Day 093 - 28 Feb 95 - Page 64
1 A. I would not use the word "lapses".
2
3 Q. Faults?
4 A. Faults?
5
6 Q. Faults?
7 A. No, I would not use the term "faults". I would use
8 "non-conformities", yes, I would use that.
9
10 Q. Failing to reach the standard that is laid down in some
11 way, not conforming to the standards that are set?
12 A. It is conformance to the standards. This is prior to
13 start up. So, if they saw a problem, they will fix it. If
14 it is during operations, the inspector will not allow it to
15 operate. So, it is not, I would not call it "lapses" or a
16 "fault".
17
18 Q. So if there is a minor, even a minor, score that would stop
19 that area or piece of equipment or that process? It would
20 just stop the whole process, would it?
21 A. No.
22
23 Q. Would it have to be critical to do that?
24 A. No, Well, it is on the opinion of the inspector. If he
25 sees something critical -- let us say he happens to see a
26 metal going through the plant, he will stop that and make
27 sure that, where it came from, if the metal detectors are
28 working properly.
29
30 Q. These on this page are all noughts, there are no problems
31 at all identified?
32 A. That is what it shows, that is correct.
33
34 Q. So really it is up to the inspector on the ground whether
35 the process continues or stops.
36 A. That is correct. He has the authority to stop the line
37 and he has the authority to even stop the entire facility,
38 to shut it down.
39
40 Q. Have you visited Tysons plant in Nashville?
41 A. Absolutely.
42
43 Q. How many times?
44 A. I cannot -- let me make a rough estimate.
45
46 Q. Approximately?
47 A. Probably 15 to 20 times.
48
49 Q. Have you ever seen inspectors say: "This is unacceptable;
50 stop this, stop this line"?
51 A. No, I have not.
52
53 Q. "Stop this procedure"?
54 A. No, I have not.
55
56 Q. "Close everything"?
57 A. No, I have not.
58
59 Q. No. So, if something though was in the critical column,
60 which is the maximum non-conformity with the rules?
