ML20054F055
| ML20054F055 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/11/1982 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| NUDOCS 8206150175 | |
| Download: ML20054F055 (147) | |
Text
NUCLEAR REGULATORY CCMMISSION g
g.
p a
w ;J L l b in'l k BEFORE THE ATOMIC SAFETY AND LICENSING BO_ARD In ti:e Mat:::ar cf:
TEXAS UTILITIES GENERATING COMPANY, et al. :
DOCKET NOS. 50-445
(
50-446 (Comanche Peak Steam Electric Station, l
Units 1 and 2)
-i e
DATE:
June 11', 1982 PAGES: 1758 - 1904 i
AT:
Fort Worth, Texas 1
ol
(
REPORTD*G I
ALDERSOX 1
f.
400 virginia Ave., S.W. W==hd"g.=n, D. C. 20024 Talachene: (202) 554-2345 8206150175 820611 PDR ADOCK 0500044S T
b 1758 1
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
[}
2 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 3
In the Matter of:
O 4
TEXAS UTILITIES GENERATING
)
COMPANY, et al.
)
e 5
(Comanche Peak Steam Electric)
)
Docket Nos.
50-445 Station, Units 1 and 2
)
50-446 2
6
)
R I
A Times Square West,
[
8 Fort Worth Hilton d
1701 Commerce Street, q
9 Fort Worth, Texas h
10 Friday E
June 11, 1982 g
11 m
d 12 The above-entitled matter came on for further 3
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13 g
hearing, pursuant to adjournment, at 9:00 a.m.
E 14 BEFORE:
2 15 MARSHALL E. MILLER, Chairman g
Administrative Judge T
16 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission g-37 Washington, D.C.
20555 g
18
=
DR. KENNETH A.
MCCOLOM, Member 5
Administrative Judge 19 l
Dean, Division of Engineering, Architecture and Technology 20 Oklahoma State University Stillwater, Oklahoma 75074 2) 22 DR. RICHARD F. COLE, Member 0
Administrative Judge Atomic Safety and Licensing Board 23 U.S. Nuclear Regulatory Commission 24 Washington, D.C.
20$55
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25 i
ALDE; ON REPORTING COMPANY,INC.
~ 1753 1
APPEARANCES:
- O k/
2 On Behalf of the Applicants, Texas Utilities Generating Company, et al 3
NICHOLAS S.
REYNOLDS, Attorney p\\ >
4
- and -
WILLIAM A. HORIN, Attorney e
5 Debevoise & Liberman 1200 Seventeenth Street, N.W.
3 6
Washington, D.C.
20036 R
b 7
SPENCER C.
RELYEA, Attorney N
Worsham, Forsythe and Sampels j
8 2500-2001 Bryan Tower 4
Dallas, Texas 75201 l
c 9
On Behalf of the NRC Staff:
10 z
5 MAJORIE ROTHSCHILD, Attorney II 4
- and -
GEARY MIZUNO, Attorney 2
z Office of the Executive Legal Director f-3 U.S. Nuclear Regulatory Commission
(_)y ['
Washington, D.C.'20555 Y
E 14 g
SPOTTSWOOD BURWELL k
15 Li ensing Project Manager Comanche Peak Steam Electric Station w
U.S.
Nuclear Regulatory Commission g
Ej Office of Nuclear Reactor Regulations Washington, D.C.
20555 g
j7 18 19 8n 20 21 r~s 22
2 1
admitted in evidence.
O 2
Then teke the documents end groceed, or et 1eest 3
those where you think you need to have inquiry made on them, O
4 rather then doing it eiecemeer, which eekee e 1ot more time e
5 back and forth, and that sort of thing.
Is this possible?
U h
6 MR. JORDAN:
It sounds good to me.
R 7
JUDGE MILLER:
Okay.
Nl 8
MR. REYNOLDS:
That's acceptable, Your Honor, tj d
9 JUD0m MILLER:
All right.
Do what you can'that 10 seems feasible and we'll move -- instead of having to mark each E
11 one for identification and then summarize.
By now you've isj 12 probably got them to the point where you're able to size them up Q
13 pretty much, with your associates working, perhaps, as you go 14 along.
2 15 MR. JORDAN:
Okay.
Well, I'm a tad confused.
I was s
y 16 going to go right back into them immediately. 'What you're us
!i 17 saying --
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18 JUDGE MILLER:
Well, whatever you're preparing to do e
g now, but let your associates help out, and I noticed that they 19 n
20 nodded their heads that they could be doing this.
They can go 21 ahead and be numbering.
You don't have to get information to 22 mark for identification.
Number them.
You know that they're 23 going to be admitted subject to the objection, so you're fixing 24 your numbers and putting them on.
You don't have to go through 25 ;
the witnesses to do it, or the Board.
ALDERSON REPORTING COMPANY,INC.
1765
-3 1
MR. REYNOLDS:
Mr. Chairman, I'd like the record to 2
reflect that Mr. Chapman is back on the panel.
3 JUDGE MILLER:
Mr. Chapman, we're glad to have you j
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4 back, sir.
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5 All right.
You may proceed, Mr. Jordan.
Hl 6
While we have a moment, let me also announce that the R
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Board has conferred and feels that Mr. F.B.
Lobben of Columbia, M]
8 Maryland, has been injected sufficiently into the record in terms d
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9 of his reports, some reaction to the report in part by Applicant's zog 10 witnesses, and the like, but the Board believes that it would E
l 11 prefer to have Mr. Lobben produced as a witness, and since the 3
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12 Applicant has to that extent, we would therefore request the
(_) 3 es 13 Applicant to produce him at a con.venient, time wh'e'n scheduling g
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14 among all of you for our next and hopefully concluding sension a
g 15 on this Section 5.
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16 MR. REYNOLDS:
We will do so.
W N
17 JUDGE MILLER:
Thank you.
18 Now, as to the ASME, we have not pre-judged and E
19 certainly don't intend to pre-judge in any way.
We thought it gn 20 might be helpful to counsel to indicate that our present feeling 21 is that we doubt if it would be worth going to considerable
()
expense to produce in terms of the Board's needs to have a 22 23 record.
24 Now, we do not foreclose you in any way and you're
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25 perfectly free to do -- put on all your evidence, including that.
ALDERSON REPORTING COMPANY, INC.
'i~1766
>4 1
We're not intimating that you shouldn't.
We're simply trying to 2
help you, knowing that you have problems with scheduling.
We 3
think it would be sufficiently marginal under the present state O
4 of the record where meny metters are covered, end ehet you con e
5 cover also by.other means, but nonetheless we leave it entirely 5
h 6
to your discretion.
You're entitled to do whatever'you wish.
R R
7 I guess, now, that covers all the matters that we N
j 8
have on the various witnesses that are projected presently for d
d 9
next time.
The schedule we announced yesterday, and the -- both 10 the identification of witnesses by the 23rd of June and the filing 11 of testimony, written testimony by July.16th, and the other 3
I 12 matters likewise remain the same.
.O I ta 1e there enythins.further now in thee degerement c
l 14 before we go back to the panel?
2 15 MR. SINKIN:
Mr. Chairman, if I could just bring up j
16 a few matters.
as 6
17 JUDGE MILLER:
Yes.
18 MR. SINKIN:
One, I talked to Mrs. Ellis about the 5"
g transcripts, and she said that previously the Board had requested 19 n
20 that the NRC get the transcripts as quickly as possible to the 2I University of Texas at Arlington Depository.
22 JUDGE MILLER:
I think that was the way we left it, 23 wasn't it, Ms. Rothschild?
24 MS. RDTHSCHILD:
Yes.
i 25 JUDGE MILLER:
The Staff did put them as soon as ALDERSON REPORTING COMPANY,INC.
_________________________________________J
5 1767 25 1
possible at the agreed location and will continue to do so?
O 2
Ms. ROrusCurtD:
Yes.
3 JUDGE MILLER:
Yes.
4 MR. SINKIN:
All right.
e 5
The second matter, we're fully aware of the Board's bl 6
reservations about any discovery or interrogatories or any of R
7 that, but one thing that occurred to us, we have people coming N{
8 to us and saying, I know about such and such a problem.
It's d
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entirely possible that in NCR that we don't have the Applicants 10 have identified that problem, documented that problem, stated 15m q
11 their disposition of that problem, and it might well not be isj 12 worth anybody's time calling the witness if we knew that fact.
Ol' wee womaeri=s ir vera~ eve we cou1a' work out some l
14 very limited discovery, limited to perhaps the NCR, DDR 1,og on g
15 items that are brought to us where we might be asking for a oc j
16 total of 20 or 25 NCR's just to be sure we're not bringing up as d
17 something that's not worth bringing up.
18 JUDGE MILLER:
Well, that seems reasonable, if E
h 19 handled with discretion, and of course you can always do it.
n 20 We would recommend -- and Applicants have been very cooperative, 21 as we see it, in the production of documents.
22 ps Is there any reason why-they couldn't request, even 23 it were a little speedy?
24 MR. RSYNOLDS:
Well, in the first place, the 25 Intervenor has examined every NCR that's in the files of the ALDERSON REPORTING COMPANY, INC.
1768 06
]
Applicants.
Secondly, I don't see that we need any formal
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grocedure, if they wene 1e, ther simg1r ce11 tie end we'11 see 3
if we can work it out.
O 4
30008 x ttsa:
ve -
eniax thee wou1a neaa1e it-e 5
MR. SINKIN:
I would stress that these are matters b
6 we weren't aware of all during discovery, so there was no R
7 reason for --
M[
8 JUDGE MILLER:
No, we're not being critical.
As a dd 9
matter of fact, we think all parties have handled massive i
h 10 discovery and numerous documents commendably.
It's a' tough
!!!j 11 problem and we haven't solved it, but nonetheless I think everyone 3
g 12' has been most cooperative.
iii
,Q 13 All right.
You may progeed.
h 14 MR. JORDAN:
Your Honor, if I'm understanding you 2
15 correctly, I think perhaps the best thing to do -- the next stack j
16 is what I have my hand on, four inches or five ' inches thick, or so-as d
17 JUDGE MILLER:
Ycu've got a big hand.
18 MR. JORDAN:
Whatever.
You already know I'm not F
19 good at estimating time or distance.
g n
20 And perhaps what we should do is take five minutes 21 and mark them all now, and then go with them.
22 JUDGE MILLER:
That might save time, yes.
23 (A short recess was taken.)
24
///
25 ALDERSON REPORTING COMPANY, INC.
i 1700
>l
?P I
JUDGE MILLER:
The records show, now, that the next 2
group or groups of documents have been numbered through CASE 3
Exhibt 70.
4 That is to say, we have documents starting with CASE 5
exhibit 53 and extending through CASE exhibit 70.
0 Now, there is another group of documents
-- in k
7 addition, we've just been handed CASE Exhibits 51 and 52, which a
k were -- well, it doesn't matter.
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Do we now have the numbering through 70.
jog 10 Now, while the numbers are being affixed to the next x
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group that we've been informed about, I've asked Mr. Jordan, d
12 3
Counsel for CASE, to have h is associates continue numbering,if e
Od 13 sJ j they wish to have th,em numbered ~, while we proceed now with the 14 indentification for the record and the interrogation of the
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15 panel on CASE Exhibit 51 through 70, I guess it is.
a:
y 16 Is that agreeable?
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17 MR. JORDAN: Yes, sir, it is.
5
{ 18 MR. REYNOLDS:
I have one point for clarification.
)
E 19 g
Is the Board pre-disposed to provide -- to grant n
20 objections on the basis of cumulative evidence?
Are you 21 pre-disposed to receive everything?
22 JUDGE MILLER:
Well, we are, upon the representation
,]
23 of Counsel that these documents all pertain in one way or another 24 to the records and so forth on quality control and with the basis 4
25 of the ruling that we gave yesterday when you made the motion I
i ALDERSON REPORTING COMPANY,INC.
f 1770
>2 1
on cumulativeness, that the Board cannot rule on that one way or
@p v
2 the other until we see the totality, at which point it's moot.
3 You may have a continuing objection on that.
O 4
Okey.
groceed.
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MR. JORDAN:
Your Honor, I'll proceed first with CASE h
h 6
Exhibits 51 and 52.
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A 8
8 Case Exhibit 51 is a four-page document, the first d
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9 page of which has what appears to be, at the top, QA nonconformance 5g 10 report log, although approximately the top half of the words II have been lost in the copying.
On the second page, I see that 3
f I2 that say QA nonconformance report log.
c Oi' JoDoE M1ttER: Now, you see by this grocess that l
14 numbering and showing them to them to opposing Counsel, you need 15 not laboriously go through each one page by page.
.j 16 Just identify very briefly 51, which is part of the us d
17 group the foundation has been stipulated to and the Board has 5
h 18 indicated that the cumulative objective, at any rate, will be i:
h 19 overruled on all a continuing basis, but you can zip right through e
20 now.
21 MR. JORDAN: Y es.
I just wanted to be certain of the 22 identification because of that particular copying problem.
23 JUDGE MILLER:
Okay.
24 MR. JORDAN: In the upper left corner of the document 25 is the number 77-1,in the first column nder word date is the ALDERSON REPORTING COMPANY,INC.
- ~ 1771 3
1 date 3/2/77.
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2 CASE Exhibit 52 is a document, the first page of 3
which states at the top of the right QA significant deficiencies k-)
4 log.
The year 1979 is written to the right and left of the 5
language QA deficiencies log and under the column date, is the l
6 date 1/10/79.
R 7
I would ask -- I need Ms. Bielfeldt back on the panel.
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8 JUDGE MILLER:
She's working on the continuing d
q 9
numbering.
She's not really a member of the panel.
We brought 5
10 her up in an exceptional circumstance but --
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II MR. JORDAN:
Let's see if I can avoid it..
E i
l E.
I2 JUDGE MILLER:
All right.
5
-( ) 5 13 BY MR. JORDAN:
b I4 G
Mr. Tolson, do you have these documents?
g 15 BY WITNESS TOLSON:
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Ib A
Yes.
W I7 Tell us what CASE Exhibit 51 is, sir?
G m
IO MS. ROTHSCHILD:
If I might, I'd ask --
p 19 8
MR. REYNOLDS:
Mr. Chairman, there is no objection on n
20 foundation.
2I JUDGE MILLER:
I know.
l 22 l(])
MR. JORDAN:
I think my --
23 JUDGE MILLER:
I think these documents pretty much
(])
indicate what they indicate or they don't.
You have given us 25 a summary.
We have no problem.
ALDERSON REPORTING COMPANY. INC.
F4 1770
- p I
We're trying?to move on. You've got no problem.
k 2
BY MR. JORDAN:
a 3
g Mr. Tolson, can you explain the purpose of the 4
document, CASE Exhibit No. 51, or Ms. Spencer, sir.
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BY WITNESS SPENCER:
h h
6 A.
These are logs that are used for tracking purposes to 7
indicate to us in the Dallas office when a response is due to the w
0 NRC on these matters.
d q
9 It's for tracking purposes only.
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10 p
g By "these", you mean CASE exhibits 51 and 52?
g II E
BY WITNESS SPENCER:
is A.
Right.
o O l 13 g
- Now, there does appear to be a difference between E
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the two logs that we're looking at.
6 x
9 15 J-G 51 says QA nonconformance report log.
a:
l 52 says QA significant deficiencies log.
16
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17 Do they nonetheless serve the same purpose for w
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18 different periods of time?
P A
h 19 BY WITNESS SPENCER:
n 20 A
Yes, they do.
21 g
With respect to CASE exhibit 52, under the column 22 Determination, there are a number of blanks.
Q 23 Can you explain to us what the blanks signify?
24 BY WITNESS SPENCER:
'O O
25 A.
There are two columns Determination.
j ALDERSON REPORTING COMPANY, INC.
5 3
). 1773 I
G I'm sorry.
2 7.m talking about the second column from the left.
3 Headed Determination BY WITNESS SPENCER:
i 5
A.
Okay.
j 6
Well, let me just explain that the first column, I R
eS 7
believe, is completely filled out throughout the log.
a 8
8 The first column I believe is completely filled out, dd 9
the first column entitled Determination.
- 7..
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10 JUDGE MILLER: It appears to be.
II WITNESS SPENCER:
If it was indicated as " unknown" in D
f I2 the first column and we later determined that yes or no, i t was c
13 not reportable, then we filled it in in the second column.
It's l
14 just an evolutionary process.
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15 JUDGE MILLER:
I note with some further explanation a:
j 16 in some cases.
as b'
17 WITNESS SPENCER:
Right.
M I8 JUDGE COLE:
On CASE 51 and 52, who is R.J.G.?
n I9 g
WITNESS SPENCER:
Mr. Bob Gary.
Executive vice n
0 president and general manager of TUGCO.
BY MR. JORDAN:
2
]
G And what was the basis for the determinations as to 23 whether or not items were reportable?
24 BY WITNESS SPENCER:
25 A.
1 ALDERSON REPORTING COMPANY, INC.
~6
+
1774 SP 1
g Did you make that determination, Ms. Spencer?
O 2
av "'T"ess ser"cra:
3 A
No, I did not.
C, 4
g Who did, to your knowledge?
Or did it vary, depending 5
,5 upon the --
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6 BY WITNESS SPENCER:
N 7
A.
The responsibility for determining the reportability A]
8 under 10CFR50.55 (e) rests with the manager of quality assurance.
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g Who is?
z 10 BY WITNESS SPENCER:
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II A.
Mr. David Chapman.
D g
12, G
We were discussing yesterday, you will recall, the S
Q j 13
. matter of the hilti bolt backfit program.
E 14 Does that give us an example of this log demonstrating w
2 15 a 55 (e) reporting?
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16 BY WITNESS SPENCER:
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17 A.
It should,yes.
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18 G
Can you take us to it in here?
E 19 g
To help you, I believe we were given a date of 20 December 4, 198 --
i 2I BY WITNESS SPENCER:
22 A.
I have.it.
23 l g
could you tell us where it i-?
4 BY WITNESS SPENCER:
O A.
It's CASE Exhibit 52.
ALDERSON REPORTING COMPANY, INC.
1775 1
The eighth page, second entry.
2 7 \\
V 2
g Can you tell me the SVAR number?
BP 3
BY WITNESS SPENCER:
4 A.
No. 40.
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I.see at the bottom of that page, Ms. Spencer, an hl 6
SVAR 44 relating to hilti bolts ultinately determined not to be R
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reportable.
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8 Can yea tell me what that involved?
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9 BY WITNESS SPENCER:
2 10 A.
Not from that very brief description, no, I can't.
II I don't know.
is I
12 MR. REYNOLDS:
Mr. Chairman, is this cross-examination ?
.O !'3 3uo0s x1ttsa:
aoa-e xaow-h I4 MR. JORDAN: Your Honor, I would move the admission 15 of those two documents, 51 and 52.
3[
I6 MR. REYNOLDS:
Continuing objection.
as N
I7 JUDGE MILLER:
CASE Exhibits 51 through 70 are
- ax 18 admitted into evidence.
19 (The documents referred to were g
n 20 marked CASE Exhibit Nos. 51 through 21 70, respectively, for identification 22 and were received in evidence.)
23 BY.MR. JORDAN:
24 Does'the witness panel have CASE Exhibits 53 through g
25 70?
i ALDERSON REPORTING COMPANY, INC.
a-f 1776 I
(Panel replied in the affirmative.)'
)
2 MR. JORDAN: Did the Board get its sets numbered?
3 JUDGE COLE:
We have a numbered set.
m 4
JUDGE MILLER:
We have them, yes.
5 MR. JORDAN: Your H onor, I believe we still need the b
0 identification, although you've jus'c admitted them.
R 7
JUDGE MILLER: Very briefly, since they are already e.]
8 numbered.
By the way, we'll need two more numbered sets.
We d
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can have them marked at our office.
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10 (Bench conference.)
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11 JUDGE MILLER:
I guess we need only one set, then.
D j
12 MR.70RDAN:
Okay.
O l is CASE Exhibie 53 1e e document, the first gese of l
14 which contains under the subject, Section Quality Assurance 15 Audit No.
1.
Which is apparently marked with a marker.
j 16 Again, the markings are CASE markings and should be rs h
I7 disregarded.
18 CASE Exhibit 54 is a document, the first page of which E
19 under subject states Quality Assurance Audit No. CP-3.
20 There is a 54 series.
Since these were previously 2I stapled separately.
CASE Exhibit 54A is a document, the first 22 page of which, under subject, states Quality Assurance Audit No.
Q 23 CP-3.
It is distinct from 54 in that the date on the cover page 24 is September 30,'1975.
25 CASE Exhibit 54B is a document on the first page of ALDERSON REPORTING COMPANY, INC.
]3-9 I
which above the address is the number BRB-0848.
It is a letter Sp 2
dated October 6, 1975.
3 CASE E::hibit 55 is a document, the first page of which O
has -- is a memorandum which says Subject Status Audit CP-4 and5.
5 CASE Exhibit 56 has a cover page document which states j
h 0
under subject Status - CP-5, Audit and Findings.
R R
7 CASE Exhibit 57 has as its cover page a document which X
states under subject, Status CP-6 Audit and Findings.
d CASE 58 states on its cover page under status, --
h 10 under subject, Status CP-7 Audit and Finding.
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.h CASE 59 states on its cover page under subject, ti 12
- Z Status CP-8, Audit and Finding.
13 CASEExhibit 60, on the cover page.under subject states, I
Status CP-9 Audit and Findirig.
2 15 CASE Exhibit 61 states under subject, on the cover Ef I0
- page, Status CP-10, Findings and Audit.
d d
17 CASE Exhibit 62 on the cover page under subject states M
18 Status CP-ll, Audit and Audit Findings.
5 19 CASE Exhibit 63 on the cover page under subject states 20 Status CP-12, Audit and Audit Findings.
2I CASE Exhibit 64 on the cover page there appears the 22
.ordin, Audit so. cP_13, approximate 1y one_guerter down trom the O
23 top of the page to the righthand side.
24 c3SE Exhibie 65 on the first page under subject, O
25 states, B&R Quality AssuranceAudit No. CP-14 Audit Report.
ALDERSON REPORTING COMPANY. INC.
!~1778 13-10 1
CASE Exhibit 66 on the cover page states, Subject p
2 CPSES job 35-1195, Brown & Root Audit -- Brown & Root QA --
3 The correct language is Brown & Root QA Audit No.
O v
4 CP-15.
5 CASE Exhibit 67 states on the cover page under subject h
6 Status CP-16 Audit and Audit Findings.
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7 CASE Exhibit 68 on the cover page states, Status -
Nl 8
CP-17, File.
d d
9 CASE Exhibit 69 on the cover page, approximately one-10 third down the page in the center, states, Audit No. CP-18.
Ey II CASE Exhibit 70 on the cover page under subject states is g
12 Comanche Peak Steam Electric Station (CPSES) B&R Internal Audit 13 numbers, CP-19.
l 14 BY MR. JORDAN:
15 0
I would ask these questions of Mr. Vurpillet.
j 16 Mr. Vurpillet, can you describe what this package of us CASE Exhibit 53 through 70 is?
b 18 MR. REYNOLDS:
Mr. Chairman, we don't object to foundation.
E 19 JUDGE MILLER: You say you do?
g es 20 It's too late anyway; they're already in evidence.
21 MR. REYNOLDS:
Well, what is he asking the witness to O
22 1dentify ehem for, 23 JUDGE MILLER:
I don't know.
24 MR. JORDAN: I simply wanted a general description, 25 not an identification of each one.
ALDERSON REPORTING COMPANY,INC.
A
~1779 h
1 So we can have some discussion about them.
2 JUDGE MILLER: Is there some generic turm that would 3
describe that group of exhibits?
O 4
WITNESS yuRPIttEr, Yes.
The documenes are audie 5
reports and other documents dealing with the audits -- the items h
0 that are covered in the audit reports that were performed by
^e.
b 7
Brown & Root on the Brown & Root functions at Comanche Peak.
N j
8 BY MR. JORDAN:
d ci 9
What was the purpose of these audits, Mr. Vurpillet?
10 Generally, again.
II BY WITNESS VURPILLET:
is f
I2 A.
Well, the purpose of audits generally is to assess c
Oi' the etetue end errectiveaese or the img1eme=teeiom or the groereme l
14 and functions being audited.
15 G
Did the -- did undertaking the audit that are g
16 reflected in CASE Exhibit 53 through 70, did the auditors as h
17 essentially look at the records of the matters being audited?
a:
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18 BY WITNESS VURPILLET:
12 I9 g
A.
Yes.
I'm sure they looked at the records.
n 20 0
My question is, did they go and do physical inspections II themselves of aspects of construction or material, as opposed 22 l
to looking at records?
23
//T 24 s
25 !
ALDERSON REPORTING COMPANY,INC.
1780 R
1 A
Reviewing records and examining the ongoing work in 7s w_)
2 some way, witnessing the work that is going on, interviewing 3
people that have done the work.
They generally do not go out O) q_
4 and re-inspect items that have already been inspected, although e
5 that could happen in some cases, and often does.
5 h
6 JUDGE MILLER:
Off the record a minute.
R 7
(Discussion off the record.)
Kl 8
JUDGE MILLER:
All right.
You may proceed.
dd 9
BY MR. JORDAN :
i h
10 g
Mr. Vurpillat, we -- "we" being CASE -- received E
h 11 these documents, CASE Exhibits 53 through 70, from the Applicants D
j 12 on discovery, and as you will see, comparing CASE Exhibits 53
,(d' 3 g
13 and 54, CASE Exhibit 53 is Audit 1 and. CASE 54 is Audit 3,.are m
h '14 you aware, sir, of whether there is an Audit 2 that is missing?
2 15 BY WITNESS VURPILLAT:
f 16 A
No, Mr. Jordan, I'm sorry, I'm not.'
M d
17 g
You're not.
Does anyone else know whether this audit
{
18 record is incomplete, missing Audit No. 2?
P
{
19 (Panel indicates in the negative.)
n 20 0
I would ask you, Mr. Vurpillat, to turn to CASE 21 Exhibit 55.
There is on the cover, or as the first two pages
/s 22 of CASE Exhibit 55, a document dated November 5, 1981.
That
.V 23 appears to be a review of the audit.
24 Can you tell me, fi rs t',
this is not part of the audit 25j itself, is that correct?
ALDERSON REPORTING COMPANY,INC.
1781
-2 1
BY WITNESS ~VURPILLAT:
2 A.
Well, it's not part of the information developed by 3
the audit team.
O 4
a Can you te11 me war enis dooument was gregered2 e
5 BY WITNESS VURPILLAT:
5l 6
A.
Yes.
This document was prepared to -- simply as a 7.
7 status thing.
As I recall, I ordered the review done of the Ml 8
audit files to make sure that every question that had been d
ci 9
brought up during the audit, that the so-called loop had been 10 closed and that we had documentation that all of the findings j
11 had been resolved satisfactorily.
D y
12 And if you'll recall, I think some place.in the pre-c Q
13 filed testimony, and what have you,.indicatsd I came o.n board in l
14 mid-1980, and at one point I just wanted to be sure that,every-
{
15 thing -- the loop had been closed on the audit findings for y
16 Comanche Peak.
<ss g
17 G
Who is R. M.
Klimist?
!5 18 BY WITNESS VURPILLAT:
k 19 A.
Rose Klimist, at the time of the execution of the 20 CASE Exhibit 55, was the Brown & Root audits manager.
21 O
And she is the individual you designated to undertake 22 the review of the audits?
23 BY WITNESS VURPILLAT:
24 A.
Yes, as the audit manager it would have been her 25 responsibility, yes.
ALDERSON REPORTING COMPANY,INC.
i 1782 o3 1
O You said at the time; she's not in that position?
(V3 2
BY WITNESS VURPILLAT:
3 A.
No.
She is no longer with Brown & Root.
4 MR. JORDAN:
For my purposes at least, I think we can e
5 move the stack of 53 to 70 out of our way for the moment.
bl 6
JUDGE MILLER:
Very well.
They're all into evidence.
7.
7 okay.
We have one set which we have numbered that 7.l 8
the Board can use temporarily.
We will need two more for the d
d 9
Board's own purposes.
- r
h 10 MR. JORDAN:
This is the next set.
E 5
11 JUDGE MILLER:
Of the next set.
p]
12 MR. JORDAN:
Your Honor --
O j ia auoG8 alttsa:
tee the reco=d enow taet the aext l
14 group of proferred exhibits are those numbered CASE Exhibits 71 2
15 through 105.
j 16 Do we have the same stipulation on'those, Counsel?
as d
17 MR. REYNOLDS:
Yes.
18 JUDGE MILLER:
Very well.
5 19 CASE Exhibit Nos. 71 through 105, then, are admitted 20 into evidence with the continuing objection and under the same 21 terms as we did with the previous group.
22
< CASE Exh1 hits Nos.
,1 through 10s O
23 were marked for identification i
24 and received in evidence.)
Q 25 !
MR. JORDAN:
Yes, sir.
I'll proceed.
l ALDERSON REPORTING COMPANY, INC.
1783
^
4 1
CASE Exhibit 71, let me ask Mr. Vurpillat, perhaps he q(v' 2
can help.
3 BY MR. JORDAN:
4 G
Mr. Vurpillat, as you look at these stack of exhibits e
5 that are before you, is there on there an identifying number that El 6
I can use that is a good unique number, or other designation or R
7 can you tell me what the best thing to use is?
El 8
BY WITNESS VURPILLAT:
U d
9 A
I think perhaps the best thing to use has been af h
10 yellowed out and I can't read it.
I think the --
i!il 11 G
Will the date be sufficient?
is f
12 BY WITNESS VURPILLAT:
(
13 A.
Well, I think the date and under; the subject monthly h
14 QA/QC report for whatever the time is.
{
15 G
Good.
Thank you.
a:
g Therefore, CASE Exhibit --
~
16 v5 6
17 MR. JORDAN:
For the record, Your Honor, I'm told 5
18 that the highlighting, at least that done on the first page of 71 e
19 and various.other first pages, was not put on there by CASE.
It g
20 was apparently already on there when we got the documents.
21 Now, CASE Exhibit 71, the first page under subject 22 states, the second line, monthly QA/QC report for June 1975.
23 CASE Exhibit 72, under subject on the first page, 24 the second line,' states monthly QA/QC report for August 1975.
25 CASE Exhibit 73, under subject, the second line, ALDERSON REPORTING COMPANY,INC.
1784
-5 1
states monthly QA/QC report for September 1975.
2 CASE Exhibit 74, under subject on the first page, 3
the second and third line state QA activity report for period
/~
4 June 1 through June 30, 1976.
=5 CASE Exhibit 75, under subject, the second and third 5l 6
line, state QA activity report for period July 1 through July 30, R
R.,
7 1976.
Kl 8
CASE Exhibit 76, on the first page under subject, d
9 second and third line state QA activity report for period 5
10 August 1 through -- it appears to be -- August 31, 1976.
E h
11 CASE Exhibit 77, under subject, the second and third 11 j
12 line stat.e QA activity report for period November 1 through 3
Q j 13 Notember 30, 1976.
m l
14 CASE Exhibit 78, under subject, the second an,d third 15 line state QA activity report for period March 1 through March 31, j
16 1977.
as g
17 CASE 79, under subject, the second line states QA 18 activity report for period -- I'm unable to read the month.
It e
19 g
has been highlighted, although it says then 30, comma, 1977.
The n
20 date of the document itself is May 9, 1977.
On the second page 21 at the top it does state QA activity for April 1977.
O CASE Exhisit e0, on the first page unser sub3ect, 22 23 second line states QA activity report for period May 1 to 31, 24 1977.
The May 1 is difficult to read.
25 CASE Exhibit 81, under subject on the first page, ALDERSON REPORTING COMPANY, INC.
1785
-6 i
second line states QA activity report for period June 1 through 30
,~(,)
2 1977.
3 CASE Exhibit 82, cover page, under subject, second
(_)
4 line, QA activity report for period July 1 through 31, 1977.
e 5
CASE Exhibit 83, cover page, under subject, second El 6
line, QA activity report for period August 1-31, 1977.
R R
7 CASE Exhibit 84, cover page, under subject, second 3
y 0
line, QA activity report for period October 1-31, 1977.
O d
9 CASE Exhibit 85, cover page, under subject, second b
10 line, QA activity report for period November 1-30, 1977.
El 11 CASE Exhibit 86, cover page, under subject, states D
j 12 QA activity report for period December 1 through 30, 1977.
(~~'
O 13 CASE Exhibit 87, on the cover page under, subject g
M 14 states CPSES activity -- QA activities -- let me correct,this, 2
15 CPSES QA activities for January 1978.
g 16 CASE Exhibit 88, under subject, on'the cover page, d
6 17 second line states CPSES QA activities for February 1978.
18 CASE Exhibit 89, cover page, under subject, second I
{
19 line states CPSES QA activities for March 1978.
n 20 CASE Exhibit 90, cover page, under subject, second i
21 line states CPSES QA activities for -- I'm unable to read the 3
22 date, although the month I can read, 1978.
The date of the I (V 23 document itself is May 1, 1978.
24
///
\\
25 l
ALDERSON REPORTING COMPANY, INC.
L
1786 al 1
CASE Exhibit No. 91 states on the cover page, second 2
line, QA Activities for May, 1978.
3 CASE Exhibit 92 on the cover page, under subject, O
4 second 11ne, steees QA.Aceivietes for au17 1978.
e 5
CASE Exhibit 93, cover page under subject, second 5l 6
line states, QA Acitivities for August, 1978.
7 CASE Exhibit 94, cover page under subject, states --
K j
8 second line QA Activities for September, 1978.
d Q
9
. CASE Exhibit 95, cover page under subject, second
,z 10 line, states QA Acitivites for December, 1978.
II CASE Exhibit 96, cover page under subject, second is f
I2 line, states QA Acitivities for February, 1979.
(_) 3 p
13 CASE Exhibit 97, cover page under silbject, second j.
h 14 line, states QA Activities for April, 1979.
g 15 CASE Exhibit 98, cover page under subject, second a
j 16 line, states QA Activities for December, 1979.'
A h
I7 CASE Exhibit 99, cover page under subject, second line x
h IO states QA Activities for January, 1980.
E 19 CASE Exhibit 100, cover page under subject, second 20 line, states QA Activities for July, 1980.
.I I
CASE Exhibit 101, cover page under subject, second 22 O
11,,,
,,,,,,Q,
,,,1,1,1,,
,,,s,p,,,,,,,
1,,0.
23 CASE Exhibit 102, cover page under subject, second O
11ne, seeees Q^ ^ctivities for oecember 1980-25 CASE Exhibit 103, cover page under subject, second ALDERSON REPORTING COMPANY, INC.
1787 2
I line, states QA Activities for January, 1981.
JP' 2
CASE Exhibit 104, cover page under subject, second 3
lines, states QA Activities, October of 1981.
l 4
CASE Exhibit 105, cover page under subject, second line, 5
states QA Activities for December, 1981.
0 Your Honor, we would move that CASE Exhibits 71 1
g through 105 be admitted.
A k
JUDGE MILLER: They have been admitted into evidence.
d o
9 MR. JORDAN:
Your Honor, with the Board's leav6, ; -
10 Mr. Sinkin will cross-examine.
E=
II MR. REYNOLDS:
Mr. Chairman, is Mr. Sinkin subject'to D
N I2 the same qualifications and requirements as you are going to O!is g1ece on Mrs. E1u s if ehe cross-exeminee2 m
l 14 JUDGE MILLER:
Well, he would be unless they,want to h
15 make the offer under other sections af our rules -- a showing, a
d I6 I mean.
as d
17 Do you have any objections, Counsel?
15 18 MR. REYNOLDS: No, sir. No objections.
5 19 CROSS-EXAMINATION (Continued) 20 BY MR. SINKIN:
21 0,
Mr. Vurpillet, the documents that are marked as 71 0
22 through 105, ceu1e you give us a genera 1 descrigtion of what 23 those documents are?
(
24 BY WITNESS VURPILLET:
25 A.
Yes.
Those documents are reports of the monthly ALDERSON REPORTING COMPANY, INC.
i
1788 3
1 activities for various months.
The report is prepared by the q(>
2 Project Quality Assurance Manager and sent to the Quality 3
Assurance Management Staff in Houston.
4 0,
On CASE Exhibit 71, the first document, third page, e
5 third paragraph states :
5l 6
"A DDR Trending Log up to date through R
7 June 30, 1975, is attached."
N]
8 Could you explain to use what the meaning of the d
I word " trending" is in that paragraph?
10 What did Brown & Root have in mind in terms of 3z II E
trending?
D 12 BY WITNESS VURPILLET:
O. !
r3 a.
1 don't think I cou1d sev whee Brown & Rooe had in 14 mind at that time, because I wasn't part of the Brown & Root 15 organization at that time.
g WITNESS TOLSON: Could I assist you in that, Mr.
16 as 6
17 Vurpillet?
u 18 WITNESS VURPILLET:
Certainly.
E 19 MR. SINKIN:
We're at document No. 71, page 3, g
n 20 Mr. Tolson, the third paragaph.
" DDR Trending log."
2I I might help you to look at Page 4, the chart.
22 WITNESS TOLSON: The log itself appears to be a break-Q 23 down of DDR's into the categories listed on the sub-reports and l
24 Page 4.
25 ALDERSON REPORTING COMPANY, INC.
1789 I
BY MR. SINKIN:
o 2
O Just to back up a second, a DDR is a what?
3 BY WITNESS TOLSON:
od 4
A.
Deficiency and Dispostion Report.
5 g
And that is the predecessor to the NCR?
6 BY WITNESS TOLSON:
R b
I A.
That's correct.
Ml 8
g And what we see on the chart on the 4th page, it is d
d 9
a breakdown of the DDR's by category and is each' box representing h
10 one DDR?
iii Q
ll BY WITNESS TOLSON:
D g
12 A.
That would be my assumption, at this point in time.
13 0
In your knowledge of this sytem, is.it.possible for
- m b
I4 one DDR containing a single deficiency, to be counted more than 15 once during the trending?
I0 E
Could it fall into more than one ca'tegory and cause h
17 a box to appear in more than one category?
m
{
18 BY WITNESS TOLSON:
E 19 A.
That appears to have happened as we look on the two 20 succeeding pages.
2I G
You are referring perhaps to page 5 and 6 and I see on 22
{
Page 6 DDR-C-30.
23 BY WITNESS TOLSON:
I4 A.
That's correct.
I 25 -
G It has two categories?
i ALDERSON REPORTING COMPANY, INC.
~
7 1790
}
I BY WITNESS TOLSON:
2 A.
That's correct.
3 And I would assume in that case, then, that they would O
4 eggeer en the gragh es douh1e eneries.
=
5 g
Turning to CASE Exhibit 72 and page 3 of 72, the next El 6
chart, I see in the bottom left it says:
R b
7
" Report for period 3/17/75 through 8/31/75."
X]
8 And it appears to me what is happening is there is tJ I
a cumulative recording of the DDR's.
It's not individ'ual 10 segments month to month but the chart, indeed, is an accumulation
=
11 of DDR's since March of '75?
D g
12 Is '. hat correct?
E
. O s.'
sv w1r"zss ronso":
m h
14
. A.
That is possible.
a g
15 g
Possible?
a:
d I0 BY WITNESS TOLSON:
as 17 A.
We're going back a long time.
a:
{
18 0
I understand.
E I9 g
BY WITNESS TOLSON:
n 20 A.
In this kind of detail --
21 g
Is that how it appears to you?
O 8' " T"zss Totso":
A.
It appears to me to be the same thing.
Q g
Turning to CASE Exhibit 73 the last page of the 25 exhibit is again a chart and would it be correct to assume that --
ALDERSON REPORTING COMPANY, INC.
1731
-8 EP 1
well, let me ask you --
2 We now have a different looking chart.
It comes up 3
from the bottom instead of down from the top.
It's got little O
4 circles insteaa of little squares.
=
5 However, the categories at the top appear to be the 5l 6
same.
Is it your understanding that this is a continuatica. of R
b 7
the same process, just on a slightly different chart?
A j
8 BY WITNESS TOLSON:
d c;
9 A.
Yes, sir.
8 10
///
j 11 a
y 12 S
13 g
m E
14 is 2
15 y
16 d
d 17 a
5 18 is" 19 R
20 21 22 23 24 25 ALDERSON REPORTING COMPANY,INC.
~
1792 pl 1
0 Turning to CASE Exhibit 80, in CASE Exhibit 80 on O
2 eeee 5 we heve e chere mernd nonconformence trend caeesories 3
and on Page 6 we have a table nonconformance trend categories.
O 4
are we now dee1ine in those documenes with uCR's e
5 rather than DDR's?
!l 6
We're now in May of 1977.
If you look on the last R
7 pages of this Document No. 80, there are attached documents M]
8 titled Brown & Root quality assurance department, nonconformance d
d 9
logs.
As you back up through the document you do come to the i
h 10 DDR log.
E h
11 What I'm asking is whether the chart on the fourth D
j 12 page is now NCR's but not DDR's.
I'm sorry, it's the fifth'page 5
{-
13 that.has the chart.
l '14 BY WITNESS TOLSON:
9, 15 A.
From a cursory review, I would concur in your a:
g[
16 conclusion.
as 17 G
And on the seventh page we have a document, a chart 18 titled deficiency trend categories, 10 CFR 50, Appendix B E
19 g
criteria, and we have a series of Roman numerals down the side n
20 of that chart.
2I Are those Roman nemerals the criterion sections of 22 10 CFR 50, Appendix B, is that what they refer to?
23 BY WITNESS TOLSON:
24 A.
Thats correct.
J 25 0
In CASE Exhibit 84, on Page 17 of that exhibit, ALDERSON REPORTING COMPANY,INC.
1793 22 1
titled quality assurance criteria for nuclear power industry --
2 have you found that page?
3 BY WITNESS TOLSON:
fs
(_)
4 A
Yes, sir.
=
5 g
on the left are the 10 CFR, Part 50 --
5 h
6 BY WITNESS VURPILLAT:
R 7
A Which exhibit are you on?
K]
8 g
I'm sorry.
CASE Exhibit 84.
Od 9
BY WITNESS TOLSON:
I h
10 A
Mr. Sinkin, this is the page immediately behind j
11 the log, is it not?
m j
12 g
Immediately behind the NCR log in that document.
(])
13 I think it was Page 17 of that d'ocument, c.tled quality assurance l
14 criteria for nuclear power industry.
M 15 On the left we see 10 CFR 50, Appendix B, and a j
16 series of Roman numerals, and in the middle we-have criteria w
d 17 and a series of titles.
I presume those are from Appendix B.
U k
18 BY WITNESS TOLSON:
E 19 A
That appears to be the case, yes, sir.
gn 20 g
on the right we have ANSI N-45.2 and a series of 21 numbers down the right side.
- (}
Can you explain to me that column?
22 23 BY WITNESS TOLSON:
24 A
The numbers which appear under the title ANSI N-45.2,
()
25 the corresponding numbers in ANSI N-45.2 correspond to the numbers l
ALDERSON REPORTING COMPANY,INC.
1794 23 1
in Appendix B, covering the same sections.
O 2
a and suet to continue on the seme document, the next 3
to the last page, there is a chart with a little curve peaking O
4 uewerd.
1 enet, in your under tendine, e contino tion oe the e
5 earlier DDR log?
Is that what's going on there?
h 6
BY WITNESS TOLSON:
ag 7
A Well, you said the next to the last page.
On my a
8 copy that's a log.
d d
9 0
I'm sorry.
Back up one more.
Now, the chart with i
h 10 little circles.
z
~
j 11 BY WITNESS TOLSON:
D g
12 A
That appears to be correct.
13 G
Let me ask you, Mr. Tolson, we have really three logs.
l 14 in this document, around the eighth p' age starts the nonconformance 2
15 log, and it continues on until a chart titled nonconformance a;x 16 trend categories.
Are you with me so far?
j us
![
17 BY WITNESS TOLSON:
s 18 A
Yes, sir.
k 19 G
Then we start more nonconformance log, and it continue:s 20 on until we have the quality assurance criteria document we 21 looked at earlier.
Then we have a deficiency trend category, 22 and let me ask you, just to make sure, the deficiency trend 23 categories chart, is that charting NCR's or some other document?
24 BY WITNESS TOLSON':
p) w 25 A
That's charting DR's.
ALDERSON REPORTING COMPANY, INC.
1735 4
1 0
DR's?
<\\
v 2
BY WITNESS TOLSON:
3 A
Yes, sir.
O 4
a And then fo110 wine thae chere is something ce11ed e
5 deficiency log, which I see is the DR log.
bl 6
BY WITNESS TOLSON:
9 8
7 A.
,That's correct.
Ml 8
G Now, each DR -- I notice in the DR log, looking at dd 9
that for one second, the third column has deficiency trend
- s h
10 category and a series of Roman numerals in it.
I assume that 25 h
11 those Roman numerals also come from Appendix B.
U f
12 BY WITNESS TOLSON:
Q 13
. A.
That's correct.
l 14 g
So that each DR is in fact considered a deficiency
$l 15 under Appendix B specifically?
m tj 16 BY WITNESS TOLSON:
as 17 A.
That's correct.
z
{
18 G
Whereas an NCR could be written under Appendix B or 19 g
for a nonconforming condition that was not considered under n
20 Appendix B, is that correct?
21 BY WITNESS TOLSON:
22 A.
Would you repeat that?
]
23 g
All right.
Let me come at it a little differently.
24 We have DR's here identified, each one specifically 25 to a criteria in Appendix B?
ALDERSON REPORTING COMPANY,INC.
1796
>5 1
BY WITNESS TOLSON:
2 A.
That's correct.
3 G
Could you take the NCR log -- or going to the NCR's O
4 themee1 vee end toox ee them, end identify each NCR to e criterie e
5 under Appendix B, or are there NCR's written on matters that hl 6
don't fall under Appendix B?
R d
7 BY WITNESS TOLSON:
nl 8
A.
I have --
do 9
G Still having problems with the question?
,z h
10 JUDGE MILLER:
Well, what's the problem?
i5 h
11 WITNESS TOLSON:
Well, I guess because I'm developing D
y 12 a sad case of tunnel vision here.
Appendix B requires a
.O !13 aoacoarormeace report, or e aoacoaformeace erstem-oxav.
- Now, l
14 I suppose that if I want'ed to I could go through the exercise of l
15 trying to relate a nonconformance report to a specific Appendix B a:
16 criterion.
Normally the --
g as 17 JUDGE MILLER:
Well, what's done in these reports?
$i 18 That's what we're trying to find out.
If you can tell us, tell E
19 g
us.
If you can't, don't guess about it.
n 20 BY MR, SINKIN:
2I G
Mr. Chapman, do you want to --
22 BY WITNESS CHAPMAN:
]
23 A.
I think maybe I can help.
Many times a nonconformance 24
~
()
report is written as to procedure or to specifications, or V
25 written to record some nonconforming physical condition and not ALDERSON REPORTING COMPANY, INC.
1797
>6 1
specifically against a criterion of Appendix B, although O
2 Aggendix B hee reauired ehee grocedure to be in g1ece.
3 G
There would be some NCR's -- or would.there be any O
4 NCR's ehet wou1d be written direce1y esainse a criterion in e
5 Appendix B?
5 l
6 BY WITNESS TOLSON:
R 7
A.
It would be rare if it did occur, because mcst of the Ml 8
time you're working to an engineering specification as opposed to d
C 9
using Appendix B as the basis for inspection.
,z h
10 G
Fine.
Could any -- perhaps Mr. Tolson or Mr. Chapman 11 are the logical parties to do this -- the difference between the D
N 12 DR log and the NCR log, would a DR and an NCR be written on the 25 pd y 13 same condition?
u l
14 BY WITNESS TOLSON:
$l 15 A.
Only if the DR had been issued in error.
Then it a
~
16 gj would do that.
We touched on this briefly yesterday, that a
- ,5 17 deficiency report dealt primarily with procedural matters, not 18 related to hardware.
NCR's deal with hardware.
So if the E
19 a
inspector wrote a DR thinking it was a procedural matter but in M
20 subsequent reviews was determined to be a hardware item, then it 21 would be upgraded to an NCR there in closing the DR.
22 O
Well, if someone used an improper procedure, or
]
23 used a procedure improperly, either way, that resulted in a non-24 conforming condition, would we end up with both a DR and an NCR?
25,
jjf ALDERSON REPORTING COMPANY, INC.
1798
>7 1
BY WITNESS TOLSON:
2 A.
Yes, but they would be cross referenced to each 3
other.
O 4
2 cross referenced to each other.
=
5 BY WITNESS TOLSON:
5l 6
A.
Yes.
R 8,
7
///
K j
8 dd 9
mi h
10
!!!mp 11 m
j 12 3
0.
5 l
14 2
15 s
if 16 i
d l
d 17 i
=
l 18
=
g 19 H
l 20 l
21 i
22 g
- v 23 lO 24 25 l
I ALDERSON REPORTING COMPANY,INC.
I I
1739 1
g If you will turn to CASE Exhibit 86, it seems to 2
contain essentially the same things that have been going on in-al 3
the documents immediately preceding it.
R3 V
4 But, laying that beside CASE Exhibit 87, in CASE g5 Exhibit B7, in CASE Exhibit 87, we now have a three-page 6
document that is titled the same, under the subject, CPSES QA 7
activities.
This one is for January 1978.
A CASE Exhibit 86 is for December 1977.
d ci 9
g Can you explain to me why CASE Exhibit 87 no longer h
10 x
has any of the backup materials that we find in CASE Exhibit 86
=
h but 3s merely a three-page summary of activities?
0' 12 BY WITNESS TOLSON:
2 e
Qg 13 A.
If we briefly study all we've e ne through to this u
l 14 point, we have dealt basically with accumulation documents, g
15 trend documents, that tells management nothing.
a:
j 16 Okay.
M
!;[
17 A bunch of open circles and a bunch of closed circles E
18 in a cjiven category that does not provide upper level E
19 management with anything except something to throw in the trash 20 can when they get it.
21 Okay?
22 This was the primary reason for changing the format.
23,
In other words, we are trying to communicate with management, 24 to keep management involved with the activities on site.
25 '
G Well, if you will turn to the third page of 87 and 1
i ALDERSON REPORTING COMPANY, INC.
1800 22 I
.;p the fourth page of 86 --
0 2
I'm suet using this ree ur as en ex-g1e, I see thee 3
in 86 on the fourth page, we have 3.0 deficiency and nonconformance (m
t) 4 reports.
=
5 Are you with me?
5 h
0 BY WITNESS TOLSON:
R b
7 A.
I am now.
3l 8
g Okay.
d 9
And on the second document, 87, on the third page 10 we have 3.0 NRC items.
Should that he NCR items?
Or is that NRC
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f items?
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12 BY WITNESS TOLSON:
S 13 A.
No.
I think that's stated correctly.
h 14 G
It's NRC items.
Fine.
g 15 To make it more useful -- what I'm seeing is, in the z
y 16 first document, 3.0, we have a summary of DDR activity and a as
(
17 summary of NCR activity and a summary of DR activity, at the z
{
18 bottom of the page, and I see the same thing in 2.0, in the E
I9 e
second document.
n 20 BY WITNESS TOLSON:
2I A.
Yes, sir.
22 Q.
All right.
23 My question is, you seem to be communicating the same 24 information up front in the second document as you did in the 25 first.
It's just that we're missing all of the stuff in the ALDERSON REPORTING COMPANY,INC.
e 1801 i
w I
back.
/j
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2 How, in your view, has 'this improved your communication 4,
3 to management?
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j 4
BY WITNESS TOLSON:
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5 A.
The fact-is, it probably,.has not, Mr. Sinkin.
g 9
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6 G
Okay. ' Fine.
i 7,,. / ',,
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. o 7
BY WITNESS TOLSOb:
fl
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8 A.
I guess what we have really done is save the d
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ratepayers a little money on xerox.
z 10 G
Fine.
I'misure the" rat payers will appreciate that.
m w
Q II If you will turn to CASE, Exhibit 95, the fourth page in I2
~
is a graph titled NCR. Trending, l978, and it appears i be a o
m d 13
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- s plotting from January 1978 to December 1978 of various trend m
E 14 categories, the legend for.which is given in the upper ight
-4 wy
.s g
15 side of the graph.
a:
y 16 Is that irideed what we have here?
as N
17 BY WITNESS TOLSON:
5 18 A.
That appears to be the case, yes, sir.
E I
19 l
g G
Then tha' mark made'for each month on this graph is n
l t
20 only the NCR's for thatemonth?
.s i
2I BY WITNESS TOLSON:
)
22 A.
That's correct.
^
)
2 It's not a cumulati've total?
G
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24 BY WITNESS TOLSONi J
l 25 '
A That's correct.
J ALDERSON REPORTING COMPANY,INC.
t
1802
>4 1
4 In what we've been seeing so far, are we seeing an O
gp v 2
evolutionary process of change in the trending process, the very 3
manifestation, It's all the trending process in its various O
4 manifeseations, so fer, 5
BY WITNESS TOLSON:
0 A.
Yes.
If we continue on this same line of reasoning, R
I we'll end up where we were yesterday with the corrective action l
8 centers.
d C
9 That.'.s where it gets to.
Okay.
8, 5
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///
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5 18 i5" 19 8n 20 21 22 0
23 O
25 ALDERSON REPORTING COMPANY, INC.
1803 al 1
G Let me back up for one second.
CASE Exhibit 93, j
()
2 just to be sure we have it.
There are actually two graphs in 3
CASE Exhibit 93, the last two pages, one being NCR trending,
()
4 titled NCR trending, and one titled DR trending.
=
5 BY WITNESS TOLSON:
h h
6 A
That's correct.
7 G
Those are then for the NCR's and the DR's?
Kl 8
BY WITNESS TOLSON:
d C
9 A
That's correct, io 10 G
Then going to CASE Exhibit 105, this is dated Ez q
11 January lith, 1982.
E j
12 Mr. Vurpillat, I see that you are now obviously on N~
5
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13 b,oard.because it's addressed to you.
m h
14 BY WITNESS VURPILLAT:
[
15 A
Yes.
m j
16 G
Now we have a system in which -- on the third page --
e g
17 Mr. Tolson, if you could share yours with Mr. Vurpillat for a 5
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18 moment -- on the third page we have a chart with a series of P
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19 numbers down the left side and letters across the top and n
20 handwritten numbers in the center, and on the left side there are 21 divisions into G and M.
22
{)
Do you see those, Mr. Vurpillat?
23 BY WITNESS VURPILLAT:
24 A.
Yes.
25 l G
Are these the categories general and mechanical?
ALDERSON REPORTING COMPANY, INC.
16H)4 2
1 BY WITNESS VURPILLAT:
(')
2 A
Yes, I believe that's correct.
3 g
And then the graph at the back of this one, we have 1
()
4 an NCR trending log with three lines on it.
The legend says 5
general, mechanical, all categories, so the numbers on the e
2nl 6
previous page are then combined into this graph, is that correct?
9 8
7 BY WITNESS VURPILLAT:
%[
8 A
The numbers are depicted on that graph.
dd 9
BY WITNESS TOLSON:
r g
10 A
Yes.
E 5
11 G
And in Applicant's Exhibit 51 we have the Brown &~ Root y
12 NCR trend categories.
It was general, Roman II was mehcanical,
}S 13 Roman III was mechanical compone,nt supports. 'Those trend
]l 14 categories are essentially the same as'these trend categories?
2 15 BY WITNESS VURPILLAT:
g 16 A
What was your exhibit refernce?
w y'
17 G
The exhibit reference is Applicant's Exhibit $1 and 18 CASE Exhibit 105.
E 19 BY WITNESS VURPILLAT:
g e
20 A
Yes, I think that's the same thing.
21 BY WITNESS TOLSON:
22 A
Yes.
23 MR. SINKIN:
Mr. Chairman, I think that concludes 24 my cross-examination on this packet.
25 JUDGE MILLER:
We will recess for ten minutes.
(A short recess was taken.)
ALDERSON REPORTING COMPANY, INC.
~ 1805
>l
- p 1
BY MR. JORDAN:
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2 g
Mr. Vega, you testified some time ago -- I can't recall 3
if it was yesterday -- to the Lobbin report and the company's
(, )
4 reacton to it, and criticisms of it.
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5 I would ask you, sir, did you state in your testimony Mal 6
yesterday all the criticism the company has of the Lobbin report, R
7 which is Applicants Exhibit 48?
Ml 8
BY WITNESS VEGA:
4 C
9 A
I think you're misleading people when you refer to i
h 10 them as criticisms.
I believe that the record will reflect t
j 11 that our position is that we implemented some things that were a
p 12 recommended.
3
({}. d 13 Other thing's, as we should under our responsibilities.
g l
14 as the Applicants, have evaluated these things.
If we di,d not 15 feel that they contributed to the program, we didn't implement a
g 16 them.
e 6
17 That is our responsibility.
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18 g
Your testimony is, you don't have any criticisms of E"
19 j
g the Lobbin report?
n 20 BY WITNESS VEGA:
2I A
There are some things in the Lobbin report that we
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have disagreed with.
Now, disagreeing isn't necessarily a 22 23,
criticism of something.
24 g
Okay.
That's fine.
I'll be glad to use your
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25 terminology.
i ALDERSON REPORTING COMPANY, INC.
1806 I
2 BY WITNESS VEGA:
j 2
A.
If we had some professional disagreement -- he has 3
stated an opinion. We have disagreed with it and we have implemented the things that we felt enhanced the program or things
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that we concurred with.
8 6
The other, we have rejected.
N b
7 g
Okay.
A k
0 Let me ask first, with respect to the disagreements.
Od 9
Did you describe all those disagreements in your j
O 10 y
oral testimony previously?
Eq l1 BY WITNESS VEGA:
is y
12 A.
I believe I.have.
The complete record would be our 5
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13 response to the Lobbin report submitted to Mr. _Clements.
h I4 G
And that is Applicants --
what?
49 and 50,,if I'm g
15 not mistaken.
a:
g 16 MR. REYNOLDS: Do you. have that, Mr.' Vega?
us I7 WITNESS VEGA: Yes, I do.
b 18 JUDGE MILLER: Are the numbers correct?
49 and 50, i
19 g
I believe Counsel said.
n 20 WITNESS VEGA:
I believe they're correct, Your Honor.
1 2I JUDGE MILLER: Thank you.
l 22 Proceed.
~
i
'23 '.
-MR. JORDAN:
Your Honor, I believe I must take another l
24 moment *to get the direct testimony.
25 l JUDGE MILLER:
Very well.
Go ahead.
j l
l ALDERSON REPORTING COMPANY,INC.
t
i 1807 i
BY MR. JORDAN:
o? S k/
2 G
We'll be going to your direct testimony, members of EP 3
the Panel, and I would begin with Mr. Chapman.
I think it's
()
4 important to the record to be clear just exactly how the quality 5
assurance responsibilities were divided up at the project, l
6 particularly with respect to Brown & Root.
R R
7 My question, sir, is what was Brown & Root's role A
1 l
8 is quality assurance / quality control at the beginning of the d
d 9
project?
If you could describe it generally.
io 10 BY WITNESS CHAPMAN:
E h
11 A
At the beginning of the project Brown & Root, as I
12 the general contractor, had the overall functional management of 5
( ), $
l.3 not only construction but also the construction quality assurahce, k
14 quality contro.
g 15 Our role as Applicants was-that of a surveillance x
g 16 of Brown & Root's QA activities.
M I7 G
And did -- can you describe how Brown & Root's role z
18 changed over the course of the project?
19 g
BY WITNESS CHAPMAN:
n 20 A
The Brown & Root role changed considerably in January 2I of '78 when we became involved in the direct functional management 22
(])
of all the Brown & Root construction QA Activities, with the c
23 j exception of those under the ASME Boiler and Pressure Vessel 24
()
Codes Section 3, the original one.
25 We maintained audit and surveillance of those ALDERSON REPORTING COMPANY,INC.
1808 "4
EP 1
activities.
(3 sJ 2
G Okay.
3 On Page 5 at Answer 9 to your testimony, the last 4
sentence states:
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5 "The TUGCO QA organization exercises hl 6
direct functional management over all R
E 7
activities except ASME's Code work and Ml 8
exercises control over all activities, d
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including ASME Code work."
x 10 That reflects, I believe,what you just said.
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II BY WITNESS CHAPMAN:
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12 A.
That's correct.
O !
is Cen you exg1ein, whee is direce functione1 menegemene2 a
.m l
14 BY WITNESS CHAPMAN:
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15 A.
Well, that, Mr. Jordan, I guess would characterize a:
i[
16 as being in the -- at all levels of organization being invo:ved v5 6
17 in, not only policy decisions, but also day to day ~ management h
18 decisions at all levels.
A h
19 Q
Did you, in effect, replace -- with respect to Brown &
n 20 Root now -- the top level of Brown & Root management in their --
gj with respect to the non-ASME QA function?
22 BY WITNESS CHAPMAN:
23 A
No.
I would say that it would be more accurate to 24 characterize it as -- characterize our view -- role, as taking --
25 being the management ourselves, in an integrated organization.
ALDERSON REPORTING COMPANY, INC.
1809 5
1 We didn't replace Brown & Root as a quality assurance 2
organization.
3 g
So the Brown & Root organization remained essentially
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4 as it was and you, the Applicants --
5 BY WITNESS CHAPMAN:
6 A
Became active in the day to day decision making, yes.
R
- E 7
G Is it accurate that it was essentially the same Brown 4
k 0
Root positio'ns that were involved?
Od 9
BY WITNESS CHAPMAN:
i
~
og 10 A
Yes.
With some exceptions, but essentially from an 11 orgnization overview standpoint, yes.
B g
12 g
Now, when you say " exercises control over all 5
(]) j 13 activities,' including ASME Code work", I. hear a distinc6fon there g
h 14 and is the difference that you do not have this close
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15 integration of your operation into the ASME QA related operation?
m j
16 BY WITNESS CHAPMAN:
W 6
17 A
That's correct.
f 10 Brown & Root is the certificate holder for ASME work E"
19 at Comanche Peak and therefore, must under that certificate, g
n 20 according to the rules of ASME Boiler and Pressure Vessel Code, 21 they must maintain the line functional management of those 22 activities.
p su 23 Our role is still the ultimate control as the owner.
24 g
By ultimate control as the owner
-- I would like (a')
25 to pursue that a little bit more with respect to ASME.
ALDERSON REPORTING COMPANY, INC.
1810
?6 1
Is it then your testimony -- well --
x59
(
2 Does the Applicant have the authority to change or 3
direct Brown & Root to change any procedures or actions which
()
4 Brown & Root is authorized to take as the certificate holder?
e 5
BY WITNESS CHAPMAN:
bl 6
A I think what you're getting into is what I was talking R
7 about as far as functional management goes.
A j
8 Brown & Root in ASME work writes their own procedures.
d q
9 They set up the QA system for Code work and its a Brown & Root 2og 10 system.
So in that regard, we don't get into the nuts and bolts II of that activity.
S y
12 They must, of course, meet the requirements of the 5
()
13 Code.
They must obtai.n the signatures and the sign-off from I4 the authorizing and inspection agency.
But as far as the day to 9
15 m
day down at the working level of activities, those activities x
j 16 are Brown & Root management.
M h
I7 G
Okay.
x IO I want to draw the distinction between -- there are.
E l9 8
actions, are there not, Mr. Chapman, related to ASME Code work n
l 20 which an organization is authorized to take, by virtue of having 2I a certificate; correct?
22 BY WITNESS CHAPMAN:
23 A
That's correct.
24
{}
g Which an organization without the certificate would 25 not be authorized to take?
ALDERSON REPORTING COMPANY, INC.
1 1811 57 Sp
'l
'BY WITNESS CHAPMAN:
2 A.
That's correct.
3 g
Correct?
4 And I take it that the Applicant does not ove'rrule 5
or direct Brown & Root to change its actions that fall into the 1
0 category of authorized by their certificate?
R 7
BY WITNESS CHAPMAN:
K]
8 A.
That's correct.
We have obviously all the authority dd 9
we need to make sure that if such a situation arose, t' hat they 2,o 10 are meeting the Code but we don't get in there and tell them 3m 11 Q
exactly how to do every little thing.
is j
12 They must meet the requirements of the Code.
5 Oi' a
so vou mie t -11 ia omeo=e e1'se who is ASME qualified n
I4 but you wouldn' t -- for example, to' require Brown & Root to b:
g 15 change something but you wouldn't do it yourself?
z i[
16 BY WITNESS CHAPMAN:
d i
6 17 A.
Well, I think we're creating a hypothetical situation 18 when you talk about causing Brown & Root to change something.
i:
t-19 Their system must meet the requirements of the Code g
n 20 and without any specifics as to what type of a situation, I j
21 really don' t know how to respond to the question.
j 22 WITNESS VURPILLET:
Maybe I could add something that 23 will help, Mr. Jordan.
l 24 The ASME Code, like most specifying documents, l
25 regulatory documents, permit several ways that things can be ALDERSON REPORTING COMPANY, INC.
1812 8
- p done in an acceptable manner.
A number of ways to do things I
2 in an acceptable manner.
3 Our ASME program procedures delineate how we have O
4 chosen an acceptable way -- one accpetable way to do those
)
e 5
functions.
b 3
0 If the Applicant, in their role as Applicant, has 7.*"
7 overall responsibility for the QA program for Comanche Peak, n]
8 directs us or asks us, in either case, to change the way we're dd 9
doing it, we would respond to that positively, if the request O
10 g
involved doing it another acceptable way, and that acceptable
=
f way was acceptable to our authorized inspection agency.
f I2 So we would probably react in that case the same as a
h we would in any other part of the program or in construction 13 l
14 procedures, for that_. matter.
g 15 fff x
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17 18 E
19 g
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23 O
25 ALDERSON REPORTING COMPANY,INC.
1813 1-1 1
Q Mr. Chapman, on Page 4, Answer 7 to your testimony, 2
vou seid thee the meeeures teken to reseructure the oA oreeni-O 3
zation at Comanche Peak -- is this the 1978 change?
O 4
av w1rness ca^ra^n:
e 5
A.
Yes.
Enl 6
G You testified to.
R R
7
-- enhanced the quality function for the project.
7.
-8 8
First, you give a rather general description there d
d 9
of what you believe resulted.
Are you able to quantify this af h
10 enhancement in any way?
h 11 BY WITNESS CHAPMAN:
is y
12 A.
I don't know whether I can quantify it to your 3
( -
13 satisfaction.
I can certainly qualify.it,.I think.
l 14 The reorganization, as I have stated in my previous 2
15 answer, involved our becoming more actively involved in the g
16 management and it became more of an integrated-organization.
It us
([
17 became a Comanche Peak quality organization as opposed to separate M
18 entities, such as Brown & Root quality assurance, TUGCO quality 5
{
19 assurance, other contractors, and so forth, and allowed us to i
n 20 utilize the people available, whatever their company affiliation, 21 in the most advantageous manner.
22 G
In the same answer you say that.the QA organization p
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\\
23 is now tailored specifically for and responsive to the needs of a
24 the Comanche Peak Project.
l 25 BY WITNESS CHAPMAN:
i A
Yes.
ALDERSON REPORTING COMPANY, INC.
1814
')- 2 1
g Are you there, Mr. Chapman, stating that this QA/QC (3
x/
2 organization is somehow distinct'from QA/QC projects at other 3
nuclear power plants?
(O/
4 BY WITNESS CHAPMAN:
e 5
A Certainly.
It's the Comanche Peak quality assurance h
h 6
program.
R d
7 g
Recognizing that, what is -- is there some distinction Xl 8
from those at other nuclear projects that --
dd 9
BY WITNESS CHAPMAN:
i h
10 A
Well, I think what this answer refers to is that El 11 previously I believe that the quality assurance program and 3
y 12 documents that implemented that program had basically been set up 3
([]) $
13 from.a corporate standpoint in Houston, ocuments, procedures, d
a h
14 instructions, were controlled from Houston, and the logistics E
2 15 of it from an administrative standpoint of making sure that 5
i j
16 procedure changes were timely and such things as that.
w d
17 Those were the matters that we solved in making a E
5 18 site specific program, because now as conditions and needs change 5
{
19 the governing documents that control those procedure and those n
20 activities can change in a timely manner.
l 21 0
Then I think what I'm hearing is that -- is it not
- ("%
22 the case that you mean that you -- that the measures you've taken l U l
23,
improved the situation with respect to Comanche Peak but you're l
i
[}
not really making a comparison with other nuclear power plants?
24 25 l MR. REYNOLDS:
Objection.
ALDERSON REPORTING COMPANY, INC.
1815
'l
')- 3 1
JUDGE MILLER:
Sustained.
(~)
(_/
2 MR. JORDAN:
I believe he already has made such a 3
comparison in his testimony, but it sounds like he's not making it.
/~T 1
()
4 JUDGE MILLER:
Well, he says he's not, and we don't
=
5 wish to get into collateral inquiry, so --
5l 6
BY MR. JORDAN:
R 8
7 G
Mr. Chapman, I would ask you to turn to the 2l 8
attachments to your testimony, beginning with what has been d
q 9
admitted as Applicant's Exhibit 42-A.
10 Can you explain, sir, under TUGCO QA manager, 3mq 11 block -- about the middle of the page on the right-hand side --
l 12 BY WITNESS CHAPMAN:
E
( ),
13 A
Okay.
l 14 G
Who's that?
g 15 BY WITNESS CHAPMAN:
x j
16 A
That is I.
W b^
17 JUDGE MILLER:
Your grammar is excellent.
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18 BY MR. JORDAN:
5 19 g
G The TUGCO site QA supervisor?
n 20 BY WITNESS CHAPMAN:
21 A
That's Mr. Tolson.
22
)
G Tolson.
And you, sir, have been in the position of 23 site QA manager --
24 BY WITNESS CHAPMAN:
25 A
Since September of
'76.
ALDERSON REPORTING COMPANY, INC.
1816 0-4 1
G
'76.
O 2
BY W1TNESS CHAPMAN:
3 A
Oh, I'm sorry.
I'm sorry.
I missed the " site."
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4 He's not site QA manager, either.
e 5
G Right.
I integrated the titles.
h h
6 Asking you, Mr. Chapman, you have been TUGCO QA 9g 7
manager since --
N]
8 BY WITNESS CHAPMAN:
dd 9
A Since September of 1976.
i h
10 0
And Mr. Tolson, as TUGCO site QA supervisor --
E I
11 BY WITNESS TOLSON:
j 12 A
Since February the 15th, 1977.
5
(~')
d 13 G
Thank you.
'77.
\\_/,g h
14 Did those positions exist before those dates?
2 15 BY WITNESS TOLSON:
j 16 A
Yes.
W f
17 G
Who was in your position of TUGCO QA manager before 18 1976 -- September '76, Mr. Chapman?
h 19 BY WITNESS CHAPMAN:
gn 20 A
Mr. H.
C.
Schmidt.
21 G
He was there, was he not, since basically the
(~%
22 beginning of the project?
\\_)
23 BY WITNESS CHAPMAN:
24 A
Yes.
)
25 G
And Mr. Tolson, in your case, who preceded you as ALDERSON REPORTING COMPANY, INC.
1817 0-5 1
TUGCO site QA supervisor?
O 2
eY WIrNESS TOtSON:
3 A.
Mr. P. M. Milam, Jr., M-i-1-a"-m.
O 4
G Why did he 1eeve the grosect, sir 2 i
e 5
BY WITNESS TOLSON:
5l 6
A.
Well --
R 7
0 I'm sorry.
Did he leave the project?
3l 8
BY WITNESS TOLSON:
d C
9 A
No, he did not.
10 G
What position did he take as of February '777 3
I II BY WITNESS TOLSON:
j 12 A.
I'm not sure.
He took a position in the TUSI 5
f 13 construction organization.
h 14 G
I see.
Mr. Chapman, are you aware of why the, change a
g 15 was made between Mr. Milam and Mr. Tolson?
a:
~
16 g
BY WITNESS CHAPMAN:
v5 6
17 A.
Yes.
5 5
18 G
Would you explain that, please?
i:
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19 BY WITNESS CHAPMAN:
n 20 A.
We felt that the working relationships needed to be 21 improved between the various quality assurance individuals and 22 entities on the site.
23 G
It was your view, then, that Mr. Milam was not i
24 performing adequately in the position?
25
///
ALDERSON REPORTING COMPANY, INC.
1818
,0-6 1
BY WITNESS CHAPMAN:
()
2 A
Not at all.
3 G
Just to be clear, your point is that he was
()
4 performing -- you're not saying that he was not performing
=
5 adequately?
U h
6 MR. REYNOLDS:
Objection.
S 7
JUDGE MILLER:
Overruled.
What are you testifying to?
8 WITNESS CHAPMAN:
I'm testifying that Mr. Milam was dd 9
and is an excellent quality assurance man.
I'm testifying that 10 personalities and interpersonal relationships developed that I 11 felt needed changing.
E j
12 JUDGE MILLER:
That's a fair answer.
5 Q y
.13 BY MR. JORDAN:
m 14 G
Going to the block to the left of TUCGO site QA t
{
15 supervisor is B&R QA manager.
Who is that?
m 16 BY UITNESS CHAPMAN:
g W
d 17 A
That's Mr. Vurpillat.
5 18 G
And that is since mid-1981?
5
{
19 BY WITNESS VURPILLAT:
n 20 A
August 1980.
21 g
August 1980.
Thank you.
22 Can you tell us who was in that position -- did that
{)
23 position exist prior to that?
24 MR. REYNOLDS:
I object.
Mr. Chairman, are we going
{
25 to go through each position in the quali:y assurance organization Al_DERSON REPORTING COMPANY, INC.
1
1819 i)-- 7 I
and ask who has held these positions fur the duration of the j
)
xs 2
entire project?
And if so, what is the probative value or 3
relevance of it?
(
4 JUDGE. MILLER:
What is the materiality?
e 5
MR. JORDAN:
Your Honor, to answer the first of the 5l 6
questions, no, we would not go through every position.
We would R
R 7
likely go through some more of them.
M 8
The probative value really relates back to dd 9
Mr. Taylor's testimony of yesterday, in which he emphasized the o
10 importance of the people to the QA function, and accordingly 3=
11 it is important to know who the people were and perhaps why the q
S y
12 changes were made, if changes were indeed made.
([) 3j 13 JUDGE MILLER:
Well, he attached importance td.all m
h 14 of the people, not just the QA people.
g 15 MR. JORDAN:
Yes, I think he did, but I can't --
m j
16 JUDGE MILLER:
So therefore, unless you're making W
N 17 some point of distinction that has some significance, if it's
{
18 worth taking the time, if you want to be the judge of that for P"
19 g
the time being.
n 20 MR. JORDAN:
Well --
21 JUDGE MILLER:
We're permitting you for the time being.
(])
22 We don't intend to go through the whole roll call.
23 MR. JORDAN :
Okay.
It is not something that I 24
()
intend to pursue for long.
25 fff ALDERSON REPORTING COMPANY,INC.
1820 H8-1 BY MR. JORDAN:
M 2
G Did the B&R QA manager position exist before 3
August 1980?
4 BY WITNESS VURPILLAT:
3 5
A Yes.
N 6
G And who was in it then?
R 7
BY WITNESS VURPILLAT:
M]
8 A.
My immediate predecessor for a very short period of d
d 9
time is my current boss, whose name is Dr. Knox Broom.
He was 2i h
10 acting QA manager for a short period of time.
h 11 JUDGE MILLER:
Will you spell that name?
is j
12 WITNESS VURPILLAT:
The first name is Knox, K-n-o-x, 5. 13 and the last.name is Broom, B-r-o-o-m.
h 14 JUDGE MILLER:
Thank you.
2 15 WITNESS VURPILLAT:
Prior to Dr. Broom, the QA 7;
manager's name was -- individual name, Tom Gamon, G-a-m-o-n.
16 vs d
17 BY MR. JORDAN:
M 18 G
Dr. Broom, as I recall, is a senior executive of k
19 Brown & Root, is he not?
gn 20 BY WITNESS VURPILLAT:
21 A
He's senior vice-president, yes.
22 G
And has he been involved in the Comanche Peak Project 23 as a high-level executive of Brown & Root since the beginning 24 of the project, to your knowledge?
O 25 A.
If not right at the beginning, shortly thereafter.
ALDERSON REPORTING COMPANY, INC.
1 l
1821 l-1 1
G Can you tell.us how long the project has been under Q
2 his direct responsibility?
3 BY WITNESS VURPILLAT:
4 A
Are you talking about Dr. Broom?
{}
e 5
G Yes, I am.
hl 6
BY WITNESS VURPILLAT:
R 6,
7 A
I don't -- I think the connotation that the project 3
g 8
was under his direct responsibility is not quite correct.
As d
o; 9
the executive to whom the QA manager reported directly in the z
h 10 administrative scheme of things at Brown & Root, I believe that 11 that was sometime in 1976 or '77.
D j
12 BY WITNESS CHAPMAN:
E 13 A
Mr. Jordan, I'd like to add something to that.
At l
14 no time has the project ever been under the direct resp:nsibility g
15 of anyone other than the Applicant.
a:
g 16 G
Yes.
Thank you.
as g
17 Mr. Vurpillat, are you aware of when Mr. Gamon left 18 the position of B&R QA manager for Comanche Peak?
E l9 g
BY WITNESS VURPILLAT:
n 20 A
He was not QA manager for Comanche Peak.
He was 21 Brown & Root's power group QA manager, and I believe he left 22 that position in about March of 1980.
Second quarter.
q[O 23 G
Do you know why?
i l
lO 24 BY WITNESS VURPILLAT:
25 A
No, I don't know why.
I was not involved in the ALDERSON REPORTING COMPANY,INC.
l
1822
,-2 1
decision to replace Mr. Gamon.
(])
2 G
Mr. Chapman, are you aware of why Mr. Gamon left?
3 BY WITNESS CHAPMAN:
()
4 A
I was not involved in the decision either.
e 5
G To your knowledge, TUGCO/TUSI, the Applicant in this k
6 case, was not involved in that decision?
R 7
BY WITNESS CHAPMAN:
A]
8 A
That is correct.
O d
9 G
Gentlemen -- Mr. Chapman, in your testimony, going now 10 to Applicant's Exhibit 42-B, I'd simply like you to tell us E=
Q 11 clearly who reports to whom here.
D I
12 The vice-president for nuclear, does the Comanche c
(")% y 13 peak -- is that the individual responsible for the Comanche Peak N-m l
14 Project?
g 15 BY WITNESS CHAPMAN:
m j
16 A
That's the individual responsible for the nuclear w
17 operations, health physics, quality assurance, and he also has e
{
18 an engineering and administrative services staff.
E I9 g
G I don't know whether you mentioned construction, but n
20 that would be included?
2I BY WITNESS CHAPMAN:
22 fw A
No.
Construction is under the TUSI organization.
%)
23 It's shown on the left-hand portion of that Exhibit 42-B.
That 24 arrangement does provide the required separation of quality O
25 assurance from the undue effects of costs and schedules.
ALDERSON REPORTING COMPANY, INC.
1823
-3 I
G Under -- comparing exhibits -- Applicant's Exhibits 2
42-A and 42-B, I see a Brown & Root on 42-B.
The Brown & Root 3
project QA manager reporting directly to a site QA supervisor.
]
4 Is the site QA supervisor a TUGCO person?
o 5
BY WITNESS CHAPMAN:
h h
6 A.
Yes.
That's Mr. Tolson.
R 7
G Okay.
And the Brown & Root project QA manager is s
8 8
whom today?
d ci 9
BY WITNESS CHAPMAN:
- r:og 10 A.
Mr. Gordon Purdy.
11 G
And with respect to this position, when did Mr. Purdy is N
I2 take that position?
s 13 MR. REYNOLDS:
Objection.
h 14 JUDGE MILLER:
What is the point of this?
g 15 MR. JORDAN:
Sir, again the point is the significant
=:
16 g
personality.
It may be that Mr. Taylor thinks'everybody should us 17 be good, but it's surely obvious that some -- the people with h
18 authority should be good.
They're the ones you depend upon.
It i:
19 g
seems to me it's important to know, as we look at the status of n
20 quality assurance during the life of the project, who was involved 2I and when and whether they're still involved.
22 JUDGE MILLER:
Well, that's getting pretty tenuous.
23 ;
Do you have any evidence to follow up on this, or are you just 24 putting names in the record?
25 MR. JORDAN:
Well, we are putting -- we have what we ALDERSON REPORTING COMPANY, INC.
1
)
1824
.- 4 I
would have, and I believe this is the last of the individuals.
- ()
2 JUDGE MILLER:
All right.
Go ahead and finish the 3
whole thing.
(~)T 4
MR. JORDAN:
Or the last of the positions.
\\_
=
5 BY MR. JORDAN:
3a h
6 G
Mr. Purdy took the position when?
R 7
BY WITNESS CHAPMAN:
X]
8 A
I believe it was last October.
dd 9
G And he was preceded by whom?
b b
10 BY WITNESS CHAPMAN:
i j
11 A
Mr. James V. Hawkins.
3 j
12 G
Do you know why that change was made?
E
)d 13 BY WITNESS CHAPMAN:
h 14 A
Yes, I do.
2 15 G
Can you explain that, please?
U y
16 BY WITNESS CHAPMAN:
w 17 A
Yes.
It was basically the same reason-that we made 5
{
18 the change in the site QA supervisor in early 1977.
Mr. Hawkins E
{
19 is an outstanding quality man, but there developed some n
20 personality conflicts that, in my opinion, in order to operate 21 the way we were structured, we needed to make some changes.
It 22 had nothing to do with quality assurance job performance.
23 0
That's fine.
Do you know how long he was in the 24 position?
O 25
///
ALDERSON REPORTING COMPANY, INC.
'y
'1825 L1-5 1
BY WITNESS CHAPMAN:
()
2 A
I believe about 14 months, in that neighborhood.-
3 G
He was preceded by whom?
O 4
av w12"ess ca^ra^":
e 5
A Let's see.
Hl 6
BY WITNESS VURPILLAT:
R R
7 A
He was preceded by Miss Rose Klimist.
M g
8 G
Who was in the position for how long?
d Ci 9
BY WITNESS VURPILLAT:
i og 10 A
Approximately eight months.
E g
11 G
And who decided that Miss Klimist should leave the 3
j 12 position?
5 13 BY WITNESS CHAPMAN:
]
14 A
It.was someone in Brown & Root.
I was not involved a
2 15 in it.
U y
16 BY WITNESS VURPILLAT:
d 6
17 A
That happened just prior to my coming with Brown &
5 18 Root, Mr. Jordan, and I don't know.
E 19 g
G Do you know whether the reason had to do with a need n
20 to improve the quality assurance program?
21 BY WITNESS VURPILLAT:
22 A
No -- yes, I know that, and the answer to that is no, 23 it was not for that reason.
24 G
Thank'you.
And Miss Klimist was preceded by whom?
25
///
ALDERSON REPORTING COMPANY,INC.
1826 il-6 1
BY WITNESS VURPILLAT:
2 A
She was preceded by Mr. J.
P.
Clark, III.
.j 3
G Who held the position for how long?
O 4
8' " '"sss voar' "^T:
a 5
A From Febr.uary 1978 through December 1979.
b h
6 G
Again, the change was not made to improve the quality R
7 assurance program?
A]
8 BY WITNESS VURPILLAT:
dd 9
A To my knowledge, there was no problem with the 10 implementation --
E h
11 BY WITNESS CHAPMAN:
3 g
12 A
I was aware of that, and it had nothing to do with 5
.13 the : quality ' assurance program.
h.14 G
And Mr. Clark'was preceded by whom?
t 2
15 BY WITNESS CHAPMAN:
5 16 A
Peter Bussolini, B-u-s-s-o-1-i-n-i.
g W
6 17 G
Who held the position when?
18 BY WITNESS CHAPMAN:
5 19 A
From clear back, he was the first person in that job.
20 G
Again, the change was not made to improve the 21 quality assurance program?
22 BY WITNESS CHAPMAN:
23 A
No.
24
///
25 ALDERSON REPORTING COMPANY, INC.
1827
<- 1 1
MR. JORDAN:
Yotir Honor, I think that I would have hV 2
to search for another document to proceed on this line.
3 We are ready with the next set of documents, so why O
4 den e we go with thee2
=
5 JUDGE MILLER:
Very well.
h 0
MR.REYNOLDS:
Does that conclude cross-examination R
b 7
of Mr. Chapman's direct testimony?
M 0
MR. JORDAN: Not at all.
d c;
9 JUDGE MILLER:
we have another group of proffered 5g 10 exhibits by CASE, which appear to be numbers 106 through'172.
!!!m Q
11 Is that correct, Mr. Jordan?
is y
12 MR. JORDAN: That appears to be correct.'
E' O
3uoor a1ttsa:
xer we neve the seme st1 u1etion, 9
l 14 Mr. Reynolds?
{
15 MR. REYNOLDS:
You may.
a:
i[
16 JUDGE MILLER: Thank you.
as h
I7 CASE Exhibits 106 through 172 are admitted into a:
IO evidence, subject to the same stipulation as the preceding groups.
I:
g (The documents referred to were 20 marke.' CASE Exhibit Nos. 106 through 21 172, respectively, for 22 O) identification and were received u
3 in evidence.)
24 MR. JORDAN:
Thank you.
25 ALDERSON REPORTING COMPANY. INC.
1
)
(-2 1828 P
1 BY MR. JORDAN:
Gi) 2 0
. Again, the panel has one set'.
s_
3 Mr. Tolson, you are familiar with these documents?
(])
4 BY WITNESS TOLSON:
e 5
A Between myself and Mr. Vega and Mr. Chapman, we could-0 answer any questions that you --
R b
7 g
Okay.
Ml 8
At the moment, I just want to know, could you tell e
9 me, is there a good, unique number or designation on each of o
h 10 these that,I should use to identify it with?
=
k BY WITNESS TOLSON:
D
'd 12 Z
A On'the ff
- the ones on top, the number in the S
13
(') j bottom righthand corner; I suspect as we move through.the ss E
14
.stack we are going to find a'different, unique number.
g
{
15 g
Okay.
x g
16 Well, we'll start --
W
{
17 JUDGE MILLER: What is a common number?
I'm sure x
M 18 there is some method here.
C6 I9 g
BY MR. JORDAN:
n 20 Didn't the designation number change slightly over g
2I time?
t 4
s 22 BY WITNEbS TOLSON:
rN
- )
23 It may'have and that's the reason I answered what I g
24 did.
O 1
i C
'MR. JORDAN:
That's the problem, I think.
s b
I 1
ALDERSON REPORTING COMPANY, INC.
5
.'t
f.
1823 1
WITNESS TOLSON:
The sequence.
2 BY MR. JORDAN:
3 g,
yes.
h 4
BY WITNESS TOLSON:
e 5
A.
The sequence praference designation on the identifiers 5
6 probably changed.
R b
7 MR. REYNOLDS:
Mr. Chairman, may I have a point of M
8 8
clarification?
Od 9
JUDGE MILLER:
Yes.
o 10 MR. REYNOLDS:
Is my understanding correct that
.~
k II cross-examination on CASE Exhibits 1 through 105 has been D
concluded? And that this now constitutes CASE cross-examinati5n a
on these exhibits before us?
E 14 W
JUDGE MILLER:
Is that correct?
2 15 MR. JORDAN:
I think so, unless we have some reason g
16 to go back to them.
us h
17 JUDGE MILLER:
All right.
h 18 MR. REYNOLDS:
I just want to make it clear that as E
I9 g
we go through these, we are concluding cross-examination on each n
20 document?
2I JUDGE MILLER:
My understanding is that is correct, g
yes.
MR. REYNOLDS:
Otherwise, we could be here forever.
g MR. JORDAN:
Mr. Chairman, that has been my intention l
25 with respect to them.
ALDERSON REPORTING COMPANY, INC.
1830 9-4 1
JUDGE MILLER:
All right.
?
2 Proceed.
3 v,_ 'MR. JORDAN: All right.
fi 4
Document marked CASE Exhibit 106, the lower right
'J e
5 corner states Report No. SSR-1.
h h
6 CASE Exhibit 107, front page far right corner, Report R
d 7
No.SSR-002.
A 8
CASE Exhibit 108, first page states in the -- states J
c; 9
about a third of the way down the middle of the page, SSR: 3 and 4.
z 10 CASE Exhibit 109, front page, lower right corner
=
5 II states SSR --Report No. SSR-4.
B f
I2 CASE Exhibit 110, front page, lower right corner S
13
^'3 (V 5 states SSR-010.
u I4 CASE Exhibit 111, in the middle of the page,,
15 approximately a quarter of the way down on the first page, y
6 states SSR: 011.
M CASE Exhibit 112, lower right corner, states Report e
5 18 No. SSR-12.
P" 19 j
CASE Exhibit No. 113, lower right corner, states 20 i
Report No. SSR-15.
i 21 l
CASE Exhibit 114, about a quarter of the way down l
22
(~';
the page, slightly to the left, states SSR-16.
G 23 CASE Exhibit 115, lower right corner, first page, 24
("')
states Report No. SSR-023.
(_/
25 CASE Exhibit 116, states approximately a third of l
ALDERSON REPORTING COMPANY, INC.
-5 1831 I
the way down the center of the front page, SSR: 026.
h 2
CASE Exhibit 117, states lower right corner, first 3
page, Report No. SSR-039.
g 4
CASE Exhibit 118, first page, approximately a third 5
of the way down the center, SSR: 042.
h 6
CASE Exhibit 119, first page in the center, R
7 approximately a quarter of the way down, SSR: 046.
e.
k 0
CASE Exhibit 120, first page center, approximately a d
quarter of the way down, SSR: 047.
O 10 y
CASE Exhibit 121, first page in the center, one quarter of the way down, SSR: 048.
d 12 15 CASE Exhibit 122,, first page in the first line of 13 y8 the first paragraph, reads:
E 14
" Transmitted herewith is surveillance g
2 15 g
report 049."
~
16 CASE Exhibit 123, first page, about a quarter of the 6
17 g
way down, SSR: 050.
!5 18 g
CASE Exhibit 124, one quarter of the way down the 19 center of the first page, SSR: 051.
20 CASE Exhibit 125, first line of the first paragraph 21 on the first page, reads:
22
-s
)
" Transmitted herewith is surveillance l
23 report 053."
24
)
CASE Exhibit 126, one quarter of the way down the center or the first page, SSR: 054.
i ALDERSON REPORTING COMPANY,INC.
1832
}-6 1
CASE Exhibit 127, first page, first line of the G
.yL/
2 first paragraph reads:
3
" Transmitted herewith is surveillance
]
4 report 055."
e 5
CASE Exhibit.128, front;page"in.the_ center, SSR:057.
hl 6
CASE Exhibit 129, first page in the center, SSR:059.
7 CASE Exhibit 130, first page in the center, SSR:062.
3 8
CASE Exhibit 131, in the center, SSR:
.064.
d d
9 I'would d'uble check to be sure we're correct.
o z.
10 Was the last one I read 031, CASE Exhibit?
I'm sorry.
25 II 131 was the last CASE Exhibit I read.
U I
I2 JUDGE MILLER:
Yes.
5.
Q g 13 gg,. JORDAN: Finc. Thank you..
E 14 W
CASE Exhibit 132, center, front page, SSR: 066.
2 15 g
CASE Exhibit 133, front page center, SSR: 067.
~
16 g
CASE Exhibit 134, front page, center SSR No. 086.
6 17 CASE Exhibit 135, front page center, SSR: 070.
g 5
18
=
CASE Exhibit 136, front page center, SSR: 074.
19 l
CASE Exhibit 137, bottom right corner, front page, 20 Report No. SSR 085.
2I CASE Exhibit 138, first line reads:
22
" Transmitted herewith is surveillance 23 report No. 089."
24 CASE Exhibit 139, under Subject, near the top of the 25 page, states Re-issue of SSR: 092.
ALDERSON REPORTING COMPANY, INC.
1833
~
1 CASE Exhibit 140, first line, first paragraph states:
2
" Transmitted herewith is surveillance 3
report No. 094."
()
4 CASE Exhibit 141, front page, center states: Site 5
Surveillance Report No. 095.
0 CASE Exhibit 142, first page, first line of the first R
b 7
paragraph, states:
X k
0
" Transmitted herewith is surveillance d
I report No. 097."
10 CASE Exhibit.143, first line of the first paragraph E
y II on the first page, states:
" Transmitted herewith is surveillance S
OB' reeore No. 105."
E 14 g
CASE Exhibit 144,'firsf. page, centered, is SSR-ll3.
2 15 g
CASE Exhibit 145, first page, first line of the first J
16 y
paragraph states:
6 17
" Transmitted herewith is surveillance xz 5
18
=
report No. 116 "
19 l
CASE Exhibit 146, first line of the first paragraph 20 on the first page, states:
21
" Transmitted herewith is surveillance 22 C-report No. Il6-A."
23 CASE Exhib it 147, first page, first line of the O
eirse eer 9reen states:
25
" Transmitted herewith is surveillance ALDERSON REPORTING COMPANY. INC.
1834 l
,2-8 1
report No. 117."
2 CASE Exhibit 148, first page centered, is SSR-120.
3 CASE Exhibit 149,'on the Subject line on the first
- 'O 4
eese-== tee site surve111eace nerort "o. 124.
e 5
CASE Exhibit 150 on the first page, beneath the bl 6
Subject line, states Site Surveillance Report No. 127.
R 6,
7 CASE Exhibit 151, on the Subject line on the first j
8 page, states CPSES Site Surveillance Report No. 129.
dc 9
CASE Exhibit 152, on the first page, Subject line g
10 states Site Surveillance Report (SSR) No. 130.
Ez 4
11
///
a i
($
12 i
E S
i /N 13
' d.5 i4 m
2 15 g
j 16 as 6
17 a
18 19 i
20 21 22 0
23 O
25 i
i j
ALDERSON REPORTING COMPANY,INC.
~1835 53 - 1 1
-CASE Exhibit 153, subject line,nthere appears'SSR-136.
('M (s'
2 That's on the first page.
3 CASE Exhibit 154, first page, below the subject line,
()
4 centered, appears SSR-141.
=
5 CASE Exhibit 155, below the subject line on the first 5l 6
page and centered, appears SSR-142.
R d
7 CASE Exhibit 156, below the subject line, first page, Al 8
centered, appears SSR-147.
d o
9 CASE Exhibit 157, below the subject line, first page, i
h 10 appears, centered, SSR-150.
E h
11 CASE Exhibit 158,.first page, below the subject line D
g 12 and centered, appears SSR-155.
5
()
' 13 CASE Exhibit 159, first page, below the s,ubject line l
14 and centered, appears SSR-156.
g 15 CASE Exhibit 160, first page, below the subject line 16 and centered, appears SSR-160.
g e
d 17 CASE Exhibit 161, first page, below the subject line,
{
18 appears Site Surveillance Report SSR-001.
In addition, the E
19 g
document, first page, to the upper right is dated January 4, n
20 1982.
21 CASE Exhibit 162, below the subject line and centered, 22
{]}
appears Site Surveillance Report SSR-82-002.
23 CASE Exhibit 163, first page, below the subject line 24 and centered, appears Site Surveillance Report SSR-82-003.
25 CASE Exhibit 164, below the subject line and centered, ALDERSON REPORTING COMPANY, INC.
I 1836 51 - 2 1
appears Construction Surveillance Report SSR-82-005.
2 CASE Exhibit 165, below the subject line and centered, 3
appears SSR-156.
(]
4 CASE Exhibit 166, below the subject line and centered, a
5 appears SSR-160.
bl 6
Could I have a moment, Your Honor?
R 7
JUDGE MILLER:
I thought you were going to make it by a Ml 8
quarter till.
dd 9
MR. JORDAN:
Sir?
i h
10 JUDGE MILLER:
I thought you were going to make it 25
- cy 11 by a quarter till.
D g
12 All right.
We'll recess now for lunch.
Let's try S
{3, g.13 and make it a quick one.today.
12:30 please.
l 14 (Whereupon, at 11:45 a.m.,
a recess was taken b
15 until 12:30 p.m.,
the same day.)
g 16
---o0o---
as i
17 5
18
~
19 8n 20 21 O
23 24 25 ALDERSON REPORTING COMPANY, INC.
1837 i-1 1
AFTERNOON SESSION rh q,)
2 12:30 p.m.
3 JUDGE MILLER:
All right.
Let's take our seats, r^)
4 please.
i e
5 I think, Mr. Reynolds, you indicated there was a 5l 6
schedule matter that you wished to incorporate in the record.
R d
7 MR. REYNOLDS:
Yes.
With the leave of the Board, X
j 8
Mr. Schmidt will address it.
O d
9 MR. SCHMIDT:
I'm Homer Schmidt from Texas Utilities b
d 10 Company.
With respect to the current status of the project, 3l 11 Unit 1 is 87 percent complete; Unit 2 is 49 percent complete.
{
12 The total project is approximately 76 percent, considering all 9
(]) u 13 facilities..
5 14 Various maj'or milestones that have been completed g
15 previously, all our major concrete was completed in July of '79 1
x f
16 on Unit 1, October of 1980 on Unit 2.
w 6
17 We energized transformers in the switch yard, 138 KV l
18 system, on January lith, 1980, and the 345 KV system was
-n 19 energized on July 1st, 1981.
So the switch yard is in operation.
20 There are various other systems in operation.
For 21 example, the surface water system, which is a safety related
-x 22 system, was first operated on March 5th, 1981, at' it is in J
23 operation at the present time.
24 Major milestones to go are hydrostatic tests of
~
)
25 various systems, scheduled for September of
'82.
We will begin ALDERSON REPORTING COMPANY, INC.
1 1838 F-2 1
hot functional teuts in December of '82.
Our structural integrity
()
2 test and integrated leak rate test for the containment building 3
is scheduled for March of '83.
()
4 A VOICE:
For Unit 1.
g 5
MR. SCHMIDT:
For Unit 1, yes, sir.
N 6
And that leads to a fuel load in mid '83, m ane of '83.
R Q
7 In addition to that, with respect to our turn-over n[
8 of status, we have some 300 systems and subsystems identified as d
d 9
various packages to be turned over from construction to i
h 10 operations, and of those 300 we have so far turned over
=
g 11 approximately 200 to the start-up test program.
So those are 3
12 moving right along.
S (v~) g 13 Are there any other questions that you have with m
14 respect to the scheduling?
2 15 JUDGE McCOLLOM:
What about Unit 2?
You gave some f
16 anticipated tests of the -- hydrostatic tests,-the hot functional e
d 17 and containment and the fuel loading on Unit 1.
Do you have that U
18 on Unit 27 E
19 MR. SCHMIDT:
I don't believe I have those specific gn 20 dates, but generally it's about 18 months behind Unit 1.
21 JUDGE MILLER:
Thanks very much.
22 Mr. Jordan, I guess there are certain corrections s
O 23 you will want to note for the record.
24 MR. JORDAN:
Yes, sir, there are.
s 25 After the -- at the end of the last session before ALDERSON REPORTING COMPANY, INC.
1 1839
)-3 1
lunch, we were marking CASF exhibits in the 160's.
AV 2
JUDGE MILLER:
Yes, they all have been marked.
3 MR. JORDAN:
I'm sorry, so they've been marked.
I was O
4 identifyine them.
e 5
JUDGE MILLER:
Right.
E h
6 MR. JORDAN:
We discovered we had some duplications A[.
7 in the packages that we were going through.
As a result, we have
%l 8
changed -- withdrawn from the packages the duplicate documents, d
d 9
the packages that everyone has should now be in the correct order.
10 The numbering and identification th' rough CASE El 11 Exhibit 163 is correct.
I believe I had identified through that D
g 12 document.
I'll now identify from there forward.
E 13 CASE Exhibit 164, the document on the first page of l(]
l 14 which below the subject line and centered states Construction 2
15 Surveillance Report SSR-82-005.
I i
j 16 So we're perfectly clear, that is a document of W
d 17 substantially more than one page.
We had had a one-page 18 confusion there.
?
19 CASE Exhibit 165, the document on the first page of l
20 which on the subject line in the center it states SSR-82-005, 21 Addendum 1.
l l
22 CASE Exhibit 166, on the first page, centered below 23 the subject line reads Site Surveillance Report SSR-82-006.
24 And that completes that particular packagc of CASE 25 f exhibits.
Therefore, Your Honor, I nu st --
l ALDERSON REPORTING COMPANY, INC.
f
1840 3-4 1
JUDGE MILLER:
Well, we have admitted the exhibits
()
2 as marked through 172.
3 MR. JORDAN:
Yes, because we had duplicates,
()
4 accordingly we do not have exhibits past 166 in this package.
e 5
JUDGE MILLER:
Well, then, are you deleting 167 5
h 6
through 172 as marked and admitted into evidence?
We already R
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7 have them in evidence.
A
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8 8
MR. JORDAN:
Your Honor, we would delete from the d
d 9
package and from the documents that are in evidence the documents 10 marked -- originally marked 164 through 169, and would intend El 11 to renumber accordingly.
m y
12 JUDGE COLE:
The ones we have are already numbered.
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13 Why don't you just delete 164 to 169 and leave the others as l
14 they were?
m 2
15 MR. JORDAN:
Okay.
We'll have to go back and do that, 5
g 16 then, because I just identified them.
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17 JUDGE MILLER:
Well, just do it, state it for the 18 record; you are withdrawing --
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U 19 MR. JORDAN:
Okay.
That's fine.
g n
20 JUDGE MILLER:
-- the exhibits which have been 21 previously admitted, and which were numbered CASE's Exhibits 164 22 through 169.
Those exhibits are now deleted at the request of gS G
23,
CASE.
24 (CASE Exhibits Nos. 164 through P
25 169 were withdrawn.)
ALDERSON REPORTING COMPANY, INC.
1841 4-5 i
JUDGE MILLER:
Then you need to identify 170, 171 2
and 172.
3 MR. JORDAN:
Okay.
CASE Exhibit 170 is a document
[j 4
on the first page of which, below the subject line, centered, e
5 reads Construction Surveillance Report SSR 005.
b h
6 CASE Exhibit 171 is a document or :he first page of R
d 7
which, on the subject line, centered, reads SSR-82-005, s
8 8
Addendum 1.
d d
9 And CASE Exhibit 172 is a document which reads on 1:
h 10 the first page, centered beneath the subject line, Site E
I 11 Surveillance Report SSR-82-006.
d j
12 JUDGE MILLER:
Is that it?
S
'l 13 MR. JORDAN:
That is it for this package, yes.
J h
14 JUDGE MILLER:
All right.
Then the CASE exhibits 2
15 thus identified, with the corrections already made are and j
16 remain admitted into evidence, subject to the stipulations that e
6 17 we had from the start.
18 MR. REYNOLDS:
Yes.
h 19 JUDGE MILLER:
Very well.
g n
20 MR. REYNOLDS:
Mr. Chairman, while I'm thinking about 21 it, may I make a housekeeping suggestion?
~3 22 JUDGE MILLER:
Yes.
J 23 MR. REYNOLDS:
Would the Board be interested in 24 asking the Intervenor to type a list describing both content of 25 exhibits and the exhibit number to be designctea for use in the ALDERSON REPORTING COMPANY, INC.
l 16&J 1
forthcoming hearing, so that all of this could be avoided and O
2 gerhege we cou1d eeigu1eee it or reed it into the record end we 3
wouldn't have to go through reciting each document this way.
- O 4
JUDGE MrttER:
That wou1d be hetofu1.
e 5
MR. JORDAN:
Does counsel mean --
6 JUDGE MILLER:
The Board has in mind to request at R
7 the upcoming hearing, first of all, that all exhibits be 3
8 8
previously displayed to opposing counsel, numbered and listed d
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with a sufficient descriptive material and indicating also I
1 10 whether or not there are objections, and if so the nature of the i5 h
11 objections, so that we will be able to proceed in advance, really.
is j
12 We would suggest also that counsel cooperate in the --
c 13 not only in the listing and exchange of witnesses as we've l
14 scheduled, but incorporate in it the handling of the documents Y
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16 to proceed from listings.
as 6
17 As a matter of fact, there's no reason why counsel
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18 couldn't stipulate where they're capable of stipulation, and then e
19 g
put the description in the record.
n 20 Very well.
Anything else that might save time now 21 in the handling of exhibits or evidence?
22 All right.
Go ahead.
23,
MR. REYNOLDS:
Another thing might make the proceeding 24 more efficient.
It's been reported that CASE had seven potential 25 l witnesses for the forthcoming hearing, and we would encourage ALDERSON REPORTING COMPANY, INC.
1643 L4-7 i
CASE, and I think it's the Board's intention in its scheduling
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2-order that those names be made available to the parties as soon 3
as possible, not wait until the last date for doing so.
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4 JUDGE MILLER:
Yes.
I understood Mr. Jordan had stated that's what he intended to do.
Not later than the e
5 h
8 6
scheduled date, but he also indicated as soon as,he could, or e
f7 even piecemeal, that he would give notice.
I think that's been
,f8 agreed to.
dd 9
MR. REYNOLDS:
Thank you.
i h
10 JUDGE MILLER:
Anything else that anyone has to 3
g 11 suggest in the way of expediting the upcoming conclusion of k
d 12 this stage of the hearings?
3md 13 (No response.)
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E 14 JUDGE MILLER:
All right.
a 2
15 You may proceed, Mr. Jordan.
16 MR. JORDAN:
Thank you, sir.
g e
d 17 BY MR. JORDAN:
I 18 G
Mr. Tolson, do you have before you CASE Exhibits 106
=
19 through 172?
8 n
l 20 BY WITNESS TOLSON:
l l
21 A
Yes, sir.
l l
22 g
Can you explain what the purpose of these documents is ?
23 BY WITNESS TOLSON:
24 A
I'd like to ask Mr. Chapman to discuss that.
25 g
Mr. Chapman.
l ALDERSON REPORTING COMPANY, INC.
1
1844 4-8 1
BY WITNESS CHAPMAN:
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2 A
One of the things I think we need to recognize from 3
the start here is that when we're talking about surveillance,
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4 surveillance reports and surveillance activities, we're talking e
5 about an activity that is outside the scope of 10 CFR 50, 6
Appendix B, and is used by us as a management tool to give us a R
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little bit more broader view of our quality assurance activity, X
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and so when you go through these surveillance reports, they need d
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to be looked at in that light.
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Let me follow that response, Mr. Chapman.
Well, I E
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g 12 asked, though what you stated is useful, and that is what are B
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13 these documents?
l 14 BY WITNESS CHAPMAN:
n 2
15 A
Those are site surveillance reports.
They appear g
16 all to be the same type of document.
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And what is a site surveillance, of which these are 18 reports?
0 19 BY WITNESS TOLSON:
R 20 A
Mr. Jordan, just to echo what Mr. Chapman said, 21 this is a report of managemen'. activities that we do over and 22 above the requirements of 10 CFR 50, Appendix B.
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23 4
I'm sorry I --
24 JUDGE MILLER:
Nobody has yet told us what they are, 25 gentlemen.
What are they?
Generically, what are these?
How ALDERSON REPORTING COMPANY, INC.
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1845 l-9 1
do they fit into your record keeping activities?
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2 WITNESS CHAPMAN:
A surveillance is basically a 3
broad, a more broad activity than an audit.
It's done -- we 4
have used it in the past primarily as a tool to identify possible 3
5 areas where perhaps more management attention should be placed, A
6 that management attention being audits, for instance.
It's a R
R 7
kind oi' an early detection system to help us, help guide our N
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formalized quality assurance program, in its effort to perform dd 9
the functions of detecting, identifying and resolving non-i h
10 conforming matters.
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25 ALDERSON REPORTING COMPANY, INC,
1846 15-1 1
G Is that correct?
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2 BY WITNESS CHAPMAN:
3 A
- yes, 4
G Do they cover the full scope of activities at the 5
site?
Not each individual one but the program?
3 0
BY WITNESS CHAFMAN:
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7 A
Yes.
On a seleted badis.
It's across the Board.
Ml 8
g And just for clarity, in reviewing these, if we look d
to CASE Exhibit 106, it appears following the term Item / Activity o
h 10 Description, this particular one reads:
El II
" Control of operational travelers."
ri 12 3
Nould we then, at least in most cases, be. able to S
OE' determine the euhsece of the audit -- 1 m sorry -- the uhsece of l
14 the surveillance and the resulting report from that descr,iption?
15 BY WITNESS CHAPNAN:
j 16 A
Yes.
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And these particular surveillances, do they involve --
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18 Well, let's look at the first one:
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19
" Control of operational travelers."
CASE Exhibit 106.
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20 It says that this is an in-process surveillance.
2I BY WITNESS CHAPMAN:
22 A
That is correct.
23 g
Does that mean that you or whoever performed the 24 surveillance,in effect --
25 ALDERSON REPORTING COMPANY, INC.
is-2 1847 00P I
BY WITNESS CHAPMAN:
2 A.
Observed the use of the travelers system.
That's 3
what it would mean to me, yes.
O 4
a oxey.
5
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Did the individual then, who performed the j
6 surveillance, go to a record of the travelers and review it's use?
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7 Review the use of the tr.tvelers in that record; is that the m
point?
d ci 9
BY WITNESS CHAPMAN:
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10 A.
Mr. Jordan, it could have included that act.ivity.
3=y 11 We've just been presented these reports and in order to fully D
l 12 understand the scope, then we'd have to spend a little time S
13 reading each one to get an answer to your question.
l 14 Depending on the particular status, if you will,
$l 15 of the activity that was being surveilled, then that's really a
j 16 what the bottom line is.
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17 Unless you read the case, you can't really tell.
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18 0
Mr. Chapman, I do want to be clear on what you first 19 g
said in response to questions concerning the site surveillance 20 reports.
21 I believe you said that they were not required ~by C)
Appendix B, in your view --
23 BY WITNESS CHAPMAN:
th A.
I said my surveillance is not an activity recognized by 25 Appendix Bf as are audits, inspections, tests and so forth.
ALDERSON REPORTING COMPANY, INC.
18 @
3-3 1
O Okay.
Thank you.
f 2
MR. REYNOLDS:
Mr. Chairman, I'd like to object to 3
this line of cross-examination.
The witness has already
)
4 testified that it is not required by Appendix B, therefore, it is 5
not a formal part of th, quality assurance program that is h
6 required by NRC regulations.
R 7
It is an activity that is conducted above and buyond 3
8 8
the legal requirements for quality assurance and, therefore, it's d
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not relevant to what the point Counsel is trying to make.
.z h
10 JUDGE MILLER:
It may be.
E 5
II We haven't had yet clear cut boundaries; insofar as it S
9 I2 e
does seem to have some relationship to quality control, at the S
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5 moment we'll let it in and see where it's going.
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l 14 Try to keep it within the scope, however, of,your --
g 15 MR. JORDAN: I expect it to be -- I hope, one question.
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16 BY MR. JORDAN:
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And the question is, does the Applicant rely at all e
18 on the site surveillance reports to assure its compliance with F
l 19 g
Appendix B7 n
j 20 BY WITNESS CHAPMAN:
l l
21 A.
To a degree, although that is in addition to our lb 22 normal formal approved quality assurance program.
That is V
23 ;
additional.
l 24 MR. JORDAN: That would complete our handling of
's 25 CASE Exhibits 106 through 172.
l l
ALDERSON REPORTING COMPANY, INC.
l
i-4 1849
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JUDGE MILLER:
Very well.
i 2
Are there any -- you haven't concluded your 3
examination on that subject; have you?
4 MR. JORDAN:
On which subject?
5 JUDGE MILLER:
On all subjects covered by you so far, 3
6 in order to turn it over to anyone else --
R b
7 MR. JORDAN:
Oh, no.
N 8
8 JUDGE MILLER:
All right.
d 9
Go ahead.
h 10 MR. JORDAN:
I have tended to the parties, the witness i
j 11 panel and the Board, a set of -- and a short set of documents D
g 12 which I believe we can similarly stipalate to.
I don't know 5
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13 whether Counsel has the same technical objection to these or not.
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14 JUDGE MILLER: What are these, generally?
15 MR. JORDAN:
These are -- for everyone's information, i[
I0 these are -- these appear to us, at least, to felate to the as I7 Applicants relationship or -- the reasons the Applicants changed IO its QA Program in 1978, when, in effect, it integrated its own C
i.
I9 8
management into Brown & Root more thoroughly in a non-ASME Area.
n 20 JUDGE MILLER: They don't appear to be separately 2I numbered.
Are you going to introduce them as a group?
l '";
22 MR. JORDAN:
We did not number them yet, Your Honor.
H 23l This one had slipped through the crack, I'm afraid.
There are I
24
'l very few and I think we can number them very quickly.
J 25 !
JUDGE MILLER:
All right.
l ALDERSON REPORTING COMPANY, INC.
1650 4-5 1
MR. JORDAN:
And I would proceed with the same 2
cryptic description.
3 JUDGE MILLER:
Very well.
O 4
MR. aoRo^n:
c^SE Exhibit 173 is e two-gese documene, o
5 the first page of which has anumber toward the upper left, QBR-006.
h j
6 I note for the record that I believe on every page R
7 of every document, of every one of these documents that I'm A
8 8
going through at this moment, there will be a typed -- somewhere, d
9
,usually at the upper right, CASE Exhibit 20 and that, in most o
h 10 cases, should have been marked out already and a type in page 5
II number.
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12 Those were put on there by CASE, for your information, S
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13 as part of our exhibits to the-Summary Disposition Motion.
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l 14 JUDGE MILLER: They will be disregarded.
15 MR. JORDAN:
CASE Exhibit 173 -- I'm sorry.
g 16 174 is a two-page document, headed ' Texas Utilities us f
I7 Services Inc.
There appear to be an R and E written in in IO handwriting above the Texas Utilities Services,Inc.
E I9 8
CASE Exhibit 175 is a one-page document.
There is a n
20 number to the upper left, QBR-29.
21 CASE Exhibit 176 is a four-page document with a
' g3 number on the first page of the upper left corner, QBR-31.
22 V
23 Correction.
It is a five-page document.
CASE 176.
24
,3 U
1 25 ALDERSON REPORTING COMPANY, INC.
1851 6-1 1
CA'iE Exhibit 177 is a three-page document.
On the Q
2 first page of the upper left, QBR-40.
3 CASE Exhibit 178 is a two-page document.
On the O
4 rirse vese ia the uover 1ere, OBR-52.
e 5
CASE Exhibit 179 is a two-page document.
To the b
6 upper right there is a date, January 3, 1978, below which is a R
7 number TVR-414.
Al 8
CASE Exhibit 180 is a one-page document with a date d
c 9
January 7, 1978, telegram to J.T.Munisteri, from R.J.' Gary.
2:
10 CASE Exhibit 181 is a two-page document which is II Brown & Root letterhead and appears to be a letter dated January is N_ I2 10, 1978 to Mr.
R.
J.
Gary, Texas Utilities Generating Company, s
g 13 CASE Exhibit 182 is a three-page document.
To the I4 upper left under Brown & Root,Inc., it states, January 10, 19 --
m 15 a three-page document, I believe I said -- under Brown & Root, Inc. it states January 10, 1978 and GE-BQ-XX-0263.
CASE Exhibit 183 is a two-page document.
To the z
18 upper left, below Brown & Root, Inc., it states GE-BA-XX-0264.
l
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l 19 g
CASE Exhibit 184 is a one-page document.
To the-20 upper right it states March 20, 1978 and the number QBR-62.
'l CASE Exhibit 185 is a one-page document on Brown &
Q Root,Inc. letterhead, dated March 31, 1978 to Mr. R. J. Gary, 23 from Mr. Munisteri.
It is stamped, Received, April 5, 1978, O
a 3-oerr-25 CASE Exhibit 186 is a three-page document.
To the ALDERSON REPORTING COMPANY, INC.
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.16574 3-2 1
Ep upper left is the number QB R-64.
O 2
CASE Exhibit 187, is a one-page document.
To the 3
upper right is September 26, 1978 and QBR-65.
O 4
an aErnotos:
xar 1 inautre or coun e1 it he he-e 5
provided the panel with one or two sets?
b 6
MR. JORDAN:
I believe we have supplied two sets R
7 to the panel or attempted to.
Nl 8
MS. ROTHSCHILD:
Mr. Jordan, which was CASE 184?
dd 9
MR. JORDAN:
184?
bg 10 JUDGE MILLER: A one-page letter dated March 20,1978, i
j 11 QBR-62.
D p
12 MR. JORDAN:
Right.
5 13 JUDGE MILLER:
To Mr. Munisteri from Mr. R.J. Gary.
h I4 MR. JORDAN: Thank y ou.
g 15 BY MR. JORDAN:
16 g
G Turning to CASE Exhibit 174, Mr. Chapman, I would as h
17 ask you to turn to the second page of that exhibit.
x
!i 18 BY WITNESS CHAPMAN:
j P"
19 8
A Mr. Jordan, I believe that Mr. Tolson is more familiar n
i l
20 with this particular --
21 g
That's fine.
O Sir, at the end f the paragraph at the top appears 23 the following sentence:
"The designer is showing some sign of I
recognizing that the 'Nothing can be done i
ALDERSON REPORTING COMPANY, INC.
1853 6-3 4
I so poorly by Construction that i' O
2 cannot be accepted en a use-as-is.
3 basis' syndrome has some undesirable O
4 onsoins effects -
e 5
In that sentence, is the Designer -- who is the 5
h 6
Designer?
R b
7 BY WITNESS TOLSON:
Xl 8
A.
I would assume, Mr.
Jordan, the is his referring rJ d
9 to the construction engineering group representing Gibbs & Hill
,z 10 on the site.
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11 4
The subjects of the memorandum as a whole, as we can U
g 12 see from the first page of it, B & n QC performance, and it s
13 appears, as one reads it, to be related to B&R QC performance.
l 14 Were you involved in the meeting that is reflected 15 in this memorandum, CASE Exhibit 174, which on the first page j
d 10 as having been called by Don Hansford?
as II BY WITNESS TOLSON:
ec I0 A.
It's Dan Hansford, and no, I did not participate in e'
I
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g this particular meeting.
20 0
Are you, Mr. Tolson, or Mr. Chapman, aware of a 21 concern that arose at the time of this memorandum, which is May 22 14, 1956, of a concern that is reflected in the last sentence
- O 23 of the first paragraph on the second page of the document, related 24 to accepting matters on a "use-as-is" b asis syndrome?
25 1
ALDERSON REPORTING COMPANY,INC.
1854 6-4 1
BY WITNESS TOLSON:
M 2
A.
I think I have a general understanding of what the 3
intent of the statement is yes, sir.
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What is that understanding?
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BY WITNESS TOLSON:
hj 6
A.
.A large construction job, when you first get R
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started, you've got what I'll call a human break-in period where N
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it takes a relatively long time for people to get used to working d
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together and getting communication links established and that 5
g 10 sort of thing and the way I would interpret that particular j
11 statement, it is primarily educational. In this case, on the 3
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12 part of the QA/QC people, to understand the designer's recipe S
13 in all casec.
It does not in all cases have to be perfect, from l
14 a performance standpoint.
2 15 BY WITNESS CHAPMAN:
y 16 A.
I think there's another dimension here.
I think-as 6
17 this break-in period also requires or is required so that everyone s
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18 associated with'the" job recognizes that there are in almost E
19 g
engineering activity of any kind -- not just nuclear -- there are n
20 many, many proper to design and construct an engineering project 21 construction.
22 The fact that it got constructed or was built some 23 way other than what a particular drawing showed, does not mean 24 that it was incorrect or inadequate.
a 25 The designer can only put one solution on a drasing.
l ALDERSON REPORTING COMPANY, INC.
1855
$ -5 1
So what it appears to me, with just the few minutes I've had O
2 to read ehis thing, it appears that there obvious 1, w,s some 3
concern as far as the QA man there.
Q 4
Now, the extent of it, the specific instance, I do 5
not know, but the break-in period that Mr. Tolson referred to j6 involves all these things that sometimes aren't apparent when you're R
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looking at that type of statement.
4 8
8 0
Yes, sir.
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5.
Mr. Tolson, if you can recall now, for the period of g
10 May, 1976 or to the best of your recollection, in that period of 5
5 Il time, 1976, was there a concern among the Applicants personnel a
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12 with a "use-as-is" syndrome on the part of Gibbs & Hill?
S 13 BY WITNESS TOLSON:
h 14 A.
No.
I think what Mr. Milam is trying to convey here 9_
15 is that in the course of the meeting, and I think you have to j
16 read --it would be preferable to read the whole' thing, as opposed a5 17 po picking out one sentence, because it is a summary of what had
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18 transpired in a time frame.
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One statement in particular, just to emphasize what n
20 re m trying to say -- back here on the first page, the third line 21 up from the bottom, It was talking about Mr. Hawkins who was 22 talking at that time.
He explained that the owner's QA has been 23, and will continue to be hard to satisfy.
24 So, really, I take that and the other statement into 25 context on both individuals, that they were, in essence, coming ALDERSON REPORTING COMPANY, INC.
i 1856 6-6 1
down real hard on, apparently, QA/QC and as a defense mechanism, i) 2 QC,says, "Well, hey, get off my back.
Why don't you get on 3
construction?"
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4 And therein lies the "use-as-is" syndrome, a
5 Okay?
I 6
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But without any specifics in the memo, then we're all R
R 7
out here philosophizing on this.
Ml 8
Now, let me ask you, was there a concern with the O
9 "use-as-is" syndrome on the part of Brown & Root at that time?
E 10 BY WITh4SS TOLSON:
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Q 11 A
Within the context of that.way I've just explained D
y 12 it, I would assume that there was.
5 g
You do not -- you cannot recall personally?
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14 BY WITNESS TOLSON:
h 15 A
I wasn't at this particular session, so I don't know a
j 16 for sure what was discussed.
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Outside of this particular session, taking into E
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account your knowledge of the project at that time, can you n
0 recall such a concern?
With respect to Brown & Root?
2I BY WITNESS TOLSON:
22 A
Again, Mr. Jordan, within the context of the way
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3 I tried to exp1Ain it, yes.
G Okay.
Thank you.
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25 WITNESS VURPILLET:
Mr. Jordan, let me just briefly, ALDERSON REPORTING COMPANY, INC.
l 1857 I
so we can get this thing turned in the right direction
-- early
)
2 in the job, any job, when you have an inspector or inspectors 3
working the job and they find things that don't agree with the
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4 drawings and specifications and they identify those things, 5
they're doing their job.
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That item which has been identified is then given R
7 to the engineer and said, "Here is what we'd like to do about Al 8
this.
Is it okay the way it is.
It appears to be and it appears d
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that it will do what you intended."
zo 10 The engineer comes back and says, " Yeah.
That's okay.
E 11 Leave it like it is.
It meets our intent."
is y
12 Now, you go back to the inspector and say, "This 5:
13 5
item that you identified is okay like it is.", and you have to be o
l 14 careful in the beginning of a project, particularly one as E
2 15 important as this, that the inspectors, when they hear that two U
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17 attitude, "Well, hell, I'm not going to identify that.
They're 18 going to use as is anyway."
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20 attitude. And I think that's the purpose of this meeting and I 21 that they perceived this "use-as-is" syndrome, perhaps, in that 22 manner.
23 We wanted to make very sure with the people involved 24
-- that the inspectors understood they still had to go out and if 25 they found something not in accordance with a specific way the l
ll ALDERSON REPORTING COMPANY,INC.
1858 I
engineer had detailed it on a single drawing or a piece of the 2
specification or a procedure, we still wanted that identified ip 3
because certainly the inspectors were not qualified to make the 4
judgment as to whether or not you could leave it like that.
5 They had to assume that it was wrong and somebody el5e 6
had to look at it, so keep identifying.
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We wanted to make sure that that happened.
K 8
8 BY MR. JORDAN:
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I do want to be clear.
5H 10 p,
That is your understanding from your experience on
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You fI weren't --
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A Oh, yes --
9 15 g
-- available at the time at this project?
T 16 g
BY WITNESS VURPILLET:
6 17 A
That's right.
But it's one of the things on any w
18
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project that you have to.be;very careful about.
19 g
That certainly is the way I read that memo but, again, n
20 I was not involved.
2I g
Okay.
22 Now, if I may pursue for a moment with you, Mr.
23 Vurpillet, you emphasized the fact that this is a problem that 24 arises early in the job and I think you have explained it. It 25l is perfectly understandable for any of us.
ALDERSON REPORTING COMPANY, INC.
=.
1859 6-9 1
':y question is, shouldn't this "using as is" h
2 problem -- in other words, the decision to use things as is --
3 sorry.
Let me make it clearer.
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4 The situation of --
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25 i
ALDERSON REPORTING COMPANY, INC.
i
1860 (7-1 1
4 The situation "use as is during the life of the 2
project" should decrease during the live of the project?
3 BY WITNESS VURPILLAT:
4 A.
No, I didn't intend to imply that.
The thing that 5
should happen, that ycu should he concerned about at the 6
beginning of the job is the perception that the inspectors get R
6, 7
when they first see a disposition "use as is" that they don't 8
8 give up, if you will, and it's in the beginning of the job that d
ci 9
you have to be careful that the inspectors don't give'up.
As z
h 10 the job goes on and they continue to see this, then -- you've 3=
11 instructed them, and such, and they don't get as disturbed.
They f
12 don't get disturbed when they see that.
They recognize that S
Q 13 they should still continue to identify the problems and let the I4 people that are qualified judge whether they are acceptable as 15 they are or they're not.
It's the inspector's perception that d
I0 is primarily at the beginning of the job and n6t the "use as is,"
as I7 particularly in the beginning of the job.
a:
18 G
I see.
Sir?
E I9 g
BY WITNESS CHAPMAN:
n 20 A.
I would add, though, that it's not restricted to the 21 beginning of the job, but continually we strive to communicate 22 Q
back to the identifiers of the problems the reasons for such 23 dispositions so that we can continue to head off that kind of 24 concern.
25 G
Mr. Chapman, have you had a chance to see briefly ALDERSON REPORTING COMPANY, INC.
1 1861 37-2 1
each of the documents in the package --
2 BY WITNESS. CHAPMAN:
3 A
Yes, I have.
()
4 G
-- CASE Exhibits 173 to 187?
e 5
BY WITNESS CHAPMAN:
3 N
h 6
A Yes.
R R
7 G
When we, CASE, requested on discovery the correspondence s]
8 between Texas Utilities and Brown & Root related to the change-dd 9
over of quality assurance responsibilities that occurred in 1978, d
10 as I understand it this is what we were provided.
El 11 Would that be a fair description of these documents?
3 j
12 BY WITNESS CHAPMAN:
3
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d 13 A
I don't think it's -- I don't recall that it's an l
14 accurate description or tr.e question.
I believe the question 2
15 was documents that related to Brown & Root's performance, not g
16 limited to the change in organization.
e 6
17 G
Okay.
Thank you.
I'll take the correction.
5 18 Would these documents fit the description you just
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U 19 gave, having corrected me on what the question was?
g n
20 BY WITNESS CHAPMAN:
21 A
Yes.
22 G
Thank you.
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23 MR. JORDAN:
Your Honor, I don't recall whether --
i 24 either I moved or you ruled that CASE Exhibits 173 to 187 be
)
(
j 25 admitted.
i ALDERSON REPORTING COMPANY, INC.
1862 7-3 1
JUDGE MILLER:
Well, I'll eliminate any doubt.
They O
2 wi11 he admitted.
3 (CASE Exhibits Nos. 173 through 187 O
4 were marxea for iaentification ana e
5 received in evidence.)
h 6
(Long pause.)
R
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7 MR. REYNOLDS :
Mr. Chairman,.does that conclude cross M]
8 on CASE Exhibits 173 through 187?
dd 9
MR. JOFDAN:
Your Honor, in the same sense that I 10 previously stated with respect to the documents that we've El 11 previously been through with this panel of witnesses.
it g
12 JUDGE MILLER:
Very well.
5 13 MR. JORDAN:
I'd like to turn now to Ms. Spencer, l
14 her direct testimony.
2 15 MR. REYNOLDS.
Mr. Chairman, does that then conclude
=
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16 the cross-examination of Mr. Chapman?
- s1 I
17 JUDGE MILLER:
Are you through on cross-examination U
{
18 with Mr. Chapman?
i A
h 19 MR. JORDAN:
I could not say that I am through on M
l.
20 cross-examination with Mr. Chapman.
I'm through only with the l
i 21 particular notes that I had on specific points, but I can't say 22 that I'm through with him.
l (V]
[
23 MR. REYNOLDS:
Wouldn't it be more orderly, i
24 Mr. Chairman, to proceed and finish Mr. Chapman before we jump 25 around?
The record we've made so far would easily vouch for that, i
j ALDERSON REPORTING COMPANY,INC.
1863 l7-4 1
JUDGE MILLER:
Well, that may be, but the cross-
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2 examination interrogator has the choice.
e 3
BY MR. JORDAN:
O 4
a 81 s Svencer, r'a 11ke to he c1eer where you fit in e
5 the organization of which you are a part.
Would you appear on 2n 8
6 any of the attachments to Mr. Chapman's testimony, 42-A --
e N
7 Applicant's 42-A, B, C or D?
Does your position appear there?
N 8
8 BY WITNESS SPENCER:
a d
d 9
A Not my position, per se.
bg 10 G
I'm sorry?
Ej 11 BY WITNESS SPENCER:
is y
12 A
No.
O !
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'ua not' m
l 14 BY WITNESS SPENCER:
R 15 A
Not my position.
l j
I6 G
Could you describe what your position is in the i
as g
17 hierarchy?
18 BY WITNESS SPENCER:
4 O
i 19 A
If you look at Applicant's Exhibit 42-B, the ge 20 orientation chart entitled TUGCO/TUSI Home Office and CPSES Field j
21 Organization, I report to the supervisor of QA services under 22 the manager of quality assurance.
I 23 G
Okay.
Do you report directly to that supervisor?
(
24 BY WITNESS SPENCER:
25 A
Supervisor of QA, yes.
I ALDERSON REPORTING COMPANY,INC.
1864 (7-5 1
JUDGE MILLER:
Mr. Vega?
2 WITNESS SPENCER:
Mr. Vega, yes.
3 BY MR. JORDAN:
O 4
o.
Ana r unaer tena it, your runction is taee ce en e
5 auditor?
h h
6 BY WITNESS SPENCER:
7 A.
Yes, it is.
That's my title.
M]
8
///
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17 18 E"
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20 21 0
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25 ALDERSON REPORTING COMPANY, INC.
1865
- )-1 1 l g
You testified, beginning, apparently, on Page 6, I
()
2 Miss Spencer, concerning an unresolved I&E Report 80-20 relating 3
to circuit breakers, safety and non-ssfety cables, and I believe
( ))
4 you have attached the I&E Report 80-20 to your testimony -- J'm e
5 sorry -- that is Applicant Exhibit 44-A, 80-20, is that correct?
393 6
BY WITNESS SPENCER:
J e
Rg 7
A Yes, it is.
A g
8 g
Okay.
Thank you, d
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(Long pause.)
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10 JUDGE MILLER:
Who's on third?
E h
11 MR. JORDAN:
I'm --
F y
12 JUDGE MILLER:
Okay.
5 A}
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13 MR. JORDAN:
I don't know.
I think I'm at plate.
l 14 JUDGE MILLER:
You're at plate.
Okay.
Batter up.
l 2
15 BY MR. JORDAN:
j 16 g
The matter that is -- that:: arises in I&E Report 80-20, e
d 17 as I understand it, that particular matter was determined --
18 discovered by the Nuclear Regulatory Commission in its own P
19 inspections, is that correct?
R 20 BY WITNESS SPENCER:
21 A
Yes, it is.
22 g
It was not discovered through inspections of the jg U
23 TUSI/TUGCO organization?
L, 3 24 BY WITNESS SPENCER:
O 25 '
A To my knowledge, that's correct.
i ALDER:: ION REPORTING COMPANY, INC.
1866 1-2 1
G Miss Spencer, I would ask you whether this document
()
2 that is marked as CASE Exhibit 44-A is, to your knowledge, in 3
fact -- I'm sorry, marked as Applicant's Exhibit 44-A represents
(])
4 a complete record with respect to the matters that arose in e
5 I&E Report 80-20?
1 hj 6
MR. JORDAN:
Let me strike that.
R R
7 BY MR. JORDAN:
Ml 8
G Miss Spencer, you've been handed a document that's --
d c
9 of three pages, the first page of which has a date on it of i
h 10 September 24, 1980.
3l 11 MR. JORDAN:
I would ask that this document.be i
d 12 marked for identification as CASE Exhibit 188.
1 Eo in j 13 JUDGE MILLER:
So marked.
%/ a 14 (CASE Exhibit No. 188 was l
2 15 marked for identification.)
i j
y 16 BY MR. JORDAN:
d I
d 17 0
Miss Spencer, this document relates to I&E Report
{
18 80-20, does it not?
E 19 BY WITNESS SPENCER:
R 20 A
Yes, it does.
21 G
And it includes a notice of violation, Appendix A 22 that is not included in Applicant's Exhibit 44-A, is that correct?
23 BY WITNESS SPENCER:
24 A
Would you repeat the question?
l 25 0
It includes a notice of violation headed Appendix A l
l l
ALDERSON REPORTING COMPANY,INC.
1 i
1867
,8-3 1
that is not included in Applicant's Exhibit 44-A, is that correct?
()
2 BY WITNESS SPENCER:
3 A
It does include -- your CASE Exhibit 188 does include
()
4 the attachment Appendix A, yes.
=
5 MR. JORDAN:
Your Honor, we would move the admission En h
6 of CASE Exhibit 188.
R 7
JUDGE MILLER:
Any objection?
E]
8 (No response.)
d c;
9 JUDGE MILLER:
It may be admitted.
E 10 (CASE Exhibit No. 188 was 3mg 11 received in evidence.)
3 N
12 BY MR. JORDAN:
3 13
()
0 okay.
On Page 6 of your direct testimony, h
14 Miss Spencer, near the bottom you begin a discussion of IAE a
g 15 Report 79-11.
m p'
16 Now, Miss Spencer, that relates, does it not, to a M
17 situation involving pouring concrete on the dome of -- involving a
18 a concrete pour on the dome of Unit 2 -- I'm sorry, Unit l?
E 19 9
BY WITNESS SPENCER:
M 20 A
Yes, it does.
21 g
Can you describe for us the situation that is raised, 22
{)
that is the subject of that I&E report, as discussed in your 23 testimony, Answer 12?
It appears to have been a situation of 24 some damage to the work that had been done and then a repair 25 undertaken by the construction crew.
My question is, could you ALDERSON REPORTING COMPANY, INC.
1868 D-4 1
describe for the Board what you -- or perhaps Mr. Tolson, A
ls_)
2 describe for the Board what the quality assurance / quality control 3
activities should have been with respect to those construction
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4 activities?
g 5
BY WITNESS SPENCER:
h 6
A I'll let Mr. Tolson answer that question.
R 7
BY WITNESS CHAPMAN:
K]
'8 A
Mr. Jordan, on matters of this type, I believe that dd 9
if the issue is how the matter was carried, closed out, responded b
10 to, to the NRC, whatever, that type question should be directed 11 to Miss Spencer.
S y
12 Anything related to the actual quality assurance /
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13 quality control specifics should be directed to Mr. Tolson or l
14 Mr. Vega or myself.
$l 15 g
Okay.
Thank you, Mr. Chapman.
I'll certainly try x
y 16 to do that to speed things along.
s 6
17 Mr. Tolson, you're a viewer now at the plate.
18 BY WITNESS TOLSON:
A 19 A
Well, I just dropped the ball.
Would you repeat 20 the question?
21 (Laughter.)
22 G
okay.
The question is, in the circumstances
)
23 discussed on Pages 6 and 7 in Answer 12 of Miss Spencer's 24 g
testimony involving this correction to a problem that arose in V
25 I the concrete on the Unit 1 dome, what should the quality ALDERSON REPORTING COMPANY, INC.
1860
$8-5 1
assurance / quality control involvement have been?
()
2 BY WITNESS TOLSON:
3 A
Okay.
First of.all, we should have been on site.
(])
4 Secondly, it -- you know, I hope you and the Board are fully i
e 5
familiar with the details, or at least I know you are.
h 6
G Don't count on it.
E d
7 BY WITNESS TOLSON:
A 8
8 A
We're talking about one-half cubic yard of concrete.
d i
c; 9
The inspector should have been on site.
There would not have i
10 been any -- for that small a volume of concrete -- have been Ezg 11 anything other than just presence to be there to be able to state 3
f 12 that ' yea, verily,' the concrete was batched and replaced in o
I (])
13 accordance with the standard requirement.
l 14 BY WITNESS CHAPMAN:
4 g
15 A
Mr. Jordan, I believe a review of some of the details x
16 is in order.
That particular placement was begun under normal j
e d
17 weather conditions.
And I think a little background is worth-i 5
5 18 while to understand why there was no quality assurance personnel e
19 on the site at the time.
g n
20 The records will indicate that before this particular 4
21 placement was finished, the weather deteriorated and it began 22 to rain.
The placement was terminated.
It was covered to p
,i s_)
23 protect it from the rain, secured for normal curing and as --
24 since there was no further work planned, the quality control l
25 !
people involved left the site and went home.
ALDERSON REPORTING COMPANY, INC.
1870
,8-6 1
Subsequent to their departure the rain increased O(_/
2 greatly, to the extent that part of the protection was washed 3
away and some of the concrete.
()
4 The concrete craft management personnel in charge e
5 recognized what the situation was and in an attempt to make the h
j 6
best of a bad situation, knowing, from his knowledge of concrete R
7 placement that something should be done before it set up, he M
8 8
then proceeded to batch this small amount of concrete, since he d
q 9
had access to the information to get the proper mix.
He 10 personally batched it and supervised the placement of it to E
11 salvage the pour, and therefore it could be that -- in those k
I 12 unusual circumstances, even had he tried to get in touch with 5
{])
13 the quality control person, it's not altogether unlikely that 14 they couldn't have gotten out there in time, so still there's a --
g 15 it was an attempt on -- a misplaced attempt on the part of a x
g 16 craftsman to do the job right.
Otherwise he would have gone to e
6 17 the trouble to get the batch ticket and make sure he was getting 5
{
18 the proper proportions.
E 19 g
G Now, in the normal course, however -- in fact, is it n
20 not the requirement, for one thing, that the batching itself be 21 done subject to quality control?
22 BY WITNESS CHAPMAN:
23 A
That's correct.
24
("3 G
And so the batching should have been done and then (m/
25 I the actual placement of this concrete should have been done ALDERSON REPORTING COMPANY, INC.
1871 D-7 1
subject to quality control?
2 BY WITNESS CHAPMAN:
3 A
That's true.
4 BY WITNESS TOLSON:
e 5
A May I clarify that, Mr. Jordan?
b h
6 Q.
Certainly.
R 7
BY WITNESS TOLSON:
s 8
8 A.
The actual batching activities, the batch plant is r.5 ci 9
all the way to the back of the plant so we're talking about 5g 10 basically an observation type, it's a presence type QC effort,
!!!x Q
11 if you will, as opposed to some sophisticated testing program in
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12 or thing,' stuff of that nature, for the batching operation.
5 N
13
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20 21 in 22 I.k,_.)
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24
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1 ALDERSON REPORTING COMPANY. INC.
1672 1 Ep 1
G And the means by which the company learned of this I) 2 situation was as the result of an anonymous allegation made to 3
the Nuclear Regulator Commission; was it not?
Which later turned
()
4 out to be true?
5 g
BY WITNESS CHAPMAN:
9 6
A That's partially true.
R
- S 7
Our people received a phone call sometime in March N
j 8
of '79 and my site personnel conducted an investigation.
It d
q 9
lasted several days.
I don't know how long and concluded, 2
O h
10 essentially, that as faras they could tell, the allegation had
=
II merit.
D g
12 Later that month, possibly a few days to a week 5a 13 5
later, the NRC Region 4 received a; telephone-call, as I understand s
m l
14 it, from someone -- I guess we can presume it is the same. person.
2 15 They conducted a prelminary investigation and j
16 originally, I don't believe'they'could1 substantiate any allegation, w
b' 17 About that time -- they were still conducting their 5
18 investigation and meeting with this individual.
E l9 g
About that same time, Brown & Root Construction management n
20 personnel started investigating and, as a result of all these 2I efforts and a review of some of the records, because apparently 22 rg the alleger was not sure exactly what date it could have occurred
%J 23 on and I believe the records will indicate the meteorlogical 24 g
records were examined to try to determine from that data what (J
25 l it could have been.
l ALDERSON REPORTING COMPANY,INC.
1873 L9-2 1
I don't know.
Maybe Ron, Mr. Tolson, can refresh l
O 2
my memory but it was finally determined that it had to be one 3
particular night and from that it was isolated to one concrete O
4 senere1 fore-n, so it was, I euess, e combination of inveeeiseeive 5
j effo ts.
r 6l It wasn't altogether from an alleger to the NRC.
7 It was kind of a two-way --
3 8
0 In other words, there was first, in effect, an d
q 9
alleger who went to the company?
z BY WITNESS CHAPMAN:
11 A.
That's correct.
i j
it f
12 G
To your knowledge, was that anonymous?
13 BY WITNESS CHAPMAN:
l 14 A.
Yes.
m g
15 G
Do you now know who that alleger is?
a:
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16 BY WITNESS CHAPMAh:
cr5 N
I7 A.
I do not.
IO G
Ms. Spencer, a-page 10 of your testimony, Answer 18, 4
s
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19
-- Answer 17, actually, you state:
i 20
" Discrepancies cited in I&E Report 8115 21 have been identified as nonconforming i
22 conditions in accordance with established 4O 23 QA procedures."
i 24
.p Now, my question is, does that mean that once the jV 25 company learned of these conditions as the result of the I&E i
ALDERSON REPORTING COMPANY, INC.
1874 1
Report, they were then identified as nonconforming conditions A
2 and normal QA pr'ocedures were followed:
U1
,9-3 3
BY WITNESS SPENCER:
4 A.
To the best of my knowledge, yes.
e 5
g Mr. Tolson, can you state further?
h 6
BY WITNESS T0LSON:
R S
7 A
I'm sorry, Mr. Jordan, it's getting later and later X[
8 in the week.
Could you repeat your question?
dd 9
0 Yes.
z, 10 The first sentence on Page 10, Answer 17 of Ms.
II Spencer's testimony, do you know from the number what I&E Report is f
I2 8115 is?
e 13 (J3 5
BY WITNESS TOLSON:
m l
14 A.
I'm' familiar with the subject, per se.
g 15 g
You are?
Okay.
e g
16 It states that the discrepancies cited in that report I
^
17 had been identified.as nonconforming conditions in accordance m
18 with established QA proedures.
i':"
19 g
That means, does it not, that after you learned of the n
20 conditions and discrepancies as a result of the NRC inspection 2I that led to 8115, then you identified them as nonconforming 22 conditions in accordance with established QA procedures and handled C-)
23 them normally?
From there.
24 BY WITNESS TOLSON:
25 A
That's correct.
ALDERSON REPORTING COMPANY, INC.
1875 9-4 I
BY WITNESS VEGA:
1ll 2
A..
I would like to make a point related to that question.
3 We had conducted an audit on the same type of
(])
4 activity relative to concrete.
We had iden.;ified a deficiency 5
g via the audit about a week-- and I'm speaking from memory --
9 6
before this particular inspection report or the NRC inspection ReS 7
was conducted.
M 8
8 And so we had some corrective action going on in an dd 9
area very similar to this and it can really be identified as 10 part of the problem and I believe the Commission so rotes in
=
k II their report.
S y
12 JUDGE 11C COLLOM:._What stage:.of completion are the 5
i('N 13 so-called identified and corrected in accordance with approved
' \\m/
m l
14 procedures?
g 15 WITNESS TOLSON:
We're staying substantially on e
g 16 schedule.
We're having a tough time pulling the completion i
e h
17 figures just off the top of my head.
e l
M 18 The inspection efforts associated with correcting P"
19 8
the deficiency is targeted to the major milestones of the project.
n 20 21
///
22 t0 23,
i 24 in
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25 '
l ALDERSON REPORTING COMPANY, INC.
1976
-l
'p 1
MR. REYNOLDS:
Would this be a convenient time to m,j 2
take five-minute break?
s 3
JUDGE MILLER:
Yes.
4 (Short recess.)
5 JUDGE MILLER: You may proceed.
h 6
MR. JORDAN: Thank you, YOur Honor.
R Cg 7
BY MR. JORDAN:
3 k
0 A
Turhing'to the I& E Report, which is Attachment 3 d
a 9
to Ms. Spencer's testimony, and Applicants Exhibit 44B, I would 0
10 have you turn to the first page of that exhibit, at the bottom
=
h of which is the number 3.
I think it's the fifth page of the d
12 5
exhibit.
Or perhaps we can be;in with the one numbered 2.
i 13 Protective coating.
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l 14 Mr. Vega, you were responding in respect to this g
15 matter. Can you tell me, at the time of this inspection, which e
g 16 was October of 1981, how long had the protective coating e
b^
17 applications of concrete in containment building 2 been going on 5
18 at that time?
P
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19 BY WITNESS VEGA:
n 20 A
I can't tell from this report.
21 g
Does anyone else know?
~s 22 BY WITNESS TOLSON:
m) 23,
A Not specifically, Mr. Jordan.
yS g
Are you able to give an estirtate of a year, six 24 m/
s 25 months, anything of that sort?
ALDERSON REPORTING COMPANY, INC.
18??
I BY WITNESS TOLSON:
V 2
A.
The order of magnitude of a year would be reasonable.
Sop 3
g Were the records for the Containment Building No. 1 O
4 coatins
=1 11er1r xeve, to your xno 1ea e?
s 5
g (No response.)
N 6
g Perhaps you didn't understand it.
I'll rephrase it.
R E,
7 This I&E Report 8115, Applicants Exhibit 44B, reflects M
8 findings related to the records for the application of concrete d
9 in -- the coating application on concrete in Reactor Containment o
g 10 Building No.
2.
E j
11 And my question simply is, did you keep your coating in y
12 records for RCB 1 in the same fashion?
5 13 BY WITNESS TOLSON:
g
.)
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14 A.
Mr. Jordan, I don't believe this report addresses g
15 the concrete coating of Unit 2.
m j
16 g
I believe I'm reading -- let's make' sure we're in a5 17 the same place.
x
{
18 I&E Report 8115, Applicants Exhibit 44B, which is A
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19 to the Spencer testimony.
n 20 I read on the third page of the report, which has 21 the No. 2 at the bottom, 3 (a).
22 p)
"The NRC Inspector reviewed six records 23 of protective coating application on 24 concrete in Reactor. Containment Building Number 2."
ALDERSON REPORTING COMPANY, INC.
1878 I
BY WITNESS TOLSON:
0-3 I_)
2 A
Okay.
Now, I'm with you.
I was on Page 5.
SP 3
g Okay.
$)
4 My questica simply is, were the records for the coating 5
j application on RCB 1 kept in the same fashion as those on RCB 27 4
2 0
BY WITNESS TOLSON:
4 M
7 A
Well, the record keeping system was the same.
I'd n
8 8
have to go back and look at those records to see if it was a
d 9
similar to what is discussed in here.
10 g
Okay.
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l II Now, Mr. Vega, I think you testified a moment ago k
g 12 to an audit that, in effect, would have or perhaps already had 3
({}
g 13 found the deficiency.
E 14 w
Is that not the audit referred to on the following g
15 page?
Page -- numbered Page 3, which is the fifth page of x
i j
16 Applicants Exhibit 44B.
e 4
f I7 i
BY WITNESS VEGA:
m IO A
Yes.
E 19 l
3 g
Now, t he following item on that same page refers n
20 to steel coatings application and on the following page is an 21 indication of a violation with respect to t' hose coatings O
eve 1tc tioa-23 First, could you simply tell us, what's the purpose 24 of the protective coating application on steel, referred to 25 tnere?
ALDERSON REPORTING COMPANY, INC.
k 1873 I
BY WITNESS TOLSON:
0-4 2
A It serves two basic functions.
One is protection i
3 from corrosion in the environment of the containment structure
)
4 and, secondly, the concept of a coating, the only reason we 5
g inspect it is, you want some assurance that it's not going to 4
6 peel off and clog up the sumps...
R S
7 g
And the coating is safety related; is it'not?
A O
k 0
BY WITNESS TOLSON:
d 9
A It is covered under the inspection program, yes, sir.
O 10 y
G And, in fact, if it were to peel off and plug up
=
f
~
the sumps, as you raised that concern, that would raise a concern d
12 z
for Safety; wouldn't it?
S l l BY WITNESS TOLSON:
E 14 g
A As I understand the engineering aspects of it', yes, e
2 15 sir.
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16 e
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///
18 E"
19 8n 20 21 ll I
23,
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25 ALDERSON REPORTING COMPANY,INC.
______d
l 1880
.1 1
Q Miss Spencer, on Page 12 to 13 of your testimony lll 2
there appears a discussion of ;ework performed on the Unit 2 3
reactor vessel support structure.
lg) 4 I take it, Miss Spencer, in which it was discovered e
5 that the reactor vessel supports were off by, I believe, 45 6
degrees, so that it was out of phase by 45 degrees, e
R 7
BY WITNESS SPENCER:
M 8
8 A
Yes.
dd 9
g such that in fact you couldn't put the reactor in it, io 10 is that correct?
E h
11 BY WITNESS SPENCER:
3 y
12 A
I believe that's so, yes.
E p} j 13 You testify that this occurred as a result of a m
l 14 design error, Miss Spencer.
Would that be then a design, an 2
15 error that occurred, or caused, caused by -- I don't know what 5
g 16 the cause would be, but was the responsibility-of the Gibbs and W
l 17 Hill engineering organization?
=
5 18 BY WITNESS SPENCER:
5
{
19 A
I believe it was an interface problem.
I think n
20 Mr. Chapman would like to address that.
21 G
Certain1;.
i 22 BY WITNESS CHAPMAN:
s I
a 23 A
It basically is an interface problem with the NSSS 24 designer, the nuclear steam supply sustem designer, and the
-w x-]
architect engineer, where there as a question about whether the l
25 !
l l
ALDERSON REPORTING COMPANY,INC.
i 1881 1-2 1
Units 1 and 2 were to be mirror image or same hand, if that's
-m,)
2 descriptive enough, or were they to be mirror image reflections 3
of one another.
Does that answer your question?
-~
)
4 g
Well, my question was whether in effect Gibbs and e
5 Hill made the design error.
A 4
6 BY WITNESS CHAPMAN:
R 7
A No.
3 8
8 g
Then Gibson and Hill and Westinghouse made the design dd 9
error?
io 10 BY WITNESS CHAPMAN:
3 h
11 A
No.
There's no design error involved.
It's an 3j 12 orientation mistake or misunderstanding or what have you, wherein S
13 one entity is planning to have a same-hand orientation for Unit 2 r')
g x/
m l
14 as was for Unit 1, and the other organization had the NSS,S system,
{
15 the reactor vessel in this case, oriented as a mirror image.
=
j 16 JUDGE McCOLLOM:
Why did they have'the difference?
W b'
17 WITNESS CHAPMAN:
I can't answer anything very 5
{
18 specifically other than some units that Westinghouse in this case P
g had provided NSSS systems for, I understand. have in fact used 19 n
20 mirror image so that it's not unusual for that to be the case.
21 Mr. Vega can address that better than I can.
22 WITNESS VEGA:
Dr. McCollom, at first it was sort of r~3
%)
23 a trade-off between duplication of engineering design or 24 duplication of components.
It was felt at one time that having r3d 25 a mirror image plant would cut down on engineering and that that I
l ALDERSON REPORTING COMPANY, INC.
A 1882
.-3 1
was a desirable aspect.
)
2 Westinghouse, on the other hand, because of placing 3
long-term orders with their subcontractor, Combustion Engineering,
)
4 had contracts in for Combustion to build for Westinghouse several e
5 reactor vessels.
However, those vessels were identical, and so E9 6
at this particular point the benefit of having identical R
7 components, as opposed to components that could fit into mirror X
y 8
image designs, the decision was made to go identical component.
dd 9
There was discussion on both sides, Westinghouse --
io 10 it wasn't a total lack of interface, rather it was Gibbs and Hill 11 understood that Westinghouse would provide a mirror image vessel; 3
{
12 Westinghouse understood that Gibbs and Hill would accontmodate
(]}
Sg 13 their identical component concept.
l 14 BY MR. JORDAN :
2 15 G
Now, as I understand it, this situation was discovered g
16 after the supports for the Unit 2 reactor had been constructed, W
g 17 correct?
E 18 BY WITNESS VEGA:
k 19 A
That is correct.
g n
20 g
Was this matter reported to the Nuclear Regulatory 21 Commission?
22 BY WITNESS CHAPMAN:
23 A
I don't believe it was.
24 BY WITNESS TOLSON:
25 !
A Mr. Chapman, can I clarify that?
The matter was ALDERSON REPORTING COMPANY, INC.
l 1883
-4 1
discussed verbally at the site with the Commission, but since l
2 the reactor vessel couldn't be assessed you're not talking in the 3
0.55(e) game because there's no way you could hook the plant up
)
4 to have a safety problem.
e 5
G When you say it was discussed at the site, you mean b
6 it was discussed with Mr. Taylor?
R 7
BY WITNESS TOLSON:
A 8
8 A
That's correct.
He was aware of the misorientation do 9
problem, and there was nothing formally required.
i h
10 G
And I take it that the company's position was that j
11 there was no safety significance to the fact that the reactor a
y 12 could not be placed in the containment?
l b
13 BY WITNESS CHAPMAN:
Dg a 14 A
Well, there is no safety significance, Mr. Jordan, 2
15 if you can't place and operate the reactor.
The safety j
16 significance we're concerned with is the safety of the plant and e
d 17 the public.
If you can't set a reactor vessel in place and
{
18 connect the piping thereto, and subsequently be able to operate it 5
19 there's no safety significance at all.
gn 20 G
Now, I think you said this, but in order to remedy 21 this problem you had to go in and in effect -- well, let me ask 22 you, did you tear out the supports that had previously been l
23 constructed?
24 BY WITNESS CHAPMAN:
l 25 A
No.
And I previously stated that all the pads were j
l l
ALDERSON REPORTING COMPANY, INC.
1884
- 1-5 1
complete.
I don't think they were totally finished.
What
()
2 happened was some reinforcing steel, some holes were drilled to 3
take into account the different locations of the supports; some
(])
4 holes were drilled in the concrete, additional reinforcing steel e
5 was added to accommodate the concentrated loads at the new A
6 orientation -- or the new location of the support pads.
R 7
G And then you were able to place the reactor as the M
j 8
design had called for?
d d
9 BY WITNESS CHAPMAN:
io 10 A
Yes.
E l
j 11 G
Now, in the -- is it not the case that your activity k
j 12 to correct this, of drilling the new holes and putting in the 5
13 new supports for the reactor, that is indeed a safety related
(}
l 14 activity, is it not?
2 15 BY WITNESS CHAPMAN:
a j
16 A
That's correct.
e 6
17
///
s 5
18 E
19 8n 20 21
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23 i
(5) 25 t
I l
ALDERSON REPORTING COMPANY, INC.
1885 I
G I would like to get clear.
2- \\b 2
The design of the reactor is subject to quality top 3
assurance requirements; is it not, Mr. Chapman?
AV 4
BY WITNESS CHAPMAN:
5 g
A.
Definitely.
N 6
G Can you describe the quality assurance layers or R
b 7
requirements that this design would have had to go through up to A
j 8
the point of having constructed the supports that turned out to d
ci 9
be wrong?
Y 10 BY WITNESS CHAPMAN:
E 11 A.
The nuclear steam supply system is furnished by is y
12 Westinghouse and the design fabrication of that system comes 5
13 under the Westinghouse quality assurance program.
14 Once the components of that system reach site,, our g
15 site, then the installation of those components is under the a
j 16 Comanche Peak quality assurance plan, so that "- thl, is not as h
17 really unique to Westinghouse.
x
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18 Most of our vendors supply us services and its P"
19 g
for the plant under their own quality assurance programs.
n 20 G
Now, indeed, however, under Appendix B, is not the 21 Applicant responsiblc to monitor those quality assurance programs?
22 BY WITNESS CHAPMAN:
23 A.
This is correct.
And we have an audit program that 4
is -- that has conducted audits on not only Westinghouse but 25 other vendors, to assure their compliance.
AL DERSON REPORTING COMPANY,INC.
l id86 3-2 ee 1
4 And your responsibility applies to the design as 2
well as to the fabrication of those materials; does it not?
3 BY WITNESS CHAPMAN:
O 4
a.
neein, 1ee me seeee enee we, es ehenreticane, have 5
g the responsibility, regulatory responsibility for everything a
6 connected with this plant, from a safety-related angle.
R b,
7 G
But, specifically, you have a responsibility for 7.]
8 quality assurance of the design of the reactor; correct?
O ci 9
BY WITNESS CHAPMAN:
bg 10 A.
That's correct and Appendix B states that we are Il given the latitude through the regulations to assign specific is g
12 responsibilities for certain aspects of our own quality assurance
{Sg 13 to these vendors under their programs.
l 14 Although the ultimate responsibility remains with g
15 the Applicant for those quality assurance programs?
x y
16 JUDGE MILLER:
Wait a minute.
as h
I7 First of all, don't both of you talk at the same x
I0 time.
E I9 8
Secondly, This is getting very repetitious, Counsel.
n 20 You have gone over this three or four times now.
2I MR. JORDAN: Well, I think that's it, in any 22 event.
23 JUDGE MILLER:
Good.
24 BY MR. JORDAN:
D G
Ms. Spencer, can you tell us whether the Applicant ALDERSON REPORTING COMPANY, INC.
j
2-3 1887 op I
has made reports to the Nuclear Regulator Commission pursuant O
2 to loCrR, Part 21?
To your knowleage?
3 BY WITNESS SPENCER:
4 A.
Not to my knowledge, no.
5 g
Is it your understanding that 10CFR21 applies to the l
6 Applicant?
R b
7 BY MITNESS SPENCFR:
3!
O A.
In various degrees,yes, it does.
O C
9 g
Does it apply, in your understanding, to the extent
,Z h
10 that the Applicant would be required to make reports?
II MR. REYNOLDS:
Objection.
This is beyond the scope D
g 12 of direct.
9 13 JUDGE MILLER:
I believe it is.
l 14 Objection sustained.
g 15 BY MR. JORDAN:
age 3
a:
16 Spe gi g
Now, Ms. Spencer, in your testimon? you refer to us 6
17
" honeycomb conditions in the concrete placement of the Unit 2 5
{
18 Steam Generator compartment walls".
E g
Can you tell us how extensive that honeycoming was 19 a
20 on those salls?
Or Mr. Tolson.
2I BY WITNESS TOLSON:
22 A.
It included, of course the sizes with honeycomb 23 because you're talking about a surface phenomenon, to start with.
24 It varied in magnitude and dimensions with each one.
25 It would be in each one of the compai-tmehts.
ALDERSON REPORTING COMPANY, INC.
i 3-4 1868 Ep 1
For the averaging standpoint or in the interest of
()
2 trying to visualize the situation, it would run from a maximum 3
on the order of five by fifteen feet, down to infinitesimal size.
(])
4 g
Can you give us some estimate of the total of the e
5 percentage of the. area of the -- in the two steam generator U
6 compartments walls where honecombing occurred?
R d
7 BY WITNESS TOLSON:
A 8
A Yeah.
On the ord'er of ten to twenty percent.
d y
9 g
Ten to twenty?
10 BY WITNESS TOLSON:
3=
II A
Yes, sir.
And that is an estimate.
k g
12 g
And did the utility, the Applicant, report this S
{)
honeycombing matter to the Nuclear Regulatory. Commission as soon 13 l
14 as it was discovered?
2 15 BY WITNESS TOLSON:
}
j 16 A
Yes, we did.
I w
4 17 g
And in your response, are you referring to a report pursuant b
l Y
18 to Section 50-55(e) of the regulations, the Commission's E
I9 g
regulations?
n 20 BY WITNESS TOLSON:
2I A
That's correct.
l
~2 BY WITNESS CHAPMAN:
^
23 A
Mr. Jordan, I'd like to add something to that.
24 You asked, I think, did we report this situation
- [}
25 immediately to the NRC.
ALDERSON REPORTING COMPANY, INC.
1869 53-5 I
I think the answer to that question is yes, but as 2
far as pursuant to the requirements of 55 (e), that is, fcrmally, 3
I believe we received a citation on that, failure to report this
()
4 in a timely manner.
g 5
G Okay.
Thank you.
N h
6 BY WITNESS TOLSON:
R 7
A Well, I need to clarify that response.
A 8
8 I reported the problem to Mr. Taylor, verbally.
d 9
What we got cited for was not filing an interim report thirty zo 10 days subsequent to the verbal conversation.
II BY WITNESS CHAPMAN:
k N
I2 A
Pursuant to 55 (e).
5
(])
13 JUDGE MILLER:
Are we going to close on the panel, l
14 Mr. Jordan?
$j 15 MR. JORDAN:
Well, our situation is, I've been
=
j 16 foregoing any further fooling with documents at this point because e
h 17 I thought we'd get something else out of'the way but in terms --
18 at least in terms of documents and this panel, no.
P" I9 g
JUDGE MILLER: What about in terms of cross-n 20 examination.on their direct testimony?
21 It seems like we've been spending a lot of time 22
(~')
for very little in the last half hour or so, so if we could --
v 23 !
you're probably close to the end --
i 24 MR. JORDAN: All I can tell you is that I'm approaching
(])
25 the end of what I have been able to prepare cross-examination of i
i i
ALDERSON REPORTING COMPANY,INC.
1890 I
on the testimony in the last week, yes, sir.
2 MR. REYNOLDS:
Mr. Chairman, is the implication of 3
that that we're going to come back in July and re-examine this
()
4 panel?
5 JUDGE MILLER: Not necessarily.
h 6
MR. JORDAN:
Exactly.
Not necessarily.
R 8
7 JUDGE MILLER: It is the Board's belief that you've 4
8 8
got a half an hour in which you should be able to finish.
d d
9 We're going to have to ask you to move from the z,
o 10 e
subject limit to a time limit, I'm afraid, Mr. Jordan, if you II don't --
3 N
I2 MR. JORDAN:
Well, I'm going to --
5
()
5 JUDGE MILLER:
We don't intend to bring back the 13
=
l 14 panel on matters you wish to cover.
You've got another half g
15 hour1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> to cover it.
m E
I0 We think you can do it but you're naving an awful lot e
6 17 of interruptions here.
E
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18 MR. JORDAN:
I just -- I want to be -- well, I think A"
19 g
that I have stated the situation, at least, of my preparation n
20 and we're going to do it as quickly as possible, since the person 2I who really knows what's going on is Ms. Ellis.
That explains 22 the reason for the interruptions.
23 I will attempt to move ahead.
24 JUDGE MILLER: As far as the panel is concerned,
(])
25 answer the questions.
Answer them directly, explicitly.
If you ALDERSON REPORTING COMPANY,INC.
l 1891 1
can answer them yes or no, say yes or no.
3-7 2
Now, let's not all start volunteering, extending this top 3
record, as we've been doing for the past couple of hours.
O 4
I xnew you're erring to se he1gfu1 end we eggreciete g
5 it, but,nonetheless, let's move forward now, in a direct and 9
6 expeditious fashion.
R Cg 7
BY MR. JORDAN:
7.]
8 g
Mr. Vurpillet, turning page 3, Answer 6 of your do 9
testimony, 10 BY WITNESS VURPILLET:
=
k A.
Yes, I have it.
in G
You describe some changes that were made in the quality o
Q 13 assurance manual.
14 That, sir, is the quality assurance manual of Brown
{
15
& Root for ASME; correct?
d I0 BY WITNESS VURPILLET:
as h
I7 A.
Yes, that's correct.
c:
18 G
Why were the changes made that you refer to in your is I9 g
Answer A-6, on page 3?
c:
20 (No immediate response.)
2I G
Sorry.
Perhaps I could be clearer.
22 Q
The first sentence..says:
23 l "Had been revised by Brown & Root several 4
Q months before the ASME survey."
25 Why was that provision undertaken?
ALDERSON REPORTING COMPANY,INC.
18%'
'33-8 1
BY WITNESS VURPILLET:
E 2
A The decision had been made'-to revise the manual in an 3
attempt to make the manual more concise.
Actually, to take some em
(_)
4 of the procedural detail that had been in the previous editions e
5 of the manual out of the manual and place it in the implementing h
j 6
procedures that were used in the implementation of the Code R
CE 7
requirements on the project.
K 8
8 And that's generally why the --
O q
9 G
Okay.
zo 10
- You said the decision had been made.
Was that II decision made by the Applicant?
3 N
I2 BY WITNESS VURPILLET:
5a fs 13 A
The decision was made with the concurrence of the
'-)
5 4
u l
14 Applicant.
The discussion took place between the two groups.
g 15 I don't know that we went to the Applicant and said, "We want x
0 to make this change.", or they came to us and Said, "We'd like to make a change."
m I0 It could have been either way.
E" 19 8
JUDGE MILLER: Your answer is, it was jointly made by n
20 both 21 WITNESS VURPILLET:
Both parties concurred in the
()
decision to change the manual in this manner.
23 '
BY MR. JORDAN:
()
7.
Does anyone else on the panel know exactly who 25 l initiated the change?
i ALDERSON REPORTING COMPANY,INC.
I
1893 I
BY WITNESS TOLSON:
O\\l 2
A I'll take credit for it.
23-9 j
3 g
Mr. Tolson.
Okay.
()
4 Sir, in your testimony -- Mr. Vurpillet, again.
5 Page 6 in your Answer 12, referring to documents 6
control, you say, I believe, at the top of Page 7:
R b
7 "The matter raised by the survey team - "
i N
k E
Is that the ASME survey team?
d BY WITNESS VURPILLET:
b h
A Yes.
a G
" Concerns the timeliness in performing d
12 Z
the review, not that the records were 3
(~)1 being reviewed improperly."
13
\\_
E 14 g
HOw did you reach that conclusion?
2 15 BY WITNESS VURPILLET:
g 16 l
A It's simply a matter of fact.
17 l
w G
That's what the ASME team told you?
4 m
18 2
BY WITNESS VURPILLET:
4 I
k i
19 A
Yes.
i 10 g
Okay.
21 BY WITNESS VURPILLET:
i I()
A That was our understanding, yes, of their finding.
I 23
\\
///
24 O
25 l
l ALDERSON REPORTING COMPANY, INC.
1894 24-1 1
G Your Answer 13 on Page 8 confused me.
It refers to Dd 2
a procedure that had been revised, and the new revisions 3
deleted a paragraph which described the establishment of ANI O
4 ho1d gaines -- ^NI is euthorized nuc1eer insgector2 e
5 BY WITNESS VURPILLAT:
h 6
A.
Yes.
That's correct.
That's a person, as opposed to R
6, 7
an organization.
Ml 8
G Yes, an individual.
d c;
9 And then it says the ANI continues to use his own 2
h 10 method of establishing hold points.
I guess what I'm not
=
q 11 understanding is why is it that a procedure continues after it it
{
12 has been deleted from the -- in a recent revision?
3 13 BY WITNESS VURPILLAT:
l 14 A.
Well, the problem in this case was the particular a
g 15 paragraph that was deleted, it implied that the ANI was not able a:
g 16 to establish the hold points as he might want to, and that was as Li 17 not the case, but since there was that implication the paragraph
{
18 was deleted and the ANI continued to do business in establishing E
19 hold points as he always had, and he applied them as he saw fit.
20 MR. JORDAN:
Mr. Chairman, I will provide the witness 21 with a copy of a document.
It was CASE Exhibit 55 in the response s 22 to the summary disposition motion.
Actually, it was distributed 23 to the parties in the package.
24 JUDGE MILLER:
What's its exhibit number?
25 !
MR. JORDAN:
It was CASE Exhibit 55.
l ALDERSON REPORTING COMPANY, INC.
1895 34-2 1
JUDGE MILLER:
It still is, then, isn't it?
2 MR. JORDAN:
Was CASE Exhibit 55.
I 3
JUDGE MILLER:
That was changed?
O 4
an. acaoin:
voor nonor, it e99 ears thet we do noe e
5 have copies enough for the Board here at this moment, but I would b
h 6
proceed, if that's all right with you.
R R
7 JUDGE MILLER:
You may proceed.
Nl 8
MR. JORDAN:
In fact, I'm not even sure I have a dd 9
copy for myself.
We don't have enough copies.
i h
10 JUDGE MILLER:
Well, what's the question?
Go ahead.
E h
11 BY MR. JORDAN:
it
{
12 Mr. Vurpillat, I place a document before you.
S Q
g 13 MR. JORDAN:
I would ask that it be marked as CASE 14 Exhibit -- for identification as CASE Exhibit 189.
2 15 BY MR. JORDAN:
i
- [
16 G
I wonder if you might simply describe the document, as j
ti 17 physically.
l j
18 JUDGE MILLER:
It's marked.
What is it?
E 19 MR. REYNOLDS:
A foundation is not required.
k 20 MR. JORDAN:
I simply want identification.
21 WITNESS VURPILLAT:
I don't think I know.
t 22 WITNESS TOLSON:
Let me try to settle it.
]
23 JUDGE MILLER:
No.
You're volunteering.
I just want n
24 you to stop volunteering.
Answer questions.
He didn't ask for U
25 views.
If the witness knows, he can tell.
If he doesn't know, ALDERSON REPORTING COMPANY, INC.
1896 94 - 3 1
he can say he doesn't know.
Now let's move on.
m5-)
2 BY MR. JORDAN:
3 G
Mr. Tolson, do you recognize this document?
(
4 BY WITNESS TOLSON:
e 5
A Yes, I do.
k 8
6 0
What is that?
I k
7 BY WITNESS TOLSON:
A 8
A A set of notes of a manual review that was conducted dd 9
at the site subsequent to the October survey by the ASME people.
b g
10 g
Who conducted the review that this document reflects?
E h
11 BY WITNESS TOLSON:
D d
12 A
It was under the direction of Texas Utilities, 3
O l is eerrormea dv subcoatrector vereoaae1-14 G
Who was the subcontractor?
m 2
15 BY WITNESS TOLSON:
g 16 A
It could vary, Mr. Jordan.
e i
17 JUDGE MILLER:
Do you know who it was?
E 18 WITNESS TOLSON:
Yes, sir.
E 19 JUDGE MILLER:
Okay.
ge 20 BY MR. JORDAN:
21 G
This is subsequent to the ASME October survey,
(}
22 correct?
23,
R.
REYNOLDS:
Objection.
I think we're wasting time.
~T 24 This is cumulative evidence.
Its probative value is substantially (J
25 outweighed by the presentatica of repetition.
ALDERSON REPORTING COMPANY, INC.
1897 94-4 1
JUDGE MILLER:
Sustained.
(
MR. JORDAN:
Well, Your Honor, we were given this 2
3 document in a stack of documents in response to an interrogatory.
()
4 JUDGE MILLER:
That may be.
We're not trying e
5 interrogatories.
We're trying a case.
Now move on.
En h
6 MR. JORDAN:
I'd ask that the document be admitted, R
R 7
CASE 189.
8 8
JUDGE MILLER:
It will be admitted.
Od 9
(CASE Exhibit No. 189 was marked i
h 10 for identification and received aj 11 in evidence.)
y 12 BY MR. JORDAN:
(])
3 13 G
Pagd 8, Answer 14 -- I guess that's Question 14 on E
14 Page 8.
The answer would be on 9.
I believe I'll be asking
$e 2
15 Mr. Vurpillat, this being your testimony, refers to AFCO Steel 5
g 16 providing material without being on an approved suppliers' list.
w d
17 Are you able to tell us how long that condition 5
18 existed prior to that time?
h 19 BY WITNESS VURPILLAT:
gn 20 A
AFCO was on the approved suppliers' list.
The 21 inference -- I don't see that inference in the response.
There 22 was some question as to whether the material in the shape that
(])
23 they supplied it was within the scope that they had been placed 24 on the approved suppliers' list, and that was not the case, but U'~N 25 ;
there was a question about that.
i ALDERSON REPORTING COMPANY, INC.
'1898 14-5 1
0 Okay.
I'm not sure which was not the case.
OV 2
There was material they supplied which was not within 3
the scope of their approval on the approved suppliers' list?
O 4
Bv WITNESS vuRPIttAT:
e 5
A That was the question that was raised.
hl 6
0 I see.
And that was resolved in the negative?
R 7
BY WITNESS VURPILLAT:
M g
8 A.
Any possibility that that was a problem was resolved dd 9
by the fact that Brown & Root went in and did the review of the 10 forming processes that were questioned to determine that indeed
!!!l 11 they were adequate, and we found that they were adequate and that 3
g 12 the material that was supplied under any possible configuration Q
13 was acceptable.
m l
14 G
Now, that was done -- when did yca do that, going in 2
15 to determine the adequacy?
g 16 BY WITNESS VURPILLAT:
el d
A.
We had determined the adequacy of AFCO as a supplier
!E 18 well in advance of purchasing material from AFCO.
We went in E
{
19 after the survey, the ASME survey to put it in a point of time, n
20 to make an additional review of the procedures involving the 21 forming processes that were in question, and found that
< pJ regardless of whether they were questionable or not that they 22 23 had been acceptable.
24 0
I see.
And was that the first time that Brown & Root 25 l had done that review?
ALDERSON REPORTING COMPANY, INC.
1899
$4-6 1
BY MR. VURPILLAT:
()
2 A
Of those particular forming processes, yes.
3 4
Page 11, Answer 16 of your testimony, Mr. Vurpillat,-
()
4 refers to, I believe, the signing of process sheets in blank by e
5 an ANI, correct?
h 8
6 BY WITNESS VURPILLAT:
e
{
7 A
Yes.
K 8
8 G
What does that situation involve?,, What is the sheet dd 9
that the ANI is signing in blank?
10 BY MR. VURPILLAT:
3*g 11 A
There are forms that are filled out relative to a k
j 12 process, for example, welding.
Before the welding is done there
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13 is a process sheet that's filled out that shows the steps to be l
14 followed in making a particular fabrication, making a particular 2
15 weld to keep it simple.
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16 In this particular case -- in any case, the ANI has d
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17 the responsibility and the right to identify those portions of i
18 the process that he wishes to inspect spefically, and when he
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19 does that then he will sign the process sheet, and the question
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20 arose as to whethar it was acceptable for him to say to us, for 21 instance, when you weld we want to see the configuration before i
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you begin the weld and after it's fit up, and this is an example, 22 l
23 a hypothetical, and we want to see all of those.
And that's a l
24 generic hold point, if you will.
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25 With those generic hold points established, he signed l
l ALDERSON REPORTING COMPANY, INC.
t
1900 14-7 1
the process sheets and said whenever that comes up, will you
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2 make out the process sheet for a particular weld at our hold 3
Points in those specific cases, and that's what was done.
And
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4 there was a concern from the survey team that that was not a g
5 proper way to handle that.
There was a concern from a subsequent a
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ANI that he didn't want to do it the same way his predecessor R
8 7
had, and so when that happened we stopped doing it.
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The ANI's signature on the process sheet indicated dd 9
that he had indeed been there and done the inspections at the I
h 10 hold points when he was supposed to?
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11 BY WITNESS VURPILLAT:
k A
No.
The signature we're talking about is the g
12
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13 signature indicating that he had established the hold points, h
14 told us ahead of time that this is what he wanted to see.
2 15 g
I see.
And the other ANI who came later didn't want j
16 to do it that way?
A 6
17 BY WITNESS VURPILLAT:
18 A
He didn't want to do it that way.
E 19
///
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20 21 22 CE) 23 24
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25 ALDERSON REPORTING COMPANY, INC.
i 1901 ss-1 I
g Your Answer 17 that begins on Page 12, refers to Mg)
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2 welding procedure specifications.
It does not specify travel 3
speed, but controls for heat input in the welding.
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This was a finding by the ASME team.
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BY WITNESS VURPILLET:
4 6
A That's correct.
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Which,in fact, also resulted in an NCR?
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M BY MR. VURPILLET:
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A Yes.
We documented their concern on an NCR.
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a Could you tell me, if you know, Mr. Vurpillet, or hII any of the panel who knows, what is -- what could be the impact d
12 3
of the incorrect travel speed in undertaking the weld governed S
O-by the specification in question?
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14 W
BY WITNESS VURPILLET:
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15 A
There was -- I can answer -- there was no problem x
j 16
-- there was no incorrect travel speed.
The problem related to M
h II the establishing a method of measuring the heat input..into m
18 the weld.
It gets to a very technical welding situation and it k
19 8
is necessary to control the amount of heat that you put into a n
20 piece of metal when you' re welding.
21 You want to make sure that you don't put too much heat,
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It could damage material metallurgically.
So there are a number 23 of ways to determine that you have not done that.
And the measurement -- that's called the measurement 25 of the heat input.
ALDERSON REPORTING COMPANY, INC.
1902 25-2 10P 1
You can do that any number of ways.
2 We chose to do it by measuring the width of the 3
resultant weld bead.
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The survey teem indiceted ehee they fe1t -- their e
5 interpretation was that that was not enough.
IN addition to h
h 6
measuring the width, we had to also measure the depth or, in lieu R
7 of that, had to have measured the speed at which the weld metal A
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was deposited.
d ci 9
GV o And the speed, if incorrect, could give you an z
h 10 indequate or non-complying weld, if it's too fast or too slow?
sx II Isn't that correct?
it y
12 BY WITNESS VURPILLET:
O 13 a.
1n this gerescu1er cese, es fer as ingue is concerned, b
I4 you would only have a problem if it were too slow.
15 And the physicalities involved indicate that --
id I0 indicated to us that there is no way that we co'uld have gone as h
I7 slower than the requirement and ended up with a bead width that 18 was not far in excess of the limits that we had previously E
19 established.
gn 20 g
Okay.
21 So, in other words, your bead width inspection would 22 control for the slower --
Q 23 BY WITNESS VURPILLET:
24 A
Yes.
25 g
Okay.
ALDERSON REPORTING COMPANY, INC.
1903
$5-3 1
, And. bead is spelled b-e-a-d, in this case?
tho 2
BY WITNESS VURPILLET:
3 A.
Yes.
I think I made that correction in the testimony.
4 0
Okay.
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JUDGE MILLER:
I guess that's it.
You did it.
9 6
MR. JORDAN: It might as well be.
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7 JUDGE MILLER:
Very well.
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0 MR. REYNOLDS:
Mr. Chairman, I think the record should d
reflect that the Board has been extremely indulgent of this o
h cross-examination by committee that the Intervenors have conducted.
El However, in the interest being more efficient next ti 12 E
time, I request instructions from the Board that it cease in the O@
is next hearing.
h 14 JUDGE MILLER:
I don't think it's necessary.
I think g
15 Counsel has indicated that_ part of'it"is due'to tihe fact that he m
16 hasn't time to familiarize himself thoroughly with a large amount j
us 17 of exhibits of this material.
I'm sure the' time will come when m
5 18 we resume --
E 19 MR. REYNOLDS:
I don't intend to be critical of g
n 20 Counsel.
21 MR. JORDAN: Your Honor, I would never intend to put h
22 the Board to sleep.
v 23 l JUDGE MILLER: We would like to move.
We understand 24 your problem.
You've been handling a large number of documents.
25 MR. REYNOLDS: Does that conclude cross-examination ALDERSON REPORTING COMPANY. INC.
1904
@S-4 1
of Mr. Vurpillet?
Bo T kl 2
JUDGE MILLER: I haven't heard anybody say that.
3 MR. REYNOLDS:
I was hoping somebody would.
4 JUDGE MILLER:
I think this is a good point.
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Do you wish to conclude with any of these witnesses?
9 3
6 MR. JORDAN: No, sir, we are not -- I'm not prepared R
b 7
to conclude with respect to any of these witnesses.
M 8
JUDGE MILLER: You want all of them back?
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9 MR. JORDAN: Yes, sir.
However, I will be pleased to h
10 commit to the Board and Counsel, that is we -- if I can make a
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II conclusion that I don't need one of them, I will tell everyone.
NI JUDGE MILLER:
Okay.
Fair enough.
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We will adjourn at this time and resume at the time E
14 and place in July.
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Thank you very much, m
g' 16 (Whereupon, the hearing in the above-entitled matter was 6
17 adjourned at 2:45 p.m.)
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25 l ALDERSON REPORTING COMPANY, INC.
NUCLEAR REGULATORY COMMISSION This is to certify that the attached proceedings before the O
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD in the matter of:
TEXAS UTILITIES GENERATING COMPANY, et al UNITS 1 & 2 t,
Date of Proceeding:
June 11, 1982 Docket llumber:
50-445 & 50-446 Place of Proceeding:
Fort Worth, Texas were held as herein appears, and that this is the original transcript thereof for the file of the Commission.
Judy Bradley Official Reporter (Typed) l
-wn Officia Repoter(Signatub) f i
l i
l