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UNITED STATES DISTRICT COURTNORTHERN DISTRICT OF OHIO
WESTERN DIVISION
4 UNITED STATES OF AMERICA,
5 Plaintiff,
- Docket No. 3:06-CR-712
- Toledo, Ohio- October 1, 2007- Trial6 V.
7 DAVID GEISEN, et al.,
8 Defendant.
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VOLUME 2 OF 15TRANSCRIPT OF TRIAL
BEFORE THE HONORABLE DAVID A. KATZUNITED STATES DISTRICT JUDGE.
12 APPEARANCES:
13 For the Plaintiffs:
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Richard A. PooleU.S. Department of Justice3rd Floor1400 New York Avenue, NWWashington, DC 20005202-514-0838
Thomas T. BallantineU.S. Department of JusticeP.O. Box 23984Washington, DC 20026202-514-2956
Miller & ChevalierBy: Andrew T. Wise
Richard A. HibeySuite 900655 Fifteenth Street, NWWashington, DC 20005202-626-5801
19For the Defendant
20 Geisen:
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q7aýý?LATý?':ý- EEC-y D 5 2D-3
1 For the DefendantCook:
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5 Court Reporter:
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Gordon & ErmerBy: Denis F. Gordon
John F. ConroySuite 6401828 L Street, NWWashington, DC 20036202-833-3400
Tracy L. Spore, RMR, CRR1716 Spielbusch AvenueToledo, Ohio 43624(419) 243-3607
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9 Proceedings recorded by mechanical stenography, transcriptproduced by notereading.
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(Commenced at 1:16 p.m.)
THE COURT: Good afternoon, ladies and gentlemen.
I hope everyone had a decent lunch, even though it was quick.
Is the government ready to call its first witness.
MR. POOLE: We are, Your Honor. The first witness
is Brian Sheron.
(The witness was sworn by the clerk)
BRIAN SHERON, DIRECT EXAMINATION
BY MR. POOLE:
Q. Would you state your name, please, and spell it for the
record.
A. Brian Walter Sheron.
Q. And is "Sheron", S-h-e-r-o-n?
A. That's correct.
Q. Mr. Sheron, where do you work?
A. The U.S. Nuclear Regulatory Commission.
Q. What's your position there?
A. Currently the Director of the Office of Nuclear
Regulatory Research.
Q. What does the Office of Nuclear Regulatory Research do?
A. We support the licensing offices by performing analyses,
developing computer codes, performing experiments to confirm
regulatory decisions or to investigate safety issues.
THE COURT: Ladies and gentlemen, and this includes
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both the jury and all counsel, if at any time during this trial
you cannot hear either a witness or counsel, I would appreciate
it if you would raise your hand, and we'll correct the situation
as quickly as possible. Thank you. Pardon the interruption.
MR. POOLE: Thank you, Your Honor.
BY MR. POOLE:
Q. Mr. Sheron, in 2001 at the time of the bulletin about
nozzle cracking and subsequent activities, what was your
position at the NRC then?
A. I was the Associate Director for Project Licensing and
Technical Assessment in the Office of Nuclear Reactor
Regulation.
Q. What were your duties there?
A. I was responsible for all safety analyses and licensing
activities associated with -- at that time 103 operating nuclear
plants in the U.S.
Q. Were you one of two associate directors in licensing?
A. Yes, in the regulatory office.
Q. How long have you been with the Nuclear Regulatory
Commission?
A. Since April, 1976.
Q. Can you tell the jury what jobs you've held there?
A. I started out in the analysis branch, which did thermal
hydraulic safety analyses of reactors and analyzing potential
13: 2 1 ; 52 25 accidents. I was involved on the Bulletins and Orders Task
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Force during the Three Mile Island accident and worked on a
number of the safety issues that evolved from the Three Mile
Island accident.
I was then promoted to Section Chief in the
Reactive Systems Branch. I was then promoted to the Branch
Chief in the Reactor Systems Branch. This is all in the Office
of Nuclear. Reactor Regulation.
In 1985 I was promoted to Deputy Division Director
and Division of Safety Review and Oversight in the Office of
Nuclear Reactor Regulation.
1987 I was promoted to Division Director, I think
it was Systems Safety in the Office of Nuclear Regulatory
Research. I was in that office for seven years.
In 1994 I came back to the Office of Nuclear
Reactor Regulation as the Director of the Division of
Engineering, and in 1997 I was promoted to Associate Director
for Technical Assessment and Safety Assessment. Then in May of
2006 I was promoted to Office Director in the Office of Nuclear
Regulatory Research.
Q. Thank you. What offices in that position as Associate
Director for Licensing, what offices reported to you?
A. I had three divisions that reported to me: Division of
Licensing, Project Licensing; the Division of Safety Systems,
Assessment; and the Division of Engineering.
Q. What's your educational background?
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A. I have a bachelor of science degree from Duke University
in electrical engineering, a master of science and Ph.D. in
nuclear engineering from the Catholic University of America in
Washington, D.C.
Q. Are you familiar with the Davis-Besse Nuclear Power
Station?
A. Yes, I am.
Q. What is the Davis-Besse Nuclear Power Station?
A. It's a Babcock and Wilcox designed pressurized water
reactor. Basically, a commercial nuclear power plant.
Q. In 2001 do you know who the owner was?
A. I believe it was FirstEnergy Nuclear.
Q. Is that the entire name of the company?
A. I think that's the name we usually used.
Q. Okay. Now, did FENOC hold a license to operate the
Davis-Besse Nuclear Power Station?
A. Yes, they did.
Q. I'm going to ask you to look at Government's Exhibit 1.
Is that the license held by -- the original license which was
subsequently
A. Yes,
held by FENOC in 2001?
I believe so. Yeah, 1980.
MR. POOLE: Your Honor, we'd offer Government's
Exhibit 1.
MR. WISE: No objection.
THE COURT: It will be admitted without objection.
13:26:11 1 BY MR. POOLE:
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Q. Do you recognize the first page of the license displayed
on your screen? Is that the first page of the license?
A. Yes, it is.
Q. Now, are nuclear power plants, commercial nuclear power
plants, required to be licensed by the Nuclear Regulatory
Commission?
A. Yes, they are.
Q. And is it part of a pretty pervasive regulatory scheme?
A. Could you clarify? When you say "scheme" --
Q. Is it part of a set of regulations that governs the
operation of the plant?
A. Yes. There's a code of federal regulations that
prescribe" what is required in order to apply for and obtain a
license for a nuclear power plant in the U.S.
Q. Do the obligations of the licensee end once the license
is obtained?
A. No, the licensee is required to maintain the plant in
accordance with conditions of its license and in accordance with
all applicable rules and regulations.
Q. Okay. Are you familiar with the Bulletin 2001-01?
A. Yes, I am.
Q. What was your involvement with that?
A. I basically directed my staff to prepare it and issue
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Q. I'm handing you now Government's Exhibit 29. Do you
recognize that as Bulletin 2001-01?
A. That's correct.
MR. POOLE: Your Honor, we offer that document into
evidence.
MR. GORDON: No objection.
THE COURT: It will be admitted without objection.
BY MR. POOLE:
Q. I'm going to display the first page of that document to
the jury. Do you recognize on your screen the first page of
that bulletin?
A. Yes.
Q. With the heading and caption enlarged?
A. Yes.
Q. Tell the jury, please, what was the bulletin about?
What was its purpose?
A. Its purpose was to request all licensees that were in
the high susceptibility category, in other words, their vessel
heads were considered most susceptible to this kind of cracking
that we had seen at the Oconee nuclear plant, to submit to us
either the results of recent inspections of their vessel head to
determine whether or not they had seen any of this cracking, or
to tell us when they intended to shut down the plant and inspect
for this cracking on the vessel head nozzles.
Q. Let's back up a little bit and tell the jury, how did
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the cracking problem come to the attention of the Nuclear
Regulatory Commission?
A. We first learned about it from some overseas information
at the Bugey nuclear plant in France where they had found some
small axial cracks in the nozzle penetrations.
Q. For the benefit of the court reporter, are you able to
spell the name of the French plant?
A. B-u-g-e-y.
Q. Thank you. So you learned about small axial cracks at
Bugey, I think you said in the early '90s?
A. Yes, I was actually not in the Office of Nuclear Reactor
Regulation at the time; I was in the Office of Nuclear
Regulatory Research, but my staff, who was in the office at the
time, had followed it and was aware of it, so they informed me
of it, and I started as the Division Director in 1994.
Q. Was there subsequent evidence of a cracking problem
found at other plants?
A. Yes. I think it was right around also in the 1994-'95
time frame there were several U.S. plants that had inspected
their vessel heads and had found small axial cracks in the
penetration and J-groove weld at that time. These were brought
to our attention. We had some interactions with the licensees
on the significance of these cracks. And what we concluded was
that as long as the cracks remained small and/or ended in the
axial direction, they did not pose a safety problem; however, we
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were concerned that if these cracks grew or turned in an
axial -- I'm sorry, a circumferential direction, they could
begin to pose a safety problem. So because of that, I
instructed my staff and we issued a generic letter, I believe it
was 9701.
Q. What did generic letter 9701 do?
A. We asked the industry to provide us a plan for
monitoring these cracks that had been found in order to confirm
that they were not growing in an unacceptable manner or
orienting differently from axial.
Q. All right. Did you subsequently receive information
that gave you a greater cause for concern?,
A. The industry responded to generic letter 9701 by
proposing a program where plants that were considered the most
susceptible to this stress corrosion cracking would inspect
periodically their vessel heads. In other words, each plant
would not inspect every outage, but they would take turns
rotating among the plants monitoring for this cracking.
In early 2001, while one of these inspections was
being performed at the Oconee site, they found evidence of a
large circumferential crack, and I believe it was the Oconee 3
unit, and they also saw evidence of leakage through the J-groove
weld with subsequent small amounts of boron deposited on the
vessel head right near the penetration.
Q. What difference did this circumferential crack make to
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you?
A. A circumferential crack poses a much more significant
safety concern. The reason is that if the crack goes through
the wall or circumferentially around to a point where the
internal pressure of the reactor, which is around 2,200 pounds
pressure, is stronger than the remaining ligament that's holding
this penetration, it could physically blow the penetration out
of the vessel head.
Q. Let's back up a minute and tell the jury what an axial
and circumferential crack is.
MR. POOLE: I'd like to ask Dr. Sheron to'come down
and indicate to the jury the direction an axial crack would go
and the direction that a circumferential crack would go.
THE COURT: Of course. Your voice carries very
well, so please continue to keep it up, Mr. Sheron.
Q. Dr. Sheron, in which direction would an axial crack grow
on the nozzle?
A. It would grow basically vertically like this. This is
the J-groove weld in this area right here. Where the weld --
(motioning) this kind of penetration into the vessel head. The
cracks would grow axially in this direction. So as you can see,
even -- with the internal pressure of the reactor, you can't
really -- you can't really -- the axial cracks in this
direction, the internal pressure would try to pull the cracks
apart, but because it's contained within the vessel head, there
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would be no bursting or anything. However, if the crack turned
and went circumferentially in this horizontal direction, as you
can see it went through the wall and groove around to the point
where there is only a small ligament, the internal pressure
could actually rip that ligament and this whole assembly would
go sailing up (motions)due to the internal pressure of the
reactor.
Q. All right. So was this the concern that motivated
Bulletin 2001-01?
A. Yes.
MR. POOLE:
126, a three-dimensional
THE COURT:
For the record, we're using Exhibit
model of the nozzle.
Are you going to offer 126 at this
time?
MR. POOLE: We are, Your Honor.
THE COURT: Any objection to 126, the model?
MR. GORDON: No, Your Honor.
MR. WISE: No, Your Honor.
THE COURT: It will be admitted. Thank you,
gentlemen.
MR. POOLE: All right. I would like to show the
witness Government's Exhibit 137, a cross-sectional view of a
reactor vessel head, and offer that into evidence.
THE COURT: It will be admitted without objection,
thank you.
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Q. Using this diagram of a reactor vessel head, can we run
through the weld, where the nozzle is, and the different parts
of the surface structure?
A. You see where it says CRD nozzle, and you see where
the --
THE COURT: Mr. Sheron, see if you can make a mark
on there. I think it will work if you touch it with your hand.
A. The welds would be right in this region here where the
control rod drive penetrates the vessel head. These are
installed by -- the penetrations are installed during assembly
by actually cooling them down, very cold, so, as you know, metal
expands and contracts when it's heated and cooled. You
actually cool it down, then they will insert the penetrations in
the vessel head, and then as they warm up, they expand and
actually wedge themselves in place. And then they put a weld
down at the bottom, which seals them. And this is done because
there's a lot of calculations; as the plant heats up and comes
to pressure, there's a lot of dimensional changes. They want
to make sure all the stresses that are in the material are
within limits, so there's a reason why they do it that way.
MR. POOLE: Just so we make this clear, I'd like to
identify the same thing on the three-dimensional model. We are
using Exhibit 125, a one-eighth scale.
THE COURT: Any objection to 125?
MR. WISE: No objection.
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MR. GORDON: No objection.
THE COURT: It will be admitted without objection.
BY MR. POOLE:
Q. Is this a three-dimensional model of the bottom part of
the vessel head that we were just looking at?
A. Yes.
Q. For the jury's benefit, will you point out the weld and
the region where the cracking problem occurs?
A. The weld is right here at the bottom part of the head
where the penetration comes through, and the cracking would
occur -- remember, these are hollow tubes, and the control rods
pass through them. The cracking would occur down in this
region here towards the lower half, lower part of this.
Q. Over all of these sort of mushroom-shaped objects are
the nozzles for the control rods or other types of nozzles?
A. Yes.
MR. POOLE: Your Honor, at this time we would like
to display Government's Exhibit 136 and offer it into evidence.
It is a CRDM nozzle cross-sectional view.
MR. WISE: No objection.
MR. GORDON: No objection.
THE COURT: It will be admitted without objection.
BY MR. POOLE:
Q. All right. Dr. Sheron, is that yet another depiction of
the control rod drive mechanism nozzle?
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A. Yes, it is.
Q. And can you explain to the jury what the, I guess,
violet-colored area is?
A. You mean, like, the orange-colored, or which area is it?
Q. That area there.
A. That's the -- that would be inside the reactor vessel
that normally under operating conditions would be filled with
high pressure, high temperature water inside the reactor vessel.
Q. I think you mentioned 2,200 pounds per square inch.
A. Roughly, yes.
Q. It says 2000 here?
A. Yes.
Q. So going up the nozzle, the center area of the nozzle is
the same color. Is that all pressurized?
A. Yes, it is.
*Q. Now, the area above -- well, and is this -- what is this
area that I've indicated on there?
A. That's sort of a cross-section of the reactor vessel
head.
Q. So that's this area here?
A. The carbon steel, yes.
Q. The area above the reactor vessel head, is that
pressurized?
A. No, it's not.
Q. So is the air pressure roughly the ambient air pressure
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there?
A. Yes, basically it's open to the containment building.
Q. Okay. Can you, using this diagram, tell the jury what
you learned about how nozzle cracks initiate?
A. They initiate from stress corrosion cracking. It's a
phenomena that is still not totally understood, but there are
certain conditions which seem to aggravate it, if you want to
call it, or accelerate it. The amount of time that a component
is operating at high temperature, high pressure, also the actual
temperature that the component is exposed -- or is held at is a
parameter as well as being exposed to the coolant, water inside
the reactor vessel. A lot of times it's initiated because
there are residual stresses in the metal. A lot of times from
welding. And once you get an initiation of a crack, these
internal stresses tend to drive the crack and it will continue
to crack until usually it moves out of the field where the
stresses have dropped down to a very low value.
Q. Okay. Using this diagram, where do they initiate?
A. They were initiating down in the J-groove weld area
right here, and they would grow axially upwards, but they would
turn circumferentially in the area right here.
Q. All right. And you mentioned that at Oconee leakage
was found?
A. Yes, it was.
Q. Where does the leakage come from?
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A. The leakage would come from primarily coolant that would
go through the wall crack in the penetration, and there is a
slight anulus between the reactor vessel head and the control
rod drive penetration tube. And so once the liquid was through
the wall, it would come up the anulus to the surface right here.
Q. All right. So is the anulus the area, the gap between
the reactor vessel head and the nozzle?
A. Yes.
Q. And is that -- the nozzle is round, is it not?
A. The nozzle is round.
Q. So the anulus would be a round gap around the nozzle?
A. Yes.
Q. And this diagram shows boric acid, boric acid deposits
on the surface of the head?
A. Yes.
Q. Is that characteristic of the sort of deposits that were
found at Oconee?
A. Yeah, I think actually the green on the left is probably
a little bit exaggerated in terms of the size compared to the
vessel head, but it was very small amounts.
Q. All right. Now, at the time that the bulletin was
created, was there heightened concern compared to the concern
you had back in '97?
A. Yes, because of the fact that Oconee found the
circumferential crack, which the industry had previously told us
13:48:21 1 they didn't believe that these cracks could be -- would turn and
13:48:26 2 become circumferential. They believed they would all remain
3 short and axial. Then, obviously, there was the safety concern
4 that if there was large axial cracks and they continued to grow,
13:48:38 5 at some point the internal pressure of the reactor could
13:48:43 6 basically blow one of these penetrations off of the vessel head.
13:48:55 7 Q. What did the Bulletin 2001-01 require licensees to do?
13:49:02 8 A. The bulletin required licensees to provide us with
9 information. The information we sought was for them to tell us
10 what inspections they had previously done at their plants to
11 look for this kind of cracking, or if they have not done recent
13:49:25 12 inspections to tell us what their plans were to inspect. The
13:49:30 13 bulletin suggested that plants should shut down -- that had not
13:49:36 14 been inspected should shut down and inspect prior to December
15 31, 2001; and said that if they did not agree to shut down by
16 that time, they needed to provide an alternative schedule and a
13:49:51 17 rational safety basis for that.
13:49:55 18 Q. Just to be clear, did the bulletin itself contain a
13:50:00 19 requirement to shut down by December 31?
20 A. No, it didn't.
13:50:05 21 Q. Did the bulletin require them to respond with
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23 A. Yes.
13:50:15 24 Q. Now, when responses to the bulletin came in from
13:50:22 25 licensees like Davis-Besse, did you review them?
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A. Not personally, no.
Q. Were they reviewed?
A. Yes, they were.
Q. By who?
A. My staff.
Q. And did you receive information about the bulletin
responses?
A. Yes, my staff would periodically brief me on the
responses that they had received and their assessment of them.
Q. Do you recall the assessment of the -- of Davis-Besse's
first response to the bulletin?
A. Yes, I do.
Q. What was that?
A. My staff told me that they had not provided sufficient
information or justification to operate beyond December 31,
2001.
Q. What did you do?
A. Normally we pick up the phone and we talk to the
licensee, explain to them what the deficiency was, and give them
an opportunity, if they believe they had more information, to
submit it.
Q. Did you do that in this case?
A. I believe, yes, we did.
Q. What did you tell them?
A. That the --
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Q. If I can back you up a bit, do you recall who you talked
to?
A. I believe it was the vice-president, Guy Campbell,
probably his staff.
Q. It wasn't either of these defendants, was it?
A. They might have been on the phone, but I don't know for
sure.
Q. What did you tell Mr. Campbell?
A. That the staff had reviewed their submittal and they had
not provided adequate justification to operate to the date that
they had proposed, which was to shut down on March 31, 2002. We
said that either they needed to provide us with better
justification for why they didn't believe they had cracking, or
that we expected them to shut down by the end of December.
Q. What was their response?
A. Well, they believed they could provide us -- they could
have provided us with additional information that would support
their proposal, and so they said that they would submit
additional information.
Q. Now, a minute ago you said that the bulletin did not
require licensees to shut down. What further steps did you
take in that regard?
A. If I could explain, the bulletin is a vehicle that the
Nuclear Regulatory Commission uses to obtain information. The
basis for it is in the Code of Federal Regulations, in CFR 50
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part 54(F). And what that does is it allows the NRC to gather
information in order to determine if we need to suspend, modify,
or revoke a license. In other words, we can collect
information from licensees, but we can't require them to do
anything without further action. In this case if we needed
to -- if we wanted them to shut down, we would have to order
them to shut down. And --
Q. What steps did you take?
A. Well, around -- I believe it was mid October I was
getting concerned because the licensee had still not been able
to convince my staff that they did not have any extensive
cracking on the vessel head. They had not provided sufficient
information. I also spoke with our legal staff about what the
options were, and they explained that to issue an order is not
something you generate overnight; it takes some time to develop
it; it has to go through a legal review because when you do
issue an order, it comes with a lot of rights that the licensee
has, they can appeal it, it can be challenged, so we had to make
sure we had a strong safety case. So I was worried that if the
licensee was unable to provide us with sufficient justification,
we would be coming down to the wire in December, and we might
have to issue an order. So I instructed my staff to start
preparing basically a draft of an order that we could issue
should the licensee not be able to make their case.
This did not preclude the licensee from continuing
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to submit whatever information they had to justify their
position, but the thought was that if ultimately they were
unable to do that, we would be able to issue an order and have
it ready to go before December 31.
Q. Now, while that's going on, the order is being prepared,
are there written submissions and meetings between Davis-Besse
personnel and NRC staff?
A. Yes, there were additional submissions. I think some
videotapes were provided. I believe my staff probably had
10 several meetings with them or conference calls.
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Q.
A.
Did you attend any of those meetings?
I might have sat in a few, but I can't remember which
ones.
Q. Did you personally review the submissions?
A. No, I didn't.
Q. Who did?
A. It was the material and component engineering staff.
Q. All right. Did there come a time when you personally
were involved in a meeting with people from FirstEnergy to
discuss this situation?
A. Yes.
Q. When was that?
A. November 28, I believe.
Q. All right. What happened on November 28?
A. The licensee came in in the morning, this is after they
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had presented video tapes that my staff had observed and the
like, and we met with them; they provided whatever additional
information they had at the time. They did propose some
compensatory measures that they would take. And we finished up
the meeting, I believe it was around lunch time.
Q. Okay. Did you later that day make a decision about
whether Davis-Besse would be permitted to continue to operate
beyond December 31?
A. Yes, we had an internal meeting that afternoon and
discussed it with the staff that was involved in the review and
ultimately we concluded late in the afternoon that the -- based
on the information that was provided to us by the licensee, we
felt there was reasonable assurance they could operate through
February 16 without endangering public health and safety.
Q. Was there unanimity among the NRC staff on that subject?
A. When we first met, the question I asked my technical
staff was: What date did they believe the plant could operate
safely to? And there was not unanimity on that. My staff
had -- there were varying opinions from the plant should have
shut down last August to the plant can run well beyond March 31.
I then asked them, I said, you know, I said that the licensee
had proposed to shut down on February 16 and do the inspection.
And I asked them, I said: Do you believe that that poses an
unacceptable risk or is that date acceptable from a safety
standpoint? And all of the staff agreed that they did not
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believe there was a safety problem or safety concern with
operating up until February 16.
Q. Now, did you subsequently learn about conditions at
Davis-Besse that would have resulted in a different decision had
they been brought forth on November 28, 2001?
A. Yes, we did.
Q. What did you subsequently learn?
A. We had been told that at the previous outage the vessel
head had been cleaned of any boron. The reactor control rod
penetrations typically leak in these plants, and so licensees
had -- this licensee as well as others were supposed to have a
boric acid corrosion control program in which on every outage
they would go in and inspect, and if they found evidence of
leakage, perhaps from a control rod flange or the like, they
could -- they would repair the flange and clean up the boron.
So the vessel head, we were told, had been cleaned.
Our initial assessment was that the -- even if
there was some amount of cracking on the Davis-Besse
penetrations, it was most likely less than what was found at any
of the other or some of the other B&W plants that had operated
longer. And, therefore, we felt that at the most during this
next cycle, the most we would find would be the same kind of
boron deposits that were found at the Oconee plant, which was a
small, dry, powdery substance on the surface. Had we known
that there was large amounts of caked-on boron -- also saw the
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photograph that was taken during the 2000 outage, which showed
the reddish-colored boron running out of these inspection or
weep holes. And, obviously, since boron is white, the reddish
tint would have indicated that there was corrosion going on
because that's -- that's basically iron oxide.
We also learned when they did the augmented
inspection, the AIT, that we found out that the utility was
having the radiation filters and the containment cooler filters
clogging with increasing frequency with boron over the past, I
guess, several months or years, which we were not made aware of.
Q. In the regulatory system that the NRC has, does the NRC
have the capacity to verify the information that is provided to
it by licensees?
A. Only in certain circumstances. If a licensee, for
example, submits a thermal hydraulic calculation, we have the
ability to independently do our own calculation. But when it
comes to inspection results or information, we normally don't
have that capacity, and we normally rely on the licensee to
provide it to us.
Q. Do the regulations require that truthful information be
provided?
A. Yes. 10 CFR 50.9.
MR. POOLE: We would move to admit Government's
Exhibit 201, which is a copy of the regulation, and display it
to the jury. And I don't know if the Court shut me down.
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THE COURT: Yes, I did, in between time so they're
not constantly staring at an exhibit we've already passed.
Any objection to 201?
MR. WISE: No, Your Honor.
MR. GORDON: No objection.
THE COURT: It will be admitted without objection.
BY MR. POOLE:
Q. Can you see it on your screen there?
A. Yes.
Q. Is the enlarged portion of it, 50.1(a), the regulation
you referred to?
A. Yes.
Q. Could you read it to the jury.
A. "Information provided to the Commission by an applicant
for a license by licensee or information required by statute or
by the Commission's regulations, orders, or license conditions
to be maintained by the applicant or the licensee shall be
complete and accurate in all material respects."
Q. Was the information provided in those bulletin responses
the sort of information that 50.9 is talking about?
A. Yes, it is.
Q. How so?
A. We're -- well, first off, it's provided under oath or
affirmation from a licensee, which means they are supposed to
attest that it's true and correct to the best of their belief.
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Also, 50.54(F), because it's going to be used to determine
whether or not we need to suspend, modify, or revoke their
license, it has to be accurate in order for us to make that kind
of decision.
Q. And is it information by an applicant for a license or
information required by statute or regulation?
A. It's information required by regulation or statute.
It's any information that is -- that the NRC requires as part of
its regulatory process.
Q. What I'm getting at is the bulletin responses. Were the
bulletin responses required by the statute or regulation?
A. Yes, 50.54(F).
Q. Thank you.
MR. POOLE: That's all the questions I have, Your
Honor.
THE COURT: Cross-examination, Mr. Wise?
MR. WISE: Thank you.
BRIAN SHERON, CROSS-EXAMINATION
BY MR. WISE:
Q. Good afternoon, Doctor. Bulletin 2001-01 was issued
because of the concern about circumferential cracks, right?
A. That's right.
Q. It did not come out of your agency because of a concern
about axial cracks?
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A. No.
Q. And it didn't come out of your agency because of a
concern about head degradation?
A. No.
Q. There had been no hole in the head found at Oconee?
A. Correct.
Q. And it was your belief that the danger of a
circumferential crack was the ejection of the nozzle, correct?
A. That's correct.
Q. Not that it would develop into a cavity in the head?
A. Correct.
Q. Oconee was a fairly new experience for the NRC, correct?
A. Yes.
Q. The first time in the U.S. there had been
circumferential cracks of that nature, correct?
A. Yes.
Q. Fair to say that essentially what was seen at Oconee was
this popcorn boron?
A. That's what it's been termed as, yes.
Q. The reason it's called that is it had a distinctive
shape that looked like popcorn, right?
A. And it was dry.
Q. And dry?
A. Like a dry fluffy -- looked like popcorn.
Q. At Oconee the majority of the deposits were found on the
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downhill side of the nozzles, right?
A. I think that's where it was found. I'm not 100 percent
sure.
Q. And the majority of the circumferential cracks that were
found at Oconee were found on nozzles that were around the
outside of the reactor vessel head, correct?
A. I really don't know which nozzles had the cracks at
Oconee.
Q. Let me ask you this just as a general matter. When
we're talking about these reactor vessel heads, we're talking
about domes, correct?
A. Uh-huh. Yes. Yes.
Q. And the issue that you were dealing with involved
nozzles that protruded straight up through the dome, right?
A. That's correct.
Q. You told the jury a little bit before about the issue of
stresses?
A. Yes.
Q. Is it fair to say as a general matter that the nozzles
around the outside rim of the dome were at a higher stress than
the nozzles that were at the middle of the dome?
A. No.
Q. Isn't it true, Dr. Sheron, that because of the way that
the head was shaped, when the head expanded from being heated,
that it was the outside nozzles that were placed at the greatest
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stress?
A. Yes, if there were no residual stresses during
installation. However, when my staff did some checking on the
construction techniques -- when these nozzles are installed,
they have to be installed perfectly straight. And we were told
of some situations where once these nozzles were installed that
the constructors installed some chains to actually bend them and
pull them so they were perfectly vertical. Doing that puts --
it puts residual stresses in the material. And these residual
stresses can't be calculated. And so one of the problems is
that you don't know where the highest stress field is in all the
nozzles. You could have nozzles in the center that have higher
stresses on them than the nozzles on the downhill sides just
because there might have been some residual stresses introduced
during construction that nobody really knew about.
Q. If those nozzles had been manipulatedby the people who
were installing them?
A. Yes.
Q. But as a general matter, based on the shape of the
nozzles, the ones on the outside --
A. My understanding is if there were no unknown residual
stresses, then the higher stresses would be on the downhill side
of the head.
Q. At the point that you were issuing the bulletin, flange
leakage was not a concern in terms of degradation or corrosion
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of the head, right?
A. Correct.
Q. And by "flange leakage" what I'm talking about is the
connections above the insulation and above the reactor vessel
head, correct?
A. Correct.
Q. It was your belief that if the head was clean that
flange leakage running down a nozzle and hitting the head would
not cause corrosion; is that right?
A. Under the assumption that also there was no leakage
coming from underneath from the vessel head.
Q. Assuming that all you were seeing was leakage from
above, if it hit the hot head, the view was that that was not a
corrosion danger, correct?
A. That's correct.
Q. That's because the head was at such a high temperature
that the water would evaporate, right?
A. That's correct.
Q. And the boron would remain on the head in a dry state?
A. Yes.
Q. In fact, you had some plants, for example North Anna,
that had historically had evidence of a significant amount of
flange leakage, right?
A. Yes, we've seen pictures of that.
Q. You, yourself, in fact, at one point joked about North
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Anna and compared it to Luray Caverns, right?
A. From the pictures, yes.
Q. Luray Caverns is an underground cavern in Virginia known
for long stalactites and stalagmites -- although I probably
reversed those two -- true?
A. Yes.
Q. The idea is North Anna had a lot of flange leakage they
had seen?
A. Yes. When it leaks, as the water evaporates, the boron
remains, and it forms just like a stalactite or stalagmite
would.
Q. Let me ask you this about the date in the bulletin, the
December 31, 2001 date. That was not a scientific date that you
chose, correct?
A. That's correct.
Q. It was a date that you chose more or less because it was
five months or so away from when the bulletin was issued?
A. Yes.
Q. But it wasn't a date that your staff said, Dr. Sheron,
we think that this date, because of calculations we've made, is
an important drop-dead date, right?
A. That's correct.
Q. And one of the things that you recognized, both you and
your staff, was that it was actually unsafe to ask plants to
shut down too quickly, correct?
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A. Yes.
Q. Because if a plant was unprepared to enter a shutdown,
it could actually be less safe to force them to shut down early
than to allow them to operate for a short time, right?
A. In some instances, yes.
Q. You said when Mr. Poole was asking you questions that
you did not personally review the Serial Letters that
Davis-Besse submitted?
A. Correct.
Q. Your staff did?
A. Yes.
Q. You relied on your staff to assess the bulletins?
A. Yes, the bulletin responses.
Q. Thank you. The responses, right.
And you relied on your staff to judge the accuracy of the
responses?
A. That's correct.
Q. And the completeness of the responses?
A. That's correct.
Q. When your staff said to you, Dr. Sheron, this one looks
good, you accepted that?
A. Yes.
Q. And if they told you this one has problems, you accepted
that?
A. Well, I would usually ask for an explanation as to why
1 they believed it was unacceptable.
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Q. You said at some point your staff told you that there
was a
A.
Q.
that?
problem with Davis-Besse's initial response?
Yes.
And you made a phone call to Guy Campbell to discuss
A
Q
A
Q
on the
I believe that's who I spoke with, yes.
October 3 sound about right as the date that happened?
That's probably about the right time.
You said to Mr. Poole that Dave Geisen might have been
phone?
A. I don't know. A lot of times when I call, a utility
vice-president would set it up as a conference call and many
times the vice-president will have a number of staff in the
room, just as I will have a number of staff in my office when we
have the -- when we have the conference calls. I can't
remember who was on the other end of the phone with Mr.
Campbell.
Q. You have no reason to believe Mr. Geisen was on the
other end of the phone?
A. I don't know. Right.
Q. Did you give any notice to Davis-Besse that this call
was coming on the 28th?
A. I believe my staff had set up the conference call so
they knew -- they at least set it up and arranged the time that
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I would call Mr. Campbell.
Q. You said that at some point your staff viewed the
videotapes of the prior inspections at Davis-Besse?
A. Yes.
Q. You didn't attend that session?
A. No, it was in the evening.
Q. But members of your staff did?
A. Yes.
Q. People that were familiar with head inspection
techniques?
A. Yes.
Q. People that were familiar with the requirements of the
bulletin responses?
A. That's correct.
Q. People that had been reading Davis-Besse's responses in
the past?
A. Yes.
Q. That were presumably familiar with their submissions?
A. Yes.
Q. One of the folks on your staff told you after the
session that the meeting had been basically worthless, right?
A. That's correct.
Q. That you hadn't missed anything?
A. They said that from the videotapes that they observed it
was indeterminate what the condition of the head was.
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Q. That was because of the quality of the tapes?
A. That's what I was told. They were not very good
quality.
Q. And you didn't question that opinion?
A. No.
Q. If your staff had said to you, Dr. Sheron, we saw the
tapes and they looked good to us, you wouldn't have questioned
that opinion?
A. That's correct.
Q. No one said to you after that meeting, boy, Davis-Besse
just tried to pull one over on us, did they?
A. No.
Q. And had any of your staff indicated such a conclusion to
you, that would have caused you great concern?
A. Yes.
Q. I take it that if there were ever an indication from
your staff that they were being deceived, it would have caused
you to push up the pressure to have Davis-Besse shut down on the
31st of December, correct?
A. If we felt we were being deceived, in other words, we
were receiving false information or that the licensee was lying
to us, first I would have turned it over to our Office of
Investigations. But yes, we would probably have taken swifter
action to actually require the plant to shut down.
Q. You described a meeting on the 28th of November that you
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did attend.
A. Yes.
Q. And that was the meeting that was held on the day that
the decision to allow Davis-Besse to continue to operate was
made?
A. That's correct.
Q. Can you describe the presentation that Davis-Besse made2
A. I really don't recall the detailed contents of it. It
was, again, their justification for why they believed they coul
operate safely through February 16.
Q. Do you recall that they described the past inspection
history to.you?
A. They might have, but it's been five and half years; I
really don't remember.
Q. Do you recall that any member on your staff stood up at
the meeting and said, wait a minute, that's not accurate; we've
seen the videotapes; that's not true? Anything like that?
A. No, I don't believe so.
Q. Now, that certainly is something that you would have
remembered --
A. Yes.
Q. -- had it happened?
A. Uh-huh.
Q. After you made the decision, you and your staff on the
28th, to allow Davis-Besse to continue to operate, your staff
d
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and you were required to draft a letter setting forth the
justifications for allowing the plant to continue, right?
A. Yes. We said we would do that.
Q. And that's something that's supposed to be done right
away after the decision is made?
A. There's no requirement for it.
Q. In this case the letter was drafted over a year later?
A. Yes.
Q. And that was because your staff dropped the ball?
A. Yes.
Q. You sign off on the letter after it's written?
A. I think I did. I think, yeah, it was probably about a
year later.
Q. And your staff told you that it was going out?
A. If I signed off on it, yes.
Q. Okay. You, I take it, reviewed the letter before it
went out?
A. Yes.
Q. And the technical things that were set forth in the
letter, I take it you trusted what your staff was telling you in
that regard?
A. That's correct.
Q. For the points that were made in the letter, if they
told you it was true, you trusted them?
A. Yes.
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Q. You are aware that letter that went out stated that the
'96 inspection was a "fairly complete visual inspection of the
RPV head," right?
A. It's been -- it's probably been about five years since
I've seen the letter, so I can't tell you.
MR. WISE: Okay. The Court's indulgence.
BY MR. WISE:
Q. Dr. Sheron, I've handed you a copy of Defendant's
Exhibit 1 for identification. Do you recognize this as the
letter setting forth the reasons Davis-Besse was allowed to
continue to operate?
A. Yes.
Q. If you can turn to the page marked Number 6 with me and
look at the second to last full paragraph.
MR. POOLE: Your Honor, just a point of order
before we publish the document, it should be admitted.
THE COURT: It hasn't been proposed.
This is your material on here because you haven't
turned off the computer, but the jury is seeing a blank screen;
am I correct?
THE JUROR: Correct.
THE COURT: Very good.
BY MR. WISE:
Q. Doctor, have you had a chance to review that paragraph?
A. Okay.
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Q. In that paragraph, Doctor, your staff stated that the
staff concluded that the '96 inspection was a fairly complete
visual inspection of the RPV head, correct?
A. This is the second to last paragraph on page 6.
Q. I'm sorry; I misled you. The second to last full
paragraph on page 6.
A. I'm sorry.
Q. I apologize. That wasn't clear.
A. Okay.
Q. Your staff concluded, did they not, that the '96
inspection was a fairly complete visual inspection of the RPV
head, correct?
A. Yes.
Q. And that was based on reviewing videotapes, correct?
A. Yes.
Q. The main focus of the discussion on the 20th of November
was on the compensatory measures that FirstEnergy offered to
make, correct?
A. This is the discussion with the licensee?
Q. Yes, on the 28th of November.
A. Yes, that was one of the main parts of the meeting.
Q. Okay. One of the things that went on in the meeting was
a discussion of a probabilistic risk assessment?
A. That's correct.
Q. And your staff had reviewed the probabilistic risk
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assessment?
A. Yes.
Q. And informed you of their views on it?
A. Uh-huh.
Q. The risk assessment that your staff was analyzing that
day involved a column that expressly took no credit for any of
the inspections, correct?
A. I really don't know. I can't remember.
Q. Doctor, I'm going to hand you what I've marked as
Defendant's Exhibit Number 2 for identification. Can you take
a look at the first page of that document.
A. Okay.
Q. Doctor, do you recognize Defense Exhibit 2 for
identification as the submission of FirstEnergy to the NRC on
November 30, 2001?
A. Yes.
Q. If you will, turn with me to page 2 of 6 of attachment
1.
A. Okay.
Q. Do you see table 2 on that page?
A. Yes, I do.
Q. Table 2 on that page is the probabilistic risk
assessment numbers that were being given to you and your staff
by FirstEnergy, correct?
A. Yes.
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Q. And the table presents three different cases, right?
A. Yes.
Q. The first is a case involving partial inspections in 10,'
11, and 12 RFO?
A. Yes.
Q. The second case is if there's credit only for a partial
inspection in 10 RFO?
A. That's correct.
Q. That's the 1996 inspection, correct?
A. I think it would be 1996, yes.
Q. And the last case in this probabilistic risk assessment
is numbers if no inspections are credited, correct?
A. Yes.
Q. At the end of the day on the 28th, you and your staff
essentially decided that with the compensatory measures in
place, your conclusion was that Davis-Besse was safe to operate
until February 26, 2002, from a circumferential cracking
standpoint, correct?
A. February 16, I think.
Q. I'm sorry; did I say 28? You're right, 16th.
A. That is correct.
Q. And that there was not a significant risk of ejecting a
nozzle, correct?
A. Correct.
Q. In the end, your conclusions proved to be correct,
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right?
A. What we learned from the inspection, once they removed
the head and after they found the corrosion, was that the
cracking that was found in the penetrations was consistent with
our assessment of what we expected to find if they did the
inspection.
Q. It was consistent with what you expected to find?
A. Yes.
Q. It was consistent with what they had predicted in their
model?
A. I can't say it was consistent with what they predicted.
In other words, you can't verify very small numbers like this.
Q. Let's put it this way: The corrosion was a surprise,
correct?
A. Yes.
Q. Certainly no one expected to find the corrosion in the
head at Davis-Besse?
A. We assumed that they had cleaned their head. We were
told at least a number of times that they had cleaned the vessel
head and that there were no substantial amounts of boron that
had been left on the head.
Q. Okay. But, my question was, no one on your staff
expected when Davis-Besse shut down for inspections in 2002 to
find a cavity in the head of the reactor vessel, right?
A. That's correct.
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Q. And if Davis-Besse hadn't found corrosion in the reactor
vessel head, it's fair to say that we wouldn't be here today,
right?
A. That's correct.
Q. You testified on direct that you, if you had seen the
photograph that was taken in 2000, and knowing the information
about the clogged filters, your decision would have been
different, correct?
A. I said it most likely would have been different, yes.
Q. You, the NRC -- and by "you" I mean the NRC -- has a
resident inspector at Davis-Besse, correct?
A. That's correct.
Q. And at every plant in the country?
A. Yes.
Q. Your resident inspector, it's fair to say, are your eyes
and ears at the plant?
A. Yes.
Q. They have access to reports regarding potential safety
conditions?
A. I presume they do, yes.
Q. You know that your resident inspector at Davis-Besse was
given the photograph in 2000, correct?
A. I was told that, yes.
Q. And you know that your resident inspector was given
reports about the clogged filters, correct?
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A. I was told that also, yes.
Q. You and your staff -- strike that.
Would you agree with me that as a general matter -- well,
not as a general matter. Strike that.
You would agree with me that it's difficult to look back
with hindsight and make an accurate assessment of what you would
have done, right?
A. I don't think it's that difficult.
Q. Do you remember being interviewed by the Office of the
Inspector General on May 15, 2002?
A. I think I was. I don't recall the details.
Q. The six-month period after the hole was found, I take it
you spoke with a number of people, correct?
A. I spoke with a lot of people.
Q. Interviewed on a number of occasions?
A. Yes.
Q. Let me show you what I'm marking as Defense Exhibit 3
for identification. If you take a look at the first page and
the second, and the very top of the second page, and let me know
when you're done.
A. You wanted me to look at page 2 and 3?
Q. No, not yet. Having looked at the first two pages,
does that refresh your recollection about this interview?
A. Yes.
Q. You were interviewed by the OIG, Office of Inspector
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General, on May 15, 2002?
A. Yes.
Q. During that interview you told the Office of Inspector
General that it's hard to go back and speculate in hindsight
what you would have done had you known about those things,
didn't you?
A. I might have said that, yes.
Q. Are you not sure?
A. If it's in here, then I said that.
Q. Turn to page 34, if you would. I'd direct your
attention specifically to line 22.
MR. POOLE: Page 30-, please?
MR. WISE: Page 34, Mr. Poole.
A. I said it's hard to go back and speculate.
BY MR. WISE:
Q. You also said that you couldn't say whether it would
have ultimately influenced your decision, correct?
A. I haven't read that far, but I presume that's --
MR. WISE: That's all I have, Your Honor.
THE COURT: Any redirect?
MR. GORDON: Your Honor, if I may, there's another
defendant here.
THE COURT: I'm sorry. Mr. Gordon, pardon me.
My apology.
MR. GORDON: It's the first time I've been heard
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from, so I understand.
BRIAN SHERON, CROSS-EXAMINATION
BY MR. GORDON:
Q. Good afternoon, Dr. Sheron. You and I have not met;
I'm Dennis Gordon; I'm co-counsel for Mr. Cook.
Dr. Sheron, you don't know Mr. Cook, do you?
A. No.
Q. Never met him before?
A. I don't believe so.
Q. Never spoken to him over the phone?
A. I speak -- I've spoke with many licensees. He might
have been on a conversation, but I don't recall.
Q. You don't have any recollection of ever having any
contact with him?
A. No.
Q. Dr. Sheron, in the period in the fall of 2001 that we've
been discussing, how many people worked under your supervision
directly or indirectly at the agency?
A. I would guess about 300.
Q. About 300. So when you've been referring in your,
discussions with Mr. Poole and Mr. Wise to your staff, you're
talking about roughly 300 people, correct?
A. No, it was only a small handful that were involved
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directly with the -- with reviewing bulletin responses at
Davis-Besse.
Q. All right. How many would that have been?
A. Material and Component Engineering branch, and that
branch had about maybe 40 people in it at the time. I'm not
sure all 40 were involved directly with the bulletin and
reviewing the responses, so it was perhaps maybe about 10 or 15
at the most.
Q. So when Mr. -- when you described to Mr. Wise your
reliance on the work of your staff in bringing to you the
product of their work, it's that group of people to whom you're
referring; is that right?
A. Yes.
Q. Just as matter of information, in your discussion, your
informational discussion about the potential hazard posed by
circumferential cracks in the nozzle, you talked about the
possibility that a crack could grow to the point where -- I
think you used the term "ligament failure" because of the
direction of the nozzle through the head?
A. Yes.
Q. And it was your best judgment -- and I mean by "you",
you and your staff's best technical judgment in the fall of
2001, was it not, that that would require a crack of about 330
degrees around the nozzle?
A. About that size, yes.
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Q.
eject?
Around 90 percent around the nozzle before it would
A. Well, it would be more than 90 percent.
Q. More than 90 percent. My math on my feet is not as
good as it used to be.
Let me ask you a few more questions about the draft order
that you described both to Mr. Poole and Mr. Wise. And I think
you said that you directed your staff to begin preparation of
the order sometime in October; you may have said mid October,
thereabouts?
A. That's correct. Yes.
Q. And you did it because -- and you described the process
that was required inside the agency before you could actually
issue such an order?
A. Yes.
Q. Technical justification, the legal clearances of the
Office of General Counsel, that sort of thing?
A. Uh-huh.
Q. There came a time, did there not, Dr. Sheron,
approximately November 21, when the order was finished and in
final condition and it was sent by your boss to the Executive
Director of Operations of the agency with an indication that he
intended to issue it?
A. Yes.
Q. Shortly thereafter?
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A. Yes.
MR. GORDON: May I have a moment, please, Your
Honor?
THE COURT: Of course.
(Discussion had off the record.)
MR. GORDON: May I approach, Your Honor?
THE COURT: Yes. Counsel should always remember
that they may approach at anytime a witness unless that
privilege is abused. I don't expect that to happen with this
counsel.
BY MR. GORDON:
Q. Dr. Sheron, I've handed you a multipage document which
we've marked for identification as Defendant's Exhibit 4.
Would you take a look at that, please, and tell me whether you
can tell us what that document is?
A. This is the letter that my supervisor at the time, Sam
Collins, signed out to our Executive Director of Operations,
Bill Travers. And it is a copy of the order which he basically
said he intended to issue to FirstEnergy.
Q. And Mr. Collins' memorandum takes up the first two pages
of this multipage document; is that right?
A. First page and a half, yes.
Q. First page and a half. And attached thereto, that is
the actual order that he sent to Mr. Travers on the 21st?
A. Yes.
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Q. Let me direct your attention to the first sentence on
the second paragraph in Mr. Collins' memorandum beginning with:
FirstEnergy Nuclear Operating Company. Are you with me?
A. Yes.
Q. Can you read that sentence, please?
A. "FirstEnergy Nuclear Operating Company has not provided
sufficient information to justify deferral of its VHP nozzle
inspections beyond December 31, 2001 at Davis-Besse Nuclear
Power Station Unit Number 1, a Babcock & Wilcox designed plant."
Q. Dr. Sheron, it is the fact, is it not, that as of
November 21, the date of this memorandum, the sentence you just
read accurately stated the conclusions that your staff had
reached as a result of their review of all of the information it
received from Davis-Besse up until that point; isn't that the
case?
A. That's correct.
Q. Thank you. And as you told both Mr. Poole and Mr.
Wise, between the 21st and the 28th you and your staff received
additional information which caused ultimately the decision not
to go ahead with that order --
A. Yes.
Q. -- isn't that correct?
And the new information that you received included, did
it not, Davis-Besse's agreement to advance their shutdown from
March 31 to February 16? That was one new piece of
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information, correct?
A. Correct.
Q. Davis-Besse's agreement to reduce the operating
temperature at the head by about six or seven degrees during the
remaining period until February 16, that was another new piece
of information; is that right?
A. It was one they proposed.
Q. And Davis-Besse's agreement to provide the dedicated
operator in the control room to assure that in the event there
was a loss of coolant accident, the necessary emergency core
cooling systems would be activated?
A. That's correct.
Q. As matter of fact, that idea was yours, wasn't it?
A. Yes, I think it was.
Q. And they accepted that, your suggestion, that they would
agree to do that, correct?
A. Yes.
Q. Was there any other new information from Davis-Besse
other than those three things that you received between November
21 and November 28?
A. I don't recall any, but, you know, I would have to defer
to my staff if they had received anything in between.
Q. But you do recall the three items we've just discussed?
A. That's correct. Yes.
Q. You testified on direct, I believe in response to Mr.
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Wise -- and let me find my notes because I don't want to
misstate this -- you testified on several occasions today that
in the period of time, the fall prior to November 28, you,
meaning you personally, and your staff, had been assured the
Davis-Besse head had been left clean in 2000?
A. Yes, I was told that on a couple of occasions.
Q. Now, in the interview with the Inspector General, to
which Mr. Wise directed your attention, you testified, did you
not, that the president of the company had told you that there
was boron left on the head?
A. I think I used the term a light dusting.
Q. Was that what you told the IG that he said?
A. I would have to look back, but that's what Mr. Saunders
told us and Mr. Collins' office because he came in to assure us
that they had -- you know, that he would not operate this plant
if he did not personally feel assured that it would be safe to
operate. And he said the vessel head had been cleaned and that
there was only a, as he termed it, a light dusting of boron that
was on the head.
Q. Do you still have Defendant's Exhibit 3 in front of you?
I will again hand you what's been marked for identification as
Defendant's Exhibit 3, the transcript of your May 15 interview
with the -- with the Inspector General. Let me direct your
attention to page 19 of that transcript. Do you have page 9
(sic), Dr. Sheron?
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A. Yes, I see it.
THE COURT: You meant 19; did you not?
MR. GORDON: I'm sorry. I did. I still mean 19.
BY MR. GORDON:
Q. And you gave an answer to a question beginning at line
13?
A. Yes.
Q. And you said, Okay, let's put it this way: The
president of the company did not -- they were not trying to
argue they didn't have cracks, okay. Their argument is that we
may have cracks, but we don't think they're at any stage that
are imminently ready to fail in a circumferential manner.
And then the questioner, whose name has been blocked in
the transcript, said: Okay.
And you continued, Bob Saunders, the president, even told
us at one point, he says, hell, yeah, I know I've got some boron
on the head. Now, he didn't tell me -- he couldn't tell me
where it was coming from, whether it was coming from flanges or
whether it was coming from an axial crack. So they were not
trying to argue they didn't have cracks.
Do you see anything in there about a light dusting?
A. No.
Q.
A.
Q.
Is that what you told the IG, what's recorded there?
I presume this is an accurate transcript, yes.
One final brief area, Mr. Sheron. The transcript that
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you have in front of you, your May 15 interview, would you turn,
please, to page 49, very close to the end of the transcript.
Do you have that, sir?
A. Yes.
Q. And this occurred -- I will represent the transcript
reflects, I believe, after the IG's agents had finished asking
you questions, on page 47 they said: Is there anything else you
can think of that may be pertinent that we should know? And
you gave a fairly long discussion about the regulatory process
in which your agency is engaged and some reflections on that
process that you had had as a result of the Davis-Besse
experience.
And beginning on page 49, line 19, according to the
transcript, you said the following: It's just like Indian
Point. I mean, they couldn't even measure offsite what got
released, and then you sit there and read the newspaper and
think they had a meltdown or something. I mean, people just
have an unnatural fear, and the press tends to fan the flames.
It's totally inconsistent with -- it's funny, with our goals, if
you look at the agency performance goal, the strategic goals,
stuff like: Don't kill anybody; don't contaminate land; don't
lose nuclear material, you know. And what the public is looking
for is: Don't scare me; don't have anything go wrong; and when
it does go wrong, go shoot somebody.
That's what's going on here, isn't it, Dr. Sheron? The
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people chosen to be shot are Mr. Cook and Mr. Geisen; isn't that
right?
A. I'm not qualified to answer that question.
MR. GORDON: Okay. I have nothing further, Your
Honor.
THE COURT: Thank you. Redirect?
MR. POOLE: Yes, Your Honor.
BRIAN SHERON, REDIRECT EXAMINATION.
BY MR. POOLE:
Q. Dr. Sheron, do you remember testifying about the first
call you made to Davis-Besse after your staff got back to you
about the first submission?
A. Uh-huh.
Q. I believe in your direct you did not provide a date of
that call. I'd like to hand you now Exhibit Number 68. I'm
not going to ask you to read it or publish it to the jury, but
take a look at it and see if it refreshes your recollection on
when you talked to -- first talked to Guy Campbell. It's two
pages; you can look at both if you need to.
MR. WISE: Your Honor, I think I can cut this
short. We'll stipulate the call was on September 28. If I
misspoke with a date and said October 3, which I think I might
have --
MR. POOLE: We accept that stipulation. Just
1 trying to clarify the record.
2 THE COURT: It's been stipulated between counsel
3 for Mr. Geisen and counsel for the government that the date
14:51:06 4 is
14:51:08 5 MR. WISE: September 28, Your Honor.
6 THE COURT: -- September 28, 2001.
14:51:16 7 MR. POOLE: Thank you. Mr. Sheron, I withdraw that
14:51:19 8 question.
14:51:22 9 BY MR. POOLE:
14:51:22 10 Q. Do you recall being asked about the December 3, 2002
14:51:29 11 letter, Defendant's Exhibit 1? I'll show it to you now.
14:51:46 12 A. Yes.
14:51:49 13 Q. All right. If you would, turn to the last paragraph of
14 the second page. Take a moment to read it and then I'm going to
15 ask you some questions.
14:52:13 16 MR. WISE: Judge, can I ask Mr. Poole to clarify
14:52:16 17 whether he's talking about the second page of the entire packet
18 or the second page of the letter?
19 MR. POOLE: Second page of the letter.
20 A. Okay.
14:52:25 21 BY MR. POOLE:
14:52:25 22 Q. All right. Do you recall being asked about a
14:52:31 23 representation in the attachment to that letter on
14:52:37 24 cross-examination? Do you remember being asked --
25 A. Yes.
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Q. -- whether the letter said that the '96 inspection was
generally a good inspection?
A. Yes.
Q. And that was -- that letter was written after the
corrosion hole was discovered at Davis-Besse?
A. Yes.
Q. Is that correct?
A. That's correct.
Q. And there were investigations going on?
A. Yes.
Q. Did that letter take account of newly discovered
evidence as of December, 2002?
A. It acknowledged that there was ongoing -- there were
other activities ongoing, okay. It says the sole purpose is to
capture the process used by the NRC staff in the fall of 2001
for review of defendant's response to NRC Bulletin 2001-01 for
Davis-Besse.
Q. Does it reflect the state of facts as the NRC knew them
in the fall of 2001?
A. That's correct.
Q. Thank you. In fact, by that time had you learned
additional information about the 1996 inspection?
MR. WISE: Objection. Relevance.
THE COURT: I cannot hear you.
MR. WISE: Objection to relevance.
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THE COURT: Overruled.
A. I don't actually recall that there was any new evidence
from the 1996 inspection, but what we did learn subsequent to
that was that there were substantial amounts of boron that had
been left on the vessel head at least from the previous
inspection. Whether that had actually originated from an
earlier inspection and had not been cleaned subsequent, that's a
possibility.
14:54:37 9 BY MR. POOLE:
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Q. Okay. You don't claim to be an expert on every aspect
of the things that happened at Davis-Besse, do you?
A. No, I'm certainly not an expert on everything.
Q. You were asked some questions about Defendant's Exhibit
Number 2, a submission, Serial Number 2747. Do have you
Defendant's Exhibit Number 2 in front of you?
A. The Inspector General interview?
Q. No, a FirstEnergy document.
A. No, I don't have Number 2.
MR. POOLE: I'll hand you my copy.
BY MR.
Q.
A.
POOLE:
Do you have Defendant's Exhibit Number 2?
Yes.
Q. Do you recall answering a question about a table showing
the impact of compensatory actions on the probability of core
damage?
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A. Yes.
Q. Do you recall that there were three categories?
A. Yes.
Q. Partial inspection, 10, 11, and 12, refueling outage.
Partial inspection 10, refueling outage. And no inspection?
A. Correct.
Q. Which of those three categories shows the.highest risk
of core damage probability?
A. That would be the no inspection category. That would be
the case of where it says CDF with no actions.
Q. Can you explain that, "CDF"?
A. Core damage frequency.
Q. That's without the compensatory actions?
A. Yes.
Q. So with no inspections, the risk increases?
A. Yes. Well, the licensee's assessment. Let me qualify,
this is just what the licensee provided to us. This is not
necessarily meaning NRC.
Q. This is a document provided to the NRC by FirstEnergy?
A. Yes. This was FirstEnergy's assessment of the risk.
Q. Okay. You were asked some questions about the presence
of a resident inspector at Davis-Besse.
A. Yes.
Q. Do you know if there was a resident inspector at
Davis-Besse at that time?
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A. I believe there was, but we don't -- I don't check on
every plant every day.
Q. What do resident inspectors do?
A. They perform a baseline inspection. They have a series
of inspections that they're required to do as part of their job.
And then they also, you know, if they say anything that might be
abnormal or whatever, they'll report it to their regional office
or the like.
Q. Are they expected to look at every document and every
condition report of the licensee?
A. No. They wouldn't have enough time in the day to do
that.
Q. Can you give the jury an idea of the volume of condition
reports that a typical resident inspector receives a year?
A. I was told for Davis-Besse there may be about 3,000
condition reports in a year, and they may be only able to look
at a very small percentage of those on a spot-check or an audit
basis.
Q. All right. Do you still have that transcript in front
of you from the Office of Inspector General?
A. Yes, I do.
Q. Do you remember when Mr. Wise asked you to read the
language in which you said it's hard to go back and speculate in
hindsight about what you would have done?
A. Yes.
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Q. I'm going to ask you a follow-up question on that in a
minute. But before I do, I'd like you to turn to the next
page, page 35, and read to yourself the last paragraph on 35.
A. Okay.
Q. All right. Now let's go back to 34 and talk about the
section that Mr. Wise asked you 'about. When you said it's hard
to go back and speculate in hindsight what you would have done,
what were you talking about?
A. Well, it's very difficult to speculate and say I
absolutely would have done something, you know, to say if I had
this other information in front of me, what actions would I have
taken at that time.
Q. Had the agent asked you a question about the presence of
boric acid on the head on page 34?
A. Yes, I think, yes, they did ask about that.
Q. And the -- your answer was it's hard to speculate in
hindsight what you would have done?
A. Well, because it depended upon what -- you know, what
kind of boric acid and the like, what the condition was. We
would have to have examined all the facts before we could
actually draw a conclusion.
Q. Would your answer be different if the agent had asked
you about the presence of rust and corrosion products in the
boric acid in the head?
A. I think the answer would have been, yes, we probably
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would have taken a lot swifter action because that would have
been very indicative that there was corrosion going on.
As I said earlier in my testimony, boron is white.
We've seen a number of plants that have had boron on the head
which is white. But the one photograph that showed the
red-colored boron running out of the weep holes, it was much
more indicative that there was some substantial corrosion going
on somewhere up in the head area.
Q. And that's what you told the agent one page after that
section that Mr. Wise asked you about?
A. That's correct.
MR. WISE: Objection, Your Honor. Under the rule
of completeness, if Mr. Poole wants to ask the questions, I
would suggest that he read the entire section that he just had
the witness read.
MR. POOLE: We're happy to have him read that
paragraph. The document is not in evidence.
THE COURT: Do you want him to read the paragraph?
MR. WISE: If this is the line of questioning, I
would like him to read from page 34, line 22, all the way
through page 36, line --
THE COURT: No.
MR. WISE: This is the area that Mr. Poole is
covering.
THE COURT: The jury will have it in front of them.
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Please proceed.
BY MR. POOLE:
Q. All right. You've mentioned several times a photograph
that you later saw that would have changed your view about the
conditions of the head at Davis-Besse had you seen it back in
the fall of 2001.
A. Correct.
MR. POOLE: At this time, Your Honor, I'd like to
offer and show the witness and publish Government's Exhibit 12.
MR. WISE: Object on foundation grounds.
THE COURT: Can I see the exhibit? I don't have
copies, unfortunately.
MR. POOLE: Your Honor, we have exhibit books. We
just haven't handed them up yet. I'm sorry.
THE COURT: This was the exhibit upon which the
previous examination was conducted?
MR. POOLE: Yes. The photograph that Mr. Sheron
is discussing, the one that would have caused him to act
differently about the decision of Davis-Besse, is attached to
this document, and that's the photograph I wanted to show him.
THE COURT: Refresh my recollection. Has he
identified the document?
MR. POOLE: No.
THE COURT: Why don't we do that, then we'll
consider it.
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BY MR. POOLE:
Q. Mr. Sheron, take a minute and look through that
document, please.
A. Okay.
Q. Do you recognize any part of that document?
A. Well, this is the condition report.
MR. WISE: Objection, Your Honor.
BY MR.
Q.
Do you
A.
Q.
POOLE:
Before you describe it, would you answer my question?
recognize any part of it?
I recognize the photograph.
All right.
MR. POOLE: Your Honor, we would move the entire
document. It's, I believe, pursuant to agreement by defense
counsel, authentic.
THE COURT: Part of the records of FENOC?
MR. POOLE: An authentic FENOC record. The
relevance is this witness has seen the photographs attached to
it.
MR. WISE: Your Honor, I don't object to the
photograph, but I do object to the entire document. I don't
believe this witness has ever seen this document before, and
they have to lay a foundation.
MR. GORDON: I join that objection.
THE COURT: The objection will be overruled. My
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understanding is that authentication is not an issue. He's
identified the document, and in particular the -- no, he hasn't
identified the document. We will not admit the document at this
juncture. He may refer to and you may use the photograph.
BY MR. POOLE:
Q. All right. Mr. Sheron, do you recognize the
photographs attached to that document?
A. Yes, I do.
Q. Mr. Sheron, I'm showing you one of the photographs
attached to that document. Do you recognize that photograph?
A. Yes.
Q. Is that one of the photographs that you alluded to, that
had you seen that in the fall of 2001 it would have changed your
decision?
A. Actually, I think it was the next photographs that
showed more of the reddish coming out. It's the ones on the
next page.
Q. Give me the last four digits of the number at the bottom
right-hand corner.
A. 8952.
Q. I'll display that now.
THE COURT: Is that 8952?
THE WITNESS: Yes, that's it.
MR. POOLE: Yes.
THE COURT: Very good.
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BY MR. POOLE:
Q. Would you tell the jury, Dr. Sheron, what that
photograph is and what it is about that that would have changed
your decision?
A. That's a photograph of the vessel head between the
tensioning studs and service structure. The slope portion of
it is the actual vessel head, and then the tensioning studs are
on the left, and the service structure is in the upper
right-hand corner.
The part where you see this reddish-colored rust coming
out is -- those are called weep holes, and they are in there to
allow inspection cameras to go up and examine the vessel head
area. What you see there is boron that has run down the side
of the head, and because of the reddish color apparently
contains a fair amount of iron oxide, which would imply there's
some corrosion going on up inside the service structure.
MR. POOLE: Thank you. That's all the questions
we have.
THE COURT: Thank you.
MR. GORDON: A couple more briefly, Your Honor, if
I may.
BRIAN SHERON, RECROSS-EXAMINATION
BY MR. GORDON:
Q. Dr. Sheron, you've just been talking about the
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photograph that you've identified and you said that you had seen
that before. You have no reason to think that Mr. Cook saw
that photograph at any time in 2001, do you?
A. No, I don't know.
Q. But you do have reason to believe that your own resident
inspector saw it the day that it was made, don't you?
A. I was told that the resident inspector had seen it. I
don't know if it was the day it was made or when he saw it.
Q. And you're also aware, aren't you, that the resident
inspector -- that resident inspector testified that he didn't
know that the red was indicative of iron corrosion? Are you
aware of that?
A. No, I'm not.
MR. POOLE: Objection.
THE COURT: Sustained. Hearsay. The jury will
disregard both the last question and the last answer.
Ladies and gentlemen, we'll now take our afternoon
recess for 15 minutes. Please remember my previous admonitions
which I promised would be given to you ad nauseam. Do not
discuss this case among yourselves or with anyone else or permit
anyone else to discuss it with you. Do not read, listen to, or
watch anything which might touch on this case in any way, and do
not make up your minds on the ultimate issues you will decide at
the end of the case.
We'll be at rest for 15 minutes.
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(Recess taken.)
THE COURT: The government may call its next
witness.
MR. STICKAN: The government would call Terry
Tabbert.
(The witness was sworn by the clerk.)
TERRY TABBERT, DIRECT EXAMINATION
BY MR. STICKAN:
Q. Would you please state your full name and spell your
last name for the record.
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A. Terry Arthur Tabbert, T-a-b-b-e-r-t.
Q.
A.
Q.
A.
Q.
A.
Q.
A.
Q.
A.
Q.
Group;
Mr. Tabbert, where do you reside?
Graytown.
How long have you been there?
My whole life.
How are you employed?
I work for FirstEnergy.
And what do you do at FirstEnergy?
I work for the Radiation Protection Group.
Okay. Is there any particular plant that you work at?
Davis-Besse.
And, I'm sorry, you work for the Radiation Protection
is that right?
A .. That's correct. It is a decon group, subgroup out of
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Radiation Protection.
Q. That's where you work?
A. Yes.
Q. Decon?
A. Yes.
Q. Can you tell us what you do?
A. We take care of all the radioactive waste, ship it,
clean it up, stuff like that at the plant.
Q. How long have you been working at Davis-Besse?
A. About 20 years now.
Q. How long have you been working in decon?
A. The entire time.
Q. Do your duties involve any head cleaning during outages?
MR. HIBEY: Excuse me.
(Discussion had off the record.)
BY MR. STICKAN:
Q. Do your duties include head cleaning during the outages?
A. Yes, they do.
Q. Can you tell us how many outages you have been involved
in cleaning the reactor head?
A. Probably five or six times.
Q. Okay. Were you involved in cleaning the reactor head in
2000 for the 12 refueling outage or 12 RFO?
A. Yes, I was.
Q. Can you tell us, were you part of a team?
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A. Yes.
Q. Do you remember who was on your team?
A. My -- names? My supervisor, Carl Tipton at the time; a
couple contract workers we had working we hired in from Bartlett
to help us clean for the outage.
Q. Okay. And did you work under anybody's supervision
besides Mr. Tipton?
A. Yes, engineering was involved in that outage with the
inspection and cleaning activities.
Q. Who was that?
A. Andrew Siemaszko.
Q. And before -- can you tell me, did you have a chance to
see the head, I guess the outside of the head area, before you
actually had a chance to clean the head?
A. No.
Q. Okay. Was there any cleaning done prior to your group
coming in to clean the head?
A. My shift, you mean?
Q. Yes.
A. Yes.
Q. What happened prior to your -- your decon group coming
in to clean the head?
A. They used a pressure washer to clean off the external
part of the reactor head, the stud nuts, and stud area.
Q. Do you know why they had to do that?
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A.
Q.
us how
head?
To remove the debris that was there.
Can you describe what you did in 12 RFO? Can you tell
you and your team approached your job in cleaning the
A. Prior to 12 RFO?
Q. No, on 12 RFO, how did you approach that?
A. Normally we use a vacuum cleaner, you know, suck up the
debris that would be inside the reactor head, or if there is any
on the outside. Normally it was just normal dust, and there
was a little boron debris is about it.
THE COURT: Mr. Tabbert, can you move your chair a
little closer?
THE WITNESS: Sure can. How's that?
BY MR. STICKAN:
Q. When you say "normally", is that based upon your
experience in the prior refueling outages where you cleaned the
head?
A. That's correct.
Q. You describe what it was prior to 12 RFO to clean the
head. Can you describe the boron and how you approached
cleaning it prior to 12 RFO?
A. Pretty much we'd have the head on a head stand up there,
and we'd be on scaffolding, and we'd go through the weep hole
and vacuum any dust or debris that was on top of the reactor
head, which was very minimal at that time.
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Q. What did you use to -- what kind of tools did you use to
clean the reactor head prior to 12 RFO?
A. Usually just a vacuum cleaner, dry vacuum cleaner that
we would stick it up with -- like, hook it onto a solid object,
like a handle of some sort, and stick it up through the weep
hole and vacuum along the reactor head, around the nozzle areas.
Q. Was the cleaning of the head in 12 RFO any different
than it was in the past?
A. Yes.
Q. Can you describe what the difference was?
A. Yes. We couldn't use just a vacuum cleaner to clean the
debris off the head.
Q. Can you describe what the boron was like that you had to
clean off the head?
A. The boron was very hard; it was crystallized. It was
like a rock. It was very hard to break up. A lot of the
debris would not fit through the weep hole; we had to use spud
bars, crowbars to break up the debris, try to get it out. And
we also had to use water to try to dissolve some of it to break
it loose, and also use a vacuum, then suck up the water and the
debris. And the bigger chunks we just put in trash bags and
stuff like that.
Q. Had you seen boron like that before?
A. No.
Q. Can you tell us what color the boron was?
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A. Yes. It was a gray color internally, some reddish rust
spots around the outside, but pretty much internally it was a
gray color.
Q. When you say "spud bars", can you describe what a "spud
bar" is?
A. It's a steel bar about six foot long that has a little
edge on it that you can use to chip concrete or hard material to
break it up.
Q. Okay. How was it used on cleaning the head?
A. We broke the debris loose down to the weep holes, then
we used a spud bar to chip away at the pieces. to make them
smaller to be able to remove them.
Q. Can you tell us, when you first started cleaning -- when
you first -- on the first attempt, I guess, when you first
started to clean the head, what kind of tools were you using
then?
A. We just went in with -- we have -- we had, like, a
little scraper we had to use and vacuum cleaner, and we weren't
there very long.
Q. I'm sorry?
A. We weren't there very long.
Q. Okay. Why not?
A. We were unsuccessful. We couldn't get the debris broke
loose and down to where we needed to get it broke up.
Q. Did you go back with other tools then later on?
15:41:51 1 A. Yes, that's when we got maybe a little bigger scraper
2 and the spud 'bar, tried to reach up as far as we could to try to
3 break some of the debris loose, but we couldn't reach a lot of
4 the debris, so we had to go back and rethink what we were going
5 to try to do.
6 Q. Okay. Then at some point you said you used water; is
7 that correct?
8 A. That's correct.
9 Q. Any particular temperature of water?
10 A. Well, we had, like, a steam cleaner that we used; we set
15:42:23 11 it around 140 degrees, the water.
15:42:26 12 Q. Okay. All right. Prior to your testifying today, you
13 viewed a video; did you not?
14 A. That's correct.
15 Q. And this was a video of the head cleaning in 12 RFO from
16 outside the weep holes; is that correct?
17 A. That's correct.
15:42:58 18 MR. STICKAN: Your Honor, if I might, I'd like to
19 approach Mr. Tabbert and have him identify this exhibit.
20 THE COURT: Please do so.
15:43:05 21 BY MR. STICKAN:
15:43:05 22 Q. Showing you what's marked as Government's Exhibit 17A,
23 can you identify that as the video that you viewed?
24 A. Yes.
25 Q. And how can you identify it?
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A. My initials and the date are on it.
Q. Did this video fairly and accurately depict the
conditions of the head while you and your team worked on it
during 12 RFO?
A. Yes.
MR. STICKAN: Counsel?
BY MR. STICKAN:
Q. I'm going to ask you to look at your monitor, if I'm
successful in starting this up.
MR. HIBEY: Excuse me. I'm advised -- before you
start playing it, I'd like to have an opportunity to confer with
the government about that particular tape.
THE COURT: It has not been admitted, and it is not
being, to the best of my knowledge, shown to the jury. Please
do so.
MR. STICKAN: Your Honor, we would offer
Government's Exhibit 17A for admission at this time.
THE COURT: Any objection?
MR. HIBEY: I have an understanding of what it is.
I have no objection.
THE COURT: Very good. It will be admitted.
MR. STICKAN: Thank you, Your Honor.
THE COURT: It may be displayed to the jury then.
(Video is shown.)
BY MR. STICKAN:
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Q. Mr. Tabbert, can you describe what's going on in that
video?
A. They're doing a video inspection.
Q. Can you describe what that individual is looking at?
A. Yes. He's trying -- he's looking at the nozzles.
Q. Is that a monitor that he's looking at?
A. Yes, camera monitor.
Q. Is that being inserted in a particular area of the
reactor head?
A. Yes, it's going through the weep hole. They're going
through the weep hole.
Q. Can you describe what this is?
A. That's the cleaning crew.
Q. You're part of this crew?
A. Yes.
Q. Incidentally, the inspection part that you just saw, was
that prior to the cleaning?
A. Yes, I believe so.
Q. And what -- do you know how successful that inspection
was?
A.
Q.
A.
Q.
A.
Not very.
Do you know why?
The debris was in the way of a lot of the inspection.
Can you tell us what's going on there?
Yeah. The one individual has that pressure washer,
1 that wand that's with the water. The other individual there
2 has a vacuum they're using on the flange area there sucking up
3 the water and some debris. He's going up through aweep hole
15:47:46 4 right now with that vacuum hose.
15:47:56 5 Q. What's going on there?
6 A. They're trying to remove a piece of boron right now,
15:48:03 7 some of the debris is down there. They're scraping it out with
15:48:07 8 their hand. They're getting it in a position so we could break
9 it up with a spud bar. Right there is where they're breaking up
10 some of the debris with a spud bar. Pieces fall down; the
11 water comes down. That's why the vacuum was there, to help suck
12 up the water and small debris.
15:48:32 13 Q. I just wanted to pause it there for a second just so I'm
15:48:36 14 clear on this. I'm going to show you what's marked as
15:48:40 15 Government's Exhibit 126. And with this model can you show us
16 where you were operating the spud bars? When we talk about weep
17 holes, can you point to where the weep holes are?
18 A. Weep holes are right here, this area here. We're
15:49:03 19 working off of this flange area here.
15:49:06 20 Q. And then the -- I guess this would be similar to maybe
21 one of the spud bars you used, or maybe similar to the --
15:49:18 22 A. We'd use that to break up here. Sometimes we'd try to
15:49:22 23 get up as far as we could into the weep hole and break the
24 material up. A lot of times we had to use the water, and that
25 wand broke up some of the debris, then we'd bring it down here
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where we could work at it a little bitter.
Q. These are --
A. These are the stud holes.
Q. Then you had a dam built up?
A. We had a dam built inside the stud holes and -- so we
could contain the water, keep it from falling underneath down
through the stud holes. We kept that backed up there, the water
and debris.
Q. I'm going to start it up again.
Can you describe what's going on-there?
A. Still breaking up the debris.
Q. It looks like -- is there water flowing into that area?
A. Yeah, we had -- the one individual has a wand; he's
holding a pressure washer, and he would spray on that piece of
debris and try to break it up. Normally hot water dissolves
boron fairly easily. This wasn't normal.
Q. Do you know who this individual is?
A. Not for sure, no.
Q. Do you know what he's holding?
A. It looks like the video camera.
Q. Was there an inspection going on as you were cleaning?
A. Yes.
Q. While the cleaning process was going on, was the camera
being inserted up weep holes?
A. Yes. They would be -- we'd decon in an area, clean in
1
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an area, then inspect it. If it was good, we'd move on to the
next section. If it wasn't good, we'd try to hit the spots that
3 needed to be hit again in that section.
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Q. What's going on there?
A. They're digging out a couple pieces of boron there,
debris, they're trying to.
Q. That's a spud bar being used?
A. They're using a spud bar to try to break it up to get it
out that weep hole.
Q. Were you collecting the boron in anything in particular?
A. Vacuums. The smaller pieces we'd vacuum up. The
larger pieces we'd put in a regular trash bag.
Q. I think you've already indicated what was going on
there. Those are the vacuums you're referring to?
A. Correct. The individual in the bottom there, he had a
vacuum hose. The person in the middle there has the bag for the
larger pieces of debris. The next individual's got the spud
bar. The other individual has the pressure washer.
Q. Thank you. Were you present while the head was being
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cleaned as you were cleaning, while this cleaning process -- I'm
sorry.
Were you present while the head was being inspected while
this cleaning process was going on?
A. Yes, I was.
Q. Did you have occasion to see, I guess, inside the weep
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holes while your cleaning was going on --
A. Yes.
Q. -- while the inspecting -- or while the filming, I
guess, was going on?
A. Yeah, we had an opportunity to look at the monitor and
see some of --
Q. You could see what was going on inside the head?
A. Yeah.
Q. Did that help guide where you were supposed to be
cleaning?
A. Yes, it did.
Q. Okay. All right. And did you have occasion to view a
clip of some film that depicted some of the head cleaning and
filming during 12 RFO?
A. Yes.
Q. And the clip that you viewed, was that a fair and
accurate depiction of the head cleaning inside the weep holes?
THE COURT: Excuse me. Let me interrupt you.
You mentioned Exhibit 19. Is this the same one we've been
watching?
exhibit.
of 19.
be 19A.
MR. STICKAN: No, Your Honor. It's a separate
This would be, I guess, 19A, which would be a subset
It's part of the CD that's marked as 1.9. This would
THE COURT: You'd better move it.
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MR. HIBEY: The prior one was identified as 17.
THE COURT: I understand that.
MR. STICKAN: 17A was a VHS. This would be a film
clip.
THE COURT: Before we can show it, did you intend
it to be seen by the jury?
MR. STICKAN: Excuse me?
THE COURT: Did you intend it to be seen by the
jury at this time?
MR. STICKAN: Yes.
THE COURT: Then we'll have to move for its --
MR. STICKAN: Your Honor, I would move for its
admission.
MR. HIBEY: I was waiting for it to be identified.
MR. STICKAN: Let me --
BY MR. STICKAN:
Q. Mr. Tabbert, did you have occasion to view a film clip
prior to your testifying today?
A. Yes.
Q. Did it depict the head cleaning process and some of the
filming that occurred during the 12 RFO inside some of the weep
holes?
A. Yes, it did.
Q. Were you able to see, was that a fair and accurate
depiction of what it was like to -- in cleaning the head and
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doing that filming process during 12 RFO?
A. Yes.
THE COURT: Any objection to 19A?
MR. HIBEY: No objection.
MR. GORDON: No objection, Your Honor.
THE COURT: You may want to start it over.
MR. STICKAN: Your Honor, could you publish it to
the jury, please?
THE COURT: It is published.
BY MR. STICKAN:
Q. Can you describe what we're looking at right here, Mr.
Tabbert?
A. You're looking at the head where the nozzle is coming
through, and that's the insulation package above the head.
Q. Can you tell us what's on the head?
A. A lot of boron debris.
Q. And this is being filmed by a camera; is that correct?
A. Correct.
Q. Which is similar to the camera that we saw on the last
tape?
A.
Q.
A.
Q.
A.
Yes.
Except that was outside the weep holes, correct?
Yes.
Can you --
That's the boron debris there. You can see the chunks;
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it's a dome area, about eight foot up to the top of the dome,
and a lot of that boron was piled up high up in there, wedged up
in between those nozzles; that's what we were trying to get out.
That's just another pile of the boron there, the debris
that was inside. That's the insulation package right there on
the top.
Q. What do you mean by insulation package?
A. An insulation that shields against the CRDMs there, an
insulation package. That's between there and the flange area.
Q. Okay. You mentioned the insulation package. Can you
show us on the model where the insulation is located on the
reactor head?
A. This area right here, the piece right there.
Q. Can you tell us what we're looking at here?
A. Pretty much around the top of the head, the debris, that
insulation package and that area between the head and that
package. Those are nozzles that are sticking up through there.
And that's some of that debris; the boron, crystallized boron
that we were trying to get out, remove from that area so they
could do their video inspection around those nozzles that come
through the head area.
Q. I take it that's more boron?
A. Yep, same material.
Q. Can you describe what we're looking at there?
A. Boron debris packed up in there towards the top.
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Q. Packed in underneath the insulation?
A. Yep, underneath the insulation and the head, pretty much
wedged in between there and the nozzles.
Q. Who's that good-looking guy?
A. That's me.
Q. So we knew you were there, right?
A. That's correct.
Q. All right. Let's pick up on this tape from your guest
appearance. Okay.. How was it that your picture ended up
getting on this? Pulled the camera out of the weep hole, and
there you were?
A. I don't know.
Q. What is that?
A. That's a piece of the debris, boron debris.
Q. That's at 40 and 44 seconds. What's going on here?
A. I think they're just waving the camera around right now.
Q. Do these film clips come with Dramamine?
A. What's that?
Q. I don't know if you can hear the sound.
A. Not really.
Q. Do you hear a chipping sound going on in the background?
A. I don't hear it.
MR. BALLANTINE: Your Honor, is it possible to turn
up -- I think it's the source from the government's table.
16:03:57 25 BY MR. STICKAN:
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Q. You had a chance to hear this tape before this, right?
A. Yes.
Q. Did you hear any sound in particular while you were
listening to this?
A. Yes, you could hear the spud bar hitting some of the
debris trying to break it up.
Q. Did there come a time when you stopped cleaning the
head?
A. Yes.
Q. Can you tell us what happened? What were the
circumstances behind you stopping cleaning the head?
A. They were following us; they were videoing behind us; as
we cleaned, they said yea or nay, it was good. We moved around
and got all the way around the head, and they got their video
information that they needed.
Q. Who's "they", by the way?
A. Andrew.
Q. Andrew who?
A. Siemaszko. And a Framatome individual; I don't know who
he was.
Q. Who decided when it was done? Who decided when you were
finished?
A. Andrew.
Q. And did you do anything afterwards, after you were told
you were finished?
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A. Yeah, we went out and got some pizza and beer
afterwards.
Q. Compliments of who?
A. Andrew.
Q. All right. What was the condition of the head when you
finished? Was it clean?
A. It was as clean as we were going to get it.
Q. Was there boron still left on the head when you were
told you were finished?
A. Yeah, there was some debris still in there.
Q. How would you characterize the success of your cleaning
operation?
A. We removed a lot of debris.
Q. Was there still boron on the head?
A. Yes. There was boron on the head. It was not all
removed.
Q. Okay. And did there come a time -- 12 RFO; now we're
looking forward to 13 RFO, the next outage. Were you on a
particular committee?
A. Yes.
Q. What type of committee were you on?
A. They call it 1-600.
Q. And who was on this committee?
A. Several engineers, a couple people from Radiation
Protection, different groups through the plant.
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Q. Okay. And what was the purpose of the committee?
A. To be able to do a better job on the 13 RFO cleaning the
head and able to inspect.
Q. What was your role on this committee?
A. To come up with some equipment to clean the head.
Q.- Okay. Did you discuss what type of equipment you
needed?
A. Looked at some type of pressure washers, that type of
stuff, and looked at shielding to help lower the dose when
you're up there cleaning, stuff like that.
Q. When you say "dose", what are you referring to?
A. Radiation exposure, to try to keep that low.
Q. And who else was on this committee? Was there
anybody -- let me ask you this: Was Mr. McLaughlin on this
committee?
A. Yes.
Q. Mark McLaughlin?
A. He headed up the committee.
Q. Andrew Siemaszko, was he on this committee?
A. Yes, he was.
Q. And as part of the, I guess, discussion about doing a
better job cleaning the head on 13 RFO, was there a review of
the videotapes that had been made of the prior inspections?
A. I'm sure there was.
Q. Did you have occasion to review any of the past
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videotapes?
A. No, I didn't.
Q. Do you know if anybody else did?
A. I'm sure people in engineering did, but I can't say that
for sure.
Q. Did you actually engage in some head cleaning in 13 RFO?
A. Yes, late in the outage.
Q. Describe what you were doing.
A. Well, we contracted out the head cleaning that time. We
had Bartlett take care of the cleaning, which was directed by
Framatome, and a lot of their people were getting too much dose,
radiation dose, so we kind of took over the operation after they
were done. They did a little different cleaning in that RFO
also; they cleaned the underside of the reactor head where the
nozzles come through; they cleaned that, and we also ended up
doing some cleaning up above the insulation package for debris
up above there where the CRDMs are at, so we got involved in
that.
Q .
A.
Were you able to finish cleaning the head during 13 RFO?
Yeah, I guess we did. We replaced it.
MR. STICKAN: Could I have one minute, Your Honor?
THE COURT: Of course.
(Discussion had off the record.)
MR. STICKAN: No further questions.
THE COURT: Very good. Cross, Mr. Hibey?
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MR. HIBEY: Thank you, Your Honor.
TERRY TABBERT, CROSS-EXAMINATION
BY MR. HIBEY:
Q. I brought this little podium all the way over here, but
lo and behold, there's no computer sitting on there. Good
afternoon, sir.
A. Good afternoon.
Q. Mr. Tabbert, during the time that you worked on cleaning
the head in 2000, would it be fair to say that your team was
trying to give it the best cleaning that you could give it?
A. Yes.
Q. And did anyone ask you at that time to cut any corners
on the cleaning effort that you were to undertake?
A. No.
Q. Now, the use of this demineralized water, I guess that's
a word that we haven't used during the openings yet, but the hot
water that was being used to clean the head, that was a pretty
cumbersome technique; isn't that correct?
A. Yes.
Q. And it's not as easy to do, shall we say, as a straight
vacuum job?
A. That's correct.
Q. So, in fact, you had to put up a special structure for
the water cleaning; is that right?
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A. That's correct.
Q. That included developing a plan for the control of the
water that you used in the cleaning; is that right?
A. That's correct.
Q. And you didn't want that water to go into places where
it shouldn't go in that area; is that right?
A. That's correct.
Q. And it took a couple of days to install the -- I'll use
the word scaffolding for the work that you were going to do in
that water cleaning; is that right?
A. That's part of it, yes.
Q.
process
A.
was the
Q.
A.
Q.
A.
Q.
And the Davis-Besse engineer who was in charge of that
was Andrew Siemaszko; is that correct?
I guess. I don't know who was in charge of it. He
engineer in charge of the reactor head.
He was the engineer that you interacted with?
That is correct.
You worked very closely with him; is that right?
That's correct.
And he gave the cleaning crew, of which you were a
21 member, the orders respecting the cleaning effort; is that
22 correct?
23 A. Yes, he did.
24 Q. All right. Now, during the cleaning effort, Andrew
25 Siemaszko was with a cameraman filming an inspection; would that
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be fair to say?
A. That's correct.
Q. And when they couldn't view an area, they would ask the
crew to clean it so that they could inspect that area; isn't
that right?
A. That's correct.
Q. So are we to understand that the cleaning preceded the
inspection?
A. Yes.
Q. Now, as for what you were doing, you were of the
opinion, were you not, that you were dealing with flange leakage
in this area; is that correct?
A. That was my understanding.
MR. STICKAN: Objection.
A. Yes.
BY MR. HIBEY:
Q. As a- matter of fact, you know -- do you know that
Davis-Besse has had a history of flange leakage; isn't that
correct?
A. That's correct.
Q. And your knowledge of that in part comes from the fact
that you've been experienced in cleaning the head on four or
five other occasions before this one?
A. That's correct.
Q. And so it was common knowledge within the station that
I
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Davis-Besse had a long history of flange leakage; isn't that
right?
A. That's correct.
Q. Now, am I right that the cleaning effort in 2000 had
fundamentally two components: The first was the vacuuming and
the breaking of the debris; that's one component; you would
agree?
A. Yes.
Q. And the other would be the water removal process that
you've talked about; is that correct?
A. That's correct.
Q. In total how much time was spent in the effort to clean
the head by your crew in the year 2000?
A. Actual cleaning of it or the entire setup and
everything?
Q. Well, the setup is part of the cleaning process; isn't
that right?
A. About four days.
Q. Now, this effort in its entirety was -- I'll use the
word owned by Andrew Siemaszko because he was in charge; isn't
that right?
A. That's correct.
Q. You identified another person in terms of the 1-600
team, but I'm going to ask you if you know whether Mark
McLaughlin had anything to do with this aspect of cleaning or
1 the inspection of the head?
16:16:05 2 A. I don't believe so. To my knowledge, he didn't.
,16:16:09 3 Q. Okay. Now, when you and your team ceased working on the
16:16:20 4 cleaning of the head, is it fair to say that you believe you had
16:16:27 5 successfully completed your job?
16:16:31 6 A. Yes.
16:16:33 7 Q. Indeed, would it be fair to say that you believe you had
8 had a successful cleaning of the head?
16:16:44 9 A. I'd say yes, as far as -- for the information they
16:16:48 10 needed, yes.
16:16:50 11 Q. And what was that manifestation of your belief that the
12 job cleaning -- the job of cleaning the head in the year 2000
13 was successfully completed? Is there any outward indication of
14 that amongst the group?
15 A. That it was a success?
16:17:10 16 Q. Uh-huh.
16:17:12 17 A. Yeah, I thought everybody thought we did a pretty good
18 job.
16:17:19 19 Q. That was part of the whole pizza and beer that Andrew
16:17:22 20 put up for the boys after the work; is that correct?
21 A. That's correct.
16:17:33 22 Q. This notion that the head had been successfully cleaned
16:17:37 23 was not something that was simply kept within the team as a
24 closely guarded secret; is that right?
25 A. That's true.
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Q. In fact, during an outage -- let's talk for a minute
about an outage, because there has been references to it, but
maybe this will help a little more.
Periodically on a regular, scheduled basis, the plant,
the reactor is, shall we say, dialed down for purposes of going
in there, doing cleanings and inspections and repairs; am I
right?
A.
Q.
Partially, yes.
With this subject matter, "partially" is pretty good for
me.
And you're aware in the case of 12 RFO that a little
newsletter comes out to talk about the activities of the
refueling outage and keep people apprised of what's going on in
a newsy kind of way; am I right?
A. Yeah, they have a schedule they post.
Q. They have something called the "Outage Insider"?
A. Yes.
Q. You've seen that?
A. Yes, I have.
Q. As matter of fact, I'd like to show it to you right now.
MR. HIBEY: What's the next number, please? We'll
mark this as Defendant's Exhibit 5 for identification.
BY MR. HIBEY:
Q. Mr. Tabbert, handing you what has been marked
Defendant's Exhibit 5 for identification, can you identify this
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document?
A. Yes, this is the "Outage Insider", Day 29.
Q. And it is a fact, sir, that this particular Day 29
reports on the reactor head cleaning; is that correct?
A. Yes.
Q. It is also, correct -- this report on the Outage Insider
is congratulatory of Andrew Siemaszko and his team for the
successful cleaning of the head in 12 RFO?
MR. STICKAN: Objection, Your Honor. Perhaps
Counsel should ask the witness if he's familiar with this
particular publication.
MR. HIBEY: He also says --
MR. STICKAN: He identified the "Outage Insider",
but this particular publication.
THE COURT: Edition, shall we call it.
MR. HIBEY: This particular article?
MR. STICKAN: Yes.
THE COURT: The article and the edition. He
identified what it was. Is he familiar with the May -- Day 29?
BY MR. HIBEY:
Q. The Day 29 "Outage Insider", you're familiar with that
article; are you not?
A. No.
Q. You've never seen it before?
A. No. I've never read it.
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Q. I want you to take a look at it and see if it refreshes
your recollection regarding what is reported therein.
MR. STICKAN: Objection, Your Honor.
THE COURT: Overruled at this juncture.
A. Okay.
BY MR. HIBEY:
Q. Does that particular document refresh your recollection
as to what was being published during the refueling outage
through this newsletter?
MR. STICKAN: Objection.
BY MR. HIBEY:
Q. Is there anything in that document now that you've read
that you disagree with?
MR. STICKAN: Objection.
THE COURT: Would you please ask him if it is --
discusses areas with which he has familiarity through his work.
BY MR. HIBEY:
Q. Well, let me ask it of you this way: Does this
particular article cover the subject of the cleaning of the head
in the year 2000?
A. Yes.
Q. And does it talk about the experience with respect to
the role of Andrew Siemaszko in overseeing and solving certain
issues with respect to the cleaning of the head, what he and his
team were confronted with?
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A.
Q.
by you
during
Yes.
And is this a reflection of what you recall took place
and your team with Mr. Siemaszko as your supervisor
the cleaning of the head?
MR. STICKAN: Objection.
A. Yes.
THE COURT: Overruled. You may answer if you know.
BY MR. HIBEY:
Q. The answer is "yes"; is that correct, sir?
A. That's correct.
Q. During that time you were in the area of the time shown
on the film. Were you around any of the repair work to the
flanges?
A. The nozzles, you're talking about, or the flanges?
Q. The flanges.
A. I was not up on the head, but I was in containment, yes.
Q. I mean, were you working in that head area --
A. No.
Q. -- when they were repairing flanges?
A. No, I was not.
Q. Do you know that they were repairing flanges?
A. Normally they do that every outage, but you usually pick
four or five of them.
Q. We were shown some film here today I want to
16:25:30 25 understand what it is we were looking at.
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First of all, in 17A there was an eight-minute clip of
head cleaning that was going on in the head in 2000. That was
film -- that eight-minute clip, youwere able to remember or
recall what was depicted in that film; is that right?
A. Yes.
Q. Then you were shown a digital version of the inspection
experience in the second film that was shown where you were
going through weep holes; is that correct?
A. Yes.
Q. Now, that picture, was that picture a little more red
than you remember it in your experience of going through the
weep holes?
A. I'd say -- I don't know; it pretty much depicted what it
looked like. The boron pieces were a more grayish color that
we were trying to get out.
Q. More grayish?
A. The bigger pieces were.
Q. More grayish than red?
A. That's correct.
Q. And I think there was a point in time when you heard
some -- when there was a certain noise on the tape, and did we
understand that that was a spud bar hitting on metal?
A. No, that was hitting on a piece of boron.
Q. All right. You also testified that you were a member
of the 1-600 Committee as part of the preparation for 13 RFO; is
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that right?
A. That's correct.
Q. Let me ask you this, sir: With respect to this 1-600
committee, you identified Mr. McLaughlin and Mr. Siemaszko as
being on it?
A. That's correct.
Q. Mr. Geisen was not on it, was he?
A. Not to my knowledge.
Q. And with respect to the cleaning of the head in the year
2000, at no time have you ever discussed the cleaning of the
head in the year 2000 with Mr. David Geisen; is that correct?
A. That's correct.
MR. HIBEY: Your Honor, indulge me a moment.
(Discussion had off the record.)
MR. HIBEY: Thank you, Mr. Tabbert.
THE COURT: Mr. Conroy?
MR. CONROY: Thank you, Your Honor.
TERRY TABBERT, CROSS-EXAMINATION
BY MR. CONROY:
Q. Mr. Tabbert, I'm John Conroy for Rodney Cook.
You don't know Rodney Cook, do you?
A. No.
Q. As you sit here today, would you recognize Rodney Cook
if you passed him in the hallway?
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A. No.
Q. Have you ever had any telephone conversation with him?
A. No, I have not.
Q. Have you ever exchanged any e-mail with him?
A. No.
Q. Do you know whether or not Mr. Cook was employed at
Davis-Besse at 12 RFO?
A. No, I don't.
Q. Do you know whether Mr. Cook was ever a member of the
1-600 team?
A. I never seen him there if he was.
Q. Do you know what Regulatory Affairs does?
A. Yes.
Q. What is it that you understand that Regulatory Affairs
does?
A.
Q.
head?
A.
Regulate the industry.
Do they have anything to do with the cleaning of the
Not to my knowledge.
MR. CONROY: Nothing further, Your Honor.
THE COURT: Thank you. Any redirect?
MR. STICKAN: Yes.
TERRY TABBERT, REDIRECT EXAMINATION
BY MR. STICKAN:
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Q. Just a few questions, Mr. Tabbert.
Mr. Hibey asked you about flange leakage; is that
correct?
A. Yes.
Q. Isn't it true that there is a separate inspection f
flanges?
A. Yes.
Q. Versus the inspection that you participated in with
respect to the top of the head?
A. That is correct.
Q. All right. Did you ever view any of the flange
inspection movies?
A. No, I have not.
Q. There were other people that did that; isn't that
correct?
A. That is true.
Q. So any knowledge that you have about flange leakage
would have been based upon what other people told you?
A. That's correct.
Q. Incidentally, when you were cleaning the head previ
to 12 RFO, you said the boron was different; is that correc
A. That's correct.
Q. How was it different?
A. There wasn't much of it. It was a powder; you cou
vacuum it out real easy.
or
ous
t?
id
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Q. Okay. You didn't have to use a spud bar on it and chip
it?
A. No spud bar, no water, no aggressive equipment at all.
Q. All right. Do you know what -- are you familiar with
what any type of boric acid deposit would look like that came
from a flange versus A nozzle?
A. No.
Q. You also indicated to Mr. Hibey that you thought that
the head cleaning was successful, was successfully completed; is
that correct?
A. That's correct.
Q. I think the words you used were successfully completed
for the information they needed.
A. That's correct.
Q. Now, are you basing that on the fact that Andrew
Siemaszko said: We're done, and let's go have pizza?
A. Basically that's correct.
Q. There's still boron on this head; isn't that correct?
A. Yes, there was.
Q. And there was so much boron on that head that it became
a concern for the 1-600 Committee for the next outage?
A. That's true.
Q. There was so much boron on the head that you began
thinking about what other pieces of equipment we needed to clean
this head better than we did in 12 RFO; isn't that true?
16:32:20
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A. That is true.
Q. And just one point, so we don't get confused here. The
beginning of the first tape, which was 17A, there was an
inspection going on; is that correct?
A. That is true.
Q. Now, do you know how many inspections occur in the
course of an outage?
A. On the head?
Q. Yes.
A. There should be one.
Q. Well, is there an as-found inspection?
A. There's an as-found inspection, yes.
Q. That's before the cleaning; isn't that correct?
A. That's correct.
Q. That's the way the head is; that's as found?
A. That's right.
Q. Then there's a separate inspection during the cleaning
or after the cleaning which is as-left; is that correct?
A. That's true.
Q. And what we saw was more of the as-left; isn't that
right?
MR. HIBEY: Objection, Your Honor. There's no
indication in these -- in the transcripts that there was -- what
that film was.
THE COURT: That's what he's asking him.
16:33:14 1 Overruled.
16:33:16 2 MR. HIBEY: Well, he's leading the witness.
16:33:18 3 THE COURT: What did we see?
4 MR. STICKAN: I'm sorry, Your Honor. Let me
5 rephrase.
6 BY MR. STICKAN:
7 Q. Was there cleaning going on while that inspection was
8 taking place?
9 A. Yes.
16:33:26 10 Q. Okay. Does that occur when you have an as-left
16:33:29 11 inspection?
16:33:30 12 A. Normally?
13 Q. Yes.
14 A. No.
15 Q. When does the cleaning usually occur?
16 A. Before the as-left.
17 Q. And then you would have the as-left inspection?
18 A. That is correct.
16:33:49 19 MR. STICKAN: All right. One minute, Your Honor.
16:33:53 20 (Discussion had off the record.)
16:33:55 21 MR. STICKAN: No further questions.
16:33:58 22 MR. HIBEY: If I may.
16:34:03 23
16:34:03 24 TERRY TABBERT, RECROSS-EXAMINATION
16:34:05 25 BY MR. HIBEY:
16:34:05 1
2
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7
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25
Q. The tape you were shown where the spud bars were being
used and the water was being used also, that was all with
respect to as-found, not the way you left it; isn't that
correct?
A. It wasn't as left; I know that; correct.
THE COURT: You may step down, sir. Thank you
very much.
Ladies and gentlemen, we do have a couple of
witnesses, but Counsel has asked me whether we would prefer to
start at 8:30 tomorrow morning and let you go. You've had a
long day today, and I will let you go at this juncture. Do you
want to chat amongst yourselves? Is it the consensus of the
grumbling I hear that 8:30 would be preferable? Very good.
Ladies and gentlemen, as we part, please remember
my previous instructions, and as you go home, I know this is
difficult, but please tell those with whom you come in contact,
friends, family, et cetera, that you've taken an oath to follow
the instructions of the Court, and that the Court has indicated
to you that you are not to discuss this case with anyone,
including other jurors, and that includes family, friends, et
cetera. You should tell them that at the -- after the case is
over you will be free, if you wish, to discuss it ad nauseam.
Do not discuss this case among yourselves, nor with
anyone else, or permit anyone else to discuss it with you. Do
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2
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16:37:34 5
6
7
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9
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12
not read, listen to, or watch anything reporting on this case in
any manner, touching on the case or any of the parties,
including FirstEnergy or what has been referred to as FENOC,
FirstEnergy Operating Company. Do not make up your mind on the
ultimate issues which will. be yours to determine at the end of
the case for there is much more testimony and evidence which you
will hear and observe.
Relax this evening, travel safely if you are
travelling. We will see you tomorrow morning at 8:30.
We're in adjournment.
(Adjourned at 4:37 p.m.)
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CERTIFICATE
I certify that the foregoing is a correct transcript from the
record of proceedings in the above-entitled matter.
Tracy L. Spore, RMR, CRR Date
1 INDEX
2
3 BRIAN SHERON, DIRECT EXAMINATION 106
4 BY MR. POOLE:
5 BRIAN SHERON, CROSS-EXAMINATION 130
6 BY MR. WISE:
7 BRIAN SHERON, CROSS-EXAMINATION 150
8 BY MR. GORDON:
9 BRIAN SHERON, REDIRECT EXAMINATION 159
10 BY MR. POOLE:
11 BRIAN SHERON, RECROSS-EXAMINATION 170
12 BY MR. GORDON:
13 TERRY TABBERT, DIRECT EXAMINATION 172
14 BY MR. STICKAN:
15 TERRY TABBERT, CROSS-EXAMINATION 193
16 BY MR. HIBEY:
17 TERRY TABBERT, CROSS-EXAMINATION 203
18 BY MR. CONROY:
19 TERRY TABBERT, REDIRECT EXAMINATION 204
20 BY MR. STICKAN:
21 TERRY TABBERT, RECROSS-EXAMINATION 208
22 BY MR. HIBEY:
23
24
25
U -
'90s - 112:10'96 - 142:2, 143:2, 143:10,
161:1'97 - 120:23
1I- 104:5, 109:18, 109:23,
142:9, 144:18, 154:9, 160:1110 - 128:22, 145:3, 145:7,
151:7, 163:4, 163:5100 - 132:2103 - 107:15106 -211:311 - 145:4, 163:412 - 145:4, 163:4, 167:9,
173:23, 175:2, 175:5, 175:6,175:19, 175:21, 176:2,176:7, 178:15, 179:4,184:14, 185:21, 186:1,190:17, 198:11, 199:8,204:7, 205:21, 206:25
125 -116:23, 116:24126 -115:12, 115:13,
115:16, 181:1513 -157:6, 190:18, 191:2,
191:22, 192:6, 192:19,202:25
130 -211:5136 -117:18137 -115:22140 -178:111400 - 104:1415 - 104:9, 148:10, 149:1,
151:7, 156:22, 158:1,171:18, 171:25
150 -211:7159 -211:916 - 126:14, 126:22, 127:2,
140:10, 145:19, 154:25,155:5
16th - 145:2017 - 185:1170 -211:111716 - 105:5172 -211:1317a - 178:22, 179:17,
185:3, 202:1, 207:31828 - 105:319 - 156:24, 157:2, 157:3,
156:13, 184:19, 184:23193 -211:151976 - 107:211980 - 109:211985 - 108:81987 - 108:111994 - 108:14, 112:151994-'95 - 112:181996 - 145:9, 145:10,
161 :22, 162:31997 - 108:1619a - 184:22, 184:24,
186:31:16 - 106:1
202:2, 203:10, 203:1120005 -104:15, 104:222001 - 107:7, 109:11,
109:20, 113:19, 121:15,122:16, 127:5, 135:13,144:15, 150:18, 151:23,154:8, 160:6, 161:15,161:19, 167:6, 169:13, 171:3
2001-01 - 110:21, 111:2,115:9, 121:7, 130:21, 161:162002 -123:11, 145:17,
146:23, 148:10, 149:1,160:10, 161:1220026 -104:1820036 - 105:32006 -108:182007 - 104:5201 - 128:24, 129:3202-514-0838 - 104:15202-514-2956 - 104:18202-626-5801 - 104:23202-833-3400 - 105:4203 -211:17204 -211:19208 -211:2120th - 143:1621 - 152:20, 154:11,
155:2021st - 153:24, 154:1822 - 149:11, 166:2023984 - 104:17243-3607 - 105:626 - 145:172747 - 162:1428 - 125:23, 125:24, 127:5,
145:20, 155:20, 156:3,159:22, 160:5, 160:628th - 137:23, 139:25,
140:25, 143:20, 145:14,154:1829 -111:1, 199:2, 199:3,
199:19, 199:21
33 -113:21, 137:8, 148:17,
148:21, 156:20, 156:22,159:23, 160:103,000 - 164:1530 -144:15, 149:12300 - 150:21, 150:22,
150:2431 - 121:15, 121:19,
122:15, 123:11, 125:4,126:8, 126:20, 135:13,154:8, 154:2531st - 139:19330 - 151:2334 -149:10, 149:13, 165:5,
165:14, 166:2035 - 165:336 - 166:213:06-cr-712 - 104:43rd - 104:14
44 -153:1340 -151:5, 151:6, 188:15419 - 105:643624 - 105:644 -188:1547 - 158:749 -158:2, 158:134:37 -210:11
55 - 198:22, 198:2550 - 123:25
50.1 (a - 129:1050.54(f - 130:1, 130:1250.9 - 128:22, 129:2054(f - 124:1
66 -142:13, 143-4,143:6,
144:17640 -105:2655 -104:2268 - 159:16
88952 - 169:20, 169:228:30 - 209:10, 209:13,
210:9
9-9 - 156:2490 -152:1, 152:3, 152:4900 -104:219701 - 113:5, 113:6,
113:13
Aability - 128:16able - 112:6, 124:10,
124:24, 125:3, 164:16,177:12, 185:24, 191:2,191:3, 192:19, 202:3abnormal - 164:7above-entitled - 210:17absolutely - 165:10abused - 153:9accelerate - 119:8accept - 159:25acceptable - 126:24accepted - 136:21, 136:23,
155:15access - 147:18accident - 108:1, 108:3,
155:10accidents - 107:25accordance - 110:19according - 158:13account - 161:11accuracy - 136:15accurate - 129:18, 130:3,
140:16, 148:6, 157:24,184:17, 185:24accurately - 154:12, 179:2acid - 120:13, 127:12,
165:14, 165:19, 165:24,206:5acknowledged - 161:13act - 167:18action - 124:5, 139:24,
166:1actions - 162:24, 163:10,
163:13, 165:11activated - 155:11activities - 107:8, 107:15,
161:14, 174:9, 198:12Actual - 196:14actual - 119:9, 153:24,
170:7ad - 171:19, 209:22additional - 123:17,
123:19, 125:8, 126:2,154:19, 161:22adequate - 123:10Adjourned - 210:11adjournment - 210:10admission - 179:17,
185:13admit - 128:23. 169:3
admitted - 109:25, 111:7,115:19, 115:24, 117:2,117:22, 129:6, 142:16,179:13, 179:21admonitions - 171:18advance - 154:24advised - 179:10Affairs - 204:12, 204:14affirmation - 129:24afternoon - 106:2, 126:9,
126:11, 130:21, 150:6,171:17, 193:7, 193:8afterwards - 189:24, 190:2agency - 130:24, 131:2,
150:20, 152:13, 152:22,158:10, 158:20agent - 165:13, 165:22,
166:9agents - 158:6aggravate - 119:7aggressive - 206:3ago - 123:20agree - 121:15, 148:3,
148:5, 155:16, 196:7agreed - 126:25agreement - 154:24,
155:3, 155:8, 168:14ahead - 154:20air - 118:25Alt- 128:7al - 104:7allow - 136:4, 140:4,
140:25, 170:12allowed - 142:10allowing - 141:2allows - 124:1alluded - 169:12alternative - 121:16ambient - 118:25America - 104:4, 109:3amount - 119:8, 127:18,
134:22, 170:15amounts - 113:23, 120:20,
127:25, 146:20, 162:4analyses - 106:22, 107:14,
107:24analysis - 107:23analyzing - 107:24, 144:5Andrew - 104:20, 174:11,
189:17, 189:18, 189:23,190:4, 191:19, 194:13,194:24, 196:20, 197:19,199:7, 200:23, 206:15Anna - 134:21, 135: 1,
135:7answer - 157:5, 159:3,
165:16, 165:22, 165:25,168:9, 171:16, 201:7, 201:9answering - 162:23anulus - 120:3, 120:5,
120:6, 120:11anytime - 153:8.-apart - 114:25apologize - 143:8apology - 149:24appeal - 124: 18appearance - 188:9Appearances - 104:12applicable - 110:20applicant - 129:14,
129:17, 130:5apply - 110:14appreciate - 107:2apprised - 198:13approach - 153:6, 153:8,
175:6, 178:19approached - 175:3,
175:20April- 107:21area - 114:19. 118:3.
22 -104:9, 144:10, 144:13,
144:17, 144:20, 144:22,148:21, 162:14, 162:15,162:18, 162:212,200 - 114:5, 118:920 -173:102000 - 118:11, 128:1,
147:6,147:22, 156:5,173:23, 193:10, 196:4,196:13, 197:12, 200:20.
w118:4, 118:5, 118:13,118:16, 118:17, 118:20,118:22, 119:19, 119:21,120:6, 157:25, 166:8,166:23, 170:13, 174:13,174:24, 180:8, 181:2,181:18, 181:19, 182:12,182:25, 183:1, 187:1, 187:9,187:13, 187:16, 187:19,187:21,194:6, 195:3, 195:4,195:12, 201:11, 201:17
areas - 176:6, 200:16argue - 157:10, 157:20argument - 157:10arranged - 137:25Arthur- 172:12article - 199:16, 199:18,
199:22, 200:19as-found - 207:11, 207:12,
209:3as-left - 207:18, 207:20,
208:10, 208:16, 208:17aspect - 162:10, 196:25assembly - 115:5, 116:10assess - 136:12assessment - 122:9,
122:10, 127:17, 143:23,144:1, 144:5, 144:23,145:11, 146:5, 148:6,163:16, 163:20
Assessment - 107:11,108:17, 108:24
Associate- 107:10,108:16, 108:20
associate - 107:17associated - 107:15assumed - 146:18Assuming- 134:12assumption - 134:10assurance - 126:13assure - 155:9, 156:14assured - 156:4, 156:16attached - 153:23, 167:19,
168:18, 169:7, 169:10attachment - 144:17,
160:23attempt - 177:14attend - 125:11, 138:5,
140:1attention - 112:1, 112:22,
149:11, 154:1, 156:8, 156:24attest - 129:25audit - 164:17augmented - 128:6August- 126:20authentic - 168:15, 168:17authentication - 169:1Avenue- 104:14, 105:5aware - 112:14, 128:10,
142:1, 171:9, 171:12, 198:11axial - 112:5, 112:9,
112:20, 112:25, 113:2,113:10, 114:9, 114:12,114:16, 114:23, 121:3,121:4, 130:25, 157:19
axially - 114:21, 119:20
BB&w - 127:20Babcock- 109:9, 154:9bachelor - 109:1backed - 182:7background - 108:25,
188:21bag - 183:12, 183:16bags - 176:21ball - 141:9Ballantine- 104:16,
188:23
bar- 177:5, 177:6, 177:11,178:2, 181:9, 181:10, 183:7,183:8, 183:18, 189:5,202:22, 206:1, 206:3
bars - 176:18, 177:4,181:16, 181:21,209:1
Bartlett- 174:4, 192:10based - 126:11, 133:19,
143:14, 175:15, 205:18baseline - 164:4basing - 206:15basis - 121:17, 123:25,
164:18,198:4became - 206:20become - 121:2beer- 190:1,197:19began - 206:23begin - 113:3, 152:8beginning - 154:2, 157:5,
158:13, 207:3behind - 189:11, 189:12behold - 193:6belief- 129:25, 131:7,
134:7, 197:11bend - 133:7benefit - 112:6, 117:7besse - 109:5, 109:8,
109:16, 121:25, 125:6,126:7, 127:4, 127:18, 136:8,137:22, 138:3, 139:10,139:18, 140:4, 140:7,140:25, 142:10, 145:16,146:17,146:23, 147:1,147:11, 147:21, 151:2,154:8, 154:14, 155:18,156:5, 158:11, 159:12,161:5, 161:17, 162:11,163:22, 163:25, 164:15,167:5, 167:19, 172:22,173:9, 194:12, 195:18,196:1, 204:7besse's - 122:10, 137:3,
138:15, 154:24, 155:3, 155:8best- 129:25, 151:21,
151:22, 179:14, 193:11better - 123:12, 184:25,
191:2, 191:22, 206:25between - 120:3, 120:6,
125:6, 129:1, 154:18,155:19, 155:22, 160:2,170:5, 187:3, 187:9, 187:16,188:3beyond - 122:15, 126:8,
126:20,154:8bigger - 176:21, 178:1,
202:17Bill- 153:18bit- 111:25, 120:19, 123:1,
132:16bitter- 182:1blank - 142:19blocked - 157:13blow - 114:7, 121:6Bob- 157:15books - 167:13boric - 120:13,127:12,
165:14,165:19, 165:24,206:5boron - 113:23, 127:9,
127:15, 127:23, 127:25,128:2, 128:3, 128:9, 131:18,134:19, 135:9, 146:20,156:10, 156:18, 157:16,162:4, 166:3, 166:4, 166:6,170:13, 175:10, 175:20,176:13, 176:15, 176:23,176:25, 181:6, 182:16,183:5, 183:10, 186:16,186:25, 187:2, 187:4,1A871R 1R7•22 1R•:14
190:8, 190:14, 190:15,202:14, 202:23, 205:21,206:18, 206:20, 206:23
Boron- 187:25boss - 152:21bottom - 116:16, 117:4,
117:9, 169:18, 183:15Box- 104:17boy- 139:10boys - 197:20Branch - 108:5, 108:6branch - 107:23, 151:4,
151:5break - 176:16, 176:18,
176:19, 177:8, 178:3, 181:8,181:22, 181:23, 182:15,183:8, 189:6
breaking - 181:9, 182:11,196:6
Brian- 106:6, 106:9,106:13, 130:19, 150:4,159:9, 170:23, 211:3, 211:5,211:7, 211:9, 211:11
brief- 122:8, 157:25briefly - 170:20bring - 181:25bringing - 151:10broke - 177:10, 177:23,
177:24,181:25brought - 112:21, 127:5,
193:5Bugey - 112:4, 112:8,
112:10building - 119:2built - 182:4, 182:5bulletin - 107:7, 111:11,
111:15, 120:21, 121:8,121:13, 121:18, 121:21,121:24, 122:6, 122:11,123:20, 123:23, 129:19,130:10, 130:11, 133:24,135:12, 135:17, 136:13,138:13, 151:1, 151:6
Bulletin - 110:21, 111:2,115:9, 121:7, 130:21, 161:16bulletins - 136:12Bulletins- 107:25bursting - 115:1
Ccaked - 127:25caked-on - 127:25calculated - 133:10calculation - 128:15,
128:16calculations - 116:17,
135:20camera - 180:7, 182:20,
182:23, 186:17, 186:19,188:10, 188:16cameraman - 194:25cameras - 170:12Campbell- 123:3, 123:8,
137:5, 137:18, 138:1, 159:19cannot - 107:2, 161:24capacity - 128:12, 128:18caption - 111:13capture - 161:15carbon - 118:21care - 173:7, 192:10Carl- 174:3carries - 114:14case - 122:22, 124:5,
124:19, 124:24, 141:7,145:3, 145:6, 145:11,154:15, 163:10, 171:20,171:22, 171:24, 198:11,209:19, 209:21, 209:24,21n.1 210:2 210-6
cases - 145:1categories - 163:2, 163:7category - 111:18, 163:9Catholic- 109:3caused - 139:14, 139:17,
154:19, 167:18cavern - 135:3Caverns- 135:1,135:3cavity - 131:10, 146:24Cd- 184:23Cdf- 163:10, 163:11ceased - 197:3center- 118:13, 133:12certain - 119:7, 128:14,
200:23, 202:21certainly - 140:19, 162:12Certainly- 146:16certify - 210:16cetera - 209:17, 209:21Cfr- 123:25, 128:22chains - 133:7chair - 175:11challenged - 124:18chance - 142:24, 174:12,
174:14, 189:1changed - 167:4, 169:13,
170:3changes - 116:18characteristic - 120:16characterize - 190:11charge - 194:12, 194:14,
194:15, 196:20chat - 209:12check - 164:1, 164:17checking - 133:3Chevalier- 104:20Chief- 108:4, 108:6chip - 177:7, 177:11,206:1chipping - 188:21chose - 135:14, 135:16chosen - 159:1chunks - 176:21, 186:25circumferential - 113:2,
113:21, 113:25, 114:2,114:10, 114:13, 120:25,121:2, 130:22, 131:8,131:15, 132:4, 145:17,151:16, 157:12circumferentially - 114:4,
115:2, 119:21circumstances - 128:14,
189:11claim - 162:10clarify - 110:10, 160:1,
160:16clean - 127:15, 134:7,
156:5, 173:8, 174:5, 174:14,174:17, 174:22,174:23,175:19, 176:2, 176:11,176:14, 177:15, 182:25,190:6, 190:7, 191:5, 193:18,195:4, 196:12, 206:24cleaned - 127:9, 127:16,
146:18, 146:19, 156:17,162:7, 175:16, 183:20,189:13, 192:14, 192:15,197:22cleaner - 175:7, 176:3,
176:11, 177:18,178:10cleaning - 173:13, 173:17,
173:20, 173:22, 174:9,174:16, 175:3, 175:21,176:7, 177:9, 177:13,178:15, 180:13, 180:17,182:21, 182:23, 183:20,183:23, 184:1, 184:10,184:13, 184:17, 185:20,185:25, 189:7, 189:11,190:11, 191:2, 191:10,1q1229 Iq2'R 1929.q
a m-.-.-,-.-.-.-.-.- a.-.~--,.-.-.-. -.
w U W192:10, 192:13, 192:16,192:19, 193:9, 193:11,193:14, 193:25, 194:3,194:10, 194:20, 194:21,194:24, 195:7, 195:22,196:4, 196:14, 196:16,196:25, 197:4, 197:8,197:12, 199:4, 199:8,200:19, 200:24, 201:4,202:2, 203:9, 203:10,204:17, 205:20, 206:9,207:13, 207:17, 207:18,208:7, 208:15
cleanings - 198:6clear - 116:21, 121:18,
143:8,181:14clearances - 152:16clerk - 106:7, 172:6clip - 184:13, 184:16,
185:4, 185:17, 202:1, 202:3clips - 188:17clogged - 147:7, 147:25clogging - 128:9close - 158:2closely - 194:18, 197:24closer - 175:12co - 150:7co-counsel - 150:7code - 110:13Code- 123:25codes - 106:23cold - 116:11collect - 124:3collecting 183:10Collins - 153:17Collins'- 153:20, 154:2,
156:14color - 118:14, 170:14,
176:25, 177:1, 177:3, 202:14colored - 118:3, 118:4,
128:2, 166:6, 170:10column - 144:6coming - 124:21, 134:11,
137:23, 157:18, 157:19,169:16, 170:10, 174:17,174:21, 186:13
Commenced - 106:1commercial - 109:10,
110:5Commission - 106:17,
107:20, 110:7, 112:2,123:24, 129:14
Commission's- 129:16committee - 190:19,
190:21, 190:23, 191:1,191:4, 191:13, 191:15,191:18, 191:19, 203:4
Committee- 202:25,206:21
common - 195:25Company - 154:3, 154:6,
210:4company - 109:13, 156:9,
157:9compared - 120:19,
120:22, 135:1compensatory - 126:4,
143:17, 145:15, 162:24,163:13complete - 129:18, 142:2,
143:2, 143:11completed - 197:5,
197:13, 206:9, 206:12completeness - 136:18,
166:13Compliments - 190:3Component - 151:4component - 119:8,
119:10, 125:17, 196:6components - 196:5
computer - 106:23,142:19, 193:6concern - 113:12, 114:3,
115:8, 120:22, 121:3, 127: 1,130:22, 130:24, 131:3,133:25, 139:14, 206:21concerned - 113:1, 124: 10concluded - 112:23,
126:11, 143:2, 143:10conclusion - 139:13,
145:16,165:21conclusions - 145:25,
154:12concrete - 177:7condition - 138:25,
152:21,164:10,164:13,164:16, 165:19, 168:6, 190:5conditions - 110:19,
118:7, 119:7, 127:3, 129:16,147:19, 167:5, 179:3conducted - 167:16confer - 179:11conference - 125:10,
137:13, 137:16, 137:24confirm - 106:23, 113:8confronted - 200:25confused - 207:2congratulatory - 199:7connections - 134:4Conroy- 105:2, 203:16,
203:17, 203:20, 203:21,204:20, 211:18
consensus -209:12consider - 167:25considered - 111: 19,
113:14consistent - 146:4, 146:7,
146:9, 146:11constantly - 129:2construction - 133:4,
133:15constructors - 133:7contact - 150:16, 209:16contain - 121:18, 182:6contained - 114:25containment - 119:2,
128:8, 201:16contains - 170:15contaminate - 158:21contents - 140:8continue - 114:15, 119:15,
126:7, 140:4, 140:25, 141:2,142:11continued - 121:4, 157:15continuing - 124:25contract - 174:4contracted - 192:9contracts - 116:12control - 116:9, 117:11,
117:15, 117:25, 120:3,127:9, 127:12, 127:14,155:9, 194:2conversation - 150:14,
204:2convince - 124:11Cook- 105:1, 150:7, 150:8,
159:1, 171:2, 203:21,203:22, 203:24, 204:6, 204:9
cool - 116:13coolant - 119:11, 120:1,
155:10cooled - 116:12cooler - 128:8cooling - 116:11, 155:11copies - 167:12copy - 128:24, 142:8,
153:18, 162:19core - 155:10, 162:24,
163:8Core - 163:12
corner - 169:19,,170:9corners - 193:13Correct- 131:6, 131:11,
134:2, 134:6, 136:9, 142:21,145:24, 155:2, 163:6, 167:7,183:15, 186:18correct - 106:15, 107:3,
111:3, 129:25, 131:8, 131:9,131:12i 131:15, 132:6,132:11, 132:15, 134:5,134:14, 134:15, 134:18,135:14, 135:15, 135:22,135:25, 136:17, 136:19,138:14, 138:22, 139:9,139:19, 140:6, 141:22,142:20, 143:3, 143:12,143:14, 143:18, 143:24,144:7, 144:24, 145:8, 145:9,145:12, 145:18, 145:21,145:23, 145:25, 146:14,146:25, 147:4, 147:8,147:11, 147:12, 147:22,147:25, 148:13, 149:17,150:24, 152:11, 154:16,154:22, 155:1, 155:12,155:16, 155:24, 161:7,161:8, 161:20, 166:11,172:25, 175:18, 178:7,178:8, 178:14, 178:16,178:17, 186:17, 186:22,188:7, 193:19, 193:23,194:1, 194:4, 194:7, 194:13,194:17, 194:19, 194:22,195:2, 195:6, 195:12,195:19, 195:20, 195:24,196:3, 196:10, 196:11,196:22, 197:20, 197:21,199:4, 199:6, 201:9, 201:10,202:8, 202:19, 203:2, 203:6,203:11, 203:12, 205:3,205:10, 205:15, 205:19,205:21, 205:22, 206:10,206:11, 206:14, 206:17,206:18, 207:4, 207:13,207:14, 207:18, 208:18,209:4, 209:5, 210:16
corrosion - 113:15, 119:5,127:12, 128:4, 133:25,134:9, 134:14, 146:3,146:13, 146:16, 147:1,161:5, 165:23, 166:2, 166:7,170:16, 171:11counsel - 107:1, 107:2,
150:7, 153:10, 160:2, 160:3,168:15Counsel- 152:17, 153:7,
179:6, 199:10, 209:9country - 147:13couple - 156:6, 170:20,
174:4, 183:5, 190:24, 194:8,209:8
course - 114:14, 153:4,192:22, 207:7court - 112:6Court - 104:1, 105:5,
106:2, 106:25, 109:25,111:7, 114:14, 115:13,115:16, 115:19, 115:24,116:6, 116:24, 117:2,117:22, 128:25, 129:1,129:6, 130:16, 142:17,142:22, 149:20, 149:23,153:4, 153:7, 157:2, 159:6,160:2, 160:6, 161:24, 162:1,166:18, 166:22, 166:25,167:11, 167:15, 167:21,167:24, 168:16, 168:25,169:22, 169:25, 170:19,171:15, 172:2, 175:11,178:20, 179:13, 179:18,
179:21, 179:23, 184:18,184:25, 185:2, 185:5, 185:8,185:11, 186:3, 186:6, 186:9,192:22, 192:25, 199:15,199:18, 200:4, 200:15,201:7, 203:16, 204:21,207:25, 208:3, 209:6, 209:18Court's- 142:6cover - 200:19covering - 166:24crack - 113:21, 113:25,
114:2, 114:3, 114:10,114:12, 114:13, 114:16,115:1, 119:14, 119:15,119:16, 120:2, 120:25,131:8, 151:17, 151:23,157:19cracking - 107:8, 111:19,
111:22,111:24, 112:1,112:16, 113:15, 113:18,117:8, 117:10, 117:12,119:5, 121:11, 123:13,124:12, 127:18, 145:17,146:4
cracks - 112:5, 112:9,112:20, 112:23, 112:24,113:1, 113:8, 114:21,114:23, 114:24, 119:4,121:1, 121:4, 130:22,130:25, 131:15, 132:4,132:7, 151:16, 157:10,157:11, 157:20Crd- 116:4Crdm - 117:19Crdms - 187:8, 192:17created - 120:22credit - 144:6, 145:6credited - 145:12crew - 180:13, 180:14,
194:20, 195:4, 196:13Cross- 130:16, 130:19,
150:4, 192:25, 193:3,203:19, 211:5, 211:7,211:15, 211:17
cross -115:22, 117:19,118:18, 160:24cross-examination -
160:24Cross-examination -
130:16, 130:19, 150:4,193:3, 203:19, 211:5, 211:7,211:15, 211:17
cross-section - 118:18cross-sectional - 115:22,
117:19crowbars - 176:18Crr- 105:5, 210:20crystallized - 176:15,
187:18cumbersome - 193:19cut - 159:21, 193:13cycle - 127:22
Ddam - 182:4, 182:5damage - 162:25, 163:8,
163:12danger - 131:7, 134:14Date - 210:20date - 123:10, 126:17,
126:24, 135:12, 135:13,135:16, 135:19, 135:20,135:21, 137:8, 154:11,159:15, 159:23, 160:3, 179:1Dave - 137: 10David - 104:7, 104: 10,
203:11Davis - 109:5, 109:8,
109:16, 121:25, 122:10,
w U W125:6, 126:7, 127:4, 127:18,136:8, 137:3, 137:22, 138:3,138:15, 139:10, 139:18,140:4, 140:7, 140:25,142:10, 145:16, 146:17,146:23, 147:1, 147:11,147:21, 151:2, 154:8,154:14, 154:24, 155:3,155:8, 155:18, 156:5,158:11, 159:12, 161:5,161:17, 162:11, 163:22,163:25, 164:15, 167:5,167:19, 172:22, 173:9,194:12, 195:18, 196:1, 204:7Davis-besse - 109:5,
109:8, 109:16, 121:25,125:6, 126:7, 127:4, 127:18,136:8, 137:22, 138:3,139:10, 139:18, 140:4,140:7, 140:25, 142:10,145:16, 146:17, 146:23,147:1, 147:11, 147:21,151:2, 154:8, 154:14,155:18, 156:5, 158:11,159:12, 161:5, 161:17,162:11, 163:22, 163:25,164:15, 167:5, 167:19,172:22, 173:9, 194:12,195:18, 196:1, 204:7Davis-besse's - 122: 10,
137:3, 138:15, 154:24,155:3 155:8days -194:8, 196:18Dc- 104:15, 104:18,
104:22, 105:3, 109:4dead -135:21dealing -132:13, 195:11debris -175:1, 175:8,
175:10, 175:24, 176:12,176:17, 176:18, 176:21,177:10, 177:23, 178:3,178:4, 180:23, 181:3, 181:7,181:10, 181:12, 181 :25,182:8, 182:11, 182:15,183:6, 183:17, 186:16,186:25, 187:4, 187:15,187:18, 187:25, 188:14,189:6, 190:10, 190:13,192:16, 196:6deceived - 139:17, 139:20December - 121:14,
121:19, 122:15, 123:14,124:21, 125:4, 126:8,135:13, 139:19, 154:8,160:10, 161:12
decent - 106:3decide - 171:23decided - 145:15,189:21decision - 126:6, 127:4,
130:4, 140:4, 140:24, 141:5,147:7, 149:17, 154:19,167:19, 169:14, 170:4
decisions - 106:24decon - 172:25, 173:11,
174:21, 182:25Decon - 173:4dedicated - 155:8defendant - 149:22Defendant - 104:8, 104:19,
105:1defendant's - 161:16Defendant's - 142:8,
144:10, 153:13, 156:20,156:22, 160:11, 162:13,162:15, 162:21, 198:22,198:25defendants - 123:5defense - 168:14Defense - 144:13, 148:17defer - 155:21
deferral - 154:7deficiency - 122:19degradation - 131:3,
133:25degree - 109:1degrees - 151:24, 155:4,
178:11demnineralized - 193:16Denis - 105:1Dennis - 150:7Department - 104:13,
104:17depended - 165:18depict - 179:2, 185:20depicted - 184:13, 202:4,
202:13depiction - 117:24,
184:17, 185:25deposit - 206:5deposited - 113:23deposits - 120:13, 120:16,
127:23, 131 :25Deputy - 108:8describe - 140:7, 168:9,
175:2, 175:19, 175:20,176:10, 176:13, 177:4,180:1, 180:4, 180:12,182:10, 186:11, 187:24
Describe - 192:8described - 139:25,
140:11, 151:9, 152:7, 152:12designed - 109:9,154:9detailed - 140:8details - 148:11determine - 111:22, 124:2,
130:1, 210:5develop - 124:15, 131:10developing - 106:23,
194:2diagram - 116:1, 119:3,
119:18, 120:13dialed -198:5difference - 113:25,
176:10different - 116:2, 127:4,
145:1, 147:8, 147:9, 165:22,176:7, 190:25, 192:13,205:21, 205:23
differently - 113:10,167:19
difficult - 148:5, 148:8,165:9, 209:16
digging - 183:5digital - 202:6digits - 169:18dimensional - 115:12,
116:18, 116:22, 117:4direct - 147:5, 149: 10,
154:1, 155:25, 156:23,159:15
Direct- 106:9, 172:8,211:3, 211:13
directed - 110:24, 152:8,156:8, 192:10
direction - 112:25, 113:2,114:12, 114:13, 114:16,114:21, 114:24, 115:2,151:19directly - 150:20, 151: 1,
151:6Director- 106:19, 107:10,
108:8, 108:11, 108:15,108:16, 108:18, 108:21,112:15, 152:22, 153:17
directors - 107:17disagree - 200:13discovered - 161:5,
161:11discuss - 125:20, 137:5,
171:20.,171:21, 191:6,
209:19, 209:22, 209:24,209:25
discussed - 126:10,155:23, 203:10discusses - 200:16discussing - 150:19,
167:18Discussion - 153:5,
173:15, 192:23, 203:14,208:20
discussion - 143:16,143:19, 143:23, 151:14,151:15, 158:9, 191:21
discussions - 150:23display -111:9, 117:18,
128:24, 169:21displayed - 110:2, 179:23disregard - 171:16dissolve - 176:19dissolves - 182:15distinctive - 131 :20District - 104:1, 104:11Division - 104:2, 108:8,
108:9, 108:11, 108:15,108:22, 108:23, 108:24,112:15
divisions - 108:22Docket - 104:4Doctor - 130:21, 142:24,
143:1, 144:9, 144:13document - 111:4, 111:9,
142:16, 144:11, 153:12,153:15, 153:21, 162:17,163:19, 164:9, 166:17,167:20, 167:22, 168:3,168:5, 168:14, 168:21,168:22, 169:2, 169:3, 169:7,169:10, 199:1, 200:7, 200:12
dome - 132:14, 132:20,132:21, 187:1domes - 132:11done - 116:16, 121:10,
121:11, 141:4, 148:7,148:20, 149:5, 164:24,165:7, 165:10, 165:17,174:16, 189:21, 192:13,206:16
dose - 191:9, 191:11,192:11, 192:12down - 111:23, 114:11,
116:11, 116:13, 116:16,117:12, 119:17, 119:19,121:13, 121:14, 121:15,121:19, 123:11, 123:14,123:21, 124:6, 124:7,124:21, 126:20, 126:22,128:25, 134:8, 135:25,136:3, 139:18, 139:24,146:23, 170:13, 177: 10,177:24, 181:7, 181:10,181:11, 181:25, 182:6,198:5, 209:6downhill - 132:1, 133:13,
133:22Dr- 114:11, 114:16,
117:24, 132:23, 135:19,136:20, 139:6, 142:8, 150:6,150:8, 150:18, 152:19,153:12, 154:10, 156:25,158:25, 159:11, 170:2,170:25draft -124:23, 141:1,
152:6drafted - 141:7Dramamine - 188:17draw - 165:21drive - 116:9, 117:25,
119:15, 120:4drop - 135:21drop)-dead - 135:21
dropped - 119:17, 141:9dry - 127:24, 131 :22,
131:23, 131:24, 134:19,176:3Duke - 109:1during - 107:1, 108:1,
116:10, 127:21, 128:1,133:2, 133:15, 155:4,173:13, 173:17, 179:4,184:14, 185:21, 186:1,192:19, 193:9, 193:17,194:24, 198:1, 200:8, 201:4,207:17
During -149:3 201:11dust -175:9, 175:24dusting -156:11, 156:18,
157:21duties -107:13, 173:13,
173:17
Ee-mail - 204:4early - 112:10, 113:19,
136:3ears - 147:16easily - 182:16easy - 193:21, 205:25edge - 177:7Edition - 199:15edition - 199:18educational - 108:25effort - 193:14, 194:21,
194:24, 196:4,196:12,196:19
eight - 187:1, 202:1, 202:3eight-minute - 202:1,
202:3eighth - 116:23either - 107:2, 111:21,
123:5, 123:12eject - 152:2ejecting - 145:22ejection - 131:8electrical - 109:2emergency - 155:10employed - 172:17, 204:6end - 110: 16, 123:14,
137:17, 137:20, 145:14,145:25, 158:2, 171:24, 210:5endangering - 126:14ended - 112:24, 188:9,
192:15engage - 192:6engaged - 158:10engineer - 194:12, 194:15,
194:16Engineering - 108:16,
108:24, 151:4engineering - 109:2,
109:3, 125:17, 174:8, 192:4engineers - 190:24enlarged - 111:13, 129: 10enter - 136:2entire - 109:13, 160:17,
166:14, 168:13, 168:21,173:12, 196:14entirety - 196:19entitled - 21 0:17equipment - 191:5, 191:6,
206:3, 206:24Ermer - 105:1essentially - 131:17,
145:15et - 104:7, 209:17, 209:20evaporate - 134:17evaporates - 135:9evening - 138:6, 210:8event - 155:9
evi,'--,,- - 1' 1:5 112:16
U - U113:20, 113:22, 115:23,117:18, 127:13, 134:22,161:12, 162:2, 166:17, 210:6evolved - 108:2exaggerated - 120:19Examination - 106:9,
159:9, 172:8, 204:24, 211:3,211:9, 211:13, 211:19
examination - 130:16,130:19, 150:4, 160:24,167:16, 170:23, 193:3,203:19, 208:24, 211:5,211:7, 211:11, 211:15,211:17, 211:21
examine - 170:12examined - 165:20example - 128:15, 134:21Except - 186:22exchanged - 204:4Excuse - 173:14, 179: 10,
184:18, 185:7Executive - 152:21, 153:17Exhibit - 109:18, 109:23,
111:1, 115:11, 115:22,116:23, 117:18, 128:24,142:9, 144:10, 144:13,148:17, 153:13, 156:20,156:22, 159:16, 160:11,162:13, 162:15, 162:21,167:9, 178:22, 179:17,181:15, 184:19, 198:22,198:25exhibit - 129:2, 167:11,
167:13, 167:15, 178:19,184:22expand - 116:14expanded - 132:24expands -116:12expect -153:9expected - 123:14, 146:5,
146:7, 146:16, 146:23, 164:9experience - 131:12,
158:12, 175:16, 200:22,202:7, 202:11
experienced - 195:22experiments - 106:23expert - 162:10, 162:12explain - 118:2, 122:19,
123:23, 163:11,explained - 124:14explanation - 136:25exposed - 119:10, 119:11exposure - 191:12expressly - 144:6extensive - 124:11external - 174:23eyes - 147:15
F
false - 139:21familiar - 109:5, 110:21,
138:9, 138:12, 138:18,199:10, 199:19, 199:21,206:4familiarity - 200:16family - 209:17, 209:20fan - 158:18far - 149:18, 178:2, 181:23,
197:9fear - 158:18February- 126:14, 126:22,
127:2, 140:10, 145:17,145:19, 154:25, 155:5Federal- 123:25federal - 110:13feet - 152:4felt - 126:13, 127:21,
139:20Fenoc- 109:15, 109:20,
168:16, 168:17, 210:3few - 125:12, 152:6, 205:1field - 119:16, 133:11Fifteenth- 104:22filled - 118:7film - 184:13, 185:3,
185:17, 188:17, 201:12,201:24, 202:3, 202:4, 202:7,207:24filmed - 186:17filming - 184:3, 184:14,
185:21, 186:1, 194:25filters - 128:8, 147:7,
147:25final - 152:21, 157:25finish - 192:19finished - 126:4, 152:20,
158:6, 189:22, 189:25,190:6, 190:9first - 106:4, 106:5, 110:2,
110: 3, 111:9, 111:10, 112:3,122:11, 126:16, 129:23,131:14, 139:22, 144:11,145:3, 148:18, 148:22,149:25, 153:20, 154:1,159:11, 159:13, 159:19,177:13, 177:14, 196:5, 207:3First- 153:22, 153:23,
202:1Firstenergy- 109:12,
125:19, 143:17, 144:14,144:24, 153:19, 154:3,154:6, 162:17, 163:19,172:18, 172:19, 210:3, 210:4Firstenergy's- 163:20fit -176:17five - 135:17, 140:13,
142:4, 173:21, 195:23,20 1:23flames - 158:18flange - 127:14, 127:15,
133:24, 134:3, 134:8,134:23, 135:7, 181:2,181:19, 187:9, 195:11,195:18, 196:1, 205:2,205:11, 205:17, 206:6flanges - 157:18, 201:13,
201:14, 201:15, 201:19,201:21, 205:6Floor- 104:14flowing - 182:12fluffy - 131:24focus - 143:16folks - 138:20follow - 165:1, 209:17follow-up - 165:1followed - 112:14following - 158:14, 189:12foot - 177:6, 187:1Force- 108:1
force - 136:3foregoing - 21 0:16forms - 135:10forth - 127:5, 141:1,
141:19, 142:10forward - 190:18foundation - 167:10,
168:23four - 169:18, 195:22,
196:18, 201:23Framatome- 189:19,
192:11frame - 112:19France- 112:4free - 209:22French- 112:7frequency - 128:9, 163:12friends - 209:17, 209:20front -156:20, 158:1,
162:15, 164:19, 165:11,166:25
full - 142:14, 143:5, 172: 10fundamentally - 196:5funny - 158:19
Ggap - 120:6, 120:11gather - 124:1Geisen- 104:7, 104:20,
137:10, 137:19, 159:1,160:3, 203:7, 203:11general - 132:9, 132:19,
133:19, 148:3, 148:4General - 148:10, 149: 1,
149:4, 152:17, 156:7,156:23, 162:16, 164:20generally - 161:2generate - 124:15generic - 113:4, 113:6,
113:13gentlemen - 106:2,
106:25, 115:20, 171:17,209:8, 209:14
given - 144:23, 147:22,147:24, 171:19
goal - 158:20goals - 158:19, 158:20good-looking - 188:4Gordon- 105:1, 111:6,
115:17, 117:1, 117:21,129:5, 149:21, 149:23,149:25, 150:5, 150:7, 153:2,153:6, 153:11, 157:3, 157:4,159:4, 168:24, 170:20,170:24, 186:5, 211:8, 211:12government - 106:4,
160:3, 172:2, 172:4, 179:12Government's- 109:18,
109:22, 111:1, 115:22,117:18, 128:23, 167:9,178:22, 179:17, 181:15government's - 188:24governs - 110: 11gray - 177:1, 177:3grayish - 202:14, 202:16,
202:18Graytown - 172:14great - 139:14greater - 113:12greatest - 132:25green - 120:18grew - 113:1groove - 112:21, 113:22,
114:19, 115:3, 119:19grounds - 167:10group - 151:11, 172:25,
174:16, 174:21, 197:14Group - 172:20, 172:24arou s - 190:25
grow - 114:16, 114:18,114:21, 119:20, 121:4,151:17
growing - 113:9grumbling - 209:13guarded - 197:24guess - 118:2, 128: 10,
150:21, 174:13, 177:14,181 :20, 183:25, 184:4,184:22, 191:21, 192:20,193:16, 194:14guest - 188:8guide - 184:9Guy- 123:3, 137:5, 159:19guy - 188:4
Hhalf -117:13, 140:13,
153:22,153:23hallway - 203:25hand - 107:3, 116:7,
144:9, 156:21, 159:16,162:19, 169:19, 170:9, 181:8handed - 142:8, 153:12,
167:14handful - 150:25handing - 111: 1, 198:24handle - 176:5happy - 166:16hard - 149:4, 149:14,
164:23, 165:6, 165:16,176:15, 176:16, 177:7hazard - 151:15head - 111:21, 111:24,
113:24, 114:8, 114:20,114:25, 115:23, 116:1,116:9, 116:14, 117:5, 117:9,118:19, 118:22, 120:3,120:7, 120:14, 120:20,121:6, 124:12, 127:9,127:16, 131:3, 131:5,131:10, 132:6, 132:24,133:23, 134:1, 1345, 134:7,134:8, 134:11, 134:13,134:16, 134:19, 138:9,138:25, 142:3, 143:3,143:12, 146:3, 146:17,146:18, 146:20, 146:21,146:24, 147:2, 151:19,155:4, 156:5. 156:10,156:17, 156:19, 157:17,162:5, 165:14, 165:24,166:4, 166:8, 167:5, 170:5,170:7, 170:12, 170:14,173:13, 173:17, 173:20,173:22, 174:13, 174:14,174:17, 174:22, 174:24,175:4, 175:8, 175:17,175:20, 175:22,175:25,176:2, 176:6, 176:7, 176:12,176:14, 177:9, 177:15,178:15, 179:3, 180:9,183:19, 183:22, 184:7,184:13, 184:17, 185:20,185:25, 186:13, 186:14,186:15, 187:12, 187:15,187:16, 187:21, 188:2,189:8, 189:11, 189:14,190:5, 190:8, 190:14,190:15, 191:3, 191:5.191:22, 192:6, 192:9,192:14, 192:19, 193:10,193:18, 194:15, 195:22,196:13, 197:1, 197:4, 197:8,197:12, 197:22, 199:4,199:8, 200:19, 200:24,201:4, 201:16, 201:17,202:2, 203:9, 203:11,
fact - 120:24, 134:21,134:25, 154:10, 155:13,161:21, 193:24, 195:17,195:21, 198:1, 198:20,199:3, 206:15
facts - 161:18, 165:20fall - 157:12failure - 151:18Fair- 131:17fair - 132:19, 147:2,
147:15, 170:15, 184:16,185:24, 193:10, 195:1,197:4,197:7
fairly - 131:12, 142:2,143:2, 143:11, 158:9, 179:2,182:16.
fall - 150:18, 151:22,156:3, 161:15, 161:19,167:6, 169:13, 181:10
falllnq - 182:6
U w U206:9, 206:18, 206:20,206:23, 206:25, 207:8,207:15
headed - 191:18heading - 111:13heads - 111: 19, 112:20,
113:16, 132:10health - 126:14hear - 107:2, 161 :24,
188:19, 188:21, 188:22,189:1, 189:3, 189:5, 209:13,2 10:7
heard - 149:25, 202:20Hearsay - 171:15heated - 116:12, 132:24heats - 116:17heightened - 120:22held - 107:22, 109:19,
109:20, 119:10, 140:3hell - 157:16help -174:5, 181:11,
184:9, 191:9, 198:3Hibey- 104:21, 173:14,
179:10, 179:19, 185:1,185:14, 186:4, 192:25,193:1, 193:4, 195:16,198:21, 198:23, 199:12,199:16, 199:20, 200:6,200:11, 200:17, 201:8,203:13, 203:15, 205:2,206:8, 207:22, 208:2,208:22, 208:25, 211:16,211:22high -111: 18, 118:8,
119:9, 134:16, 187:2higher -132:20, 133:12,
133:22highest - 133:11, 163:7hindsight - 148:6, 149:4,
164:24, 165:7, 165:17hired - 174:4historically - 134:22history - 140:12, 195:18,
196:1hit - 134:13, 183:2, 183:3hitting - 134:8, 189:5,
202:22, 202:23hold - 109:15holding - 114:6, 182:14,
182:19hole -131:5, 148:12,
161:5, 175:23, 176:6,176:17, 180:10, 180:11,181:3, 181:23, 183:9, 188: 10holes - 128:3, 166:6,
170:11, 177:10, 178:16,181:17, 181:18, 182:3,182:5, 182:7, 182:24, 184:1,184:17, 185:22, 186:22,202:8, 202:12hollow - 117:11home - 209:15Honor -106:5, 107:5,
109:22, 111:4, 115:15,115:17, 115:18, 117:17,129:4, 130:15, 142:15,149:19, 149:21, 153:3,153:6, 159:5, 159:7, 159:21,160:5, 166:12, 167:8,167:13, 168:7, 168:13,168:20, 170:20, 178:18,179:16, 179:22, 184:21,185:12, 186:5, 186:7,188:23, 192:21, 193:1,199:9, 200:3, 203:13,203:17, 204:20, 207:22,208:4, 208:19
Honorable - 104: 10hook - 176:4
horizontal - 115:2hose - 181:4, 183:16hot - 134:13, 182:15,
193:17hydraulic - 107:24, 128:15
1-600 - 190:22, 196:23,202:25, 203:3, 204:10,206:21
idea - 135:7, 155:13,164:13identification - 142:9,
144:10, 144:14, 148:18,153:13, 156:21, 198:22,198:25Identified - 167:22, 169:2,
169:3, 171:1, 185:1, 185:14,196:23, 199:13, 199:19,203:4
identify - 116:22, 178:19,178:23, 178:25, 198:25
Ig - 156:12, 157:23lg's - 158:6imminently - 157:12impact - 162:24imply - 170:15important - 135:21inch - 118:9Incidentally - 180:16,
205:20include - 173:17included - 154:23, 194:2includes - 106:25, 209:20including - 209:20, 210:3inconsistent - 158:19increases - 163:15increasing - 128:9Indeed - 197:7independently - 128:16indeterminate - 138:25Indian - 158:14indicate - 114:12indicated - 118:17, 128:4,
139:13, 183:13, 206:8,209:18
Indication - 139:16,152:22, 197:13, 207:23Indicative - 166:2, 166:7,
171:11indirectly - 150:20individual - 180:4, 180:25,
181:1, 182:13, 182:17,183:15, 183:18, 189:19individual's - 183:17indulge - 203:13indulgence - 142:6industry - 113:7, 113:13,
120:25, 204:16influenced - 149:17Information - 129:14information - 112:3,
113:11, 121:9, 121:22,122:6, 122:15, 122:20,123:17, 123:19, 123:24,124:2, 124:4, 124:13, 125:1,126:3, 126:12, 128:12,128:17, 128:20, 129:15,129:19, 129:20, 130:5,130:6, 130:7, 130:8, 139:21,147:6, 151:14, 154:7,154:13, 154:19, 154:23,155:1, 155:6, 155:18,161:22, 165:11, 189:15,197:9, 206:13
informational - 151:15informed - 112:14, 144:3initial - 127:17, 137:3initials - 179:1
initiate - 119:4, 119:5,119:18
Initiated - 119:12initiating - 119:19initiation - 119:14Insert - 116:13inserted - 180:8, 182:24Inside - 118:6, 118:8,
119:11, 152:13, 170:16,175:8, 182:5, 183:25, 184:7,184:17, 185:21, 187:5
Insider - 198:16, 199:2,199:6, 199:13, 199:21
inspect - 111:23, 113:15,113:17, 121:12, 121:14,127:13, 183:1, 191:3, 195:4
Inspected - 112:19,121:14, 183:22
inspecting - 184:3inspection - 126:22,
128:2, 128:7, 128:17, 138:9,140:11, 142:2, 143:2, 143:3,143:11, 145:7, 145:9, 146:2,146:6, 161:1, 161:2, 161:22,162:3, 162:6, 162:7, 163:4,163:5, 163:9, 164:4, 170:12,174:9, 180:3, 180:16,180:19, 180:23, 182:21,187:20, 194:25, 195:8,197:1, 202:6, 205:5, 205:8,205:12, 207:4, 207:11,207:12, 207:17, 208:7,208:11, 208:17
inspections - 111:21,113:19, 121:10, 121:12,138:3, 144:7, 145:3, 145:12,146:23, 154:8, 163:15,164:5, 191:23, 198:6, 207:6Inspector - 147:11,
147:15, 147:21, 147:24,163:22, 163:24, 164:14,171:6, 171:7, 171:10Inspector - 148:10,
148:25, 149:3, 156:7,156:23, 162:16, 164:20
inspectors - 164:3install - 194:8installation - 133:3Installed - 116:10, 133:4,
133:5, 133:6, 133:7installing - 133:17instances - 136:5Instructed - 113:4, 124:22instructions - 209:15,
209:18Insulation - 134:4, 186:14,
187:5, 187:7, 187:8, 187:9,187:10, 187:11, 187:16,188:1, 188:2, 192:16Intend - 185:5, 185:8intended - 111:23, 152:23,
153:19Interacted - 194:16interactions - 112:22internal - 114:5, 114:22,
114:24, 115:4, 115:6,119:15, 121:5, 126:9internally - 177:1, 177:2interrupt - 184:18interruption - 107:4Interview - 148:23, 149:3,
156:7, 156:22, 158:1, 162:16Interviewed - 148:9,
148:25Interviewed - 148:15introduced - 133:14investigate - 106:24Investigations - 139:23investigations - 161:9involve - 173:13
involved - 107:25, 125:19,126:10, 132:13, 144:6,150:25, 151:6, 173:19,173:22, 174:8, 192:17
Involvement - 110:23involving - 145:3iron - 128:5, 170:15,
171:11Island - 108:1, 108:3issue - 110:24, 124:14,
124:17, 124:22, 124:23,125:3, 132:13, 132:16,152:14, 152:23, 153:19,169:1
issued - 113:4, 130:2 1,135:17
issues - 106:24, 108:2,171:23, 200:24, 210:5
issuing - 133:24items - 155:23itself - 121:18
JJ-groove- 112:21, 113:22,
114:19, 119:19job - 164:5, 175:3, 191:2,
191:22, 193:22, 197:5,197:12, 197:18jobs - 107:22John- 105:2, 203:21join - 168:24joked - 134:25Judge- 104:11, 160:16judge - 136:15judgment - 151:21, 151:22juncture - 169:4, 200:4,
209:11Juror- 142:21jurors - 209:20jury - 107:1, 107:22,
111: 10, 111: 15, 111:25,,114:9, 114:12, 118:2, 119:3,128:25, 129:13, 132:16,142:19, 159:17, 164:13,166:25, 170:2, 171:15,179:14, 179:23, 185:6,185:9, 186:8jury's - 117:7Justice- 104:13, 104:17justification - 122:15,
123:10, 123:13, 124:20,140:9, 152:16justifications - 141:2justify - 125:1, 154:7
KKatz - 104:10keep - 114:15, 182:6,
191:12, 198:13kept - 182:7, 197:23kill - 158:21kind - 111:19, 114:20,
121:11, 127:22, 130:3,165:19, 176:1, 177:15,192:12, 198:14knowing - 147:6knowledge - 179:14,
195:21, 195:25, 197:2,203:8, 204:19, 205:17
known - 127:24, 135:3,149:5
Lladies - 106:2Ladies- 106:25, 171:17,
209:8, 209:14hoDe - 106:3 lan -582
U - Ulanguage - 164:23large - 113:21, 121:4,
127:25larger - 183:12, 183:17last - 126:20, 142:14,
143:4, 143:5, 145:11,160:13, 165:3, 169:18,171:16, 172:11, 186:19late - 126:11, 192:7lay - 168:23leading - 208:2leak - 127:10leakage - 113:22, 119:22,
119:25, 120:1, 127:14,133:25, 134:3, 134:8,134:10, 134:12, 134:23,135:7, 195:11, 195:18,196:1, 205:2, 205:17
leaks - 135:9learn - 127:3, 127:7, 162:3learned - 112:3, 112:9,
119:4, 128:6, 146:2, 161:21least - 137:25, 146:19,
162:5left - 120:18, 146:21,
156:5, 156:10, 162:5, 170:8,190:8, 207:18, 207:20,208:10, 208:16, 208:17,209:3, 209:5
legal - 124:13, 124:16,152:16
less - 127:19, 135:16,136:3
letter - 113:4, 113:6,113:13, 141:1, 141:7,141:11, 141:16, 141:20,141:23, 142:1, 142:5,142:10, 153:16, 160:11,160:18, 160:19, 160:23,
Letters- 136:7license - 109:15, 109:19,
110:2, 110:3, 110:15,110:16, 110:19, 124:3,129:15, 129:16, 130:3, 130:5
licensed - 110:6licensee - 110: 16, 110:18,
122:19, 124:10, 124:17,124:20, 124:24, 124:25,125:25, 126:12.' 126:21,127:11, 128:14, 128:18,129:15, 129:17, 129:24,139:21, 143:19, 163:17,164:10
licensee's - 163:16licensees - 111:17,
112:22, 121:7, 121:8,121:25, 123:21, 124:4,127:10, 128:13, 150:13
licensing - 106:22,107:14, 107:17
Licensing- 107:10,108:21, 108:23life - 172:16ligament - 114:6, 115:4,
115:5,151:18light -156:11, 156:18,
157:2 1likely - 127:19, 147:9limits - 116:20line - 149:11, 157:5,
158:13, 166:19, 166:20,166:2 1liquid - 120:4listen - 171:21, 210:1listening - 189:4lo - 193:6located - 187:11look - 109:18, 121:11,
142:14, 144:11, 148:5,
148:18, 148:21, 153:14,156:13, 158:20, 159:18,159:20, 164:9, 164:16,168:2, 179:8, 184:5, 200: 1,206:5
Looked- 191:8looked - 131:21, 131:24,
139:7, 148:22, 191:9, 202:14looking - 117:5, 158:22,
180:4, 180:5, 180:6, 186:11,186:13, 187:14, 187:24,188:4, 190:18, 201 :25
looks - 136:20, 182:12,182:20
loose - 176:20, 177:10,177:24, 178:3
lose - 158:22loss - 155:10low - 119:17, 191:12lower - 117:13, 191:9lunch - 106:3, 126:5Luray- 135:1, 135:3lying - 139:21
Mmail - 204:4main - 143:16, 143:21maintain - 110:18maintained - 129:17majority - 131:25, 132:4manifestation - 197:11manipulated - 133:16manner - 113:9, 157:12,
210:2March - 123:11, 126:20,
154:25mark - 116:6, 198:22Mark - 191:17, 196:24marked - 142:13, 144:9,
153:13, 156:21, 178:22,181:14, 184:23, 198:24marking - 148:17master - 109:2material - 116:19, 125:17,
129:18, 133:9, 142:18,158:22, 177:7, 181:24,187 :23
Material - 151:4math - 152:4matter - 132:9, 132:19,
133:19, 148:3, 148:4,151:14, 155:13, 195:17,198:9, 198:20, 210:17Mclaughlin - 191:14,
191:17, 196:25, 203:4mean - 118:4, 147: 10,
151:21, 157:3, 158:15,158:17, 174:18, 187:7,201:17
meaning - 156:4, 163:18means - 129:24meant - 157:2measure - 158:15measures - 126:4, 143:17,
145:15mechanical - 105:9mechanism - 117:25meeting - 125:19, 126:5,
126:9, 138:21, 139:10,139:25, 140:3, 140:16,143:21, 143:22meetings - 125:6, 125:10,
125:11meltdown - 158:17member - 140:15, 194:21,
202:24, 204:9members - 138:7memorandum - 153:20,
154:2, 154:11
mentioned - 118:9,119:22, 167:3, 184:19,187:10
met - 126:2, 126:16, 150:6,150:10
metal - 116:11, 119:13,202:22
mid - 124:9, 152:9middle - 132:21, 183:16might - 123:6, 124:21,
125:12, 133:14, 137:10,140:13, 149:7, 150:13,159:23, 164:6, 171:22,178:18
Mile - 108:1, 108:2Miller - 104:20mind - 210:4minds - 171:23minimal - 175:25minute - 114:9, 123:20,
140:16, 165:2, 168:2,192:21, 198:1, 202:1, 202:3,208:19
minutes - 171:18, 171:25misled - 143:5missed - 138:23misspoke - 159:23misstate - 156:2model - 115:12, 115:16,
116:22, 117:4, 146:10,181:15, 187:11modify - 124:2, 130:2moment - 153:2, 160:14,
203:13monitor - 179:8, 180:6,
180:7, 184:5monitoring - 113:8,
113:18month - 148:12months - 128:10, 135:17morning - 125:25, 209:10,
210:9most - 111: 19, 113:14,
127:19, 127:21, 127:22,147:9, 151:8motioning - 114:20motions)due - 115:6motivated - 115:8move - 128:23, 168:13,
175:11, 183:1, 184:25,185:11, 185:12moved - 189:13moves - 119:16movies - 205:12multipage - 153:12,
153:21mushroom - 117.14mushroom-shaped -
117:14
Nname - 106:11,109:13,
109:14, 112:7, 157:13i,172:10, 172:11names - 174:3nature - 131:15nauseam - 171:19, 209:22nay -189:13near - 113:24necessarily - 163:18necessary - 155:10need - 124:2, 130:2,
159:20needed - 121:16, 123:12,
124:5, 177:24, 183:3,189:15, 191:7, 197:10,206:13, 206:24Never- 150:10, 150:12never - 199:24. 199:25.
204:11New - 104:14new - 131:12,154:23,
154:25, 155:5, 155:18, 162:2newly - 16 1:11newsletter - 198:12, 200:9newspaper - 158:16newsy -198:14next - 127:22, 165:2,
169:15, 169:17, 172:2,183:2, 183:17, 190:18,198:21, 206:21nobody - 133:15noise - 202:21normal - 175:9, 182:16Normally - 122:18, 175:7,
175:9, 182:15, 201:22,208:12
normally - 118:7, 128:17,128:18,175:15North - 134:21, 134:25,
135:7Northern - 104:1notereading - 105:9notes - 156:1nothing - 159:4Nothing - 204:20notice - 137:22notion - 197:22November - 125:23,
125:24, 127:5, 139:25,143:16, 143:20, 144:15,152:20, 154:11, 155:19,155:20, 156:3nozzle - 107:8, 112:5,
114:17, 115:12, 116:2,116:4, 117:19, 117:25,118:13, 119:4, 120:7, 120:9,120:10, 120:11, 131:8,134:8, 145:23, 151:16,151:19, 151:24, 152:1,154:7, 176:6, 186:13, 206:6nozzles -111:24, 117:15,
132:1, 132:5, 132:7, 132:14,132:19, 132:21, 132:25,133:4, 133:6, 133:12,133:13, 133:16, 133:20,180:5, 187:3, 187:17,187:20, 188:3, 192:15,201:14Nrc -107:9, 124:1, 125:7,
126:15, 128:11, 130:8,131:12, 144:14, 147:10,161:15, 161:16, 161:18,163:18, 163:19
Nuclear - 106:17, 106:19,106:21, 107:11, 107:19,108:7, 108:10, 108:12,108:14, 108:18, 109:5,109:8, 109:12, 109:16,
112:12,123:24,154:3,154:6, 154:8nuclear - 107:15, 109:3,
109:10, 110:5, 110:15,111:20, 112:4, 158:22Number- 142:13, 144:10,
154:9, 159:16, 162:14,162:15, 162:18, 162:21number - 108:2, 137:14,
137:15, 146:19, 148:13,148:15, 166:4, 169:18,198:2 1numbers - 144:23, 145:12,
146:12nuts - 174:24Nw- 104:14, 104:22, 105:3
0
E U poath -129:23, 209:17Object- 167:10object -168:20, 168:21,
1764Objection -161:23,
161:25, 166:12, 168:7,171:14, 195:14, 199:9,200:3, 200:10, 200:14,201:5, 207:22
Objection -109:24,109:25, 111:6, 111:7,115:16, 115:24, 116:24,116:25, 117:1, 117:2,117:20, 117:21, 117:22,129:3, 129:5, 129:6, 168:24,168:25, 179:18, 179:20,186:3, 186:4, 186:5objects - 117:14obligations - 110:16observe - 210:7observed - 126:1, 138:24obtain - 110: 14, 123:24obtained - 110:17obviously - 121:3, 128:3occasion - 183:25, 184:12,
185:17, 191:25occasions - 148:15, 156:2,
156:6,195:23occur - 117:11, 117:12,
207:6, 208:10, 208:15occurred - 158:5, 185:21occurs - 117:8Oconee - 111:20, 113:20,
113:21, 119:22, 120:17,120:24, 127:23, 131:5,131:12, 131:17, 131:25,132:5, 132:8October- 104:5, 124:9,
137:8, 152:9, 159:23offer - 109:22, 111:4,
115:13, 115:23, 117:18,167:9,179:16offered -143:17office -107:18, 108:13,
112:13, 137:15, 156:14,164:7Office -106:19, 106:21,
107:11, 108:6, 108:9,108:12, 108:14, 108:18,112:11, 112:12, 139:22,148:9, 148:25, 149:3,152:17, 164:20offices - 106:22, 108:20,
108:2 1offsite - 158:15Ohio- 104:1, 104:5, 105:601g- 148:25once - 110: 16, 119:14,
120:4, 133:6, 146:2One - 138:20, 143:22,
157:25, 208:19one - 107:17, 113:19,
116:23, 121:6, 133:10,134:25, 135:23, 136:20,136:23, 139:10, 139:11,143:21, 146:16, 146:22,154:25, 155:7, 157:16,166:5, 166:9, 167:18, 169:9,169:12, 180:25, 181 :21,182:13, 184:19, 185:1,192:21, 195:23, 196:6,207:2, 207:10
one-eighth - 116:23ones - 125:13, 133:20,
169:16 -~ongoing -161:13, 161:14
open - 119:2openings - 193:17operate - 109:15, 122:15,
126:17, 136:4, 140:4,140:10, 140:25, 142:11,145:16, 156:15, 156:17operated. - 127:20operating - 107:15,118:7,
119:9, 127:2, 155:3, 181:16Operating - 154:3, 154:6,
2 10:4operation - 110:12,
190:12,192:12Operations - 152:22,
153:17operator - 155:9opinion - 139:4, 139:8,
195:11opinions - 126:19opportunity - 122:20,
179:11, 184:5options - 124:14orange - 118:4orange-colored - 118:4order - 110: 14, 113:8,
124:2, 124:6, 124:14,124:17, 124:22, 124:23,125:3, 125:5, 130:3, 142:15,152:6, 152:9, 152:14,152:20, 153:18, 153:24,154:20Orders - 107:25orders - 129:16, 194:21orienting - 113:10original - 109:19originated - 162:6outage - 113:17, 127:8,
127:12, 128:1, 163:4, 163:5,173:23, 174:5, 174:8,190:18, 192:7, 198:1, 198:2,198:13, 200:8, 201:22,206:21, 207:7
Outage- 198:16, 199:2,199:6, 199:13, 199:21outages - 173:13, 173:17,
173:19, 175:16outside - 132:6, 132:20,
132:25, 133:20, 174:13,175:9, 177:2, 178:16, 186:22outward - 197:13overnight - 124:15overruled - 168:25Overruled - 162:1, 200:4,
201:7, 208:1overseas - 112:3overseeing - 200:23Oversight- 108:9own - 128:16, 171:5owned - 196:20owner - 109:11oxide - 128:5, 170:15
Ppackage - 186:14, 187:5,
187:7, 187:9, 187:10,187:16, 187:17, 192:16packed - 187:25Packed - 188:1packet - 160:17Page - 149:12, 149:13page - 110:2, 110:3, 111:9,
111:10, 142:13, 143:4,143:6, 144:11, 144:17,144:20, 144:22, 148:18,148:19, 148:21, 149:10,153:22, 153:23, 156:24,158:2, 158:7, 158:13,160:14, 160:17, 160:18,160:19, 165:3, 165:14,166:9, 166:20, 166:21,169:17
n~nnn - 1AR-99 1RI-fl
159:20paragraph - 142:14,
142:24, 143:1, 143:4, 143:6,154:2, 160:13, 165:3,166:17, 166:18
parameter - 119:11Pardon - 107:4pardon - 149:23part - 110:9, 110:11,
117:4, 117:9, 117:13, 124: 1,130:8, 164:5, 168:5, 168: 10,170:10, 173:25, 174:24,180:14, 180:16, 184:23,191:21, 194:11, 195:21,196:16, 197:19, 202:25,209:14
Part - 168:16Partial - 163:4, 163:5partial - 145:3, 145:6Partially - 198:8partially - 198:9participated - 205:8particular - 169:2, 172:21,
178:9, 179:12, 180:8,183:10, 189:3, 190:19,199:3, 199:11, 199:14,199:16, 200:7, 200:19parties - 210:2parts - 116:2, 143:21pass - 117:12passed - 129:2, 203:25past - 128:9, 138:16,
140:11, 176:8, 191 :25pause - 181:13penetrates - 116:9penetration - 112:21,
113:24, 114:7, 114:20,117:10, 120:2, 120:4penetrations - 112:5,
116:10, 116:13, 121:6,127:10, 127:19, 146:4
people - 125:19, 133:16,148:13, 148:14, 150:19,150:24, 151:5, 151:11,158:17, 159:1, 190:24,192:4, 192:11, 198:13,205:14, 205:18
People - 138:9, 138:12,138:15per -118:9percent - 132:2, 152:1,
152:3, 152:4percentage - 164:17perfectly - 133:5, 133:8perform - 164:4performance - 158:20performed - 113:20performing - 106:22,
106:23Perhaps - 199:9perhaps - 127:14, 151:7period - 148:12, 150:18,
155:5, 156:3Periodically - 198:4periodically - 113:16,
122:8permit - 171:20, 209:25permitted - 126:7person - 183:16, 196:23personally - 122:1,
125:14, 125:18, 136:7,156:4, 156:16personnel - 125:7pertinent - 158:8pervasive - 110:9Ph.d - 109:2phenomena - 119:6phone - 122:18, 123:6,
137:5, 137:11, 137:17,13.7-2n1 160:12
photograph - 128:1,147:6, 147:22, 166:5, 167:3,167:17, 167:20, 168:11,168:21, 169:4, 169:10,170:3, 170:5, 171:1, 171:3
photographs - 168:18,169:7, 169:9, 169:12, 169:15
physically - 114:7pick - 122:18, 188:8,
201:22picture -188:9, 202:10pictures -134:24, 135:2piece -154:25, 155:5,
181:6, 182:14, 187:13,188:14, 202:23pieces -177:11, 183:5,
183:11, 183:12, 183:17,202:14, 202:17, 206:24Pieces -181 1:0pile -187:4piled - 187:2pizza - 190:1, 197:19,
206:16place - 116:15, 145:16,
201:2, 208:8placed - 132:25places - 194:5Plaintiff - 104:5Plaintiffs - 104:13plan - 113:7, 194:2plans - 121:12plant - 109:10, 110:12,
110: 15, 110:18, 111:20,111:23, 112:4, 112:7,113:16, 116:17, 126:17,126:19, 126:20, 127:23,136:2, 139:24, 141:2,147:13, 147:16, 154:9,156:15, 164:2, 172:21,173:8, 190:25, 198:4plants - 107:16, 110:5,
110:6, 112:17, 112:19,113:14, 113:18, 121:10,121:13, 127:10, 127:20,134:21, 135:24, 166:4playing - 179:11Pm - 106:1, 210:11Po - 104:17podium - 193:5Point - 158:15point - 114:4, 115:3,
117:7, 121:5, 133:24,134:25, 137:2, 138:2,142:15, 151:17, 154:14,157:16, 178:6, 181:17,202:20, 207:2
points - 141:23Poole - 104:13, 106:5,
106:10, 107:5, 107:6,109:22, 110:1, 111:4, 111:8,114:11, 115:11, 115:15,115:21, 116:21, 117:3,117:17, 117:23, 128:23,129:7, 130:14, 136:6,137:10, 142:15, 149:12,149:13, 150:23, 152:7,154:17, 159:7, 159:10,159:25, 160:7, 160:9,160:16, 160:19, 160:21,162:9, 162:19, 162:20,166:13, 166:16, 166:23,167:2, 167:8, 167:13,167:17, 167:23, 168:1,168:8, 168:13, 168:17,169:5, 169:24, 170:1,170:17, 171:14, 211:4,211:10
popcorn - 131:18, 131 :21,131 :24
a------ -- ~n*rtinn 19al 17n:6 ---. .
p u wpose - 112:25, 113:3posed - 151:15poses - 114:2, 126:23position - 106:18, 107:9,
108:20, 125:2, 181:8possibility - 151:17, 162:8possible - 107:4, 188:23post - 198:15potential - 107:24, 147:18,
151:15pounds - 114:5,118:9powder - 205:24powdery - 127:24Power - 109:5, 109:8,
109:16, 154:9power - 109:10, 110:5,
110:15preceded - 195:7preclude - 124:25predicted - 146:9, 146:11prefer - 209:9preferable - 209:13preparation - 152:8,
202:25prepare - 110:24prepared - 125:5preparing - 124:23prescribe - 110:14presence - 163:21,
165:13, 165:23present - 183:19, 183:22presentation - 140:7presented - 126:1presents - 145:1president - 123:3, 137:13,
137:14, 156:9, 157:9, 157:15press - 158:18pressure - 114:5, 114:6,
114:22, 114:24, 115:4,115:6, 116:18, 118:8,118:25, 119:9, 121:5,139:18, 174:23, 180:25,182:14, 183:18, 191:8pressurized - 109:9,
118:14, 118:23presumably - 138:18presume - 147:20, 149:18,
157:24Pretty - 175:22, 187:15pretty - 110:9, 177:2,
188:2, 193:18, 197:17,198:9, 202:13previous - 127:8, 162:5,
167:16, 171:18, 205:20,209:15
previously - 120:25,121:10primarily - 120:1'Privilege - 153:9probabilistic - 143:23,
143:25, 144:22, 145:11probability - 162:24, 163:8problem - 112:1, 112:16,
112:25, 113:3, 117:8, 127:1,137:3problems - 133:10, 136:23proceed - 167:1Proceedings - 105:9proceedings - 210:17process - 130:9, 152:12,
158:9, 158:11, 161:15,182:23, 183:20, 183:23,185:20, 186:1, 194:13,196:9,196:16produced - 105:9product - 151:11products - 165:23program - 113:14, 127:12Project - 107:10, 108:23
promoted - 108:4, 108:5,108:8, 108:11, 108:16,108:18proposal - 123:18propose - 126:3proposed - 123:11,
126:22, 142:17, 155:7proposing - 113:14Protection - 172:20,
172:23, 173:1, 190:25protruded - 132:14proved - 145:25provide - 113:7, 121:8,
121:16, 123:12, 123:16,124:20, 128:19, 155:8,159:15provided - 122:14, 123:10,
123:17, 124:12, 125:9,126:2, 126:12, 128:12,128:21, 129:14, 129:19,129:23, 154:6, 163:17,163:19
public - 126:14, 158:22publication - 199:11,
199:14publish - 142:16, 159:17,
167:9, 186:7published - 186:9, 200:8pull - 114:24, 133:8,
139:11Pulled - 188:10purpose - 111:16, 111:17,
161:14, 191:1purposes - 198:5pursuant - 168:14push - 139:18put - 116:15, 146:13,
157:8, 176:21, 183:12,193:24,197:20
puts - 133:8, 133:9
Qqualified - 159:3quality - 163:16quality - 139:1, 139:3questioned - 139:7questioner - 157:13questioning - 166:19questions - 130:14, 136:6,
152:6, 158:7, 160:15,162:13, 163:21, 166:13,170:17, 192:24, 205:1,208:2 1
quick - 106:3quickly - 107:4, 135:25
Rradiation - 128:8, 192:12Radiation- 172:20, 172:23,
173:1, 190:24, 191:12radioactive - 173:7raise - 107:3rational - 121:17reach - 178:2, 178:3reached - 154:13Reactive- 108:5Reactor- 107:11, 108:6,
108:7, 108:10, 108:15,112:11
reactor - 109:10, 114:5,114:22, 115:7, 115:23,116:1, 118:6, 118:8, 118:18,118:22, 119:12, 120:3,120:7, 121:5, 127:9, 132:6,132:10, 134:4, 146:24,147:1, 173:20, 173:22,174:24, 175:8, 175:24,
192:14, 194:15, 198:5, 199:4reactors - 107:24read - 129:13, 149:18,
154:5, 154:12, 158:16,159:17, 160:14, 164:22,165:3, 166:14, 166:15,166:16, 166:18, 166:20,171:21, 199:25, 200:12,210:1
reading - 138:15ready - 106:4, 125:4,
157:12real - 205:25really - 114:23, 132:7,
133:15, 140:8, 140:14,144:8,188:20
reason - 114:3, 116:20,131:20, 137:19, 171:2, 171:5
reasonable - 126:13reasons - 142:10receive - 113:11, 122:6received - 122:9, 154:14,
154:18, 154:23, 155:19,155:22
receives - 164:14receiving - 139:21recent - 111:21, 121:11recess - 171:18Recess- 172:1recognize - 110:2, 111:2,
111:10, 142:9, 144:13,168:5, 168:10, 168:11,169:6, 169:10, 203:24
recognized - 135:23recollection - 148:23,
150:15, 159:18, 167:21,200:2, 200:7
record - 106:12, 115:11,153:5, 160:1, 168:17,172:11, 173:15, 192:23,203:14, 208:20, 210:17
recorded - 105:9, 157:23records - 168:16Recross- 170:23, 208:24,
Recross-examination-170:23, 208:24, 211:11,211:21
red - 166:6, 171:11,202:10, 202:18
red-colored - 166:6reddish - 128:2, 128:3,
169:16, 170:10, 170:14,177:1
reddish-colored - 128:2,170:10
redirect - 149:20, 204:21Redirect- 159:6, 159:9,
204:24, 211:9, 211:19reduce - 155:3refer - 169:4references - 198:2referred - 129:11, 210:3referring - 150:22, 151:12,
183:14, 191:11reflect - 161:18reflection -201:2reflections - 158:10reflects - 158:6refresh - 148:23, 200:7Refresh- 167:21refreshes - 159:18, 200:1refueling - 163:4, 163:5,
173:23, 175:16, 198:13,200:8
regard - 123:22, 141:21regarding - 147:18, 200:2region, 116:8, 117:8,
117:13
regular - 183:12, 198:4Regulate- 204:16Regulation- 107:12, 108:7,
108:10, 108:15, 112:12regulation - 128:24,
129:10, 130:6, 130:7, 130:11Regulations- 123:25regulations - 110:11,
110:13, 110:20, 128:20,129:16Regulatory- 106:17,
106:20, 106:21, 107:19,108:12, 108:19, 110:6,112:2, 112:13, 123:24,204:12, 204:14
regulatory - 106:24,107:18, 110:9,128:11,130:9, 158:9
Relax- 210:8released - 158:16Relevance- 161:23relevance - 161:25, 168:18reliance - 151:10relied - 136:12, 136:15rely - 128:18remain - 121:2, 134:19remained - 112:24remaining - 114:6, 155:5remains - 135:10remember - 117:11,
125:12, 137:17, 140:14,144:8, 148:9, 153:7, 159:11,160:24, 164:22, 17 1:18,174:2, 202:3, 202:11, 209:14remembered - 140:20removal - 196:9remove - 175:1, 177:12,
181:6, 187:19removed - 146:2, 190:13,
190:16repair - 127:15, 201:12repairing -201:19, 201:21repairs - 198:6rephrase - 208:5replaced - 192:20report - 164:7, 164:10,
168:6, 199:6reported - 108:21, 108:22,
200:2reporter - 112:6Reporter- 105:5reporting - 210:1reports - 147:18, 147:25,
164:14, 164:16, 199:4represent - 158:5representation - 160:23request - 111: 17require - 121:7, 121:21,
123:21, 124:4, 128:20,139:24, 151:23required - 110:6, 110:14,
110:18, 121:8, 129:15,130:6, 130:7, 130:11, 141:1,152:13, 164:5requirement - 121:19,
141:6requirements - 138:12requires - 130:8Research- 106:20, 106:21,
108:13, 108:19, 112:13reside - 172:13resident - 147:11, 147:15,
147:21, 147:24, 163:22,163:24, 164:3, 164:14,171:5, 171:7, 1,71:9, 171:10residual - 119:13, 133:2,
133:9, 133:14, 133:21respect - 200:22, 200:24,
203:3, 203:9, 205:9, 209:3
omised - 171:19 176:2 176:6 180:9 187:12 reaional - 164:7 resoectinci - 194:21
U W Urespects - 129:18respond - 121:21responded - 113:13response - 122:11,
123:15, 137:3, 155:25,161:16responses - 121:24,
122:7, 122:9, 129:19,130:10, 130:11, 136:13,136:14, 136:16, 136:18,138:13, 138:15, 151:1, 151:7responsible - 107:14rest - 171:25result - 154:13, 158:11resulted - 127:4results -111:21, 128:17rethink - 178:4reversed - 135:5review - 121:25, 124:16,
125:14, 126:10, 136:7,142:24, 154:13, 161:16,191 :22, 191 :25Review- 108:9reviewed - 122:2, 123:9,
141:16, 143:25reviewing - 143:14, 151:1,
151:7revoke - 124:3, 130:2Rfo- 145:4, 145:7, 173:23,
175:2, 175:5, 175:6, 175:19,175:21, 176:2, 176:7,178:15, 179:4, 184:14,185:21, 186:1, 190:17,190:18, 191:2, 191:22,192:6, 192:13, 192:19,198:11, 199:8, 202:25,204:7, 205:21, 206:25
Richard- 104:13, 104:21right-hand - 169:19, 170:9rights - 124:17rim - 132:20rip - 115:5risk - 126:24, 143:23,
143:25, 144:5, 144:22,145:11, 145:22, 163:7,163:15, 163:20Rmr- 105:5, 210:20rock - 176:16rod - 116:9, 117:25, 120:4,
127:9,127:14Rodney- 203:21, 203:22,
203:24rods - 117:11, 117:15role - 191:4, 200:23room - 137:15, 155:9rotating - 113:18Roughly- 118:10roughly - 118:25, 150:24round - 120:9, 120:10,
120:11Rpv- 142:3, 143:3, 143:11rule,- 166:12rules - 110:20run - 116:1, 126:20,
170:13running - 128:2, 134:8,
166:6rust - 165:23, 170: 10,
177:1
Ssafe - 136:3, 145:16,
156:16safely - 126:18, 140:10,
210:8safety - 106:24, 107:14,
107:24, 108:2, 112:25,113:3, 114:3, 121:3, 121:17,
127:1, 147:18Safety- 108:9, 108:12,
108:17, 108:23sailing - 115:6Sam - 153:16sat - 125:12Saunders - 156:13, 157:15saw - 113:22, 127:25,
139:6, 167:4, 171:2, 171:6,171:8, 180:16, 186:19,207:20
scaffolding - 175:23,194:9scale - 116:23scare - 158:23schedule - 121:16, 198:15scheduled - 198:4scheme - 110:9, 110:10science - 109:1, 109:2scientific - 135:13scraper - 177:18, 178:1scraping - 181:7screen - 110:3, 111:10,
129:8, 142:19seals -116:16second - 142:14, 143:4,
143:5, 145:6, 148:19, 154:2,160:14, 160:17, 160:18,181:13, 202:7Second - 160:19seconds - 188:15secret - 197:24section - 118:18, 165:6,
166:10, 166:14, 183:2, 183:3Section - 108:4sectional - 115:22, 117:19see - 114:21, 115:3, 116:4,
116:6, 129:8, 144:20, 157:1,157:21, 159:18, 167:11,170:10, 170:13, 174:13,183:25, 184:6, 184:7,185:24, 186:25, 200:1,208:3, 210:9
seeing - 134:12, 142:19seem - 119:7sent - 152:21, 153:24sentence - 154:1, 154:5,
154:11separate - 184:21, 205:5,
207:17September - 159:22,
160:5, 160:6Serial - 136:7, 162:14series - 164:4service - 170:6, 170:8,
170:16session - 138:5, 138:21set - 110: 11, 137:13,
137:24, 137:25, 141:19,178:10setting - 141:1, 142:10setup - 196:14, 196:16seven - 108:13,155:4several - 112:19, 125: 10,
128:10, 156:2, 167:3Several - 190:24shall - 129:17, 193:21,
198:5, 199:15shape - 131:21, 133:19shaped - 117:14, 132:24Sheron - 106:6, 106:9,
106:13, 106:14, 106:16,107:7, 114:11, 114:15,114:16, 116:6, 117:24,130:19, 132:23, 135:19,136:20, 139:6, 142:8, 150:4,150:6, 150:8, 150:18,152:19, 153:12, 154:10,156:25, 157:25, 158:25,If 9q9q IS9QII1 1AO-7
167:17, 168:2, 169:6, 169:9,170:2, 170:23, 170:25,211:3, 211:5, 211:7, 211:9,211:11shielding -191:9shields - 187:8shift - 174:18ship - 173:7shoot - 158:24short - 121:3, 136:4,
159:22Shortly - 152:25shot - 159:1show - 115:21, 148:17,
160:11, 167:9, 167:20,181:14, 181:15, 185:5,187:11, 198:20
showed - 128:1, 166:5,169:16
Showing - 178:22showing - 162:23, 169:9shown - 179:14, 179:24,
201:11, 201:24, 202:6,202:7, 209:1
shows - 120:13, 163:7shut - 111:23, 121:13,
121:14, 121:15, 121:19,123:11, 123:14, 123:21,124:6, 124:7, 126:20,126:22, 128:25, 135:25,136:3, 139:18, 139:24,146:23
shutdown - 136:2, 154:24sic - 156:25side - 132:1, 133:22,
170:13sides - 133:13Siemaszko - 174:11,
189:19, 191:19, 194:13,194:25, 196:20, 199:7,200:23, 201:3, 203:4, 206:16
sign - 141:11signed - 141:15, 153:17significance - 112:23significant - 114:2,
134:22, 145:22similar - 181:20, 181:21,
186:19simply - 197:23sit - 158:16, 203:24site - 113:20sitting - 193:6situation - 107:3, 125:20situations - 133:6six - 148:12, 155:4,
173:21, 177:6six-month - 148:12size - 120:19, 151 :25slight - 120:3slope - 170:6small - 112:5, 112:9,
112:20, 112:24, 113:23,115:4, 120:20, 127:24,146:12, 150:25, 164:17,181:12smaller - 177:12, 183:11sole - 161:14solid - 176:4solving - 200:23sometime - 152:9Sometimes - 181:22somewhere - 166:8sorry - 113:2, 143:5,
143:7, 145:20, 149:23,157:3, 167:14, 172:23,177:20, 183:21, 208:4sort - 117:14, 118:18,
120:16, 129:20, 152:17,176:5ýniinht - 191,Q
sound - 137:8, 188:19,188:21, 189:3
source - 188:24special - 193:24specifically - 149:11speculate - 149:4, 149:14,
164:23, 165:7, 165:9, 165:16spell - 106:11, 112:7,
172:10spent - 196:12Spielbusch - 105:5spoken - 150:12Spore - 105:5, 21 0:20spot - 164:17spot-check - 164:17spots - 177:2, 183:2spray - 182:14spud - 176:17, 177:4,
177:11, 178:2, 181:9,181:10, 181:16, 181:21,183:7, 183:8, 183:17, 189:5,202:22, 206:1, 206:3, 209:1
square - 118:9staff - 110:24, 112:13,
113:4, 122:5, 122:8, 122:14,123:4, 123:9, 124:11,124:13, 124:22, 125:7,125:9, 125:17, 126:1,126:10, 126:15, 126:17,126:18, 126:25, 133:3,135:19, 135:24, 136:10,136:12, 136:15, 136:20,137:2, 137:14, 137:15,137:24, 138:2, 138:7,138:20, 139:6, 139:13,139:17, 140:15, 140:24,140:25, 141:9, 141:14,141:20, 143:1, 143:2,143:10, 143:25, 144:5,144:23, 145:14, 146:22,148:2, 150:23, 151:10,152:8, 154:12, 154:18,155:22, 156:4, 159:12,161:15staff's - 151:22stage - 157:11stalactite - 135:10stalactites - 135:4stalagmite - 135:10stalagmites - 135:4stand - 175:22standpoint - 126:25,
145:18staring - 129:2start - 124:22, 179:11,
182:9, 186:6, 209:10started - 107:23, 112:15,
177:13,177:15starting - 179:9state - 106:11, 134:19,
161:18,172:10States - 104:1, 104:4,
104:11Station - 109:6, 109:8,
109:16,154:9station - 195:25statute - 129:15, 130:6,
130:7, 130:11steam - 178:10steel - 118:21, 177:6stenography - 105:9step - 209:6steps - 123:21, 124:8stick - 176:4, 176:5Stickan - 172:4, 172:9,
173:16, 175:14, 178:18,178:21, 179:6, 179:7,179:16, 179:22, 179:25,184:21, 185:3, 185:7,1R9.101 I85:12 185:16
-2:1 12:1 126:24--...-------
w U W185:16, 186:7, 186:10,188:25, 192:21, 192:24,195:14, 199:9, 199:13,199:17, 200:3, 200:10,200:14, 201:5, 204:22,204:25, 208:4, 208:6,208:19, 208:21, 211:14,2 11:20
sticking - 187:17still - 119:6, 124:10,
156:20, 157:3, 164:19,190:8, 190:10, 190:14,206:18
Still - 182:11stipulate - 159:22stipulated - 160:2stipulation - 159:25stood - 140:15stopped - 189:7stopping - 189:11straight - 132:14, 133:5,
193:2 1strategic - 158:20Street- 104:22, 105:3stress - 113:15, 119:5,
132:20, 133:1, 133:11stresses - 116:19, 119:13,
119:15, 119:17, 132:17,133:2, 133:9, 133:10,133:13, 133:14, 133:22strike - 148:2Strike - 148:4strong - 124:19stronger - 114:6structure - 116:3, 170:6,
170:8, 170:16, 193:24stud - 174:24, 182:3,
182:5,182:7studs - 170:6, 170:7stuff - 158:21, 173:8,
176:22, 191:9, 191:10subgroup - 172:25subject - 126:15, 198:9,
200:19submission - 144:14,
159:13, 162:14submissions - 125:6,
125:8, 125:14, 138:18submit - 111:20, 122:21,
123:18, 125:1submits - 128:15submittal - 123:9submitted - 136:8subsequent - 107:8,
112:16, 113:23, 162:3, 162:7subsequently - 109:20,
113:11, 127:3, 127:7subset - 184:22substance - 127:24substantial - 146:20,
162:4, 166:7success - 190:11, 197:15successful - 179:9,
180:19, 197:8, 199:8, 206:9successfully - 197:5,
197:13, 197:22, 206:9,206:12
suck - 175:7, 176:20,181:11sucking - 181:2sufficient - 122:14,
124:12, 124:20, 154:7suggest - 166:14suggested - 121:13suggestion - 155:15Suite- 104:21, 105:2supervision - 150:19,
174:6supervisor - 153:16,
174:3. 201:3
support - 106:22, 123:17supposed - 127:11,
129:24, 141:4, 184:9surface - 116:3, 120:5,
120:14, 127:24surprise - 146:13susceptibility - 111: 18susceptible - 111: 19,
113:15suspend - 124:2, 130:2Sustained - 171:15swifter - 139:23, 166:1sworn - 106:7, 172:6system - 128:11systems - 155:11Systems - 108:5, 108:6,
108:12, 108:23
TTabbert- 172:5, 172:8,
172:12, 172:13, 175:11,178:19, 180:1, 185:17,186:12, 193:3, 193:9,198:24, 203:15, 203:19,203:21, 204:24, 205:1,208:24, 211:13, 211:15,211:17, 211:19, 211:21
table - 144:20, 145:1,162:23, 188:24Table- 144:22tape - 179:12, 186:20,
188:8, 189:1, 202:21, 207:3,209:1
tapes - 126:1, 139:1, 139:7Task- 107:25team - 173:25, 174:2,
175:3, 179:3, 193:10,196:24, 197:3, 197:23,199:7, 200:25, 201:3, 204:10Technical- 107:11, 108:17,
152:16technical - 126:16, 141:19,
15 1:22technique - 193:19techniques - 133:4,
138:10telephone - 204:2temperature - 118:8,
119:9, 119:10, 134:16,155:4, 178:9tend - 119:15tends - 158:18tensioning - 170:6, 170:7term - 151:18, 156:11termed - 131:19, 156:18terms - 120:19, 133:25,
196:23Terry- 172:4, 172:8,
172:12, 193:3, 203:19,204:24, 208:24, 211:13,211:15, 211:17, 211:19,211:21
testified - 147:5, 155:25,156:2, 156:8, 171:10, 202:24testifying - 159:11,
178:12, 185:18testimony - 166:3, 210:6themselves - 116:15thereabouts - 152:10thereafter - 152:25therefore - 127:21therein - 200:2thereto - 153:23thermal - 107:23, 128:15thinking - 206:24Thomas- 104:16Three- 108:1, 108:2three - 108:22, 115:12,
116:22. 117:4. 145:1.
155:19, 155:23, 163:2, 163:7three-dimensional -
115:12, 116:22, 117:4tint - 128:4Tipton- 174:3, 174:7today - 147:2, 156:2,
178:12, 185:18, 201:24,203:24, 209:11Toledo- 104:5, 105:6tomorrow - 209:10, 210:9took - 144:6, 192:12,
194:8, 201:2tools - 176:1, 177:15,
177:25top - 148:19, 175:24,
187:1, 187:6, 187:15,187:25, 205:9total - 196:12totally - 119:6, 158:19touch - 116:7, 171:22touching -210:2towards -117:13, 187:25Tracy- 105:5, 210:20Transcript- 104:10transcript -105:9, 156:22,
156:24, 157:14, 157:24,157:25, 158:2, 158:5,158:14, 164:19, 210:16transcripts -207:23trash -176:21, 183:12travel - 210:8travelling - 210:9Travers- 153:18, 153:24trial - 107:1Trial- 104:6, 104:10tried - 139:11, 178:2true - 129:25, 132:23,
135:5, 140:17, 141:24,197:25, 205:5, 205:16,206:22, 206:25, 207:1,207:5, 207:19
trusted - 141:20, 141:24truthful - 128:20try - 114:24, 176:18,
176:19, 178:2, 178:5,181:22, 182:15, 183:2,183:8, 191:12
trying - 157:9, 157:20,160:1, 180:5, 181:6, 183:6,187:3, 187:19, 189:6,193:11, 202:15tube - 120:4tubes - 117:11Turn- 149:10turn - 119:21, 12 1: 1,
142:13, 144:17, 158:1,160:13, 165:2, 188:23turned - 113:1, 115:1,
139:22, 142:19turns - 113:17two - 107:17, 135:5,
148:22, 153:20, 159:19,196:5type - 190:21, 191:6,
191:8, 206:5types -117:15typical - 164:14typically -127: 10
Uultimate - 171:23, 210:5ultimately - 125:2, 126:11,
149:17, 154:19unable - 124:20, 125:3unacceptable - 113:9,
126:24, 137:1unanimity - 126:15,
126:18Under- 134:10. 166:12
under - 118:7, 129:23,150:19,174:6
underground - 135:3underneath - 134:11,
182:6, 188:1, 188:2underside - 192:14understood - 119:6undertake - 193:14unfortunately - 167:12unit - 113:22Unit- 154:9United - 104:1, 104:4,
104:11University- 109:1, 109:3unknown - 133:21unless - 153:8unnatural - 158:18unprepared - 136:2unsafe - 135:24unsuccessful - 177:23up -111:25, 114:9, 114:15,
115:6, 116:14, 116:17,118:13, 120:5, 122:18,123:1, 126:4, 127:2, 127:15,132:14, 137:13, 137:24,137:25, 139:18, 140:15,153:20, 154:14, 165:1,166:8, 167:14, 170:12,170:16, 171:23, 173:8,175:7, 175:22, 176:4, 176:5,176:16, 176:18, 176:20,177:8, 177:24, 178:2, 179:9,181:2, 181:3, 181:9, 181:12,181:22, 181:23, 181:24,181:25, 182:4, 182:7, 182:9,182:11, 182:15, 182:24,183:8, 183:11, 187:1, 187:2,187:17, 187:25, 188:8,188:9, 188:24, 189:6, 191:5,191:10, 191:18, 192:15,192:16, 192:17, 193:24,197:20, 201:16, 210:4
upper - 170:8upwards - 119:20uses - 123:24utility - 128:7, 137:12
Vvacuum - 175:7, 175:24,
176:3, 176:6, 176:11,176:20, 177:18, 181:2,181:4, 181:11, 183:11,183:16, 193:22, 205:25
vacuuming - 196:5Vacuums - 183:11vacuums - 183:14value - 119:17varying - 126:19vehicle - 123:23verify - 128:12, 146:12version - 202:6Versus - 205:8versus - 206:6vertical - 133:8vertically - 114:18vessel - 111: 18, 111:2 1,
111:24, 112:20, 113:16,113:24, 114:8, 114:20,114:25, 115:23, 116:1,116:9, 116:14, 117:5, 118:6,118:8, 118:18, 118:22,119:12, 120:3, 120:7,120:20, 121:6, 124:12,127:8, 127:16, 132:6,132:10, 134:4, 134:11,146:19, 146:24, 147:2,156:17, 162:5, 170:5, 170:7,170:12Vho- 154:7
m a
UVhs - 185:3vice - 123:3, 137:13,
137:14vice-president - 123:3,
137:13, 137:14Video - 179:24video - 126:1, 178:13,
178:15, 178:23, 179:2,180:2, 180:3, 182:20,187:20, 189:14videoing - 189:12.videotapes - 125:9, 138:3,
138:24, 140:17, 143:14,191 :23, 192:1view -115:22, 117:19,
134:13, 167:4, 184:12,185:17, 195:3, 205:11viewed - 138:2, 178:13,
178:23, 184:16views - 144:3violet - 118:3violet-colored - 118:3Virginia - 135:3visual - 142:2, 143:3,
143:11voice - 114:14Volume - 104:9volume - 164:13
wwait - 140:16waiting - 185:14wall - 114:4, 115:3, 120:2,
120:5Walter- 106:13wand - 181:1, 181:25,
182:13wants - 166:13warm - 116:14washer - 174:23, 180:25,
182:14, 183:18washers - 191:8Washington - 104:15,
104:18, 104:22, 105:3, 109:4waste - 173:7watch - 171:22, 210:1watching - 184:20water - 109:9, 118:8,
119:11, 134:17, 135:9,176:19, 176:20, 178:6,178:9, 178:11, 181:1, 181:3,181:11, 181:12, 181:24,182:6, 182:7, 182:12,182:15, 193:16, 193:18,193:25, 194:3, 194:5,194:10, 196:9, 206:3, 209:2waving - 188:16wedge - 116:15wedged - 187:2, 188:3weep - 128:3, 166:6,
170:11, 175:23, 176:5,176:17, 177:10, 178:16,180:10, 180:11, 181:3,181:16, 181:17, 181:23,182:24, 183:9, 183:25,184:17, 185:21, 186:22,188:10, 202:8, 202:12Weep - 181:18weld - 112:21, 113:23,
114:19, 116:2, 116:15,117:7, 117:9, 119:19welding -119:14welds -116:8Western -104:2white -128:3, 166:3, 166:5whole -115:5, 172:16,
197:19Wilcox- 109:9,154:9wire -124-21
Wise - 104:20, 109:24,115:18,116:25,117:20,129:4, 130:16, 130:17,130:20, 142:6, 142:7,142:23,149:13,149:15,149:19,150:23,151:9,152:7, 154:18, 156:1, 156:8,159:21, 160:5, 160:16,161 :23, 161:25, 164:22,165:6, 166:10, 166:12,166:19, 166:23, 167:10,168:7, 168:20, 211:6wish - 209:22withdraw - 160:7Witness - 169:23, 175:13witness - 106:4, 106:5,
106:7, 107:2, 115:22, 153:8,166:15, 167:9, 168:18,168:22, 172:3, 172:6,199:10, 208:2witnesses - 209:9word - 193:17, 194:9,
196:20words -111: 18, 113:16,
124:3, 139:20, 146:12,206:12workers - 174:4worried - 124:19worthless - 138:21written - 125:6, 14 1:11,
16 1:4
yyear -141:7, 141:13,
164:14, 164:16, 196:13,197:12, 200:20, 203:9,203:11
years - 108:13, 128:10,140:13, 142:4, 173:10
York - 104:14yourself - 134:25, 165:3yourselves - 171:20,
209:12, 209:24
m