is the fact that it is abrasion resistant. Put
, 20 they had this brainstorm that they could thin the 21 stuff 50 percent thinner. They called it a 50/50 mix.
1 2 22 Give it a 24-hour pot life and this is l
I COUNTY CGURT REPORTTRS, I N C .,
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lli I why they did it, so they could extend the pot life.
2 But when they did that, the-stuff became brittle as j 3 glass and you couldn't even get a tooke gauge reading i 4 on it because as you ran your blade down, it just 5 shattered instead of giving you a nice smooth cut that i
j 6 you can read. You couldn't even read it because of 7 t'h c shattered paint. ,-
i 8 Q. Exactly what systems were inadequ' ate?
1
.n o A. The top coat, the phenoline 305.
l 10 Q. Did the procedures allow addition of thinner 11 up to that percentage?
t l 12 A. Yes.
I 13 C. Was it a typical, regular practice?
14 A. It was their standard mix.
15 Q. So it was the nix that was used everywhere, l
i 16 all the time?
j 17 A. Right. They had what they call a regular mix, i
18 a rodified mix and a 50/50. And in my experience, the four in always called for 50/50.
19 ,
20 Q. Beesuse?
21 1, . That way you didn't have to monitor pot' life.
f
! 22 Now, even though sometimes the paint
,I l
COUt:TY COURT REPORTERS, INC. .
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11:
4 1 wouldn't pour out of the bucket, according to the 2 specification, it was still good.
3 C. Uasn't pot life based on mixing temperatures 4 and some other variables besides how much thinner was 5 spplied or --
6 A. Except for the 50/50 mix.
7 0 That was different?
8 A. On the 50/50 mix you had a 24-hour pot life, 9 period.
10 0. Nc F.stter?
11 A. Right.
12 2. The p r o c e d u r .a s say that?
13 A. Right. >
14 0. You montioned the offects that the 3ddition 15 of up to 50 percent thinner had on the finished h
i 4
16 product after it uas cured?
) 17 A. Right.
i 10 Q. Could you ge into those a little more 3ctail 19 for us and how you becare aware of them? ,
20 A. Uell, when they would set a hangar down, the 21 stuff w'ould Just shatter and break and hairline erscks 22 run up r.11 through the thing, you know.
J I s COUNTY COURT REPORTERS, INC.
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i i
1 And even the craftsmen complained about 2 how it had no impset resistance, no abrasion 3 resistance. It was so brittle. But yet, a modified 4- or c regular mix performed really super, just standarf-l 5 epoxy.
6 C. You said it was pretty standard practice, sc
? 7 again, just like some of these other instances you
- 6 brought up, can wo go out into the field and maybe see 1
9 instances where this has happened? -
10 A. I believe your tooke gauge will reveal what's !
4 11 50/50 mix and what's not.
12 0. You are saying if we took a tooks gaug? and l
13 go out into the field --
14 A. And it shatters on you, it's a 50/50 base.
15 O. In other words, it will not cut a clean l i; n e ?
l
- 16 7. Pight. It won't pass the cross hatch knifs ,
1 *
- 17 test.
18 0 It will not?
19 A. Right.
I 20 0. Is that the ASTM test that you a r e' referring 21 to?
l 22 A. Yes.
l l
COUNTY _COUFT PFPORTERS, IMC. j
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i 1 Q. 'ss that a test that was used out at Comanche 2 Peak?
3 A. ': o . That is strictly forbidden. Only one 1
- 4 person I ever saw do it, thay told him to put his 5 knife in his pocket and leave it there forever.
- 6 0. Did he perform it with a single bladt- knife?
i 7 A. Ycs.
P C. Is that what the procedure allowed?
9 A. I don't recall.
10 0. Have you ever used the ASTM cross hatch test?
i 11 A. *: o . I have read it and been familiar w.i t h it 12 and forgot about it.
13 BY MF. !! At K I!:S :
14 . You mentioned another concern of yours was 15 paint that was rixed in the paint shop and then tayen 16 down to the racetor building cnd sot in the sun for 17 extended periods of time?
18 ?. Right.
19 C. Can you give me a little more detail en that, 20 also, what your concern is exactly?
21 A. 1c11, the mix temp was recorded as 6S degrees, 22 which is your standard shop temperature always. 3. n d 1
CCU :TY COUPT REPORTEPS, INC.
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lle 1 pot life was figured on that.
2 But actually, the coatings were about 3 120 degrees, and a lot of times, according to ths .
4 charts and all, you had good pot life, but the peint 5 wouldn't pour out of the bucket because it had been 6 sitting out in the 120 degrees sun.
7 0 Well, they couldn't use it if it wouldn't 9 pour out of the bucket; right?
9 A. Right.
10 0 Did that ever result in substandard paint 11 being apolied, or were you just concerned about the 12 waste of the paint itself?
4 13 A. Well, if you are worried about pot life, you 14 knr 7, if you are concerned about it, the pot life 15 wasn't at 68 degrees like everybody was figuring. ,
16 The pot life was at the maximum 17 temperature that that paint was stored at, and just 18 you know, they said it was 68 degrees when actually it 19 was sitting out in the sun at 120.
20 0 I am trying to understand what exactly your 21 concern is as far as applied coatings in the service 22 level one areas as it relates to this issue?
COUNTY COURT REPORTERS, INC.
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111 1 A. Well, to me, pot life -- I'm basically a 2 construction man. To me, pot life is determined by 3 workability. So I don't know if it had any ill 4 effects or not.
5 MR. HAUKINS: Vince?
6 BY MR. LETTIERI:
7 0 Were you aware of any reason why they would 8 leave the paint out?
9 A. Leave it out there?
10 Q. Yes.
11 A. Ucll, it was just standard. The foreman 12 - would call up, tell him they needed a half-gallon of 12 this and n31f-gallon of that and this much thinner.
14 And then when they got around to it, 15 they would mix it and then when they got stound to .
16 sending it, they would send it down.
17 And :11 this time, h :- has sent his .- a n 10 out there two, three times to pick it up and it isn't 19 there yet. So when it finally gets there, he is not
~
20 sending his guy any more. He has ordered another 21 batch. Then somebody else sends their man out for it.
22 Here is this first batch there, so he grabs that up.
COUNTY COURT REPORTERS, I t? C .
71o v.,...411e oa t- w o..-- tr enter (7f?) Ami 'r?'
lli 1 You don't have any traceability.
2 C. There was no traceability?
3 A. Not in my opinion.
I 4 0 Was there any tags on the batches?
5 A. No. We got our --
at one period there was, 6 after some of the new inspectors raised a lot of hel!
7 dbout it, i 8 But for the first year or so, we
! 9 received a littic mix slip through the mail the next 10 day, or later that day, and that's how we determincd 11 batch number.
i 12 2. Could you give me o timeframe? 1982, June 13 of 'S2 or June of '92?
14 A. Cell, I think it went on the whole time, you 15 know. They started putting the slips on, I don't ,
16 recall when. Before that, it was just a piece cf tape 17 that said 0 mix, the date, and gave the inspector who it witnessed the mix his initials, you know.
19 Q. But that information didn't follow the 20 pattern?
21 A. No. The batch numbers came separately. Ani 22 a!1 the mix info.
CCUNTY COURT PFPORTERS, INC.
110 l
1 C. And by procedure, you were allowed to accep:
2 this data that was not accompanying the paint?
l
, 3 A. 1: c 1 1 , not really, but they did stick it in 4 there finally.
- Sce, these new inspectors made a let of 6 c h e. n g e s . You ': n o w , they just would not quit. They 7 <. c u l d not shut up. So they forced them into making E some adjustrents and putting some things in writing.
9 Out it w:s at the sacrifice of their own popularity, 10 believe me.
11 "R. LETTIER!: I don't b ve any more on this 12 cone?rn. I would like to go into the next one, thcugh.
. ..y.
... u r.4 IEe,. ...
14 C. Is there anything on the storage of .attrials Ic that we ought to diccuss that you had a conecrn abou.t?
l' ?. . :cll, I Scr't r e. a l l y --
I can't rccc11 how 4
17 stringent the stortgo recuircrents have to be, but ye' 1E nev, nor.-C ctorag. nd O storage uns thc valkin; ,
1 19 through a door. 7. n d you knor, there was no control) ' l 1
l 2' : c.cs er r.yth ng lik. that. Peer 1 . const:ntly 21 Iriftant in nf cut of both placcs. And o c c a s i o n .' l l -,
- 2 : ;- :oulf i n t e r - i r. g l e 1 .' c l :n; catings ani 1
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4
.. "-13, they vsr: all thc s a.9 e eclers, same -
5 co pany. F. n4 h o .- are you going to know?
^ 2. ry stching tb: --
7 7. . :: c 11, that's c31 stnt to you by a thiri cu, E the yce 00uli r:rcly Fct.-
9 C. ce he could send you O numbers, but you ir 10 fact rcrei'ed non-0 matcrial?
11 A. You would never kn0U.
12 _. 'ut you don't kner that th?- cecurr ??
13 . *' . H o- cculi I?
14 2 m ut ycu are just saying i:'s a possibility?
15 .a . Pight. .
16 C. ;;src you concerned at all abcut the 17 ccrpatibility of prirer and top coat batches 18 T.cnufactured furing the different tineframes?
19 A. ?!o .
20 C. Here you ever concerned about the pot life 21 restrictions on zine primer?
22 4. Well, I think I was briefly, but they put it COUNTY COURT REPORTERS, I t: C .
9,o , c . ,, 4 1 1, ca -+ -.-- te calem selos rc7_1-9,
o 121 1 in and you know, they satisfied whatever concerns I 2 nad.
3 Q. So as far as you are concerned, there is no 4 problem right now that we should discuss?
5 A. On the pot life primer, I can't think cf it.
6 MR. LETTIERI: Okay. That's all I have.
7 BY MR. HAWKINC:
8 C. There is a few more issues that we discussed 9 during the deposition that Brown and Root took of you l
10 for the Department of Labor.
11 A. Right.
12 0. I wanted to discuss those cach with you now.
13 A. All right.
14 C. The first deals with an instance that you 15 were in training status and you and another inspector ,
16 vent up to elevation 905 to look at some concretc 17 curves?
1E A. Right.
I 19 C. Do you recall the instance?
20 A. Yes.
21 C. Yoa said that the surfaces had not been 22 prepared properly?
COUNTY COURT REPOPTERS, INC.
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121 1 A. They were untouched.
2 C. And that the coating was applied anyway?
3 4. Right. Surface prep.
4 Q. Were those areas in service level one?
5 A. Yes.
6 C. And specifically where?
7 A. Elevation 905 RCB 2, it was directly above 8 the pressurizer.
9 There is some equipment pads up-there 10 and they were just small items, but you know, it's 11 just the status quo of Comanche Peak.
12 C. So it was the equipment pad itself that would 13 curve around the p s .d ?
14 A. Kell, when I say curved, these things were 15 about knee-high or a little better. They.weren't .
16 curves; they were pedestals, I believe. They were 17 just lumps of concrete. I really didn't know what 18 they were, but they were pedestals.
19 There is a larger one there with 20 machinery sitting on it and those weren't the ones 21 that I was addressing there. These others were small, 22 -bout knee-high, maybe four feet. And there is three CCUNTY COURT REPORTERS, INC.
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12 )a 1 or four of them right there.
2 And you know, the stuff night stick, but 3 it j ust wasn't per spee.
4 0 Could you be more specific on how it wasn't 5 per spee?
6 ?. . ~cil, it vasn't sand blasted, i:ater blsstei 7 or acid ashed. It was raw.
E 0. Meaning?
f 9 ;. Meaning the forms had just been pulled off 10 and the fins and ridges, and I remember irregularities
, 11 were still there and it just wasn't touched.
12 And at that time they had a requirstent 13 of sand blest, water blast or acid ash, the service 14 prep.
15 r. Okay. -
16 Let's move or to another concern you hed, 17 and that involved the writing of requests for 16 information or requests for clarification, PFI's or 19 RFC's?
20 A. Pight.
1 4 21 0. V: hat's the story on that?
! i 27 A. ;; ell, that was the only avenue we had to ash I
COUNTY COURT PEPORTEP.9, INC.
9c -.3.... 1,- e4 .s-..,, -r cr*e, '
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12 1 questions and we, the oldtimers knew better than to 2 us3 thst svenue. But the new guys kept riding them.
3 And they were verbally counseled as to hey, you better 4 quit writing them or you are going to get your ass run 5 off.
6 Thet was for one, I 7 recall was counseled for that. Because the QE had no 8 answers.
9 C. Uhat do you mean the OE hs3 no answers?
10 A. Ckay.
11 You write an RFIT that' asks them a 12 c,uestion like --
well, let me think of a good one to 13 ask. For instance, specification requires a one mil 14 incher profile. We have no comparators availabic.
15 How are we to determine one mil anchor profile? ,
16 That little question like that would 17 stir up a lot of stuff. And no comparator had been 19 available the whole time I was there.
19 And so anyway, that's what you write on 20 RFIC's.
l 21 2. That was an example of something you would l
l 22 have asked for clarification?
I
- y w g .- - -r-
w9 -a--er
125, 1 A. No, that was one that somebody asked.
2 0. Someone did ask for that?
3 A. Yes.
4 :. Do you recall the response?
- 5 A. I don't think they'ever got rn answer. Just 6 because you wrote tnem, didn't mean you got an answcr.
7 0. You don't have to respond to those?
E A. Oh, you have to, but who is going to tell 9 management what to do?
10 0. Fo you are saying in that instance, en RFIC l 11. if it was written, no one responded to?
12 I. . There warc a lot of them written; there was i
12 no response. Or there was a verbal response, "cuit 14 writing then."
15 BY MP. LETTIEPI:
16 C. Would those be kept in a public record?
17 A. No. They don't keep stuff like that cround.
1? It's dangerous.
1 19 0. But a r :- n ' t the RFIC's kept for future j 20 reference?
21 A. Only by the individual _ inspector.
22 FR. LETTIERI: I don't have any more questions.
1 l
COUNTY COURT.BEPORTERS, INC.
94 e .em,.. .13, c- -- J-, tr cose, t 1 1' ? ) Act 1co,
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1 FY ft?. H A E K I t' S :
2 C.
You made another reference about the backfi:
3 program in recording the highest reading and the 4
lowest reading and the average.
5 A. Right.
6 C. I didn't understand what your concern wns or 7
what you are even talking about when I read the 8 transcript.
9 A. Chay.
10 Now, this isn't that widespread, becaust 11 the inspectors, every one of them, --
I was the least 12 experience 6 inspcetor they had. r11 the other 13 inspectors had at least fite years and two plants 14 under their bel eben they came there.
15 And s having no eyperience, and in all the pcwer, told us, "You only reccrd your first 17 unsat reading, because all these other things, it's 10
=11 going to be stripped off anyway. That's why you 19 are identifying it."
20 Pnd at first they were removing the 21 stuff. So while standing there looking over 22 ycur shoulder, ycu've got tc do on your docu ent . ': a t 7r ..,,... i.
C O t t' T Y COUP 7 FrPOPTERS, IPC.
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. J 2 So if you foun3 a '4 here, you foun' it l
f: rst and that's unset, well, you've got to reco d )
4 t, --
.. c your hig! r.ading. T r. s t ' s 14. An5 ther 311 5 th e s :- 16's en5 25's and al] that in the middle her: c' '
l 6 -x is uns:t _rr2, it's not recoried an your high 7 r- ading, av=n t5ough you've got 25 here, becaus, C -h .t's all going te be rcmoved.
f 9
so only when{ g was looking over i
10 p= opic's snoulders did that even, you.know, --
most of 11 the time I believe the recorders inspected the t,r u c 12 M2 gh.
13 .. net ne said it ia s inconsequenti:1 beceuse it 14 wa s going te he taken off anyway?
l 15 A. ".i g h t . l t
1 I
16 C. In effect, was that true? '
17 A. ; ell, it was at first.
18 C. Why wasn't it later?
19 .s . Because they did their trend analysis .? n i 20 de cided that vell, this primer here is on the 6.5 21 uh ich is only enc mil over and therefore, one ti.me 22 on ly, ust as is.
i
12 <
1 7. n d thsn they would revise that ene ti-'
2 enly an? you know, you could get about five or six 3
revisions of this ens t i n. c only, and they have got -
4 lot of coating on there, you know.
E
?nd so, if you recorded a high of f.c 6 because that u .i s the first unsat reading you came tc, 7 which is " hat l told you to do, and then you
?
mapped out this unsat area for them to remove, yet 9 might have s o r. c 12's and 14's in there. And that's 10 not showing up on your trend.
11 0. Tnc engineers would then buy it cff based en 12 6.5 being the highest and that's only a mil over?
13 A. Right. t 14 Like I said, that's not a widespread I 15 problem bccause, you know, while]lll was there ,
16 standing over your shoulder, you did it. Otherwise, I 17 believe most of the inspectors recorded what was truc 18 to the high.
19 0. How often was standing over your W
20 shoulder?
21 A. Befor we only had to deal 22 with ll probably twice a day. But then after that,
12C 1 he was there constantly.
2 But you know, most of the backfit was in 3 different areas and all that. You know, he would 4 stand up there and watch you while you would go up 5 there and look at it.
6 Q. Do you remember any specific ereas where that 7 sort of thing happened?
E A. No, not right now.
9 C. All right.
10 3Y MP. LETTIERI:
11 C. Let me just ask one thing. In the event that 12 you had a high reading and he was standing there, that 13 particular area was in fact removed?
14 A. I don't know. I mapped out the unsat arec 15 and they were supposed to remove it and evbry time, 16 they could, they would come along with their solvent 17 and remove your unsatisfactory map, your remarks, and 1R paint it.
19 0. Do you know of'any areas that were in fact 20 unsat that never got repaired that we could go back 21 and look at now? ,
l 22 A. Well, tharc's been a number of times that i l
l l
l COUNTY COURT REPORTERS, INC.
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i 1 they were caught doing that, and those might have been 2 I didn't file on ':CR's and then there was --
3 But when III was involved, he would 4 send you back out to retest cnd try to relocate th?
5 bad spots, and you know, save NOR's. And we did that.
6 He 5:d a lot of trouble on the po)crgrar 7 and stuff like that. Areas were moved out for thcr to 8 remove, and solvent removes a lot easier than 9 S t r i p -!; - C l c a n , you know.
10 C. In your opinion, by not getting a proper high i 11 reading, that it skewed the trend analysis'that you 12 were doing' 13 A. Yes.
14 BY MR. H AW K I t: S :
15 Q. But you did state that it was not a 16 widespread problem?
17 A. Yes. ,
18 You know, it's not a big concern to me. ;
i 19 None of that work is up there any more. Man, I heve 20 got a whole new, every day, headaches down here.
21 C. Well, it's a big concern to us. So I guess 22 in that light, I would like you to take it seriously s
_. -, -- - - - - y -. .- ~-
12 ]
1 at leas: for ancther half-hour.
2 A. All right.
3 I keep forgetting that there are pceple 4 up there still shrugging it out. To me the thing is 5 going already.
6 C. So what you said is true then. It was not e 7 widesprsaf problem?
8 A. Right.
9 C. But you feel that it's a problem that 10 warrants our looking into it?
11 A. I ion't know. It just depends on the stock 12 the individual inspector put in instruction.
13 .' h a n he said tnat I knew, ne was full of it. And most 14 people knew.
15 O. But to your knowledge, it was not a ,
16 widespread problem; one that can affect a final 17 acceptability of coatings in Comanche Peak?
18 A. No, I don't think so, because the backfit 19 inspectors for the most part, probably you would have 20 to hold them, but they would probably record it.
21 ti R . H AW K I t: S : Why don't we take another 22 five-minute break? And then we will come back and s
COUNTY COUPT REPORTERS, INC.
13:
1 finish this off.
2 ('.; n e r e u p o n , there was a short break 3 taken, after which the Statement 4
was resumed as follows:)
5 BY MR. HAWKINS:
6 Q. You mentioned in here also tha -
7 and destroyed some docum nts?
8 A. Yes.
9 C. Preciscly what documents were they?
10 A. Well, you know, I can't say without having 11 them, but in my opinion they were the accurate 12 adequate documentetion that existed for this arca.
13 You know, I kept finding these --
I was 14 on night shift and I kept finding original 15 documentation torn up in the trash. And so, you k r. c w ,
16 I confronted him with it. "Oh, well. It's inadequat+
17 anyway. What do I want to keep that around for?"
19 Q. Well, what do you think they would have 19 accomplished by destroying their own documentation?
20 A. Well, because if you have got an incomplete 21 document and you take a xerox copy of it and then you 22 can complete that xerox copy all you want and then you COUNTY COURT REPORTERS, INC.
l 13:
1 make another xerox copy of that and you can't tell.
2 So what you've got is a xerox copy which is supposedly 3 a certified true copy of the written.
4 C. Are you saying that Iand 5 falsified records of inspections?
6 A. Yes.
7 Q. Do you know that for fact?
8 A. No. I didn't see them do it, but I know that 5
9 j EEE[ wa s in charge of it and that bogus documents 10 ended up in the vault representing adequate primer 11 documentation.
12 And I uasn't the only one that saw them 13 destroy it.
14 O. This was adequate documentation that was used 15 to accept areas during the backfit program? ,
16 A. Yes. ;
17 BY MR. LETTIERI: I l
19 C. Do you know of anything that would help us go l 19 back and try to find a document such as that?
20 A. Well, there should be a map around, you know, 21 showing you what areas had adequate primer 22 documentation.
COUNTY COUPT REPORTERS, INO.
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l 1
i 1 and wrote out half across the paper, I made a ecpy of 2 that, on the copy I completed the page, made c ecpy of 3 that, I could have a completely covered piece of papct, 4 yet the original page was never completed. And if I 5 go to the document vault, is that in fact what I am 6 going to find?
7 A. This is what you will encounter. You'll find 8 a bunch of documents and all the conditions will be 9 exactly the same; with the same markout, the same '
10 error, whatever, they will all be the same. And they 11 are not necessarily all on the same day.
12 And where the original document might 12 not have had those on there and therefore would be en l -
14 unacceptable document, if they were to suddenly appear
, 15 through use of the copy T.achine, that would be an 16 adecuate document.
17 0. Osn you think of anywhere where we should
- 18 start looking for that, specifically?
19 A. ;;e l l , I would talk to and src l 20 what he is --
see, he has already bcen into this and --
i 21 BY v. R . H A'.? v I !; S :
22 .'. All right. I think we cre confusing the
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1 " ,
1 issue semo.
2 I think that the documents we are 2 r: ferring to all are related to the backfit progra ;
4 is that ccrrcet?
5 A. These warc thc adecusto iocumentation th-t f cx:sts for this arce. They are ongoing documents.
7 . C. ': o , wh:c' was the basis for cocepting ccs c se i t h 0 u t th- tecke gauge tort during the backfit c
regr:-?
IC 3 Yes.
11 .. - c : t's c,u i t - -irole. i'e till just :: r1 12 l o t '- to src what c r e a .s were accepted with a d c q u .t t .-
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13 100% at thet ::cuments.
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1 T, He saw it.
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19 '. r. I you know, uhen you would fi ' the- '
20 i r. t'e tr sh cnd poin' out that hey, this is th-21 lient's dccumentaticn, it's r. o t your decision to 22 throw it away just brotuse it's inedequate, they woul I
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1 esy, "CS, yes. You're right." 7. n i then thrt night 2 there they are in the trach again. Only this ti-=
2 they are outcide in the big can rather than right 4 there by their dask. Real concern from abcve.
5 O. Okcy.
s Another issue deal --
we are going bark 7 to I believe what you referred to as overspray. Again, P rhat was an application --
I don't know in what 9 building. It was four feet unsatisfactory areas?
10 A. Unit two, reactor two, what was the name of 11 that room? Elevation 60 is directly connected. It's i
12 directly connected to the elevator. There is a bunch 13 of instrument panels in there. It's hard to miss. I 14 can ir's 660. Tnere is two ways out of the clevator 15 on 860. One of them has a little room, and t h a t ' s . t.h e 16 rco I'm talking about.
17 They called me up for the inspection and
- IS they wanted to paint about oh, four or five feet, you j 19 know, to allow for these cable trays coming in or 20 something. And so they wanted this all signed off and 21 everything.
22 So they called me in for a top coat COUNTY COURT REPCPTERS, INC.
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1 repair and I went up there and it was just covered 2 with filth, weld spatter, tobacco juice and everything, 3 This was on the ceiling. And how they spit up on the 4 ceiling or why, I don't know. Eut magic markers, 5 everything, you know, that was not acceptable.
6 So I said well, you need to clean it up 7 a little better. Oh, it can't be done. I argued with 8 them a little bit. So finally I took a rag and I 9 cleaned a little spot and I said see there how nice 10 and clean you can get it? And okay, they cleaned it i 11 up.
12 So thcy got up there and halfheartedly 13 hit it again. See, craft is just trained to resist C 14 :t every step. You tell them well, you are going to 15 have to clean that up. No. Well, you can't oaint ,it.
If Then, we will see.
17 So anyway, they got it about suitable, 18 you know, enough to where my conscience would let ther 19 paint it. So they only wanted a couple of feet. So 20 they had more than that cleaned.
21 I said okay now, you've got to stop 22 right here et these --
what do they call those --
C OU::T Y COURT PEPCFTERS, INC.
ese r......: ,,_ -2 -w__... ,. cas e- ,,,,, ce, sce-
12 0 1 F i c h.n e n d inserts. I said you've got to stop right 2 here. And I think it was a Pichmond insert or 3 something.
4 There was a line there where they can 5 eas'ily tell where to stop. And I said you've got to 6
stop right there because the rest of it is totally 7 unacceptable. Okay.
E 9o when I went back to, you know, check 9
the condition of the cure and all, they had painted a.
10 cxtra four feet over there just to show me that I 11 didn't mean nothing, you know. And so you could,reci 12 the T.agic arker through it. Ycu could see the blobs 13 cf gresse painted over.
And it looked like I had 14 allowed this paint job to be put on over all this 15 trash.
15 So I went up and I asked ggg I said 17 they burned me again." I said, "I think we 10 .eed to write an 1:CR." "
Well, we can't contrcl thos?< "
19 So I let that one drop.
20 0. It's that way today? !
l 21 A. I'm not sure. See, I'm sure they have c o m-22 in :no completed it, you know, but it's there.
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1/ 0 1 See, they only paint it out so many feet, 2 ani by now they have painted on the rest of the way.
3 C. But that unsatisfactory ccndition still 4 exists, to your knowledge?
5 A. Yes.
6 And that was painting on the ceiling 7 f r o.T the clevator shaft out.
O Q. ^kcy.
9 Do you have c :t o u g h information where wc 10 -ight be able to find that area?
11 !' R . LETTIEPI: I believe so.
12 BY MP. LETTIERI:
1? C. If I understood you right, as you get to 14 elc-vation CEO, you go to the what I would call --
15 A. In the elevator the door opens on both sides ,
16 en elevation 860. On one side you are in an open area, 17 On the other side you are in a room. tie l l , it was in 18 that room.
19 And my document reflects that yes, I 23 coated out three or four feet, or how many feet I 21 allowed them to coat. But in actuality, they coated 22 out more, a lot more. Enough where they could get COUMTY COUPT REPORTERS, I t!C .
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1 cver their good greast spots and the magic Tarker. (
2 Q. You would anticipate if I were to look at i.t' i
3 today, I would still see the magic marker and the 4 grease spots?
5 A. In unit two, quite possibly, because they a
6 haven't been working a lot over there.
7 O. This is in unit two; right?
4 8 A. Yes. But in unit one, all that stuff is 9 probebly painted twice. (
10 BY MP. HAWKINS:
11 C. One of the last issues desis with your s i' 12 - a c c e p t .' n c e of the work on the liner plate that was 12 substandarc. !! a v e we already tslked about that 14 instance?
t 15 .t . I don't believe so. ,
16 0 Could you tell me some more, or de you know 17 cf the ir.s snee I am referring to?
19 A. No, not really.
19 0 Why don't you read from the deposition at 20 p.ge 109? Maybe that will refresh y o u r .r e. m o r y .
. b 21 Do you recall it? -
22 4. Yes, this was the area. I recall this onc
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COUNTY COUPT REPOFTERS, INC. '
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1 really well, because this was the area where I asked '
2 for a 60-watt bulb.. I asked for a drop cord and wit-3 the 60-watt bulb you could see.the' paint job wasn't 4 white. It was' splotched. .You know. You've got a big 5 gray spot over hare and a big gray spot cyer here.
', V-6 And I knew from two ?ays fearlier that i
7 that's high T. i l a g e , ' b e c a u s e two days ear' lier)r'e S
instructions were, " W e l l ,.. t a k e the tooke gauge up
- 9 therc and check it out."
10 But then once we discovered that was the i.
11 high ~:lage, 11 mils, well, then they didn'.t $ ant you
.12 checking it out any ecre.
.r 13 And they sa'id a few days 1 tkr'they put
.a 14 it in the procedurei that adequate lighting would be 15 ' the "inimur }ight ou'tput of a tw o-ce ll (f l a s h l i g h t . ,
1 6' "..
Se this is ir fact the instance '
that te 17
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talked abcut e.'rlier? <
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15 4. Yes. '
19 3Y MR. LETTIEPI: j 20 ~.
~:ould you pleche identify the are-?
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21 >
It's about at rzero, just .below* i the poler ,
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1 22 grain IcVel. It's ir that genercl area.
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i CCUr7Y COURT crPOPTERS, I :: C . '1 i
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If not, you will have to look at the 2
document itself and if there is no tooke gauge 3
readings, then it should say on the bottom, " area 'ed .
4 adequate priecr documentation."
5 But no one saw this documentation. And 6
when one person finally did get to see this 7
documentation, well it's under investigation no or ,,-
8 being forged and falsified.
9 SY MR. H M:N I N S :
40 C. By who?
11 7. . I believ 12 PY MP. LETTIEPI:
13 0
. If I went to the vault and I pulled any 14 specific area, instead of finding a document with 15 origins 1 signatures and original data, I will find s ,
16 l
completely xeroxed copy with no original data on it?
17 A. Well, --
18 Q.
The numbers are original, but they weren't 19 written on that piece of paper; it's a copy of --
20 Do you understand what I am saying?
21 A. No.
22 Q.
i t
For example, if I took this piece of paper
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l ,,r . -- COUNTY COURT REPORTERS, INC.
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14 '
- l. hct do you consider the minimu.m output 2 cf a flash]ight?
3 9Y f* P . H .i' K I ! S :
4 C. Ycu arc asking mc?
5 A. There is no minimum. The minimum is 7erc 6 light. And se you are making an inspestion at nr.'s 7 longth with a twc-ecll flashlight, and if it's a E little bright, that's not the minimum. That's maximum.
9 You better get a weaker flashlight.
IC And I realize this is facetious, but 11 this is what we lived uith.
12 C. I und.erstand.
13 Let's go on to one last question, :- n d I 14 know you cre contending that you were harassed nd 15 :ntimidated.
16 Let me ask you, were there any other
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17 instances besides those you have already told us in c
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which thct purperted harassment and intimidation (
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19 inhibited you from carrying out your job function ac c
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20 n inspector? (
7 21 A. ;; e l l , you know, ence they break you in right, 22 you know, you do what they want after that.
-,o COU"TY CCURT FEPOPOEPS, I !: C .
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14 1
For instanc+, they call for 6n insp etor 2
and if the wrong inspcetor c o .T. e out there, oh, no, ws 3 are net rcody yet. And so you re walking back to t '. :
4 office and you set another irspectcr. :here are ycu 5 going? Oh, I cr going out here to steam generator 6
four for g Eut he just told me that wasn't rcci f 7 yct. Sce, they just pick around until they get their 8 inspector.
9 0; if ycu were turning something d o w r. ,
w 10 (HEE- .
llwould just jerk you off that inspection and put 11 you on another one.
12 AnS this was his favorite tri.ek. Bill, 13 I want you to go out there and inspect this. I a .m
~
14 going to send ll5 to help you. Or I am going to send I
15 l to help you. And you might be doing 2,000 16 feet. Ey the time you got 500 feet done, well, they 17 have done the other 1,500 feet. They are back at th-12 office drinking coffee and they don't sign the 19 document. You, only you sign the document.
20 11 o w , you know, I have been on ic o t h sides 21 of that. I have been the inspector to help them, too, 22 you know, where I didn't sign the document. And C O U t? ? Y COURT REPORTERS, INC.
219 !:a p e r v i l l e Rd., "heaton, IL 60137 (212) 653-1622
14?
I belicve me, I wasn't about to hangar lll when I w ,
2 wouldn't have to sign the document. j l
3 It was just a general thing. j 4 r) . O k .. y .
5 So you don't recall any other- instances 6 b? sides those we have already discussed?
7 A. Uhcrc I bought substandard work? b d?
8 C. Yes. h 9 '.. Most all of the concrete surface orep was 10 inadequate to me.
11 Like I say, a water wipe, which I don't 12 'now
< what that was supposed to do, they just did that 1: becauss they wanted to. And to mc, that c,uses 14 p r ob l e. .s , you know, rather than anything else.
15 MR. H A', K I I;S : Vincent, do you have any quec* ions? .
16 MR. LETTIEFI: No.
17 l'. R . HANKINS: Do you have anything you would like 18 to say?
19 A. I can't really think of anything right now.
20 MR. HAWKIMS: All right. Well, we want to thank 21 you for coming.
22 A. Uc11, I appreciate ycu all coming dowr 5 :- r ; .
C O U t! T Y COURT REPORTERS, I I: C .
21e ': 3 ca r v i l l e :'.. rheaton. IL 601P7 (?f2) (53 '62:
14*:
, 3
- (iih i c h were all of the proceedings 2 had and testimony taken at the 4
s- Statement of the above-entitled 4- causo.)
5 E
7 E
9 10 11 12 12 14 15 .
i 16 17 i
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4 7 0 *J I T Y COURT REPORTEF.9, INC.
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l 147 l STATE OF ILLINOIS )
) SS.
COUNTY OF DU PAGE )
I, GLORIA APOSTOLOS, C.S.R., Notary Public duly qualified and commissioned for the State of Illinois, County of DuPage, do hereby certify that I reported in shorthand the proceedings had and testimony taken at the Sworn Statement of the above-entitled cause, and that the foregoing transcript is a true, correct and complete report of the entire testimony so taken at the time and place hereinabove set forth.
/
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" CERTIFIED SRORTHAND REPORTER Notary Public My Commission expires March 30, 1987.