ML20033A937
| ML20033A937 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 11/22/1981 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| ISSUANCES-OL, NUDOCS 8111300186 | |
| Download: ML20033A937 (66) | |
Text
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"/'O NUC*J.AR RIGULATORY COMICSSOCN Sg
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ATOMIC SAFETY AND LICENSING BOARD In the.%t:::m: cf:
UNION ELECTRIC COMPANY DCCKET NO. STN 50-483-OL (Callaway Unit No. 1)
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DATE:
November 22, 1981 PAm:
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St. Louis. Missouri
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UNITED STATES OF AMERICA O
2 NUCLEAR REGULATORY COMMISSIC;I 3
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD O
4
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x In the matter of:
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UNION ELECTRIC COMPANY Docket No. STN 50-483 OL R
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(Callaway Unit No. 1) n 8
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_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x d
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Jef erson Room B 10 Stouffer's Riverfront Inn j
jj St. Louis, Missouri S
Sunday, November 22, 1981 d
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The hearing in the above-entitled matter was E
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reconvend at 9:00 a.m.,
pursuant to adjournment.
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BEFORE:
a 16 JAMES GLEASON, Chairman, Atomic Safety & Licensing Board.
17 b
18 GLENN O.
BRIGHT, Member.
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JERRY R.
KLINE, Member.
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i 11 ALDERSON REPORTING COMPANY. INC.
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APPEARANCES:
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2 THOMAS BAXTER, Esq.
RICHARD GALEN, Esq.
3 Shaw, Pittman, Potts & Trowbridge
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1800 M Street, N.W.
4 Washington, D.C.
5 y
-and-E' 6
JOSEPH E.
BIRK, Esq.
E General Counsel's Office R
7 Union Electric Company E
1901 Gratiot Street 8
8 a
St. Louis, Missouri, d
Appearing on beh&lf of the Applicant.
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5 KAY DREY f
St. Louis, Missouri, d
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Appearing on behalf of the Joint Intervenors.
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ROY LESSY, Esq.
ROBERT G.
PERLIS, Esq.
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Office of the Executive Legal Director y
15 Nuclear Regulatory Commission s
Washington, D.C.
- 20555,
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Appearing on behalf of the Staff.
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ALDERSON REPORTING COMPANY, INC.
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C0NTENTS A
WITNESS DIRlrf CROSS REDIRECT RECRCGS V.DIPE BOMD 3
Donald F. Schnell )
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Bernard L. Meyers )
John W. Fisher
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Roger G. Slutter
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Eugene W. 'Iharras
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6 By Ms. Drey 1106
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By Mr. Galen 1128 7
By Ms. Drey 114c n[
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EXHIBIT NO.
FOR IDENTIFICATION IN EVIDENCE REJECTED
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Joint Intervenors No. 25 1120 1120 Joint Intervenors No. 26 1146 1146 I0
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Joint Intervenors No. 27 1147 1148 d
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$i 18 F."
19 8n 20 21 22 23,
24 25 ;
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ALDERSON REPORTING COMPANY, INC.
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[RQQEEDIEGS 2
(9:05 a.m.)
3 JUDGE GLEASON:
Let us proceed, please.
O 4
We are starting in this session, as indicated last -
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night, at the exercise of the presiding officer's authority to, ir e
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an attempt to have this proceeding proceed at a faster pace than R
7 it has in the past, we will go until 12:00 and conclude the E
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testimony of Mr. Fisher and Mr. Slutter at that time, and make d
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such other decisions that have to be made at that time, io 10 So, Mrs. Drey, please proceed.
_E 11 Whereupon, a
I 12 DONALD P.
SCHNELL
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13 BERNARD L. MEYERS m
5 14 JOHN U. FISHER
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15 ROGER G.
SLUTTER
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EUGENE W. THOMAS,
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18 the witnesses on the stand at the time of recess, having been P
19 previously duly sworn by the Chairman, resumed the stand and were n
20 further examined and testified as follows:
2I MS. DREY:
I understand that this time between now and
(])
noon is for me to conclude my questions of Doctors Fisher and 22 23 Slutter.
Is that right?
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24 JUDGE GLEASON:
That is correct.
25 MS. DREY:
I would like to request sone time so I can i
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get organized.
I know it's my time.
I know I have three hours 2
and I need some time to organize at this tine.
3 JUDGE GLEASON:
liow much time are you talking about, 4
Mrs. Drey?
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MS. DREY:
Ten minutes, I think, maybe twenty.
9 6R JUDGE GLEASON:
Ue will stand in recess for ten minutes, R
7 (A recess was taken.)
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JUDGE GLEASON:
Ms. Drey, how much more time are you d
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going to take?
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MS. DREY:
About five minutes.
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II JUDGE GLEASON:
Because you are only going to have a 3
f 12 half hour to ask questions.
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13 5
MS. DREY:
What time is it?
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I4 JUDGE GLEASON:
11:30.
$j 15 (Pause.)
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E I0 MS. DREY:
I'm ready.
A I7 JUDGE GLEASON:
On the record, please, su 3
18 Presumably we are ready to begin and the reporter will P
"g 19 record the time, please.
n 20 (The time recorded is 11: 33 a.m. )
2I JUDGE GLEASON:
I feel a responsibility to make some
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22 comments at this time in the record, and the time of my comments i
l 23 f will not be charged to Mrs. Drey or any other party.
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24 As I have indicated, it is the responsibility of the 25 presiding officer to take necessary action to avoid unnecessary f
ALDERSON REPORTING COMPANY, INC.
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1 delays in the conduct of these proceedings and to expedite the GV 2
proceedings, keeping in mind the necessity of having developed an 3
adequate record.
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It is the Chairman's judgment that there has been an e
5 unnecessary delay.
He have spent untold minutes of hearing time R9 3
6 on procedural matters, time which should have been utilized for 8
7l the taking of testimony,that has been utilized instead on questior s a
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concerning the admissibility of documents.
There have been untold d
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minutes on proper procedures which should be followed in a hearing z
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5 11 other procedural matters which, in the judgment of the Chair we u
j 12 felt was necessary to assure fairness to all parties.
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13 However, we have spent a considerable period of time m
5 14 on the chemistry and physical properties of various welds, welding 15 techniques, function: of various items and equipment.
There has j
16 been a considerable amount of time on forces and stresses involved, w
N 17 in the ' physics of these pieces of equipment and, as a consequence,
$w 18 the witnesses have been scheduled and rescheduled.
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There have been continuous delays in asking questions, n
20 requesting repetition of answers, apparently in order for the 21 Joint Intervenors' representative to write down what appears to
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22 be a word-for-word account of the responses and all of this 23 despite the Chair making arrangements for -- and probably against e
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24 f the Commission procedures -- for the Joint Intervenors' represen-t 25 '
tative to duplicate the Chairman's copy of the transcript of these ALDERSON REPORTING COMPANY, INC.
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proceedings on the following day.
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2 We are now into our fourth day on this Contention.
The 3
same panel of witnesses are on, except for Mr. Parikh, who had 4
to leave the country on a vacation that had been scheduled for g
5 some time.
I do believe the Board has been very tolerant in 0
6 allowing -- in responding to Mrs. Drey's requests for consideraticin R
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and based on her: presumed inexperience in these proceedings we a
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have delayed starting times on several occasions and have taken d
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9 a rather liberal period noon-day recess in order to allow icg 10 additional time to prepare for questions, and we have had two 11 witnesses on from Lehigh University for these past four days.
3
- j 12 The request was made by the Applicant's attorney yester-()
13 day morning that it was necessary for those witnesses, in order z
5 14 for those witnesses to return to their other responsibilities 5
2 15 that they have in connection with the University, the request 5
g' 16 was made for Mrs. Drey to try to accommodate their schedule i
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problems and to direct the questions with respect to those two N
18 witnesses.
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19 It appears to the Chair that as ' consultants to the 5
20 Applicants they have been asked questions as to what their 21 responsibilities were, what the tests were that they conducted, I
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22 how they were conducted, what were the results of those test, 23,
and what was the relationship to the parties.
And with respect
(]J 24I to the new tests or the tests that they had indicated yesterday N
25 ll that occurred in 1973, they were asked the same type of questions.
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ALDERSON REPORTING COMPANY,INC.
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So as I conclude with where I started, I think there has 2
been an unnecessary delay.
Mrs. Drey will now have a half-hour 3
from this time to finish her questions of these two witnesses.
4 There will be a limited period of time for redirect and, keeping g
5 in mind that probably the same amount of time will be allowed 9
j 6
Mrs. Drey for cross examination with respect to redirect, and R
7 then we will conclude for today.
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I will say further that the Board intends to have the dd 9
issue of embedded plates concluded by the time we recess these ie 10 hearings on Tuesday afternoon.
Hopefully, it will be before j
11 then, but in all events it will be by that time.
So we are 3
g 12 putting the parties on notice of that.
5
()j 13 Secondly, I do want to say, because I don't think I
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14 have said it on the record before, the hearings that take place s=
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y 16 Soldiers' Memorial Building and the time will be at 9:00, as it w
d 17 has been on this one.
5 18 All right, Mrs. Drey, you may start, please.
5 l
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19 (The time recorded is 11:40 a.m.)
1 5
EXXXX 20 CROSS EXAMINATION - Resumed 21 BY MS. DREY:
()
22 Q
Dr. Fisher or Dr. Slutter, would you please tell mehow 23 A a welder repairs a manual weld?
()
24 A
(NITNESS FISHER)
Yes, ma'am.
Generally, if a defective 25,
-- or deficient weld is identified before a repair can be started L
11 h
ALDERSON REPORTING COMPANY, INC.
1:6 1107 l
1 there has to be an explicit definition of what the discontinuity 2
that is to be dealt with is.
3 For example, if there is a crack, it must be completely O
4 removed and gouged out and that removed weld metal replaced.
If e
5 there are insufficient weld profiles, then an additional weld 3
6 bead and pass can be made to increase the size of the weldment to R
7 the size desired and other cohparable combinations.
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Q
.That's fine.
Where do you find that in the code, please?
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A There are, in the code, under workmanship --
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3 11
-- under Section 3.7, deals with corrections to weldments.
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12 Q
What part deals with a crack, please?
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Section 3.7.2.4.
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14 Q
And insufficient weld profile?
E 15 A
Well, that is a simple correction -- insufficient
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It is just the e
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18 Q
What about overlap?
P; 19 A
overlap is dealt with in Section 3.7 -- 3.7.2.1.
5 20 0
3.7.2. --
21 A
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22 Q
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Undersize?
23 A
You just asked me that question prior to that Mrs.
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Drey.
25 ;f Q
Is that insufficient weld profile?
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A Yes, ma'am.
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2 Q
The weld profile is not this part of the weld (indica-3 ting)?
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4 A
Profile is the complete configuration of the weld.
There e
5 are excessive convexity or concavity in the weld.
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6 Q
That's right.
That's what I thought was weld profile.
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A' No, ma.'am.
The profile is the total profile of the s
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9 Q
What do you call excessive convexity?
Where would I 7:
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j 11 A
That is dealt with, again, in Section 3.7 on corrections.
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12 Q
In what section, with what paragraph?
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Subparagraph?
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Right.
2 15 A
Convexity is dealt with in 3.7.2.1, the same technique w=
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d 17 excess weld metal and the concavity is dealt with in 3.7.2.2, 5
18 which also deals with comparable additions of undersize or under-
=H 19 cutting.
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3.7.2.2 deals with concavity and undercutting?
Is 21 that what you're saying?
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22 A
Yes, ma'am.
23 Q
Thank you.
(])
24 A
And undersize weld.
25 Q
And undersize?
AL.DERSON REPORTING COMPANY, INC.
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1 A
Yes, ma'am.
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Q Thank you.
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2 How does a welder repair a machine weld?
3 A
A welder -- he does not repair the machine weld.
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4 Our Section 4.28, dealing with -- 4.26 -- let me -- Part F, 5
g dealing with stud welding, spells out what the contractor may, 9
6 as his option, do if he desires to add manual welds to a machine R
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weld.
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8 A contractor has that option.
He may elect not to d
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do that because it may be more expensive to manually weld a zo h
10 machine weld than it is to knock it off and weld a new one on.
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II So there are twc options that he may elect to take, 3
g 12 and it would be an economic decision.
c f(,h)j Q
May I ask you, please, to look at a copy of NRC a
13 l
14 Inspection Report No. 80-14, which was filed with the NFC Staff
$j 15 experts' prefiled testimony.
Do you have it?
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E 10 A
Yes, ma'am.
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I7 Q
All right.
Would you please look in there at the x
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18 letter dated June 10, 1980, which would be the page right E"
19 8
before the detailed procedure for test program.
n 20 MR. BAXTER:
Is it on Cives stationery?
2I MS. DREY:
It's a letter from Ted Totten, project 22
(}
manager of Cives, to Bechtel Power Corporation, attention Mr.
23 '
Paul Divijak.
I'm sorry, I guess I should have said Cives.
T 24
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WITNESS FISHER:
Yes, ma'am, I see the letter.
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ALDERSON REPORTING COMPANY. INC.
1111 2-2 1
BY MS. DREY:
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2 Q
Have you ever seen that letter before?
3 A
(Witness Fisher)
No, ma'am.
(_)
4 0
Would you please take a few minutes to read it.
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Yes, ma'am.
3 6
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Q Would you turn now, please -- oh, okay.
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Would you please turn to Joint Intervenors Exhibit
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8 No. 17?
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A Yes, ma'am.
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Q And would you please explain to me how a -- well, E
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just explain that section, please.
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[] l A
I'm not sure I understand what you mean.
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Q Section 4.29.3, in Joint Intervenors Exhibit No. 17.
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A Oh, yes, ma'am.
Well, this letter, which cites 2
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three possible corrective actions that the manufacturer is
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16 going to carry out -- the one that specifically is referred to d
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in 4.29.3 says:
18
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"If there is an incomplete weld flash" -- be says 19 weld 360 degree fillet, he means a weld flash --
around the 20 machine-welded stud, that if he exercised that repair, he would 21 add at least a 5/16th inch minimum fillet weld in place of rs 22
(_)
the missing flash.
So he would have that as a possible option.
23 If he wanted to, he could bring a welder in using this shielded r"
24
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metal arc process and execute a manual weld to replace that 25 ;
j flash.
ALDERSON REPORTING COMPANY. INC.
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Q Okay. Non so he -- does it indicate then what he r~)/
2 must do, or can he just leave the -- can he leave the machine i
3 welded stud that lacks a 360 degree flash -- he could just leave
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4 it that way; is that what you're saying when you say he may do something?
9 3
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A Well, he has three options which he's citing as n
R 7
A, B,
and C. He can just leave it as it is and bend-test it, n9 8
M and if the bend test performs satisfactorily, he will leave it d
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E-as it is.
H 10 If he elects not to bend-test it, he will add this
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fillet, which must extend at least 3/8ths of an inch beyond d
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wherever the deficiency is.
O' ' S 13 Or the third, he may just say, "I'm going to replace E
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it."
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So those are the three options.
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Q Is there some way a person could tell if he d
17 bend-tested it?
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Well, it would be deformed on that 15 degree
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angle.
Visually he would be able to see that.
20 (Pause.)
21 JUDGE GLEASON:
Ms. Drey --
()
MS. DREY:
May I ask Mr. Schnell a question?
23l JUDGE GLEASON:
Sure.
)
BY MS. DREY:
25 ;
j Q
Would you please tell me if you notified the l
l ALDERSON REPORTING COMPANY, INC.
1113 2-4 I
Nuclear Regulatory Commission of your -- of the fact that you 2
had asked Lehigh University to perforn tests on machine-welded 3
plates prior to their performing the test?
(,
k--)
4 I mean that you were going to do it in the summer 5
j of 1978.
Did you notify the NRC of your intention?
9 j
6 A
(Witness Schnell)
I don't recall, ma'am.
It R
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would not have been necessary for us to notify the NRC of that s
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eventuality, since it was a test-that did not at that time 6
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have any implications related to the safety of the plant.
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10 By that I mean if there is a question that is
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it's not necessary to inform the Nuclear Regulatory Commission
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E I4 the question is -- determines that it is a safety-related j
15 matter.
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I0 So what I'm trying to say is the purpose of the A
test was to determine whether we had a"significant problem.
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M 18 Q
Did you say the rdason you took the tests -- I
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couldn' t tell yesterday, and-I don't want to spend the time on n
20 that -- but did you say the reason you had the tests done, 21 one cf the reasons you gave was because you need -- some of 22
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the workers needed to bend the studs in order to fit them in 23 l around reinforcing bars?
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A That's right.
25 l Q
Was that a problem that was anything of significance, b
ALDERSON REPORTING COMPANY, INC.
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I that problem of having to bend the studs or anything?
'2 A
No, but the -- we wanted assurance that if studs 3
had been bent as much as 45 degrees during that process, that
(_)
4 it did not have any safety implications or it did not deteriorate 5
-the ability of the plate to provide its design function.
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?
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6 Q
Were you somebody who would have known about all R
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that, the decision-making and so forth at that time?
I mean M
2 8
M were you aware of this problem before?
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'9 A
Yes, ma'am.
It was brought up on a quality oF 10 j
, assurance surveillance report, and I authorized the test.
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5 II Q
okay.
Who makes the decision of whether or not 3
it's a significant problem, this business of bending studs?
4
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13 s,/ g Who would have made that determination?
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I4 A
We normally rely on our designer, our lead
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architect-engineer, to provide us technical information
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y 16 relative to such problems.
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I7 Q
Do you remember who at the time from Bechtel
=
18 would have decided whether this business cf bending in order P"
I9
~8 to get a plate in and around the rebar was significant or not?
n 20 Do you know who at that time would have made that kind of 21; decision, or do you remember if Bechtel was even consulted at f')
that time about this problem?
s-23k A
Oh, yes, of course they were consulted.
As a
)
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'25 -
Q,
Did they decide whether this was a problem or not,
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1115 2-63 I
a significant problem, significant enough to hire Lehigh
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2 University Laboratory?
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A As I tri i to state yesterday, Mrs. Drey, we wanted
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to be -- we wanted to be as absolute as possible with this s
5 eg question so that there would'be sufficient evidence to demonstrate a
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that bending of such studs was not a significant problem, and
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7 that's why we authorized the test.
n 8
8 a
Q May I ask who decides when to send a 50.55 (e) do 9
g report to the NRC?
o6 10 A
That can be done either by the cuality assurance
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manager or the engineering manager at Union Electric.
d 12 g
Q The quality assurance manager at Union Electric ks) 5 13 j
or at Daniel?
E 14 A
Or the engineering manager.
And the criteria e
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j are explicitly called out in the regulations for when such an 16 event requires reporting.
6 17 a
Q Would you have been in a position at that time to z
d 18 have known whether or not a 50.55 (e) report would have been
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called for in this situation, or they would just have done it 20 without notifying you?
I don't know what your position was.
21 A
I was engineering manager then, and normally such 22 O
reports -- I am aware e.
.t.-. when they are reported.
23,
Q Dr. Mel A
,.ld you know, does this business
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of having to bend the studs to fit the plates around congested 25 areas -- does that sound like something you might want to l
ALDERSON REPORTING COMPANY. INC.
1116 2-7 1
suggest to the architect-engineer?
I mean would Bechtel want (3
to suggest to its client that it report this kind of problem 3
to the NRC or not?
O s/
4 A
(Uitness Meyers)
We suggest to our client to e
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report those issues that we feel have a safety significance.
3 6
As we pointed out festerday, I think Dr. Fisher pointed out m
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yesterday, calculations using mathematical models indicated n
2 8
M that this was not of safety significance.
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However, the mathematical model had to be extrapolated eH 10 i
from physical tests that had gone to 30 degrees.
We agreed with
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Union Electric that the prudent and intelligent thing to do at d
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tais point in time would be to document by physical tests
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that the xtrapolation was valid.
The judgmen~t at the time E
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was that bending was not a significtnt problem, and need not --
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Q That the workers sometime had to do that?
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16 A
Yes, ma'am.
17 g
Q Would you have been in a position at that time to 18 have made the decision of whether or not this was a significant
=
19 g
problem in Bechtel?
20 A
It was in 197--
21 Q
I think they weren't quite sure when the tests S
22 x_/
were.
In the summer of '78.
23 A
In the summer of ' 78, I was the assistant project
('S 24 !
()
l manager for the SNUPPS project.
25li Q
For Bechtel?
ALDERSON REPORTING COMPANY, INC.
1117 2-8
' l s '
A Yes.
()
2 Q
Who would have made that decision?
Would you have 3
made a decision or would the project -- like when to send in a A(/
4
- 50. 5 5 (e), or didn't Bechtel participate in that kind of decision?
A Yes, they did, and usually the decision is made P
3 6
by the lead engineering person in the area of the problem.
=
8y Q
I'd like to ask one of the gentlemen from Lehigh N
8 8
University, would you think that would be a problem if you had a
d o
9 j
to take a plate and perhaps bend the studs to f1t it around::
oH 10 j
If you bent the studs more than 15 degrees, we're talking about
=
E 11 g
machine-welded.
Might one of the studs fall off?
'd 12 3
A (Uitness Fisher)
No, ma'am.
As I tried to 5
13
() g
(-
indicate yesterday, for the Board on the questions that were E
14 y
raised, the additional bend angle, if you have sound studs x
9 15 g
that have already been demonstrated to be sound, with a 15 16 degree change, there is little likelihood of --
6 17 x
Q What if they are not sound?
x M
18 A
But they would have been demonstrated to be sound
=
19 g
if they had bent through any angle at all.
20 Q
Do you know whether they were doing testing at 21 Cives at the time that would have been manufactured?
22 O,,
A I'm fairly certain they would.
It would have 23 f been the routine procedure in the fabrication process that 24 l
h_)-
j was discussed yesterday.
25 )'!
Q I have in front of me a set of documents.
The u
l ALDERSON REPORTING COMPANY. INC.
1113 2-9 I
first one is a letter from Union Electric signed by John K.
q 2
Bryan, dated May 1, 1978 to Jim Keppler.
The date of the --
3 number of the. letter is UL NRC 256, entitled " Submittal
()
4 Date, Extension, Interim Report on Bending of Studs, Callaway
'lant, Unit No.
1."
3 6
On April 4, 1978, we furnished Mr.
E.
R.
Schwebein e
R 7
verbal notification of a significant deficiency regarding n9 8
M the bending of studs on embeds in order to fit the embed d
6 9
between rebar and some of the complex structures.
j oH 10 j
Next letter, June 16, 1978.
It's from Bob
=
E 11 g
Heischman of the NRC, Region III, to John Bryan, Vice d
12 3
President, Nuclear:
C' E
13 g
" Gentlemen:
Thank you for your interim report E
14 y
dated May 1, 1978.
Pursuant to 10 CFR 50.55(e) regarding 9
15 j
the bending of studs on embedments.
We will review your T
16 y
final report on this matter upon receipt."
d 17 d
February 2, 1979.
Heischman says to John Bryan:
Ew 18 "Thank you for your final report dated January
=s E
19 g
12, 1979, pursuant to 10 CFR 50.55 (e) regarding acceptability 20 of embedded plates with bent anchor studs.
We are in the 21 process of evaluating your final report and attached test 22 O.
program."
end 2 (3
24
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a 25
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l t
ALDERSON REPORTING COMPANY, INC.
JWBoach 1119 SbNDAY I
MS. DREY:
Mr. Chairman, I would like to offer r~%
2 these three letters into evidence as a Joint Intervenor's 3
Exhibit.
O 4
JUDGE GLEASON.
Have you distributed copies?
e 5
(Documents are distributed.)
An 8
6 MR. GALEN:
Mr. Chairman, we are giving our copy e
R 7
to the witnesses.
Is that all right?
Nj 8
JUDGE GLEASON:
Yeu.
That's fine.
d
=
9 BY MS. DREY:
i 10 Q
May I ask if this looks like an official set of E
5 11 letters --
B d
12 JUDGE GLEASON:
Excuse me a minute.
You have
=$
r(,). j 13 asked, first of all, to have-this admitted into evidence, and
=
l 14 I would like to hear from the attorneys for the parties.
$j 15 MR. GALEN:
Mr. Chairman, we don't belie've any of
=
y 16 the questioning on this matter is relevant, but we have no w
objection to the document.
g 17 5 5
18 JUDGE GLEASON:
Mr. Lessy?
?
E 19 MR. LESSY:
Same position as the Applicant.
A 20 JUDGE GLEASON:
The letters will be admitted into 21 evidence as Joint Intervenor's Exhibit No. 25.
()
22 23,
(])
24 25,
h ALDERSON REPORTING COMPANY. INC.
i
) 1:.'0 3-2 jwb 1
(The document referred to was
(~J h
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2 marked as Joint Intervenor 's 3
Exhibit No. 25 for identification 4
and received in evidence.)
e 5
JUDGE GLEASON:
Ask your questions. Mrs. Drey.
Rn d
6 BY MS. DREY:
e R
8 7
Q Mr. Bryan, have you ever seen any of these letters n
E 8
before?
Do you remember?
N d
=
9 A
(Witness Schnell)
Did you mean "Mr. Schnell"?
i h
10 0
Irmean, Mr. Schnell.
I'm sorry.
E 5
11 A
Yes, ma'am, I think I probably have seen them J
12 before.
E em c
(,) d 13 Q
Did you perhaps forget that you had sent a 50.55 (e) ?
E l
14 A
Mrs. Drey, this demonstrates that my memory is 2
15 imperfect over such a time span; yes.
5 16 Q
What about you, Dr. Meyers?
Would you have seen j
a g
17 i such a letter?
5 M
18 A
(Witness Meyers)
Probably not.
5 E
19 Q
Do you remember -- Now you don't think you did see 20 one?
Right?
21 A
Well, I don't remember --
({}
22 Q
As Assistant Project Manager, you would not have 23 known that a 50.55(e) Significant Deficiency Report was filed
(])
24 about the bending of studs?
25,
A I would nave known.
I may --
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ALDERSON REPORTING COMPANY. INC.
1121 3-3 jwb i
Q But you forgot, then, also?
O A
Yes, ma'am.
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2 3
0 I see.
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4 MS. DREY:
Okay, it is now -- How much time do I e
5 have left, sir?
E N
8 6
JUDGE GLEASON:
You have six minutes.
e f7 MS. DREY:
Okay, I will start reading something.
8 It is now six minutes before the time when I have to quit.
At--
d d
9 I would like to spend my final few minutes for two purposes:
i O
jo One, to offer into evidence my packet of remaining a
3 5
11 questions of these gentlemen that I would have asked if I had
's 6
12 had time, I mean specifically of the two gentlemen -- to the 3
()
13 two gentlemen from Lehigh University.
s 14 Secondly, to ask if the Chairman will consider w
b 15 asking Union Electric to invite a Daniel employee and/or a 16 SNUPPS employee who would have personal knowledge of the embed
.s
'A d
17,
question so that we can have a full complement on the embe.d E
18 panel.
I would be perfectly happy to -- I could -- we could
=H 19 change the schedule in any way you want.
It would be 2ine.
8e 20 I don't know, maybe you've sent home the piping experts, but 21 even if there could be somebody from Daniel who would have 22 first-hand information, that would be very helpful for our
}
23,
contention which is about quality assuran'ce.
(])
24f You announced yesterday afternoon late that we h
2; ll would have this special session this morning -- I don't mean II k
f ALDERSON REPORTING COMPANY. INC.
3-4 jwb I
1
" late" -- and really I first wanted to say that I would like O
(/
2 the record to show that I personally am extremely grateful 3
for the patience, understanding, f airnes s, and even gentleness 4
with which Mr. Gleason has conducted this hearing.
e 5
I would now like to offer into evidence a collection En d
6 of questions I have not yet had a chance to ask.
I realize e
R R
7 that I spent virtually the entire time allotted to me this Nj 8
morning trying to make certain that the questions I already d
d 9
know I need to ask were written down properly, so that I i
Og 10 have used very little of my allotted three hours to ask E
E 11 questions of these two gentlemen.
That was a gamble I realized
<a 12 I had to take.
J E
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13 I also want to say that if you are concerned about m
j 14 whether or not putt _ng a collection of questions on various 2
15 shapes of paper, and handwriting, and so on, would cause any N
y 16 kind of a problem for the record, I would like to say that --
M y
17 ;
iPause.)
E 1
5 18 JUDGE GLEASON:
Mrs. Drey, may I ask a question?
=
5 e
[
19 Are the questions in a format that the Reporter can type, or 20 put them in the record?
That is the only question I have.
21 MS. DREY:
I would be happy to show them to you.
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22 JUDGE GLEASON:
All right.
\\_/
23,
(Ms. Drey hands a file folder to the Board.)
24 MS. DREY:
These are the enes I was hoping to do
{}
25 this morning.
I pulled out the ones -- I tried to give some s
l ALDERSON REPORTING COMPANY,INC.
1123 3-3 jwb 1?
priority so that I could ask -- and I'll show them to you.
O 2
MR. BAXTER:
Mr. Chairman?
3 JUDGE GLEASON:
Yes?
/
4 MR. BAXTER:
I really don't think it's appropriate e
5 for them to be in the record.
I would not object to them E
N 6
being filed with the Board as a pleading is served on other o
R R
7 parties, but they are certainly not evidentiary in any sense s
8 8
of the word.
n d
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MS. DREY:
May I continue?
io 10 JUDGE GLEASON:
Yes, go ahead.
E 5
11 MS. DREY:
Or am I out of time?
<3 d
12 JUDGE GLEASON:
Go ahead.
3o
(,m) 13 MR. LESSY:
May I look over the Chairman's E
14 shoulder while she continues?
U=
2 15 JUDGE GLEASON:
Yes.
5 y
16 JUDGE GLEA9ON:
Go ahead, Mrs. Drey.
I A
d 17 MS. DREY:
I also have what I wanted to read at 5
l 18 the start and realized I couldn't do, but I would like to I
P E
19 say if -- and I can't find the notes that I had written out, A
20 I was trying to be very specific, and I did write this out, 21 and I can't lay my hands on it at this moment, because I'm
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22 taking things in an order that I hadn't planned to take them --
1 i
22 but I would like the record to show that I personally have no
(])
24 intention of participating in any appeal of the decision of J
25 '
this Board.
.l l
ALDERSON REPORTING COMPANY, INC.
l
1124 3-6 jwb 1
So that if it would make a difference whether or A
2 not you would find this a problem in the record, that I have 3
no intention of spending a single penny on any appeal, and I 4
paid entirely for -- have paid entirely out of my husband's g
5 pocket for this initial Licensing Board proceeding, and I will n.
3 6
not spend any money on any appeal, nor will my husband.
R 7
I also will not spend even five minutes of my time
~
j 8
on any appeal.
So the decision about the operating license, d
d 9
as far as I am concerned, lies with this Board.
Furthermore, ieg 10 I will be very firm in my -- or very strong in my recommenda-j 11 tion to the intervening organizations that they allow the 3
g 12 decision to rest with this Board.
=
[Ss) 13 I also then would like to say that as far as the m
=
5 14 other question is concerned about scheduling, and about
{
15 requesting that we have an opportunity to speak with some
=
j 16 people from Da iel and SNUPPS, that is very important to our M
d 17 contention.
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18 As I study this, I have many additional questions.
P h
19 It becomes more and more apparent that the decision to install n
20 potentially defective embeds may rest with Bechtel and Union 21 Electric, not with SNUPPS and not with the NRC and not with
()
Daniel.
And yet I, without being able to talk to anyone from 22 d
23 '
Daniel, or without being able to talk to anyone from SNUPPS,
()
24 f I do not know.
I have many questions that remain.
25 g I would also like to say that whether or not you r
l ALDERSON REPORTING COMPANY, INC.
1125 3-7 jwb 1
agree to accept this package of questions, which I would like -
,f").
v 2
to have asked the experts, if you 'do not accept this package 3
then I shall ask my friend -- I will hand -- you can hand O.
4 them back to me; I will hand them toL Vera Falk, my ' friend, e
5 and.ask -- her name isispelled F-a-1-k -- and ask that she h
6 give them to a typist to put into a legible form.-
R R
7 I will then -- I will neither delete nor add to
%l 8
that package of questions, and I will then write a cover d
d 9
letter to the Chairman and Members of the Nuclear. Regulatory b
10 Commission, and explain that these are questions that I would E
5 11 like to have asked; that I absolutely believe that the g
12 Chairman of this Panel has more than _ bent over backwards to h, 3j 13 be fair, and has been extremely patient.
And it is not your a
jl 14 fault, sir; it is my fault and my inexperience, and there is 2
15 no way there would be enough time for Kay Drey to ask all the j
16 questions that are apt to develop in her mind for two gentlemen, M
d 17 those two gentlemen, who know a good deal about welding and 18 embedded plates.
5 C
19 So that I realize that.
And so either this will R
20 end up in writing as part of the record of this proceeding --
21 of this hearing, rather, or it will go in one of the zillion 22 letters I send to the NRC.
And that 's all I have to say.
(])
23,
JUDGE GLEASON:
Thank you, Ms. Drey.
24 MS. DREY:
Did I go over my time, sir?
(}
JUDGE GLEASON:
Just right on it.
25 ;
I I
ALDERSON REPORTING COMPANY, INC.
1126 3-8 jwb I
MR. GALEN:
May I proceed with my redirect?
()<
t 2
JUDGE GLEASON:
Well, we have a request in front l
3 o f us.
Do you have a response to that. request?
Mr. Baxter Q#
1 4
has made a response, but would you like to --
5 g
MR. BAXTER: It j ust doesn ' t seem to me -- I don ' t 5
6 think it makes a substantive difference in terms of getting R
7 the questions before the Board, but I just think it should s
8 be in the form of a pleading.
The words that counsel say in d
9 this room is not evidentiary, and it does not take the form of z
O g
10 e xh ibits.
I do not feel that Mrs. Drey 's work product should, E
11 either.
B N
I2 I have no objection to the questions being provided 13 to the Board and going into the pleading file, just as all the z
5 14 other motions and responses have gone in in the past.
$j 15 As to the other request, of course Joint Inter-
=
j 16 venors did state that they were not going to call any witnesses A
h 17 in the case, and we have put the people on the panel that we
=
h I0 thought were appropriate and necessary to answer the allega-P "g
19 tions.
And I think that is our prerogative as the party with n
20 the burden of proof.
21 If the Board has concerns, I would hope that they
()
22,
would wait to consider those until after the examination of l
23 '
this panel has been completed, including our complete O
24l redirect.
25 JUDGE GLEASON:
Mr. Lessy?
y 2
ALDERSON REPORTING COMPANY,INC.
3-9 jwb 1127 MR. LESSY:
Do you want me to discuss both issues?
j
(
JUDGE GLEASON:
Yes.
2 3
MR. LESSY:
Okay.
On the first question, I would 4
have no objection to Mrs. Drey 's questions in the form a
5 submitted to the Board being submitted to the Board.
Of A
d 6
course it would not be an exhibit, because Mrs. Drey is not a e
7 witness subject to cross-examination.
So I guess I agree with 8
Mr. Baxter on that point.
d I
d 9
I would like, and perhaps Union Electric can i
j h
10 assist, to get a copy of those questions as presented to the 6
s Board, at some time, and I presume that Mr. Baxter would <B d 12 also like a copy. E ( ) h 13 I agree with Mr. Baxter's comments on the second E E 14 question presented by Mrs. Drey as to other possible additional a 2 15 witnesses. 5 3-16 JUDGE GLEASOM: Excuse me? I didn 't hear that. ~ A M' 17 MR. LESSY: As to the second question, I agree 1 E b 18 with Mr. Baxter's comntents with regard to that. = H [ 19 JUDGE GLEASON: All right. Well, we will make a A 20 decision with respect to that after we finish the redirect 21 and then cross-examination on the redirect. ) 22 Go ahead, Mr. Baxter -- or Mr. Galen, I'm sorry. ("J i u-l 23 ! MR. GALEN: Thank you, Mr. Chairman, t 25) ALDERSON REPORTING COMPANY. INC.
1128 3-10 jwb 1 REDIRECT EXAMINATION O 2 BY MR. GALEN: 3 Q Dr. Fisher, I understand that you have reviewed () 4 the transcript from yesterday's hearing, and that you have a e 5 correction to make to one item in your testimony. Would you A N 8 6 point that out? e R 8 7 A (Witness Fisher) Yes. On page 1096 --
- j 8
JUDGE GLEASON: Excuse me. I am very sorry and I d d 9 apologize, but would you repeat the question, please? Y 10 BY MR. GALEN: E 5 11 Q Dr. Fisher, I understand that you have reviewed <m d 12 the transcript from yesterday 's he ring, and that you have a z_ l (')s $ 13 correction to make to one item in your testimony. Would you = s-E E 14 point that out? N=j 15 MS. DREY: Excuse me? That was the oral testimony? = j 16 Is that right? A y 17 j MR. GALEN: That's correct, Mrs. Drey. E 5 18 WITNESS FISHER: Yes, sir. On page 1096, when =H } 19 responding to the field tests that were carried out in 1980, 5 20 I ir.dicated that we did not take the load to ultimate, and 21 cited Dr. Slutter, and misquoted the level of test. () 22 It should be: The test was carried up to about 23 15 percent above the expected -- maximum expected design load, () 24 l rather than about 15 percent "of" the maximum expected design i 25 ;l load. U I i ALDERSON REPORTING COMPANY, INC. ~.
1129 3-11 jwb 1 BY MR. GALEN: () 2 Q May I have that transcript back? 3 (Witness returns document to Mr. Galen.) ( 4 Dr. Fisher, on Thursday you were asked by Mr. Chackes, e 5 I believe it was on Thursday, to identify certain worst A N d 6 possible weld deviations. You listed, in descending order: o R R 7 Cracking, lack of fusion, and a gap in the weld fillet. Is N 8 8 that correct? m d d 9 A (Witness Fisher) That is correct. Y 10 0 When you were responding to his questions, were 3 5 11 your answers in general terms for all welding applications? <a d 12 Or were they specifically directed to the fillet-welded, such 3 (]) 13 as was used on '.he manually welded anchor rods? j 14 A I was speaking at that time in response to these 2 15 fillet welds that were.being made connecting the anchors to 5 y 16 the embedment plate. A 17 Q Might Uhe worst deviation be dif ferent icr other = 5 18 types of welding applications involving different materials, =s { 19 loadings, and structural configurations? E 20 A Yes. Discontinuities are a function not only of 21 the discontinuity, but such factors as the stress, and the 22 direction of the stress relative to the discontinuity, and {) end 23 the material characteristics to resist such disctntinuity. JWB (:)#3 24 25j b n il ALDERSON REPORTING COMPANY. INC.
14:1 mas:ar 1130 I Q Okay, Dr. Fisher, again focusing you in on the three 2 deviations which you did list on Thursday, that would be cracking, 3 lack of fusion and a gap in the weld fillet for manually-welded r 4 anchor rods. Did any of those dev:. cations exist in the manually-g 5 welded embeds which are at issue in this proceeding? 6 A None that I can see from any of the reported documents. R 7 None of those specific discontinuities were ever identified as s j 8
- existing, d
9 Q What was the nature of the most serious welding devia-zc g 10 tions on the manually-welded embedded plates? E j 11 A The primary deviations cited were undersize welds, either-3 j 12 the leg, horizontal or vertical leg, and the degree of undercut. () c 13 Q And were those the deviations that were analyzed in the z 5 14 Bechtel engineering analysis 3which is part of Applicant's Exhibit 2 15 number 4? w= g 16 A That is correct. M 17 1 Q Dr. Fisher, in Mrs. Drey's review -- her questioning = h 18 concerning some of the pages in Joint Intervenors Exhibit Number P { 19 12 -- that's the 610-page document referred to in the questioning 5 20 -- she had either you or Mr. Pari I can't recall, read off 21 certain other indications which existed in the welding for (]) manually-welded anchor rods and I would like you to tell us if 22 23 any of those indications is of any structural significance. I'll (]) just go through the ones that were mentioned. 24 25l The first one was arc strike. O h ALDERSON REPORTING COMPANY,INC.
4:2: mas 1131 l 1 A Arc strike occurs when welds are made in confined r) ( 2 regions such that the electrode creates an arc between the base 3 metal and the end of the electrode and in this particular s ) 4 application any arc strike would exist and occur in the base plate. e 5 An arc strike is not a significant discontinuity in a static n N h 6 load condition. It would have no impact upon the capacity of 7 these anchors. It would not affect either their tensile strength 8 nor shear capacity. d d 9 Q Dr. Fisher, let's consider overlap. i h 10 A Overlap occurred in these connections because of the E I 11 effects of gravity, because a fillet weld was being placed around <? d 12 a vertical anchor rod. Then there tends to be a slumping of the 3 () 13 weld profile from the effects of gravity and because of the heat E 14 input from the end of the electrode. This terde to pernait the Nz 2 15 metal to overlap or pour over and, of course, because it has not E I 16 heated the base metal, the solidification process does not A d 17 integrate the two metals together and creates an overlap. E M 18 Now that discontinuity is not significant in this 5 E 19 application and it was clearly demonstrated by the tests that we A 20 carried out in tension as well, so that overlap would not have 21 been a significant discontinuity for the attachment of these (]) 22 anchors to the base plates. 23, O Let's briefly consider weld splatter. (]) 24 A Again, weld splatter is in striking the arc. There is 25 the energy input and the electrical contact of ten results in a 4 ? I i ALDERSON REPORTING COMPANY, INC.
4:3 1132 I splattering of the metal. That generally will thendhposit itself 2 -- every weld creates weld splatter. Frequently the welder will 3 take a small tool and scrape it off. Again, in my view, this 4 does not create any significant discontinuity in the applications s 5 at hand. A 6 Q And, finally, f r. Fisher, an indication of porosity. G 7 A Porosity -- every weld has discontinuities and particu-M j 8 larly fillet welds. These types of gas pockets and porosity have dd 9 no major structural significance under static loading conditions. i O 10 By static I am speaking of -- to differentiate it between a El 11 fatigue type of condition where you apply many thousands or hun-3 y 12 dreds of thousands of cycles of load,.under those' cases it some-(~) 5 \\_/ y 13 times -- a cracked propagation develops from porosity. You can m i 14 have extreme porosity conditions and in fact, because you make 2 15 fillet welds and they have a root where you cannot see it at all, j 16 they are generally, if you dissect the weld you will find dis-w d 17 continuities near the root, and porosity now, in inspecting welds, E 18 the porosity that is tolerated is defined in the specification = 19 as fairly significant. l 5 t 20 One can have between twenty and forty percent porosity 21 without deteriorating the capacity of the weld relative to its . () 22 assumed design capacity. So porosity is not a significant factor 23 in dealing with essentially statically loaded systems, and by i () 24 statically-loaded that's not to indicate that this is not an 25, earthquake, because the generic term stated means that we are t ALDERSON REPORTING COMPANY, INC. i
4:4 1133 1 not repeating the load many times. We transform the loads, OkJ 2 whether they are applied in a dynamic manner into an equivalent 3 static load system. That's a general engineering principle. 4 Q Dr. Fisher, I would now-like to direct your attention 3 5 to the Cives inspection reports for machine-welded embeds, which j 6 is Joint Intervenors Exhibit Number 24. R d 7 1 don't think you need it in front of vou, but I would s j 8 like to focus in on that particular exhibit and also on the Daniel d [ 9 data package for both manually-and machine-welded embeds, which !g 10 is Joint Intervenors Exhibit Number 12. j 11 Yesterday Chairman Gleason asked you some questions 3
- j 12 concerning whether the information for the inspection of machine-
/^ C ()% y 13 welded embeds was better in one document or the other, and I = m i 14 believe you smid that they provided equal but incomplete informa-I j 15 tion on the condition of the studs on those machine-welded embeds. = y 16 Let me ask you this question to follow that up. Was the W d 17 information in the Cives inspection reports, Joint Intervenors 6c 18 Number 24, sufficient for the purposes of conducting the type of 3 P 19 g engineering analysis for machine-welded embeds that was performed M 20 by Bechtel in August 1977 and reported in Applicant's Exhibit 21 Number 4? (]) 22 A In my opinion, the examination that was carried out by 23 Cives was completely adequate for the engineering purposes for () 24 which it was used. In looking at the two quality control documents 25, -- and that's precisely what they are, quality control documents, L ALDERSON REPORTING COMPANY, INC.
4:5 1134 1 they are produced by technicians who have really for the most part b '/ 2 -- in the United States most technicians who carry out these 3 quality controls have no understanding of the significance of O/ 4 what they produce. e 5 The engineering evaluation shows clearly that the 9 j 6 frequency of machine-welded studs that were faulty and needed R 7 replacement or had a potential for failure was in the same order j 8 of magnitude in both reports, about less than one-tenth of a d q 9 percent. And in fact, the large number of studs that were tested z O g 10 in bend testing that then led to those failing to satisfy the g 11 bend test -- and neither document clearly defines the degree of B 12 what the failure was, because in the document that Mrs. Drey () 13 provided as the Intervenors Exhibit 17, on the inspection require- = m 5 14 ments for machine-weld, that document shows that in later years { 15 some of the things that were rejected according to the 1975 = g' 16 specification which was burst and such in the flash, those would w d 17 have been tolerated two years later. 5 y 18 So the profession recognized that likely some of those p 19 g connectors that were even shown as rejectable in applying 1975 5 20 and subsequent years would have been found acceptable. 21 In my view, these documents show that there is absolute-(]) ly no reason to question the adequacy of the machine-welded 22 23 embedments. They can clearly perform the function that daeywere i 1 () 24 intended to, and both documents substantiate that. 25d O Dr. Fisher, focusing now on the manually-welded embeds, E i f f ALDERSON REPORTING COMPANY, INC.
1135 4:o, I what is the significance of the limitation on weld deviations 2 which are listed in the ANS code whichbere reviewed in some of 3 the questions yesterday? O 4 A Well, the limitations such as the amount of undercut or 5 weld undersize have origins. They are intended to cover a wide 9 j 6 range of applications and, as I indicated, those documents are for R 7 use generally by technicians that do not understand the signifi-j 8 cance of what they mean. That's because it is intended that d j 9 those things be reported and if a deficiency is to be judged, - the zcg 10 engineer is the only one capable of making that judgment. Z h 11 Because the significance of the deviation is dependent 3 f I2 not on just the deviation but the influence it has on the analysis () 13 that has been carried out, reduction in size may have no signifi-m z E 14 cance at all, because the architect-engineer may have required a E { 15 much greater weld size for other reasons. m E I0 There are minimum weld sizes called out, and for the a 17 most part those are just to increase the probability of a quality w 2 3 18 assurance. For example, minimum weld sizes are frequently cited. A 19 g Those, for the most part, are to prevent some of the discontinuities n 20 such as cracking and other objectionable defects, because the 21 quench effects -- and the code clearly cites that and it gives the (]) engineer latitude when he may deviate from that, and it just is 22 f 23 l essentially raising a flag. () 24h And in my view that was what was demonstrated with the 25, documents at hand. There were discontinuities and deviations C 3 1 il ALDERSON REPORTING COMPANY,INC.
4:7 1136 1 from what the architect-engineer had cited on his plans, but he O 2 is the only one capable of assessing whether those have any 3 significance. O 4 And, as I tried to point out earlier this week, in my e 5 opinion all of the discontinuities that were cited in the Daniel Aa 6 reports were completely acceptable. There should not have been w 7 any of those anchors repaired for the purposes cited. It was a T. j 8 complete waste of funds. d ci 9 If an investigation -- if some experiments had been zog 10 carried out when that problem was first revealed it would have Z h 11 clearly demonstrated what we showed in 1980, that the design was is f 12 completely capable of being satisfied with even the discontinuitie s = O 5 13 and deviations described in these Daniel inspection reports for a 'A 5 14 the manually-produced embedments. 5 g 15 Q Dr. Fisher, just so I make sure I understand those-x 16 j g last comments of yours, is it your testimony that if you take the as l !5 17 Daniel data and Joint Intervenors Exhibit Number 12, the 610-page E { 18 document at face value and assume that the worst weld deviations f i i: t-i 19 l g indicated therein extent 100 percent around the circumference n 20 of the anchor rods, it would have no effect on the load-carrying 21 capacity of the manually-welded embeds or upon the required margir. O 22 o, sa,ety, 23l A That is exactly correct. O 24 c Thank you, or. risher. 25l MR. GALEU: No further questions, Mr. Chairman. ALDERSON REPORTING COMPANY, INC.
1137 4:8 I JUDGE GLEASON: Mrs. Drey, do you have any further ,O A/ 2 cr6ss? 3 MS. DREY: Only the Applicant's attorneys are allowed 4 to ask. questions, is that right? e 5 JUDGE GLEASON:'Well', no. You are allowed -- N 6 MS. DREY: No. Uhat I mean is does the NRC Staff -- R R 7 JUDGE GLEASON: I've been ignoring them and I'm going sj 8 to get to them in a minute with a little apology, but I wanted to d C 9 keep things together here. z, = 10 MS. DREY: Okay, let me ask again, if the NRC Staff _3 11 asks questions may I have redirect on the NRC Staff? B f 12 JUDGE GLEASON: Not on their questions,'but -- <n s 13 MR. LESSY: To avoid the theoretical problem, we have (s 5a z i 14 no questions. 15 JUDGE GLEASON: Okay, so they have no questions. I 16 j ignored then before and I should have, when you concluded, gone w g' 17, to them and asked them if they had any cross examination, and E 5 18 for that I do apologize. p 19 MR. LESSY: I think the Chair knows if I had questions 20 I would have said so. 2I JUDGE GLEASON: I have been kind of operating on the (} 22 understanding that I would hear from Mr. Lessy if I ignored him ( I 23 : too much. () 24 (Laughter.) 25 i But apparently they do not have any questions. Now how i ALDERSON REPORTING COMPANY, INC.
4:9 1138 1 much time did this redirect take, please, for Union Electric? 2 JUDGE GLEASON: About twenty minutes, so you have twenty 3 minutes. O \\> 4 MS. DREY: I am supposed to limit my questions to his e 5 answers on that last twenty minutes, is that correct? E N N 6 JUDGE GLEASON: To the responses that you got to his e R R 7 questions, right. Nj 8 MS. DREY: I would just like to concentrate on four dd 9 words of one of his answers. May I do that? Y 10 JUDGE GLEASON: Yes. 3 5 il MS. DREY: " maximum expected design load." All right? <B d 12 I am going to have to wint it becuase you have my $9 (r x_) g 13 questions and I don't want them back, unless you are not going = l 14 to accept them in the record. uM 2 15 JUDGE GLEASON: Just eo I can understand, are you 5 g 16 referring to the correction he made in his testimony about A y 17 fifteen percent above the maximum expected design load? w= 5 18 Technically it was just a correction, but I suppose -- =H { 19 go ahead. That's all right. 5 20 MS. DREY: I think he talked about load in other parts i 21 of his responses. I'd like to ask him questions about loading, (]) 22 ; if I may. 23 ', JUDGE GLEASON: Yes, go ahead. /~T
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4:10 l 1139 1 MS. DREY: I have another question. May I refer to O'- 2 documents that I have not previously referred to? 3 JUDGE GLEASON: Hell, let's try it and see. I don't O \\/ 4 know what the objections might be. We'll have to see. e 5 MS. DREY: You will have to bear with me, as always, and N i 6I see if I can do this properly. I have listened to Dr. Fisher's R 7 answers and Dr. Slutter's answers and would appreciate it if they a j 8 could help me as professors at Lehigh University to translate d 0; 9 some of the engineering jargon into more lay language. z Oy 10 I'd like to ask -- I have in front of me a document that E j II is put out by the United States Nuclear Regulatory. Commission. 3 g 12 It's a computer printout concerning " reportable occurrance = s s_) h 13 reporbs". This particular document covers those reports received = m 5 14 from all power reactor facilities for the period September 7, '81 $j 15 through September 20, '01. It was sent to the local public = g 16 document room where I saw it and got it Xeroxed. A d 17, This particular document has 87 pages and the title at s 18 the top.of each page says "LER" -- meaning Licensee Event P h I9 Report, output on reports received from September 7 through M 20 September 21, 1981, and outputs sorted by facility and event date. 21 Each page has an average of -- actually each page does have four I i () 22 l Licensee Event Reports. I would like to show this to the Lehign 23l University gentlemen. (]) 24 MR. GALEN: Is there any particular page? I 25 MS. DREY: I first want to ask if they have ever seen 1 0 il ALDERSON REPORTING COMPANY,INC. i
4:11 1140 1 a document like this before. ( 2 WITNESS FISHER: No, ma'am. XXXX 3 RECROSS EX1U4INATION (VD 4 BY MS. DREY: e 5 0 Dr. Slutter? j 6l A (WITNESS SLUTTER) No, ma'am. R 7 MS. DREY: I'd like the attorneys to look at it, or M j 8 you did look at it, right. d =; 9 MR. GALEN: Mrs. Drey, we have one page which yce have zo g 10 provided to us from that document. 11 MS. DREY: Have you seen that one page, gentlemen? 5: I 12 WITNESS FISHER: No, ma'am. O i is WITNESS STUTTER: No, ma'em. m m 5 I4 BY MS. DREY: (. resuming) { 15 Q May I ask anyone else on the panel if that is a document m g[ 16 with which anyone else is familiar, that type of document? us ~ 17 A (WITNESS SCHNELL) Yes, I have seen them, Mrs. Drey. 5 } 18 0 Is that enough? P t-19 g May I ask either of you gentlemen or both of you to n 20 look at page 24, please? Specifically I am interested in the 21 Crystal River -- on this page there are three LER outputs on 22 Crystal River. I'm interested in the third one. 23 I43. DREY: First, may I say that I would like to offer 24 this, or did I say that already? I 25, JUDGE GLEASON: You haven't said that. 1 ALDERSON REPORTING COMPANY, INC.
3 r-4:12 1,741 1 '/ / 1 MS. DREY: May I offer this into evidence, pleasE? () V 2 JUDGE GLEASON: Is there objection, gentlemen 7/ / 3 MR. GALEN: Yes. O n U 4 MS. DREY: I don't mean the whole t51ing. I mean' jtist e 5 page 24.
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i '/. n 6 MR. LESSY:.There is objection. 00 ahead, Mr. Gal,en. g 7 MR. GALEN: Mr. Chairman, we object to the-use sof'this '4 3 / g 8 document as totally unrelated to the issues at hand concerning 4 l '+'~,r' O 9 embedded plates at the Callaway plant. ,//, ' - / ', " z, cy 10 MR. LESSY: The Staff's objection is not only~i's it 3 j 11 unrelated to the Callaway plant, although the document mentions ~ j. 12 the phrase "embedments", the question here at Crystal River is 5 O g i3 in design of the emsede end noe e construce1on eefece, gue11ty M / 'JJ 14 assurance question. We feel ~'it's irrelevant.f-r Drey,ifyouwould,whbtwouldbe { 15 JUDGE GLEASON: Mrs. = j 16 the relevance of this document?
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MS. DREY : The reason I am cubmitting this is I 2 was trying.f to explain that I only know of a few cases where a l., 3 reference to4"deadd and " live" load and seismic load appears t. in print',7a'nd I wanted to ask if I could ask questions about 4
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,I g 5 that to tnat he could perhaps explain in this case briefly-the 9 6 difference between dead and live load as it relates to this R R 7 redesigni6g, apparently, of a support. 0 A 1 8 8 r JyDGE GLEASON: Gentlemen, do you have any 6 f d d 9 objsetions to the document being used for that purpose? i Cy 10 MR. LESSY: In order to do that, it need not be E 5 11 received in evidence. <W d' 12 JUDGE GLEASON: That's true. So why don' t you . Z ) 13 ask the question off of it, and we don't necessarily have to = j" E ' 14' have it in evidence. x-MS. DREY: Well, if it's not in evidence, is ~ 2 15, Y^ f g'[ 16 ihere any ot,h,er way to get it -- A -) d 17 "f ' JUDGE GLEASON: Well -- we-j -18 MS'. DREY: Okay, I'll ask a question. [~19 JUDG'E GLEASON: Just ask the question. n
- 20 BY MS. DREY
i 21 Q Would you please -- Have you had a chance to read I (]) 22 that couple 6f paragraphs? 23 A (Witness Fisher) Yes, ma'am. () 24 Q Would you please tell me how many load designs are .25; under discussion? I just want a number, please, in the t t 9 i ALDERSON REPORTING COMPANY. INC. ema pee ^r ow - -we-
t w a-w. a __ 1143 5-2 jwb 1 ! paragraph that starts: "The cause of this event is attributed () to reclassification of the floor in 1978, requiring seismic 2 3 as well as dead and live load desiga." And then it goes on 4 to say, " Live loading of floor is restricted until modifica-e 5 tion Mar. 81-8-15 has been installed to utilize walls beneath A9 6 floor for added support and engineering eval" -- which I E I 7 assume means " evaluation" - "will be performed to establish j 8 new floor loading status" and so forth. 0 5 9 May I ask, how many load designs are -- just u 4 Y 10 number please -- are referred to in this: paragraph? E { 11 A Mrs. Drey, they do not -- 5 y 12 Q Just a number, please. () 5 13 A I can't give you such a number. j 14-Q Is " dead" different from " live" -- is a dead load 2 15 design the same as a live load design? 5 16 A Mrs. Drey, a dead load -- 2 y' 17 MRS. DREY: Could he just answer it "yes" or "no"? 5 E 18 WITNESS FISHER: I was trying to, Mrs. Drey. 5{ 19 JUDGE GLEASON: Well, there are some questions that M 20 it is impossible to answer "yes" or "no 21 BY MS. DREY: /'N 22 Q All right. V 23, s (Witness Fisher) A dead load refers to the loads (]) 24 that are there in place due to the weight of the structural 25) sy 3 tem and what it supports. A " live load" refers to whatever 1 h ALDERSON REPORTING COMPANY,INC.
1144 5-3 j wb 1 transient effects are producing it. It would appear to me () that the predominant one they're discussing is the seismic 2 3 requirements, but I am certain there are ~many other live-load () 4 requirements. So I have absolutely no way of telling you how g 5 many load cases. You would have to discuss that with Bechtel. R 6 Q When you used the phrase " maximum expected design R R 7 load," to which load were you referring? Live, or dead? %j 8 A Well, the total. When we talk about design load, i d d 9 when it cores to the resistance of a component, it's the i h 10 worst-case combination. So the architect-engineer, Bechtel in E 5 11 this case, or whomever ti e engineer is, when he designs a <b device to resist the loads is going to go through a very large d 12 l ([) h 13 number of load combinations, of dead and live loads -- mj 14 Q Okay. Thank you. E 2 15 A -- and select the one that is the worst one. 5 j 16 Q That 's fine. Thank you. A d 17 ' MS. DREY: May I offer this page and its cover page 5 5 18 inte evidence? 5 l { 19 MR. GALEN: We have the same objection. 5 20 MR. LESSY: The same obj e : tion -- 21 JUDGE GLEASON: I think I have to sustain the 22 objection, Mrs. Drey. } 23, MS. DREY: Does it just get thrown out? Or what ? 24 happens, then? 25[ JUDGE GLEASON: Well, it is not admitted, because ji ALDERSON REPORTING COMPANY, INC.
1145 5-4 jwb 1 the relevancy has not been established. () 2 MS. DREY: Okay. 3 MR. LESSY: Rejected exhibits are, under our rules, () 4 kept with the record of the proceeding in a separate file. o 5 MS. DREY: Okay..Thank you. Anj 6 How much time do I have, pleasa? Rg 7 (Pause.) 8 8 (Board conferring.) N d d 9 JUDGE GLEASON: You have about 15 minutes, Mrs. Drey. i h 10 MS. DREY: Thank you. E 5 11 BY MS. DREY: <3 d 12 Q Another case where I have seen a description in 3 () 13 something other than an engineering textbook -- or not a l m S 14 - description, but a use of the term " design load," or " load," sx 2 15 had to do with a recent accident that occurred at the Hyatt 5 16 Regency Hotel in Kansas City. 3A d 17 I have before me a collection of reprints of -- 18 it's two pieces of paper. It has reprints of three newspaper 5 } 19 articles in total on these two pages. 5 20 The first one started on the front page of the 21 St. Louis Post Dispatch dated July 22, 1981. The title of 22 the article to which I want to refer is " Engineers In Disagree- [} 23 ' ment on Hotel Disaster Cause. " []) 24 i The second newspaper article is from the St. Louis a 25 Post Dispatch dated October 15, 1981. That date is in my own l l ALDERSON REPORTING COMPANY, INC.
5-5 jwb 1146 I handwriting. The title of the article is " Walkways Collapso 2 Recreated in Study." 3 And the final of the three articles is from the 4 Wall Street Journal. Also the date is written in my hand-e 5 writing. The title of the article is, " Kansas City Hotel E9 I 3 6! Disaster Breeds Suspicions about Hallmark Family. " e i R 2 7 I would like to show this to the -- is that right? -- 8 8 to the witnesses, please. n d d 9 MR. LESSY: While she is doing that, the rejected i 10 exhibit would be Joint Intervenor's Exhibit No. 26, rejected. E 5 11 (The document referred to was <3
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= ( E 13 Exhibit No. 26 for identification Ej 14 and rejected frcm evidence.) 2 15 JUDGE GLEASON: Thank you, sir. j 16 MS. DREY: Do you need a full composite of copies a p 17 of the rejected exhibits, as well? E 5 13 JUDGE GLEASON: The reporter has to have one. h { 19 MS. DREY: She needs three? n 20 THE REPORTER: I have three copies. 21 JUDGE GLEASON: Do you want to ask a question on O 22 these? 23 f MS. DREY: Actually, I think I can -- O 24j crause.) 25 JUDGE GLEASON: That will be Exhibit 27. g i i ALDERSON REPORTING COMPANY. INC. I
1147 5-6 jwb j j lThe newspaper articles were (k 2 marked as Joint Intervenors' 3 Exhibit No. 27 for identifica-fNu (g. 4 tion.) e 5 JUDGE GLEASON: All right, Mrs. Drey. A N 8 6 BY MS. DREY: e 7 Q Are you gentlemen familiar with this accident? 8 A (Witness Fisher) Yes, ma'am. d = 9 Q Dr. Slutter? i h 10 A (Witness Slutter) Yes, I am. E! 11 Q Does this look like some three newspaper article i d 12 reprints of the coverage of the accident? E () E 13 A (Witness Fisher) Yes, ma'am. E 14 MS. DREY: I would like to offer these two pages U m 2 15 into evidence. 16 JUDGE GLEASON: Is there objection? Hearing none, d 17 they will be accepted. M 18 MR. LESSY: Wait a second. 5 E 19 MR. GALEN: Objection, s 20 JUDGE GLEASON: What is the reason for your 21 objection? (} 22 l MR. GALEN: Lack of relevance to the issues. 23 l MS. DREY: What is the relevance in your mind, i (' } 24 Mrs. Drey? i r l 25 ; MS, DREY: I would like to ask about the use of the H h ALDERSON REPORTING COMPANY. INC. i
1143 5-7 jwb 1 term " loads," and I would like for an explanation of the kinds () 2 of forces, and so forth, that occur here. 3 JUDGE GLEASON: The obj ections are denied. The 4 Exhibit will be admitted as Joint Intervenors ' Exhibit No. 27. s 5 (The document referred to, N 6 previously marked as Joint Rg 7 Intervenors ' Exhibit No. 27 for -f8 identification, was received in dd 9 evidence. ) i Oh 10 BY MS. DREY: E 5 11 Q Gentlemen, would you please tell me -- would you <3 'i 12 please look at the second page, " Walkways Collapse. Recreated E (e) =l-13 in S tudy. " The final column, the second paragraph, would you s, mj 14 please just tell me, in the first sentence of that paragraph, 2 15 would the structural weight of the walkway represent the dead 5 16 load, or the live load, of that walkway? j s b' 17 A (Witness Fisher) The dead load. s M 18 Q Thank you. 5 Q 19 Would you please tell me about your tests in -- M 20 that were written up in both the Interim Report, included in 21 the NRC Staff Witness's exhibit NRC Report No. 80-14, and []} 22 the results were also included in Union Electric -- I'm not 23! sure about that -- is there a final -- I think there is e final (]) 24 co py, right, of the Bechtel report, which is I believe the 25 final was dated -- l' i ALDERSON REPORTING CO'MPANY. INC.
7:49 5-8 jwb 1 MR. GALEN: Exhibit No. 5. 2 BY MS. DREY: 3 0 Exhibit 5, and that was dated September, whereas 4 the interim report -- what was the interim report's date? e 5 A (Witness Fisher), August 10th, 1977. R s 6 0
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R R 7 MR. GALEN: Just for the record, Mr. Chairman, I .~. n 5 8 don't think Dr. Fisher is clear on what she is referring to n d d 9 as the interim report. 2f 10 WITNESS FISHER: I see -- I think I see " attachment E 5 11 E" to the NRC -- <3 d 12 BY MS. DREY: 3 O i i3 0 Rieht. 80-14. = s 14 A (Witness Fisher) Yes, ma'am.
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2 15 Q So the 80-14 inspection report includes the interim 5 a. 16 and the panel will also have a copy of the final report, I us d 17 believe, as you said, Applicant 's Exhibit Number? 5 5 18 MR. GALEN: Five, Mrs. Drey. 5'l 19 BY MS. DREY: A 20 Q Five. Would you please tell me about the tests' 21 I want to know which one or ones of the three different tests 22 that you performed would be considered a test of the load -- 23, wait just a moment -- of the maximum expected design load? O 24 A <Wiemees Fisher > Mrs. Drey -- 25, O Maybe I shouldn't use the word " maximum." Just of t. .I h ALDERSON REPORTING COMPANY,INC.
1150 5-9 jwb 1 the load. Which of the three tests you conducted would you 2 say -- which ones of them -- would hava tested for load 3 cap 3 city? \\- 4 A For testing for load capacity were the tensil tests e 5 that were carried out in the. laboratory, which are identified A n 8 6 as specimens T-1 through T-6, in both the data sheets and in e R a 7 the plots that were provided. ~ [5 8 Q So six of the laboratory tests, the first six do 9 would be considered " load tests"? zo 10 A Pardon me? $j 11 Q I don't mean -- what I mean, if we have three tests, B j 12 the tensil test as contrasted with -- distinguished from the 5 C_s) y 13 bend test? mj 14 A The bend test -- 2 15 Q The tensil tests are considered load tests? Is 5 g 16 that what you're saying? y 17 i A Both are considered load tests, Mrs. Drey. As I E i 5 18 explained yesterday, the bend test did not subject the weldment 5 l { 19 to as critical combinations of stress that would be as severe E l l 20 as the tensil testing. 21 Q All right. New the tensil ctress -- (]) 22 A Tensil " test." 23! O I'm sorry. What di' the tensil test -- what kind i (]) l 24 of a force would that measure? l A A tensil test transmitted a force to the weld, the l 25,] l il ALDERSON REPORTING COMPANY. INC. 1 L
1151 5-10 jwb i fillet veld, whien subj ected the weld to a shear stress. All n) load vectors that act upon fillet welds produce shear stresses (_ 2 3 upon the weldment. There are two planes that we discussed 4 earlier -- e 5 Q I thought you said tensil was a pull? E N 8 6 A That's correct. o 7 Q Away from. Now you're saying it's a shear, which 8 is up and down? d d 9 A No, ma'am. i h 10 0 Which is down, I mean? E E 11 A The force that was applied to the ancnor rod is a d 12 tension force. The weld transmits the force, which is a E () 13 tension force, on the rod into the embedment plate. All A 14 loads that fillet welds are suLpseted to result in the weld Cz 2 15 being subj ected to a shear stress. It is just the direction 5 16 on which the shear stress acts. B 'A y 17 i Q All right. Now would you please take in your mind N 5 18 one of the plates, either T-1 through T-6 -- 5 E 19 A Yes, ma'am. A 20 Q -- j ust open up to one of the pages, please. 21 A T-3. 22 0 Which plate is that, please? {) 23 i A E.P. 511. ll {} 24 Q E.P.
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A-ll-1. d ALDERSON REPORTING COMPANY. INC.
1152 5-11 jwb 0 And this is specimen T-what? y O ^ T-3. 2 3 0 T-3. okay, would you please tell me where that O grete wou1d he 1oceted in the g1ene2 A I could not tell you that, Mrs. Drey. e 5 N' 8 6 0 How many studs does it have? e N ( Paus e. ) g 7 I think you said each of these plates had four 8 d studs? Is that correct? d 9 1 i 10 A No, ma'am. I_ 5 11 0 I mean, initially? <3 g n A Just a moment and I will tell you. It had 10 Z O c: j3 nchors. = E.: 14 0 Okay. In this one that you tested, could you P ease look at the page for T-3? Where. was that anchor l 2 15 5 P aced on that plate, please? l 16 .s
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It was number five. l g 17 I M 18 0 Going which -- number five on the left, or on the =H l 19 right? ? i n 20 A Well, looking at the sketch, as I look at the sheet 21 it is on the right. 22 0 What was the -- can you tell me if that stud were -- 1 23, if that anchor were not there, or were defective, what -- do i (3 24l you know what that plate -- you say you don't know where that j V l P ate would have been in the plant. So do you know whether it l 25, 't i ALDERSON REPORTING COMPANY, INC.
1153 5-12 jwb j was going to be holding up a floor, for instance, or a pipe? ,r3 (-) 2 A I cannot answer that question. 3 Q If it were holding up a floor, which way would the (3 (/ 4 stress be on that plate? e 5 A It would be a vertical load of predominant shear E N 6 force acting on the plate. 7 Q All right. Would you please look at one of the 8 specimens T-7 through whatever? d d 9 A We only went to T-6, Mrs.Drey, i h 10 Q Oh, okay. That was the tensil test. Okay, then, E 11 whatever number you call for M j 12 A The bend test? 3 g s_/ j 13 Q The bend test. m E 14 A We call those "B." du! 15 Q And these are also for manually welded? Okay. E 16 JUDGE GLEASON: You have two minutes, Mrs. Drey. g E d 17, BY MS. DREY: s 5 18 Q Okay. The bend test there, which one did you open 5 E 19 up to? Which page? 5 20 A (Witness Fisher) I have B-2 in front of me. 21 Q B-2. Can you tell ne where that plate would have () 22 been located in the plant? 23 A That was -- I can't tell you where any of these (]) 24 plates would have been located in the plant, Mrs. Drey. 25, o How did you know what the maximum expected design L ALDERSON REPORTING COMPANY,INC.
1154 l 5-13 jwb j load was on that plate? O ^ cea tacer enet, ar - orer, from the a==u=9ti a= 2 3 that the engineer stated he made. He indicated -- O a Who is he, g1eese2 A I believe this was Dr. Meyers, who had spelled out -- e 5 s and it's in our testimony -- the assumptions that are made. He 5 6I e 7 indicated that on the leg of the weldment a shear stress of 8 14.4 times the yield strength of the base metal is used. So N I don't need to know loads to understand what he has imposed 9
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6:1:maar 1155 1 Q How did you decide which one of the twelve studs you (} 2 would use for the. bend test and which for the tensile test? Did 3 Dr. Meyers also tell you which ones you wanted where? 4 A No, ma'am. g 5 Q How did you decide?- 0 j 6 A My understanding is that the NRC and Union Electric n R 7 identified the anchors that we were to test. N j 8 Q All right, would you please -- do you have -- just one dd 9 moment. Y 10 (Pause.) j 11 Do you have a copy in front of you of the detailed a j 12 procedure for test program to evaluate welds of anchor rods and () 3 13 studs? This is dated July 2, 1980, revised July 11, 1980. Do e g 14 you by any chance have that? That would be the first revision 2 15 of the detailed procedure? w= y '6 A Well, I don ' t have that. I have one that shows two M f U 17, revisions. 5 5 18 Q You have the<.second revision in front of you? i E l 19 A Yes, ma'am. l 20 0 What is that date, the second revision? 21 A August 5. {]) 22 Q Is that a part of NRC Exhibit -- I mean, the NRC Staff 23, witnesses 30-14? Do you know if that's a part of that, or you () 24 have it separately? 25 A I have this as part of Exhibit 5. t l l l ALDERSON REPORTING COMPANY, INC. l
2 g 1156 1 Q Would you please look on page three and tell me -- do Cr 2 you see in the middle of the page -- it says -- let's see, the 3 first paragraph says from the 45 plates, the second one says O 4 upon arrival. The third paragranh says anchor rods. The fourth 5 g paragraph starts, the welds that are tested shall then be photo-a 3 6 graphed from at least two angles. R b 7 A Yes, ma'am. ~ j 8 Q Does your copy then also say the welds between the plate 0 9 and the anchor rod shall then be examined by either the magnetic h 10 particle or dye penetration method and the results of tests shall = 5 II be recorded? 3 g 12 A No, ma'am. o= Q l 13 Q But what do you think that little "2" in the triangle zg 14 stands for? Does that mean there's been a change between revi- [- 15 sion one, is that standard and technical literature? y 16 A Yes, ma'am.
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I7 Q Would you then please look at the next paragraph in 5 3 18 which here starts the three-inch-by-three-inch plates. Do you know A" 19 g who took out the following two sentences for the second revision? n 20 I'm reading from the first revision: "In the event the non-2I destructive examinations show defects in the welds (other than O 22 ,,,,,,1ze e, mmee, cme, ,,e o,e,,11 coe,,1,,,,, ,,, the ccms,1,,,,, 23 I shall assess impact of these defects prior to testing. Another Q 24 rod from the furnished plates shall be selected for tne test 25 orogram to replace the one which was rejected." h f ALDERSON REPORTING COMPANY. INC.
1157 6:3 I I Might I ask if you had ever heard either of those two Akl 2 sentences that I just read? 3 A No, ma'am. O 4 Q Did you see a copy of the original detailed procedure s 5 which I assume was dated July 2, 1980? O 6 A Yes, I believe we were furnished that for comment. R 7 Yes, ma'am. A j 8 Q Was it you or Dr. Slutter, either of you, who designed d 9 the detailed procedure for test program? z Og 10 A We assisted Mr. Parikh in putting this together. _E 11 Q Was lu. Parikh at your university when that was put 's g 12 together or were you at Bechtel? -= (m 's_) y 13 A OlITNESS SLUTTER) Mr. Parikh came to Fritz Engineering = m 5 14 Laboratory for the purposes of discussing the procedure. $j 15 JUDGE GLEASON: I think we'll have to conclude, Mrs. = f 16 Drey. A N 17 MS. DREY: Thank you. Ew 3 I8 MR. LESSY: Mr. Chairman, it's a minor matter, but when P" 19 g Joint Intervenors Exhibit Number 27 was offered you had asked if n 20 there were any objections. Mr. Galen and I then spoke-virtually 21 simultaneously. He then said he thought it was not relevant and () 22 then you said denied, it will be admitted. 23 l I never had an opportunity to comment on Joint Interven-(]) 24 ors before you admitted it. I didt't want to interrupt Mrs. Drey. 25] JUDGE GLEASON: I thought I heard you object to its ? i ALDERSON REPORTING COMPANY, INC.
i 1158 6:4 t I 1 admission. 2 MR. LESSY: I did. I never was given an opportunity to 3 explain the reasons. O 4 JUDGE GI.EASON: Well, it's in. It's kind of moot now 5 because it's been admitted. 9 3 6 The bench will take one minute here and please don't go R R 7 away.
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(Board conferring.) d 9 JULGE GLEASON: Could we go back on the record a minute? 10 Gentlemen, you two people are excused, if you have time problems. II (Witnesses Fisher and Slutter 3 f I2 were excused.) () -13 ' JUDGE GLEASON: Now go off the record. m 5 14 (Board conferring.) { 15 JUDGE GLEASON: Could we go back on the record, please? = j 16 Mrs. Drey, the Board feels that it would be really highly inappro-x 17 priate to accept those questions that you have submitted simply = { 18 because they would not be matters -- they are not matters that P" 19 g should in in an evidentiary hearing sbnply because they are just e 20 your kind of statement, your questions, and we are in a cross 21 examination phase and there would be no chance for anybody to do () 22 any redirect with respect to them. 23 : There is another problem, of course, in that the Board i () 24 l is restricted to making its decision based on probative evidence 25 l in the record. I could suggest, and this is just a suggestion, i ALDERSON REPORTING COMPANY, INC.
6:5 1159 1 that when we get into the limited appearance testimony you could 2 have somebody, not yourself but'somebody else, ask those questions 3 if they wanted to so it would be in the record. 4 Those matters also cannot be used as far as probative e 5 evidence, but they are matters that sometimes the Staff responds U 6 to and sometimes not, and they are matters that the Board looks R 7 to to discover if there are any areas that are left uncovered. ] 8 on the second matter -- dd 9 MR. BAXTdR: Just for clarification, I had asked earlier 10 would the Board defer its ruling on the second matter until after g 11 our redirect had been completed. I was referring to our redirect is j 12 of the entire witness panel. All we have done today is the E O g i3 redirece of Drs. risher and S1 utter because of their need to l 14 l Jepart. 2 15 JUDGE GLEASOH: That's fine. I think it's fair to put 5 j 16 the Applicant on notice that, though we can reserve final judg-as t[ 17 ment until that transpires, as of now the probability. exists that E 18 the Board will want to call two people frcm the Daniel International = l~ 19 g Company and those people should be, if possible, Mr. Starr, who n 20 was an Assistant Project Manager at that time or the time when 21 these occurrences occurred or developed, and Mr. Holland, who we 22 understand is still with the company. 23 ! Also, I think it would be helpful to have, certainly, i l 24 ' Mr. Thomas available and Mr. Meyers just simply if there are 25 ! questions that come up that bounce back between the two companies i ALDERSON REPORTING COMPANY, INC.
6:6 1160 I so that they can respond to. And, of course, it's up to you as ,.'s) 2 to whether Mr. Schnell should be available or not. I leave that 3 to your judgment. 4 MS. DREY: May I ask you a question? g 5 JUDGE GLEASON: No,.just a minute, please. N j 6 To give some feeling on tentative timetables that we're G 7 working under, we would expect that the questions with respect to a j 8 the remaining witnesses of the panel would be concluded at the d d 9 very latest, and I emphasize latest, 12:00 on Monday. We would i a o g 10 expect -- hopefully earlier. E j 11 And of course that depends on Mrs. Drey. We would 3
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/m() $ 13 Mr. Lessy? m h 14 MR. LESSY: Yes, Mr. Gallagher. b 2 15 JUDGE GLEASON: Mr. Gallagher, at 1:00 on Monday and 5 y 16 when that is finished and hopefully that will be finished Tuesday i d 17 -- or Monday, l'm sorry, and then we will follow that if we 5 5 18 decide to go ahead with the witnesses from Daniel International = H j { 19 so that they should be available, I presume, sometime Monday in r n 20 case we get to them. 21 All right, now do you have any comments, gentlemen? Mr. l l l [ 22 l Baxter? q; MR. BAXTER: Is there anything specific in the way of 23 ; l 4 (^s) 24 h guidance the Board migh.t provide in terms of what these two 1 u 9 9 25j Daniel employees should be prepared for in terms of their docu-I d l ALDERSON REPORTING COMPANY, INC. L
6:7 1161 g I ments? 2 JUDGE GLEASON: No. I just think there certainly, you 3 know, is a lot of information that's come up with respect, of 4 course -- this Exhibit 12, the Joint Intervenors Exhibit 12. They e 5 obviously are, you know, a very key -- served a very key function E9 6 in this process. They were the construction managers; they were R R 7 there. They were the ones that would have first seen the material a j 8 as it arrived on the site. O q 9 They were the ones that submitted certain reports and zog 10 had certain conversations with your architect-engineers and E] 11 presumably with the Applicant. And so it's just -- I guess I 3 y 12 can' t do any better than that right now. (~% 5 (/ g 13 MR. BAXTER: Does the Board intend to conduct the = E '14 examination? 5= 2 15 JUDGE GLEASON: Yes. 5 y 16 MR. BAXTER: So we need not prepare any direct to e d 17 develop the record? 5 18 JUDGE GLEASON: No. =H 19 MR. LESSY: Will the parties then have an opportunity M 20 to question the witnesses or will it be solely Board examination? 21 JUDGE GLEASON: Absolutely. It's up to the parties. () 22
- 16. DREY: 'Is that all three parties?
0 23 ! JUDGE GLEASON: All three parties. l () 24l Any thing else, Mr. Lessy? u d 25'j MR. LESSY: No, Mr. Chairman. n I ALDERSON REPORTING COMPANY,INC.
6:8 1162 1 JUDGE GLEASON: Mrs. Drey? O 2 MS. DREY: I just wanted to be sure. You said the 3 questions are to be concluded at the latest by 12:00 noon on O 4 Monday to this panel. And Mr.Gallagher will start at 1:00 on g 5 Monday and will be finished by the end of that day. E j 6l JUDGE GLEASON: Hopefully the end of that day. R 7 MS. DREY: And then on Tuesday the Daniel witnesses? j 8 JUDGE GLEASON: Right. d y 9 MS. DREY: You said, I think, earlier that that would zo 10 be concluded by the close of Tuesday. E 5 11 JUDGE GLEASON: I would anticipate it would. You know, ~s y 12 there are always certain imponderables in this type of proceeding. (~T s_/ g 13 so we can't finalize some of these things, and that's one of them, m zg 14 If, for example, the cross examination with respect to $j 15 Mr. Gallagher is completed early on Monday and if the witnesses a y 16 are available from Daniel International, well, then, we would a b~ 17 proceed Monday with them and go. into Tuesday. E { 18 MR. GALEN: Mr. Chairman, there will be some redirect P" 19 g from the Applicant on the remaining three members of this panel. n 20 JUDGE GLEASOU: I presume that can be concluded Monday 21 morning. Do you have any kind of time estimate that you can give () 22 l us on that? 23{ MR. GALEN: At the present time I would say it would I () 24 l be comparable to the redirect for Drs. Fisher and Slutter. 1 25j MS. DREY: That's twenty minutes? So would you do the i i ALDERSON REPORTING COMPANY, INC.
l 6:9 1 math and tell me when you want me to stop? 2 JUDGE GLEASON: I think if we could get it finished by 3 11:00 it would be helpful. 4 MS. DREY: 11:00. I should finish, so it would be from e 5 9:00 to 11:00. 7> e' 6 JUDGE GLEASON: Right, or 11:15, somewhere.in there. R R 7 MS. DREY: May I ask that the same thing be true of Mr. R ,E, 8 Gallagher so I'll know how to time that too? They'll want d ci 9 redirect, I guess, and you want to be finished by -- z tg 10 JUDGE GLEASON: We don't know whether they want redirect j 11 at this point. 5 j 12 MS. DREY: Oh, I see. O.Xg is JUDGE GtEASON: nopefu11v, you know, his testimony se
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14 in. He'll summarize it and it won't take too long and we'll go ]. 15 right to your cross examination and hopefully we can conclude. m j 16 Much of the evidentiary coverage has already been v5 17 included and referred to in the testimony of this panel, but he u 3 18 comes from a different responsibility. i; 19 g MS. DREY: May I ask one question? If the Joint n 20 Intervenors have questions about the role of the SNUPPS organiza-2l tion would you please tell me to whom we should address those O guestions in ehe gua11ty assurance matter? 22 23 - JUDGE GLEASON: Well, Mr. Meyers and Mr. Schnell, I 24 presume. 25 MS. DREY: So that won' t be considered whatever, because i ALDERSON REPORTING COMPANY. INC. - ~.
6:10 1164 1 it's not somebody with firsthand knowledge or something? I guesc 2 Mr. Schnell is part of some of those comnittees? 3 JUDGE GLEASON: Mr. Schnell has firsthand knowledge. It O 4 depends on the question you ack, obviously. 5 MS. DREY: Okay, thank you. g e' 3 6 JUDGE GLEASON: All right, thank you. We'll see you R 7 all at 9:00 on Monday. A j 8 (Whereupon, at 1:20 o' clock p.m., the hearing was d c; 9 recessed, to reconvene at 9:00 o' clock p.m., Monday, November 23, g 10 1981,) s g 11 a g 12 s O g is = E 14
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2 15 5 16 j as l 17 l 5 18 = 19 a 20 1 21 0 22 23 l O 24j 25, ALDERSON REPORTING COMPANY, INC. L
l ) me:22a. arac uecar c= mess:cs als is Oc certif7 that the attached. ;: ccesdings before she ) g-Atomic Safety and Licensinc Board 3 the Catter ef:. UNION ELECTRIC COMPANY - CALLOWAY UNIT 1 Dace cf F: ec.eeding: November 22, 1981 OccktC llu=bef! STN-50-483-OL PI.ack Cf E:*cceed.ing: St. Louis, Missouri wore held as hereis appears, and, chit this is the crigt al. :: scscri; charect ici-che fLLs c.f the CaczL21Lec., Ann Filav Offic.ial.Teger:er (Typed.) > O $n) Officia! Repcreer (3ig:stu: e) O em O 6
HUCLEAR REGULATORY COMMISSION ( 4"cis is to certify that the attached proceedings before the Atcrqjc Safety and Licensing Board a the.satter of: UNION, ELECTRIC COMPANY - CALLOWAY UNIT 1 Date of Proceeding: november 22, 1981 Docket llutaber: STN 50-483-OL Place of Proceeding: St. Louis, Missouri wore held as herein appears, and that this is the original transcrip thereof for the file of tne Cce:::ission. .Tann Beach Official Reporter (Typed) o Of ( o / O icial Reporter (Signature) 4 O O l}}