ML20078L740
| ML20078L740 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 06/29/1983 |
| From: | Henry W DUKE POWER CO. |
| To: | |
| Shared Package | |
| ML20078L617 | List: |
| References | |
| FOIA-83-434 NUDOCS 8310240055 | |
| Download: ML20078L740 (65) | |
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s-(. UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
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In the Matter of: ) Docket Nos.
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DUKE POWER COMPANY, et al ) 50-413 (Catawba Nuclear Station ) 50-414 Units 1 & 2) )
,Ou u I, Bar bara V. Haas, Commissioner and Notary Public- ,
proceeded to take the continuation of the deposition of W. O. Henry on the twenty-ninth day of June,1983, beginning at 8:20 o' clock a.m. in the of fices of Duke Power Company, i
South Church Street, Charlotte, North Carolina.
CONTINUATION OF THE DEPOSITION OF U. O. HENRY 8310240055 830810 PDR FOIA AHLERS83-434 PDR A 44o. Colick Rd.
MSSOCidtCC P.O. 6 uo.83 Chorbite NC. zsta
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Court Reporters zo4.ss4.me f10 ,
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1 EXAMINATION: (By Mr. Guild) 2 Q. Gond morning, Mr. Henry, I believe there may be some 3 other people in the room today in addition to those present d yesterday. With me, assisting Palmetto Alliance, is Billy 5 Garde of the Government Accountability Project and Michael 6 Lowe, director of Palmetto Alliance.
7 MR. JOHNSON: I'm George Johnson of the Nuclear a Regulatory Commission.
9 MR. GIBSON: I'm Ron Gibson, counsel for Duke 10 Power. George Grier is here, Corporate Q.A. Manager, 11 and Glenn 3 ell will be here also during the deposition.
12 Counsel, yesterday the witness identified for the first Q.
13 time a document that he described as entitled "Self- Evalua-Id tion Catawba by INPO Design and Construction Criteria,"
15 which was described as an evaluation of work at the Catawba 16 construction in October of 1982. I asked then that that 17 document be produc ed so that I might inquire concerning 18 the matters therein related to quality assurance and quality I' control under contention 6, and I believe you said you were 20 going to make some kind of inquiry concerning the availability 21 of that-document.
22 MR . G IBSON : Wn determined that ,that document has 23 not been requested during discovery of this case. and is 24 not relevant to the discovery, and decline to;make it 25 available and .as indicated yesterday suggest that you take 2
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d I that document up with the Board along with the other things 2 you intend to pursue with the Board.
3 Q. Since Mr. Henry-is a' man with responsibiiities in the 4 quality assurance area, I would intend to examine him in 5 detail concerning the contents of that document. Of course, 6 not knowing what that document says, I can't presume what the 7 Contents are, but it appears from the description and title 8 that it is relevant to the subject matter of this contention.
9 Mr. Henry, we were talking yesterday when we broke about the 10 procedures available to an inspector, and specific by way 11 of example, we were talking about welding inspectors. When 12 a deficiency was noted in the work in question, and I believe,
- 13 you indicated that two procedures then available were describe d 14 in Duke Quality Assurance Procedure Q-1 which relates to 15 non-conforming item report, is that correct?
16 A. That 's c orrect.
17 And, procedure R-2 which provides for the use of a form Q.
18 that we have described or you have described as an R-2A, is 19 that correct?
20 A. T hat is also correct.
21 And, that both procedures receive some revision or clari-Q.
22 fication either as a result of recommendations of the Welding
.23 Inspector Task Force or subsequent to that Task Force, and 24 .you were explaining some of those in general?~-
25 A. Yes, sir.
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1 Q. I was trying to understand some of the provisions for 2 noting trends and I believe you indicated that as a result 3 of the October study, self-evaluation, that a procedure d change had been implemented that called for trending
- 5. R-2A's, is that correct?-
6 A. That's corr ect.
7 Q. You are trending R-2A's then?
8 A. That 's correct.
9 Q. Can you tell me, i s there a name for the report or 10 docum ent that would reflect that trending of R-2A's?
11 A. Nothing other than the trend analysis of R-2A's.
12 >k . Henry, would you maintain the custody of those re-Q.
13 ports?
14 A. No.
15 Q. Who would?
16 A. That's the responsibility of the Construction Management 17 at the site where they are generated.
18 Q. Is that the Project Manager ultimately?
39 A. Or his designee.
20 Q. Do you know who his designee would be with r espect to 21 tr end s of. R-2A 's ?
I 22 A. Not specifically.
23 Q. Would it be someone in Quality Assurance?
24 No. -'
A. , ,
25 Q. Maybe.you said, but just for clarification, how about
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1 the trend analysic for NCI's?
2 A. Yes, that's in Quality Assurance.
3 Q. W3uld you maintain those?
4 A. Yes.
5 Q. With respect to construction activities at Catawba?
6 A. Yes.
7 Q. Ar,e those documents made on a regular basis; monthly, 8 weekly?
9 A. Yes, they are in accordance with the regular schedule.
10 Q. What, would that be?
11 A. Currently that is monthly.
12 Q. For both NCI's and R-2A's?
13 A. For NCI's monthly is correct. I don't recall what that
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14 is for R-2A's.
15 Q. .Mr. Henry, with respect to construction activities at 16 Catawba, are measures taken to insure that the cause of 17 deficiencies that affect or may affect the safety are 18 identified and that those deficiencies are corrected?
19 A. Yes.
20 Q. Describe those measures, sir.
i 21 A. As described in the procedure Q-1, any significant non-22 conforming items require that such evaluation be .made as 23 far as the route cause and corrective action to preclude l
24 that occurring again. -
l 25 First, .lets see, I have the latest revision of Procedure Q.
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t(- 1 Q-1 that has been received as Exhibit Five of your deposi-2 tion. How about , if you would, direct my attention to 3 the portion of that procedure that sets forth the procedure d you just indicated.
5 MR. GIBSON: I'm conferring with my client, 6 Mr. Guild. The record will reflect that. We will not abide 7 by your request that he give an answer prior to consulting 8 with counsel.
9 Q. I just want the record to reflect my request that you 10 not consult prior to answering.
11 A. Again, your statement that this is the latest revision 12 of the procedure and what I wanted to point out to you is g,
13 that the procedure has been revised again subsequent to 14 this 6/16/82 date, and so it's not -- I was not sure we 15 should proceed with my letting you think this is the l'atest to one.
17 Q. Can we produce the latest revision then, so we will have 18 an up-to-date copy of that procedure.
19 MR. GIBSON: Why don't you ask about the revisions.
20 I don't think they would be included within your request for discovery, and if after asking questions you determine 4
21 22 that you want that item, then, at that time, I will tell 23 you whether . I think it 's necessary.
24 Q. Mr. Gibson, we have a continuing request'hnd the Board 25 has a direction that discovery materials be updated. If 6
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I there is a procedure that obviously affects the substance --
2 MR. GIBSON: I'm trying to get you to ask some 3 questions so --
4 Excuse me, let me finich the statement for the record.
Q.
5 If there is an obvious procedure such as that for non-conform-6 ing items and the latest revision has not been provided, my 7 position is that it's clearly covered by the directive from 8 the Board continuing updates for discovery request. I 9 want to have an accurate record here, and I appreciate the 10 witnesses' candor in telling me this is not the latest 11 revision, but I would ask that the latest revision be pro-12 vided now so we don't have to guess about its terms. It
' 13 serves no useful purpose for me to go through further in
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14 quiry on the su bject of procedure that has been revised.
15 MR. GIBSON: Prior to our making that available, 16 7em going to ask the witness to describe the revision that 17 has been made while we attempt to get a copy of .that available .
18 Q. That's not my question, but you would like --
19 MR. GIBSON: I'm asking. him to describe that as 20 part of his consultation with me and the preliminary to this 21 exchange between counsel.
22- g, That's not my question, .but if you want to respond to your- .
23 counsel's direction, that will be fine.
24 A. The latest revision of the procedure will"' reflect s.ome
- j 25 changes in the particular individuals who might do certain ,
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' ~ 1 evaluations which forms they would u se and the administrative 2 detail as how we complete the actions that are required by 3 the non-conforming item procedure as it exists and the one d we have here, and the point we were discussing about the 5 determination of route cause, corrective action, t hose 6 requirements that be done, this procedure that requirement 7 has not changed. We made some changes in the location, 8 the flow of paper and the administrative details as to how 9 that is done, but not to confuse you in thinking that this 10 was the latest issue is why I chose to make this statement.
11 Q. Mr. Henry, I'm interested in inquiring about all those 12 subjects, so I would ask counsel to produce the latest re-
- 13 vision.
34 MR. GIBSON: We are attempting to do that. If
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15 there are some other questions you could proceed with while 16 that is being obtained, you may take some time; otherwise, 17 we may go off the record completely.
18 Let me show you what has been received as Exhibit Four Q.
! 19 to your deposition, and this is entitled, " Procedure R-2."
l 20 Is this the latest revision of that procedure?
l 21 A. I believe this is the latest revision.
l 22 Q. .Is there some document that you could have some reference l 23 to that would confirm that that is the latest revision if 24 you are. in dou bt, si'r? "-
25' A. I think the document that Mr. Bell is looking for would r
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1 confirm this is the latest revision.
2 Q. As we go through he rest of this deposition -- First 3 let me ask you this. Are you aware of any other testimony 4 so far in your deposition, Mr. Henry, that should be corrected 5 or changed or updated?
6 MR. GIBSON: Object to the form of your question, 7 Mr. Guild. He is not correcting any other testimony. He 8 corrected your statement about this document.
9 Q. Let me finish my question, counsel. Are you aware of any 10 of your testimony that should be changed, corrected or up-11 dated in light of changes or revisions in documents or 12 procedures?
13 A. No.
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14 Q. 6ther than this particular procedure we have reference 15 to?
16 A. The second question you made the statement this is the 17 latest one, and I'm saying that it is not.
18 Q. I want to have an idea, Mr. Henry. I want your testimony 19 'to address the way things are most recently, current condi-20 tions, current procedures, current policies at Catawba unless 21 I specifically ask you about something earlier in time, s ir .
22 In. light of.that statement, i.s there anything that needs 23 to be changed, corrected or updated in what we have dis-24 cussed over the last many hours of your testihony? I want 25 to have a current idea of how things are done at Catawba.
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9 f"'. 1 A. I have attempted to answer your questions. If I felt they 2 were as current as of vesterday, I answered them that way.
3 If I felt you asked them specifically about something else, 4 I attempted to answer your question, so I will stand on the 5 answers I just aave.
6 0 . If there is anything as we go forward or anything that 7 occurs to you .that requires in order to be complete and 8 accurate and truthful that you note that there has been a 9 further update or chance or revision and I haven't noticed 10 it or it has been an oversicht on my part, I would ask you, 11 sir, that you correct the record so that the record will 12 be complete and up to date. Will you do that, sir?
13 A. I prefer not to ansker that. I will try to answer your g:;
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14 auestions. I'm not sure I can make that statement and honor 15 that request when you are talking now, in the future or in 16 the past.
17 That is my request, Mr. Henry.
Q.
18 A. I will attempt to answer your cuestions, l' We need to wait on the procedures.
Q.
20 OET THE RECORD (8:45 a.m.)
21 CONTINUING EX AMINATION: (By Mr. Guild) (9: 05 a.m. )
22 MR. GIBSON: Mr. Guild, during this adjournment,
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l 23 we reviewed the latest revision to 0-1, and determined that 24 the revisions were not as a result of the Welding Inspector ,
25 Task Forc.e. They are a part of the on-going revisions that
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ce 1 the company is required to make in all of its procedures.
2 The company has made available to Palmetto all of the r.e-3 visions to the procedures that are as a result or connected 4 with the Welding Inspector Task Force Report. We take 5 the position that this request is outside the scope of 6 the deposition and beyond the earlier discovery request of 7 the company. We decline to make this document available, and 8 will not make any other revisions to company procedure avail-9 able that were not made as a result of the Welding Inspector 10 Task Force. I understand your position that they are discover -
11 able, and I understand you wi'l t'ake that matter up with 12 the Board, and it will be resolved at that time. If you have
,{c n 13 any further areas of 1,nquiry for Mr. Henry or want to ask 14 him substantive questions about Q-Al that you have been 15 looking at which includes the substantive changes relating 16 to the Welding Inspector Task Force, you may proceed with 17 that.
18 Q. Can you we have a time check. How long have we been off 19 the record waiting for Mr. Gibson t'o reach that position.
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20 Twenty minutes. So, be procedure we are talking about is 21 not the procedure that, in fact, governs construction at 22 Catawba, is that correct, sir?
23 A. It is not the current revision of the procedure, that's l ~
l 24 corr ect. That 's 0-1. -
l 25 Counsel, for the record, it's clear that what is relevant Q. ,
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i 1 in this contention and what is discoverable is quality i 2 assurance as it relates to welding at Catawba. There is 3 no limit whatsoever that is tied to what your Welding 4 Inspector Task Force did or didn't do. I presume it's your 5 position that they addressed all the problems and everything 6 is fine out there, but, of course, it's open to us to seek 7 discovery regarding our claims and your defenses, and the a fact that you may have that as a defence should not in any 9 way, shape or form limit what is discoverable for us, sir.
10 We would specifically request that you produce the latest
.i 11 revision of the procedures affecting quality assurance at 12 Catawba specifically in this regard the latest revision of 13 g-1, ,
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14 MR'. G I BSON: : Mr. Guild, I understand your position.
15 You stated it quite eloquently. If you have any further 16 questions of Mr. Henry, would you proceed?
) 17 0 All right, s ir . This is a little bit of an exercise in p 18 futility, sir, since we are now talking about a document 19 that does not currently govern procedures, but I want to 20 understand, sir --
21 MR. GIBSON: I o bject to the' side bar' comment and 22 move that it be stricken unless we are operating under our 23 same procedu'res that all questions are deemed objected to 24 except'as to form. . I object to your preparatory remark at 25' the beginning of the question, Mr. Guild. , If yon have some 12 c :. .
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% 4 b i questions of Mr. Henry, proceed.
2 Q. What is your point, counsel?
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MR. GIBSON: I'm objecting to your preparatory 4 remark. If you have a question of Mr. Henry, please proceed 5
with your question.
6 Q. You want to seek a ruling on that, Mr. Gibson. Is that 7 your point.
8 MR. GIBSON: I have not requested seeking a ruling.
9 Q. I would ask you just not interrupt me.
10 MR. G IBSON: I will interrupt where I deem it ij necessary, Mr. Guild. If you have a question, proceed.
12 Q. That's what I was trying to do. Please don' t interrupt 13 in the middle of my question. If you have an objection or
'h"j u if you wish I restate a question, Mr. Gibson, please hence-15 forth wait until I have stated the question, and then state 16 your position, sir, all right?
17 MR. GIBSON: If you have a question, proceed, Mr.
18 Guild.
39 Q. I was trying to state one, sir. We are not talking about 20 the current procedure. We are talking about a procedure that
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l 21 is no longer in affect. I want you to. tell me first with 22 respect to what is in front of us and then I want you to 23 tell me with respect to what actually exists, all right? '
24 That is~ the form in which 'I want you 'to respon.d to the 25 questions concerning how matters are handled with regard to l
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1 non-conforming items as we talked about Q-1. Before we do 2 that, have we determined whether or not this which has now 3- been received as Exhibit Four , the procedure R-2, is this d the current revision of R-2, sir?
5 A. Yns.
6 Q. By that, I mean indicated revision nine. All right, 7 Sir. Which different individuals under the current revision 8
of Q-1 do the evaluation? How are the indivduals who perform 9 the evaluations changed from the current -- from the former 10 policy that you have in front of you to the current policies?
11 A. The significant change in that procces between this 12 revision and the current one involves designating certain 13 individuals within the departments that have responsibility a(.:1, Id for writing up various forms required by these procedure P
15 Q-1, to provide the means to assure that the language and the ,-
16 form and the substance of the reports before they become 17 the final record are as consistent as.we can make them among 18 the various departments that use this form. That's the major 19 change in the' people and providin'g the means to do that.
20 There is now an additional form that they, individuals, would 21 use to provide the details of their evaluation of non-confor-22 mance, sign that. statement and proceed on with the re-work 23 corrective action and ultimately to the file.
. 24 Q. What is the name of that form, sir? - -
25 A. The form is R-6A. The new form and current procedures 14 .
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[#::. 1 that would be used to complete what I just described.
2 Q. Who are those certain individuals who are designated 3 to make that evaluation?
d A. Currently, those individuals are designated in Quality 5 Assurance as Bill Bradley and there are individuals designated 6 in Design Engineering and also in the Construction Department.
7 Q. Who are those individuals in Design Engineering and Con-8 struction.
9 -Q. In Design Engineering, it's Chris Rolfe and Construction 10 it's. Ray Hollins.
11 Q. What is Mr. Rolfe's pozition?
12 A. He is the Supervisor of a group in Design Engineering, 13 and I don't know his exact current title.
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Id Q. And, Mr. Hollins?
15 A.- Mr. Hollins is a Supervisor in Construction Department, 16 and also I don't know his exact title.
17 Q. Does Mr. Hollins work at Catawba?
18 A. No, sir.
19 Q. In Corporate Office?
20 A. He worked'in Corporate Office.
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- 21 And, Mr. Bradley?
Q.
. 22 A. Mr. Bradley is in Corporate Office..
23 Q. What did you mean when you said -- when you spoke of
. 24 consistency? -
25 A. The end result of all of the forms is to get the required l .
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' ' ' 1 action done and provide a record for the file as to what 2 was done. The language as to hvo that is done can be made
- 3 more consistent by having a select group of well-qualified, 4 highly trained individuals to provide the details of that 5 analysis and review the documentation. So, in an attempt 6 to better explain on our forms and make that more easily 7 understood by others who may read it af ter the f act and 8 would not have been involved in all of the details that went 9 into the evaluation, it was felt that select, certain indi-10 vi' duals who could provide that consistency in writing up 11 these reports.
12 Q. Those are the three individuals you just mentioned?
g; 13 A. Those are the three individuals who are currently named.
[F 14 Q. When was this change made to procedure Q-l?
15 A. Officially it would have baen made the date of the re-16 vision of the implementation of the current revision 17 procedure, and I don't have that exact date.
18
.Q. Approximately when, sir?
19 'A . It would have approximately have been affective within 20 the last week or two.
21 Q. What is the latest revision number then to procedure 22 0-1,. current revision. What is the current revision, sir?
23 A. I don't recall that.
24 You just went off the record , and you wenE and reviewed Q. _
25 that,.did you not?
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i 1 A. Yes.
2 Q. Can you tell us for the record what that is? Did you 3 consult with the same document you consulted off the racord 4 or whatever else you need to supply for the record what 5 the latest revision is.
6 MR. GIBSON: I think you have adequately descri bed 7 it. He doesn't recall the revision number. I think you 8 have an adequate description in the record to take the 9 matter up with the Board.
10 Q. Counsel, I don't know why you insist on playing games.
11 We were off the record for twenty minutes. You vent and 12 pulled the document and you had it available to him. You p^ 13 read it, he read it, Mr. Grier read it. You were all out of 14 the room looking at the thing. Now, sir, I want the record 15 to reflect that it is available to you. It has been available 16 to you, and I'm asking a specific question, what is the i
17 latest revision number.
18 MR. GIBSON: He has answered that he doesn' t know.
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19 We are not going to go find a document again. There is an 20 adequate description in the record. If you take the matter 21 to' the Board. If you have another qu,estion of Mr. Henry, ask 22 that question, Mr. Guild, i
23 Q. How many revisions have there been since the revision l
24 that is indicated in the copy of Q-1 that is An exhibit to 25 your deposition, sir?
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' 1 A. I don't know.
2 Q. H' ave there been more than one?
3 A. I don't know, d Why has the policy been revised since the revision Q.
3 that is available before us as hearing Exhibit Five?
6 A. As I tried to just explain, it was not a change in the 7 requirements of our QA program as to what we do in resolving 8 a non-conformance or stating corrective action, but it was 9 a change to attempt to get the record clear for any . subsequent 10 reviews and for the long term filing of the document.
11 Q. Who recommended the change?
12 MR. GIBSON: I'm going to instruct him not to 13 answer that question. I think you have made a sufficient 57 -
14 identification and although I will object on a question by 15 question basis, I'm generally going to instruct him not 16 to answer any other questions about the latest revision to 17 - Q-Al. ,
18 I would like the question answered?
Q.
19 A. I will not answer. it.
20 s MR. GIBSON: I'm instructing him not to answer 21 .that specific question. I'm advising you that generally we 22 'ar e not going to answer any more questions about the revision s
23 although I will object on a que'stion to que stion basis.
24 Wa's that or any other revision subsequent"-to the, revision Q.
25' that' you have made available to me, an'd I believe that's
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- k 1 revision seventeen, recommended or resulting from the 2 October, '82, self-initiated evaluation at Catawba?
3 A. To my recollection, no, d Would you know?
Q.
5 A. I don't know.
6 Wbuld you likely know if it were connected with that, Q.
7 sir?
s A. I would be a ble to determine that.
9 Since counsel will not let you go consult any documents, Q.
10 that .doesn ' t help me. Let me see if I can be clear. Would 11 you be a person familiar with procedure changes in the 12 Quality Assurance area that resulted from recommendations c/ 13 made by that evaluation?
- t. Id A. Yes.
15 Q. You would generally know, and in this instance, you are 16 not aware, is that fair?
17 A. That's fair -
18 Did that evaluation make any recommendations with respect
. Q.
l' to procedures 0-1 or to process for handling a non-conforming 20 item?
21 A. I don't know.
22 Let'e look at the procedur. R-2A'., Now, I'm. trying to Q.
23 understand the relative responsibilities in the handling of 24 non-conforming items; in this instance, to pr'bcedure R-2 25 between Quality Assurance personnel andc Construction personnel
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e 1 All right, personnel in both Construction and Quality 2 Assurance have some responsibility for dealing with that 3 su bj ect , do they not?
d A. Yes.
5 Q. Directing your attention to the responsibility provision 6 that's paragraph number three, explain, if you would, sir, 7 the distinction between responsibilities that are placed 8 on the QA Department and those on Construction?
9 A. I think they are clearly stated there in three. I will 10 certainly try to explain your questions.
11 Q. It states in that provision that the project QA Manager 12 may assume the responsibility for trending R-2A's at his 13 Why is that discretion granted to the Project
{; discretion.
14 QA?
15 A. That is granted if QA desires or sees a need to trend 16 R-2A's independently for whatever reason, we want to trend 17 them, the procedure will 9'ive that responsibility to QA 18 to do it.
19 Complete your answer.
Q.
20 A. We went over yesterday in the proceduN. 't i directs 21 Construction to trend R-2A's.
22 Q. So, the. trending by QA would be in addition to that 23 responsibility by Construction?
24 A. It could be in addition to or it could be"-to assume 25 that responsibility and that would be the only trend.
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(- 1 Q. How would construction, then, if they would, how would 2 they be made aware of the results of the trending?
3 A. Currently the procedure requires Construction to make QA d aware of the trends and that is how it exists now. So, I 5 guess, I would ask you to restate your question.
6 Construction performs tranding at Catawba now?
Q.
7 A. That's correct.
a And, Construction makes OA aware of the results of the Q.
9 trending?
10 A. That's correct.
11 How do they do that?
Q.
12 A. They do that by forwarding the results of the trend 13 analysis to Quality Assurance Personnel.
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Id The Project QA Manager, therefore, has not assumed Q.
15 responsibility for trending at Catawba?
16 A. He has not.
17 Q.. Explain to me how Quality Assurance knows that Construc-18 tion at Catawba is reporting to them all R-2A's? .
I' A. As the procedure requires the R-2A's are logged and 20 forwarded to the designated individuals and their required 21
, signatures and reviews on the form.
22 Q. Those include Quality Assurance people?
23 A. Yes.
24 Q. Let's go forward through the procedure R-2 then. The -
25 original, the individual orginating the R-2A would 'that be 21
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-1 the inspector typ'ically?
2 A. It could be any individual, but inspectors do originate 3 them.
4 Q. Shall obtain a serial number. How do they obtain a 5 serial number?
6 A. They obtain a serial number "com the location when a log 7 is kept, a requirement that they be logged in and numbered 8 sequentially. .
9 Q. Where is that kept?
10 A. I don't know the specific location.
11 Q. Who would know for Catawba?
12 A. Mr. Davis and someone on his staff would know.
- 13 Q. Is it a central location, do you know?
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14 A. I don't know that it's a central location.
15 Q. To whom is the R-2A forwarded once originated?
16 A. As it states here, the individual originating will forward 17 either to QA or C'onstruction.
Is Q. To whom?
19 A. I don't know the individual who would get any one specific ,
20 Q. Does the individual vary? We are talking about Catawba 21 now. Is there one individual at Catawba who would be renpon-22 sible .for receiving forwarded R-2A's?
23 A. I don't know.
24 Q. Who would know that, Mr. Davidson? -
25 A.
Or his staff.
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- (', Are you generally informed on the subject of how R-3A's 1 Q.
2 are processed at Catawba?
3 A. Generally, yes.
4 Q. I will forge ahead. Is there an opportunity for the 5 originating individuals' supervision to exercise control 6 over whether or not an R-2A is originated?
7 A. I'm not sure I understand your question.
a Q. Tell me what you don' t understand.
9 A. You say " exercise control over." I, don't understand what 10 you mean by that.
11 Q. Is it consistent with Duke Power's policy that an indi-12 vidual's supervision could instruct an individual not to 13 originate an R-2A?
14 A. It's not consistent that he would instruct him not to 15 write one, no.
16 Q. So, supervision does not review decision to originate 1-7 an R-2A; does not have any authority to review the R-2A?
18 A. No, to your question.
19 Q. With respect to, again, the procedur e' set forth at R-2, 20 this is sub-paragraph 4.2,"the individual designated by the 21 Project Manager, the Pr'oject QA Manager, shall evaluate the 22 problem, etc." Is there an individual at Catawba who has 23 been designated to perform that evaluation?
24 A. Yes.
25 Q. Who is that?
23 I (E3 O
I i' 'l A. I don't know who the specific individuals are.
2 Q. Who would know?
3 A. Mr. Davidson or members of his staff.
4 Q. Paragraph 4.7, "When corrective action is completed, the 5 appropriate supervisor or person who performed that action 6 shall initial and date the f orm F-2A and forward it to 7 Quality Assurance." Who is the appropriate supervisor in a that case?
9 A. He would be the individual in that area of responsibility.
10 Q. Which area of responsibility?
11 A. Whichever area that specific R-2A was addressing.
12 Q. The craft area?
(; 13 A. It could be craf t area. ,
1d Q. Would it be Quality Control?
15 A. It could be in Quality control.
16 Does it depend on who originated the R-2A?
Q.
17 A. Yes.
~
18 Does it depend on the subject of the R-2A?
Q.
19 A. Yes.
20 Doe's it depend on both of those thir.gs at the same time?
Q.
21 A. I view those as being synonomous.
22 g,. ' So, 'if it 's a welding prob 1'em that's di scovered by a 23 concrete form builder , who is the appropriate supervisor?
24 A. Would you restate that? -
25 If there's a better example Q. Sur e , I'm taking an example. .
24
( ,
f 8 6
-., - - e
b' 1 or if this is not a good example or is inconsistent with 2 application and procedure, tell me. Anybody can originate 3 an R-2A?
d A. Yes.
5 Q. Form builder originates an R-2A about welding, who is 6 the appropriate supervisor with respect to the action provided 7 for in paragraph 4.7.
8 A. The appropriate supervisor or as regards 4.7 would be 9 the individual who carried out the corrective action that 10 was indicated that needed to be done.
11 Q. Tre supervisor of that individual?
12 A. The supervisor in the area that had to perform the actions 13 that were required by the R-2A to be done.
(
id O. The corrective action?
15 A. The corrective actions, yes, sir.
16 Four point nine, Project QA Staff shall review and Q.
17 approve completed R-2A's to assure details. Who on Proj ect 18 QA Staff performs that review?
19 A. I don't know the specific people. As stated before Mr.
20 Davidson or his staff wculd know the' names.
21 Q. Ehat is the discrepancy report log? Do you need' 'the 22 document to refer to? .
~
23 A. Yes. Form R-2B.
24 Q. Discrepancy report lo'g , R-2B, contains a Iisting of all -
25 the R-2A's initiated?
2s (J .
O e e
C: 1 A. Yes.
2 Q. Where are NCI's logged?
3 A. On Form Q-lC.
d What is that called?
Q.
5 A. It's called Form Ql-A Status Log Sheet. ,
6 Q. Mr. Henry, are all conditions adverse to quality such 7 as f ailures, malfunctions, deficiencies, deviations, defective a material and equipment and non-conformances listed on either 9 one of those two forms; that is, the R-2B or Q-lC?
10 A. Would you restate your question, all, in the items you 11 mentioned?
12 Yes, sir, I'm making reference and quoting the text of Q.
13 Criterian Sixteen, Corrective Action of Appendix B Part 50.
Id You are f amiliar with that document, aren't you?
15 A. Yes.
16 And, that provision?
Q.
17 A. Yes.
18 The question, the best I can restate it, are all conditions Q.
19 adverse to quality, such as, failures, malfunctions, deficienc:.e 20 deviations, defective material and equipment and non-conformance 21 logged on either the discrepancy report form R-2B or the 22 status log sheet,, form Q-lC with respect to construction at 23 Catawba?
24 A. All that are significant enough and as applied by, covered
'25 by these procedures are logged.
26
[':
^
e 0
C 1 Q. What is significant?
2 A. Significant are those things that require the actions 3 .that these procedures govern. I mean the scope we are talking d these discrepancies or non-conformances. If they meet those 5 definitions, would be significant enough to write them up 6 on that form. They might get put on the log.
7 Q. Again, are you satisfied that the conditions adverse to 8 quality such as those that are indicated expressed in that 9 Criterian of Appendix B are logged on either of those two 10 logs, sir, and if not, explain where they would be logged 11 and how records are kept of them such that affective correc-12 tive action is taken?
13 A. I feel that all that within the scope of that would be on 14 a log as identified discrepancy.
15 Q. On either of the two logs you have identified, the R-2B 16 or the Q-lC? ,
17 A. Yes.
18 Q. There is no other log for discrepancies that would come l' under that definition?
20 A. No other log that I'm aware of that comes under that 21 definition, no.
22 Q. How are problems d'ealt with in construction, Mr.' Henry, 23 that in your judgment' don't rise to that level of significance?
24 MR. GIBSON: O bj ection. I'm going no instruct 25 him to limit h.is answer to welding inspection and welding 27
{ .
~_ . _ _. _ _ _ . _ _ .- - - _
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'(~ 1 construction. I think that's the scope of the present depo-2 sition.
'3 Q. Ansver the question, please.
4 A. The minor and readily correctible discrepancies that are 5 found by the inspector can be corrected on the spot by 6 returning it for rework and getting it corrected to the 7 inspectors satisfaction. Those would not be logged.
8 Q. Or documented in any other way?
9 A. Not necessarily in any other way.
10 Q. Let's take a five minute break.
11 SHORT RECESS (9:40 a.m.)
12 CONTINUING EXAMINATION: (By Mr. Guild) (10: 00 a.m. )
13 MR. GIBSON: Mr. Guild, during the break, I believe 1d ~you were provided with a copy of the latest revision to pro-15 cedure Q-1 which is revision 18. I believe you earlier asked 16 Mr. Henry some questions about that revision. If you have 17 any further questions, he will respond to those, is Q. Earlier you talked about revisions to procedure Q-1 and 19 I believe that you described the significance of the latest 20 revision as including an additional form providing for a 21 uniform method of evaluating corrective action, is tha't true?
22 A. Yes. -
23 Q. I have that copy of what was handed me and described as 24 the latest revision to procedure Q-1. Would pou direct my 25 attention to that form? ,
28 C
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. _- .- - - _ _ - ~ . - . ..- - - -.. _. .- .
{1 I A. Unless it's an example, you won't find that form in this 2
procedure.
3 Q. Why not?
d A. Because that form is in procedure R-6.
3 Q. What is procedure R-6?
6 A. Procedure R-6 is the procedure that among other things 7
instructs how to fill out the form, what to do with it, a
where to send it, how to log it, who does it, etc.
- O. Is that a' new procedure?
i 10 A. Yes.
i
' Q. Is that new procedure required in order to complete 12
, the' procedural guidance for the handling of non-conforming 13
(~ items along with procedure Q-1, the latest provision?
Q.
Id A. It's required to be considered and used as appropriate as 13 directed by procedure Q-1.
16 Q. Can you do it without -- can you handle a non-conforming 17 item including the use of that new form R-2B, -
- I'm sorry,
'8 Can you handle a non-conforming Let me rephrase the question.
I' item ' including the use of additional form R-6A without
' 20 reference to the; new procedure R-6?
21 A. If I understand your question, a Q-1A b'e handled without 22 using an R-6A7 23 Q. That's not the question.
- ..~
. 24 A. Restate it please.
25
, g, Do I need another procedure in order to be able to have 29
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( I a complete set of guidance on how to handle a non-conforming 2 item through the process up to and including the use of 3 the R-6A form. There is no trick to the question.
d A. There's no trick to the answer either. I said before 5 Q-1 references R-6, and wh et e it r equir es it to be used , it 6 is to be used, and when you use that form R-6A, you do that 7 in accordanc e with procedure R-6.
8 Q. Would you direct my attention to the provisions of R-6 9 then?
10 A. Within procedure Q-1, and I direct you to 5.1.13 that 11 will then get you that reference to R-6.
12 Q. Then, direct my attention to how procedure R-6 describes
- 13 the handling of that.
k.
14 A. R-6 again is not described within 0-1 as regards the 15 details of how to do that. From Q-1, you go to R-6, and 16 then if R-6 is required to be used, then the details on 17 how to fill out the form and process it and make the evaluatio n, 18 those details and handling R-6A ar e found in procedure R-6.
19 Direct my attention to procedure R-6 then?
Q.
20 A. It's not present here. It's within the manual and as 21 stated is a new procedure at the time this revision to 0-1 22 was issued.
23 So, I want to know first, give me a complete understanding Q.
24 of what procedures I need to thoroughly track"the written --
25 any and all written procedural guidance for handling of non-
- 3 C ,
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1 conforming items.
2 A. To get a complete picture of the handling of NCI's, you 3 need Q-1 and R-6, but not all NCI's would require u se of R-6.
4 MR. GIBSON: Mr. Guild, in the interest of saving 5 time and anticipating your next request, we have had Mr.
6 Bell locate procedure R-6 and if we could take a moment to 7 write uncontrolled on each copy, we can make that available.
8 Q. I appreciate that.
9 MR. GIBSON : I want to make clear that uncontrolled 10 is not directed to be a bad word, and you may ask any ques-11 tions youwish about that designation.
12 g, I'm not sure I want to know. Let's mark thnn both the 13 latest revision of procedure Q-1, and that is revision 18, 14 is that right, sir?
15 A. Yes.
16 Q. Let's mark that as the next exhibit. That will be 17 Exhibit Six and Seven, and Exhibit Seven is procedure R-6, 18 and that's Rev. O. Is that the current revision of that 19 procedur e?
20 A. Yes.
21 Q. Do I understand you correctly to say that those are all the procedures that currently set forth written guidance on
~
22 23 the handling of construction deficiencies?
24 A. Those are the Q-A construction procedures"that talk about
.25 how to handle non-conforming items. Id'snotallofthe 3
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O
'(~' l written guidance.
2 Q. I want to understand what wa have here now. Previously 3 you described and identified and made an exhibit, we have 4 procedure R-2 entitled, " Identification and Resolution of 5 Discrepancies."
6 A. Yes, 7 Q. That details how you handle a discrepancy by ure of the 8 form R-2A as you have described?
9 A. Yes.
l
' 10 Q. We have procedure Q-1 which descri bes how you handle i
11 discrepancies as non-conforming items?
12 A. Yes.
13 Ne have procedure R-6 which coupled with Q-1 describes Q.
14 how you handle evaluation of non-conforming items, correct?
15 Evaluation of corrective action?
16 A. Yes.
17 Are there any other procedures that provide written Q.
i 18 guidance for the handling of construction deficiencies?
19 MR. GI BSON: . O bjection. I will instruct the 20 witness to limit his answer to quality control and quality 21 assurance in welding.
22 .Wbuld you answer the question, please?
Q.
23- A. These are the only Q-a' procedures I'm aware of that 24 do ~ handle NCI's at the Cattwba construction s'ite.
25 I didn' t limit my question to NCI's. Non-conforming items,
, Q.
32 CT t 8
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.h' 1 NCI's is a term with precise meaning as used by quality 2 assurance, isn't it?
3 A. Yes, d Q. It's distinct from discrepancies for example that are 5 governed by procedure R-2. Those aren't NCI's?
6 A. As we went over yesterday, R-2A's are reviewed to see 7 if they should be elevated to an NCI, so some do become 8 NCI's.
9 Q. I follow you, but what I want to understand are construc-10 tion deficiencies. I want you to tell me about any other 11 procedure that provides written instructions on how to 12 respond to identified construction deficiencies. No trick 13 to the question. I just want to make sure that I have a Id complete understanding of what written procedures there 15 are.
16 A. I did not suppose any trick to your question. I'm 17 trying to answer your question.
18 Not NCI's, but any construction deficiencies?
Q.
I' A. I' know of no other specific written guidance to handle 20 construction deficiencies.
21 Q. Let's go back and I want you to put these procedures 22 and the compliance with those procedures in the prospective 23 of some concrete examples in the welding area, Mr. Henry,
. 24 to the extent that you know. You related .yesberday the 25 ,
33
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' i 1 alternatives that' were available to a welding inspector 2 who identified construction deficiencies?
A.
3 Yes.
4 Q. Help me follow through how those alternatives are handled 5 in a specific setting using the procedures you have now 6 identified. Let's take the example of a welding problem 7 and one that is identified by a welding inspector. Now, you 8 have characterized a type of problem and I don't want to 9 put words in your mouth, but to save a little bit of time, 10 you called it minor and readily correctable. Is that your 11 term?
12 A. Yes.
., 13 Q. Give me an example of a minor and readily correctable C
14 problem in. welding.
15 A. Minor and readily correctable problem could be one where 16 a welding inspector would when called to inspect the weld 17 observe that there is dust on the weld and it needs to be 18 cleaned up before he can complete his inspection.
Describe for me how the ' welding inspector would handle
~
19 Q.
l 20 that deficiency. First of all, is that a deficiency?
21 A. In -the context that I have been speaking here, I would 22 not call that a deficiency.
23 Q. I want to understand this in the context of a deficiency.
l ,
24 Now, a deficiency, let's u se the term to mean.'a deviation l
l 25 from acceptable workmanship, all right, sir?
l
- (
l l
1 A. Yes.
2 Q. If that's not an example of a deficiency, give me one 3 that is and then describe how it is handled.
4 A. An example could be where the welding inspector was 5 called to inspect the weld, and he sees a minor amount of 6 weld splatter adjacent to the weld, and he would request 7 the craft to remove that splatter prior to completing his e inspection.
9 Q. Do you define minor there as a cosmetic problem?
10 A. Yes.
11 Tell me what the welding inspector would be expected to Q.
12 do if he identified a deficiency of that character?
13 A. He would be expected to notify the welder or the super-f7 14 vision of that welder and advise him that for him en enmplete 15 his inspection, he requests that that condition be cleared.
16 Direct my attention to procedures you have identified Q.
17 and lead me through by reference to these procedures the is written guidance that the welding inspector would follow.
19 - This example would probably not get you~ to this procedure.
A.
20 As you recall our discussion yesterday, the individual pro-21 cedures, where there is control of the condition by what 22 we normally call process control within those procedures 23 would provide a mechanism for either' individual steps to Ibe 24 signed off 'or a combination of steps. If tha$ provides 25 adequate control such that the inspector would not sign until as (1 ,
9
&' I he had the condition thathe was satisfied with, he would 2 'not be within either the two procedures we are talking about.
3 Q. What procedure would dictate or provide guidance for 4 the inspectors response in those circumstances?
5 A. To give you an example of what a welding inspector might 6 find to get youto this procedure --
7 Q. I would like for you to do that, but first let's use the 8 example so I can track it. The one you started with, and that 9 is minor weld splatter.
10 A. In that one, when that condition is cleaned up to his 11 satisfaction, he proceeds with t.%e rest of his inspec-12 tion in accordance with established criteria. If those 13 criteria are met, then he would sign off that weld as being
,3 14 acceptable, and process control would proceed on to the 15 file, 16 Q. Tell me the procedure that provides written guidance to 17 the inspector to handle it in the manner you just described.
- 18 A. One example of a procedure that would do that would be I .
I' procedure M-4.
20 What is procedure M-4?
Q.
~
21 A. M-4 is inspection of welds but that is not to be taken 22 as an exact title.
23 Is this one of the procedures that was revised in light Q.
24 -of the' Welding Inspector Task Force recommendition, if you 25 remember? We can pull them out.
(lb
i '
1 A. I don't recall, but you have that.
2 Q. Let's see if we can take it out.
3 MR. GIBSON: Mr. Guild, I think we have found a d copy f aster than you.
5 A. M-4 has not been revised.
6 MR. G IBSON : As a result of the Phlding Inspector 7 Task Force.
8 A. Yes.
Q. What dos antation is required of the identification of 10 the deficiency of the sort you have just described?
11 A. No documentation would be required.
12 Q. What written guidance is available to provide a standard r-13 for the welding inspector to distinguish between deficiencies IC 14 to be handled under procedure M-4 or process control as 15 contrasted with either Q-1 or R-2?
16 A. Again, as we discussed yesterday, if an individual pro-17 cedure does not provide the necessary controls of a particular 18 condition or the necessary process control to' sign off and l' show the acceptable condition as being reached, procedures 20 R-2 and Q-1 are available and would be used in those cases.
21
'Q. There is no other standard?
l 22 A. I don't understand the question or the' standard in 23 regards to what? I just ask you to amplify that question.
24 Q. I'm trying to understand if there is a wr;itten source i
of guidance to provide a standard for the exercise of
~
25 37 C7 .
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1 of judgment by in this instance a welding inspector?
2 A. There is no written standard to speak to the exercise 3 of judgment.
4 Q. When a welding inspector in this instance employs a 5 procedure M-4 or other routine process control for correcting 6 construction deficiency,and there is no required documentation 7 of the identification of that decision, is there any other 8 manner in which the company assures that the cause of the 9 deficiency is identified and appropriate corrective action 10 is taken?
11 A. There is no other written formal QA requirements that 12 I'm aware of.
r 13 Q. Is the Nuclear Regulatory Commission informed of the kg 14 procedures that you have described?
15 A. Yes.
16 Q. How are they, if you know?
17 A. They are informed by having ready access to all of our 18 manuals and procedures and routine scheduled inspections 19
- and review of the w>rk that is done in accordance with those 20 pr ocedures .
l 21 Do you have personal knowledge of any NRC representatives, l Q.
22 staff person or have you been inform d of procedures you have 23 described for handiing construction deficiencies?
24 A, yes, -
25 Q. Who is the NRC representat'ive that' had that information?
(?; 38 s:
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~
1 A. Mr. Van Doorn as the resident inspector at Catawba is 2 aware of these procedures.
3 Q. Are there any instructions that specify deficiencies in 4 the welding area which are not appropriately dealt with in 5 a non-documented f ashion, Mr. Henry?
6 A. You paused and I lost -- Could you restate the question?
7 Q. I want to understand specifically in the welding area, 8 are there any written procedures, written instructions that 9 specify the welding deficiencies that are not appropriately 1.0 handled by an un-documented fashion?
11 A. lio .
12 Q. In light of the procedures that you described, I want f:~. 13 you to tell me of any identified problems, short-comings b .
14 or f ailures in the implementation of t hose procedures that 15 affect welding at Catawba and then to explain generally 16 what corrective action the company has taken?
17 A. The procedures you are speaking of..bning R-2, Q-1, R-6, 18 which procedures?
l 19 The procedures we have spent the last day and a half Q.
i 20 talking about.
21 A. Q-1, R-2, M-4 and R-6?
22 Q. And, any others that you haven't referred to t. hat deal 23 with the su bject of construction deficiencies in the welding 24 ~-
area.
l 25 A. I know of no particular problems. in dealing with those (5I . -
l
C 1 other than the complex, detailed nature of the procedures 2 and the improvements that would be made as we find better
'3 ways to do the b u siness, I know of no significant or d particular problems in people understanding and carrying 5 out the procedures.
6 Well, you did identify problems in implementation of Q.
7 welding inspection procedures and those identifications --
8 that identification occurred generally in the process of 9 investigative complaints by welding inspectors at Catawba 10 in late '81, early '82, did it not?
11 A. We identified a need for better communication and 12 understanding or trying to clarify which procedures to use in
- e. 13 which cases and again as we spoke to you yesterday, if an 4
14 individual were to use Q-1 and where R-2 might be more appro-15 priate, but the reason they did that was because of some un-16 clear language in either one of those two procedures, it's 17 been corrected to try to make sure that individual uses the 18 right procedure.
19 You did identify a number of specific technical concerns Q.
20 as having confirmed basis, did you not?
21 A. Me, yesterday?
22 No, sir, You, Duke Power Company.
Q.
23 A. In what r egard. Are you talking some specific document 24 or --
25 I'm talking about the concerns expressed by the Catawba Q.
4 CE) .
N.,
I welding inspectors?
2 A. Yes.
3 Q. Those identified and confirmed technical concerns required d corrective action, did they not?
5 A. Yes.
6 Q. I want you to tell me about the corrective action, first 7 of all, would you tell me about the problems that were iden-8 tified and I want you to tell me about the corrective action.
9 A. Corrective action were those that were recommended by 10 the Welding Inspector Task Force and approved by management 11 to be implemented, and, again, as we talked about yesterday, 12 thove corrective actions were carried o'ut within whatever
,~ 13 areas of responsibility they fell in and we also talked about E'-
14 the fact that an individual was assigned to make sure that 15 all recommendations by the Task Force were appropriately 16 assigned and the actions were completed.
17 Q. I want you to be specific. Tell me what was the most -
18 significant identified technical concern that required 19 corrective action. I will make available to you some docu-20 ments and you can -- counsel, do you have a non-pirated set 21 of documents that you identified for Mr. Bradley's file.
22 I know you kept a copy of them.
I want to make them avail-23 able to the witness so he can have his complete set, your 24 complete. set.
25 MR. GIBSON: Those are in the QA Department a 4
4
f*.
5 1 block away. They were copies over there and brought over 2 here, but one of the things you have been unclear on, Mr.
3 Guild. Those are the documents for Mr. Bradley and that's d what he ju st described.
5 Q. That's what I'm going to hand to him right now.
6 Documents were given to me yesterday that purportedly come 7 from Mr. Bradley's file. Mr. Bradley is the individual you 8 just spoke of who had responsibility for monitoring the 9 implementation of the Nelding Inspector Task Force recommen-10 dations?
11 A. Yes.
12 Q. There's a stack there, and another binder there. If j
13 you see anything you ne d beyond that, please tell me, but 14 what I want you to do is address that last question and that 15 is the most significant technical concern requiring corrective 16 action.
17 A. I can't identify the most significant technical concern.
18 Q. Why not?
19 A. I'm not able to make any judgment from that as to which 20 is the most significant there, and my opinion the technical 21 concerns were not that significant.
22 Q. None of them were significant, is that your opinion?
23 A. That's the report and analysis of the technical concerns 24 showed that they .iere not that significant of -a technical 25 nature.-
42
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. +
1 Q. Did they relate to safety-related areas?
2 A. Some, yes.
3 Q. Of those your opinion is still the same? None of 4 those were significant?
5 A. Yes.
6 Q. How are you using the term significant?
7 A. I'm using that term in that the question regarded any 8 technical concerns.They were reviewed by the Task Force and 9 other personnel or resources needed to review those for
- 10 their adequacy and the result of that review showed that 11 there were no significant technical concerns.
12 Q. I'm going to use -- I'm going to quote from the same 13 provisions of Appendix B, of'.which you are f amiliar, I believe ,
(~ ~ '
14 and that's Criterion 16, corrective action. You are familiar 15 with that?
16 A. Yes.
17 Q. Are you using the term significant -- I'm asking your 18 opinion now, and I think you have just expressed your opinion.
19 Are you using the term significant in the same f ashion as 20 it's employed in the following ref erence? ' tin the case of 21 significant conditions adverse to quality, the measures shall 22 assure that the cause of the' condition.is determined and 23 corrective action taken to proclude repetition."
24 .A. No, I don't equate those as being totally"-synonomous.
25 .Q. I ask you to employ the term significant as you understand
~
( .2 . .
G *
- , . - . - _ ,m.
9 0- 1 it to be employed in that criterian of the Commission's 2 Quality Assurance Appendix B Criterio.n, and then answer the 3 queition in that light, please.
4 A. In that regard, if a non-conforming condition exists and 5 it's deemed to be a significant condition, non-conforming 6 condition, the root cause should be determined and corrective 7 actions taken.
e Q. I think you either missed me or you are not addressing the 9 point. I want to focus on the technical concerns raised 10 by the Catawba welding inspectors and I asked you to express 11 your opinion about the significance of those and you expressed 12 the opinion that they weren' t significant.
. 13 A. Yes.
Id Q. Now, using the definition of using significant as that is term is employed in this standard, exercise that same judgment 16 and express your opinion with respect to the Catawba welding 17 inspector concerns.
18 A. Using the definition in Criterion 16 there were conditions 19 that were appropriately non-conforraed and the non-conformance 20 should have and did receive the evaluation to determine the 21 root cause and corrective action. Therefore, using that 22 definition, they were significant enough to require those
. 23 reviews and analysis.
24 Q. I'm not talking about a speciNic hardware" problem. I'm 25 talking about use o.f the term significant as employed in that a
T'
? I criterian. Rising to that level of significance, if you 2 will. Employing that term used in that basis in your opinion, 3 areany of the technical concerns raised by the welding 4 inspectors significant?
5 A. They were significant as identified in criterian 16 and 6 were dealt with in accordance with that.
7 Q. With respect to the documents that are in front of you, 8 sir , and those ar e Mr. Bradley's , purportedly Bk . Bradley's 9 files, with respect to implementation of the Task Force 10 Repor.t recommendations identified the specific concerns 11 that are in your judgment significant and describe the 12 corrective action taken.
13 A. My opinion, all of the technical concerns that resulted s
14 in a non-conformance put it -- put those within the area 15 of review required by criterion 16, so in using that and 16 the word significant being there, then they were significant 1:7 enough to be considered under that criterian.
18 Q. Tell me what you are referri'ng to now.
19 A. I pulled from this file which I d'on't -- this is not -
20 the Weiding Inspector Task Force. In the file given me, I 21 see four documents here which are labeled non-conforming items ,
22 Within that there is non-conforming. item 9258, NCI 92, and 23 that's the only two I see. So, those were significant within l .
24 the. context 'of Criterion 16. That' is th ey ne'eded to receive 25 the required evaluation and appropriate corrective action 45 l(D.
I i
_ _ . . _ . _ . _ _ . _ . . _ - . - _ _ _ , . . - ~. . _
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1 be taken. ;
2 0.7 I show you a copy of a document that was made available to 3 u's' in discovery. It',s rather poor copy, but if you would, 4 sir , read that and tell' me -- I will represent that that is --
5 MR. GIBSON:, Can we mark this or have it identified 6 some how? -
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3 7 ~Q. Let me ask the witness if he can. Read that document,
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- s. .'if you would. Take a moment and read it. You don't need 9, to read it aloud, but read it and tell me whether or not 10 thatrepresentsasignificantconcernasyou[ understand, sir.
s.~ 11 A. I have rdad it.
12 Q. Yes, and your answer?
13 A. The question, please?
[' 14 Q. I want you to evaluate the~~ significance of~the concerns 15 expressed in that document.
16 A. I can't from this.
17 Q. Why not? ' i 4 18 A. There is not enough information to do that.
m 19 MR. GIBSON: I'm asking that some kind of descrip-20 tion be given or that the docume'nt be marked so the record
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21 will be clear as to what has been shown to 'him.
22 Q. We can mar,k'it if you like.
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23 MR. GIBSON: Either Nay. Describe or mark it,
. 24 Marking it is probably the easiest way.
25 - We will mark it as the next Exhibit and that would be Q.
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l Number Eight. Read that the best you can, sir, and for the i 2 record, read it aloud.
3 A. Dated up at the top and it says January,1982.
d It appears to be someone's calendar, doesn't it?
Q.
5 A.Yes, and starting "about nine o' clock it reads as follows, 6 "Found out that "L"' dimension problem (1/14/82) had not 7
,been taken care f.> Had to threaten work stoppage, bu t 8 Joe S. says that problem is being taken < care of. Talk ed 9 to' Bob and Charles B. If situation is not corrected, work 10 stoppage will be processed. Problem since summer '81,"and 11 ending about-5 30 is the number'13,662.
12~ Do you know someone named Joe S. who works in welding
'Q.
t 13 at Catawba or has worked in welding?
14' A. No. I know Joe Shropshire works in Quality Assurance.
15 He supervises Quality Assurance with respect to welding?
Q.
16 A. He does not supervise welding inspectors.
17 He reviews work of welding inspectors?
, ,0 18 A.Yes.
"39 - 'O. Do you know Charles B.?
20
, .A. Yes, Charles Baldwin works at Catawba in Quality Assur-21 ance.
27 Does he review work of welding inspectors at Catawba?
Q..
23 A. Yes. ,
24 Q. Someo,ne named Bob who reviews the work ofnwelding 25 inspectorst that work in Quality Assurance at Catawba?
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'C" S' 1 A. I know a Bob in Quali ty Assurance, and that certainly 2 would be a guess with no initial, but there is a Bob Morgan.
3 Q. He and Mr. Baldwin work together supervising quality 4 assurance?
5 A. They are both supervisors in quality assurance, yes.
6 Q.. Does the number 13,662, could it be the number of an 7 NCI for that. period of time?
8 A. Most likely, yes.
9 Q. Then, on that basi s, can you tell me whether or not 10 that expresses what in your judgment would be a significant 11 concern?
12 A. Not with that. I could not rule on the significance 13 of. those statements just wiith those notes.
t, 14 It's something that would require stop work decision Q.
15 by a welding inspector significant?
16 A. It should be a significant condition to require work 17 stoppage, yes.
Is Q. Would it then be significant and require some corrective 19 action in your opinion?-
20 A. Yes.
21 Can you tell me what corrective action was taken with Q.
22 regard to that concern?
i 23 A. No.
24 Q. What would you need to be able to do that?- -
25 A. On the related documents, if they were p'roduced, certainly
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s not from those notes that I state whether I think that is 2
significant or not.
3 Q. Do you know whether that has been taken care of or not?
4 A. No.
5 Q. I'm marking anotherexcerpt from this calendar Exhibit Nine 6
and take a look at that, sir, andread the o bservation.
7 A. "CP22A, serial number 82 reference paragraph three, page 8
four, revision 22. Statement on interpretation is in error 9
informed Art. Willful disregard of procedure." That's on a O
calendar item that has Fe bruary, '
82.
11 Q. Is that expressed in your opinion as significant concern?
12 A. I couldn' t rule on it on ju st that statement.
13 p
. Q. Do you know someone nam ed Art that works in Quality 14 Assurance?
15 A. Yes, Art Allum also works in Quality Assurance at Catawba.
16 Q. What is Mr. Allum's job?
17 JL. Mr. Allum is a supervisor in Quality Assurance.
18 Q. What is his responsibility?
19 A. His responsibility is supervision and welding inspection 20 area. l 21 Q. Did he perform that function in February of '82?
22' '
'A. I. don't recall when he went in.
23 Q. In your opinion, does willful disregard of procedure reflect' 24 a significant concern? l 25
,A. Those words are strong words. q
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ik I Q. Yes.
2 A. But, I can't rule on the significance of it from what I 3 said from what you presented there, d
Q. What is CP 22F?
5 A. CP is the common abbreviation for construction procedure.
6 But, again, without looking at that, I could not represent 7
that is exactly what that is.
a Do you know what that numbered construction procedure is?
Q.
9 I don't know that construction procedure.
A.
10 Q. Nbuld tha,t be a weldhg construction procedure?
11 A. I don ' t kno w.
12 Q.. Do you know whether or not that concern has been corrected?
13 jf A. I don't know.
Id Q. We are marking another series of documents Exhibit Ten.
15 Do-you know a V. C. Godfrey, Jr.?
16 A. Yes.
17 Q. Who is Mr. Godfrey?
18 A. My understanding is that he. is a welder at Catawba.
I' O. You don't know Mr. Godfrey?
20 I said I know -- when I said I know him, I know who he A.
21 is. I have seen him, but I don't know him as a personal 22 friend.
23
'Q. ;You know that' Mr. Godfrey is a welding inspector at 24 Catawba who has' expressed concerns that were a'ddressed in, 25 the Welding Task' Force Report?
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[' 1 A. I know that Mr. Godfrey does appear in the Welding 2 Task Force. yes.
3 Q. Look at that document and take it item by item, sir.
4 A. Do you want me to read it?
5 Q. You don't need to read it aloud. Read the first item, 6 and then respond to the same question. Actually, why don't 7 you take a few moments and examine the document and let's 8 stand down for a moment and take a brief recess.
9 SHORT RECESS (10:55 a.m.)
10 CONTINUING D(N4INATION: (By Mr. Guild) (11: 05 a.m. )
11 Q. Mr. Henry, over the break, did you have a chance to 12 examine the document we have had reference to. It's marked 13 Exhibit Ten, and it's Mr. Godfrey's notes from January 20, V
14 19827 15 A. Yes.
16 Q. On page one under the heading NCI 9085, "When called to l'7 take the NCI tags off of the pipe QC Welding found that 18 there were three heat numbers on the pipe. When ' brought
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19 to the attention of Larry Davison, I was informed that 20 the resolutions on NCI's were of no concern of mine and to 21 remove the Q-1B tags." Is that a significant concern?
22 A. Not as just reading that.. I wouldn't judge it at 23 chis point with just that limited number of facts to be 24 significant.
25 Q. NCI 9358, "Khe:n called for fit-up inspections on four 51 b
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- I welds, it was found that the heat number CA72 had two SA 2 numbers on these fits. This was also found by another fellow 3 inspector, John Bryant." Reading further, "The NCI was 4 voided by Larry Davison and he said that he did not see 5 a pro blem with the problem that I had." Does that reflect 6 a significant concern in your opinion?
7 A. Not just from the f acts presented therein, no.
8 Q. Was that concern fully corrected?
9 A. I don' t know.
10 Q. NCI 10,187, "Found there was not a piece number on the .
11 reducer or on the M-4A. This violates M-4 and H-4. Resolution 12 on this NCI stated accept as is." Does that reflect a signi-13 ficant concern in your opinion?
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14 A. Not as stated there. I wouldn't rule it significant yet.
15 Q. Was that concern corrected to your knowledge?
16 A. I don't know.
17 Q. NCI 9119, "Found that welding had violated pre-heat 18 by exceeding 500 degrees F. Resolution stated accept 19 as is. This violates all of the process spec. that we have 20 to go by." A significant concern?
21 A. I couldn't rule off those limited f acts.
22 Q. What more information would you need about that . specific 23 example to express an opinion as to the significance of that 24 -
concern?
25 A. Supporting' documents and f acts needed to be reviewed to (L
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9 s e- - .- , - . . - --
r d i determine the significance of that concern.
2 Q. Sir, I will ask you to accept as a hypothetical that there 3 was a pre-heat standard, that during routine pre-heat inspec-4 tion it was found that the pre-heat had been exceeded by 5 exceeding the standard of 500 degrees F. , that violated 6 the process specif'ications. Would that reflect a significant 7 concern in your opinion?
8 A. Not just on what you state. It would require investiga-9 tion.
10 Q. NCI 7850, " Lower pressurizer support. e W'lder overlapped it weld to another without getting the pre-heat signed off.
12 About seven inches. The NCI stated only one inch. Written c 13 up by tech. support." David Gadd, can you identify that i
14 name?
15 A. Yes, I know Mr. Gadd.
16 Q. Who is Mr. Gadd?
17 A. He is an engineer , - a construction staff at Catawba.
is Q. " David Gadd stated that he took the welding foreman's 19 word on the amount of overlapped weld." Charles Baldwin, 20 Mr. Baldwin, you know?
21 A. .Yes.
22 Q. He works in QA?
23 A. Yes.
24 Q. " Told QC ' Welding to remove the tag, but then removed 25 tag himself and told QC Welding to sign off weld." Does
= 53
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r I that reflect a significant concern in your opinion?
2 A. Not just on the f acts stated. It would require investi-3 gation. -
4 Q. Has that concern been corrected?
5 A. I don't know about that specific concern.
6 Q. "I have had several NCI's that I have written, gotten 7 approval from Beau," Beau Ross?
8 A. Yes.
9 Q. What does Mr. Ross do?
10 A. He is a supervisor in the Quality Assurance Department 11 at Catawba.
12 Q. Supervises welding inspector s?
7, 13 A. Yes.
M 14 Q. " Bu t , yet trash canned by Charles Baldwin or Larry 15 Davison. In Q-1 procedure it states that after an NCI 16 has been written, a nwmber may be obtained. They never 17 let me get a number on these items., Do those reflect signi-18 ficant concernsin your opinion?
19 A. Again it would need to be investigated to determine the 20 significance.
21 Q. You can't identify that as a significant concern on the 22 face of what I stated?
23 A. No.
24 Q. Do you know ikhether those have been corrected?.
25 A. I don't know if that specific situation has been corrected .
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.h I Q. "Harrassment," same page, "Harrassment has been a problem 2 in the past with craf t and QA. Threats made to inspectors 3 in the course of doing their jobs by angry craftsman have d not been handled by upper QA management to help protect 5 the inspector from future incidents." Is that a significant 6 concern in your opinion?
7 A. Not as stated on those f acts. Again, it would require 8 investigation.
9 Q. "Most recent incident of harrassment was Ed McKenzie and 10 Larr y Jackson. Larry- Jackson was totally in order with the 11 procedure- but was told that he instigated the problem.
12 Welder, Howard Beard threatened to push John Bryant off a 13 scaffold if he rejected his work. John was told by Larry Id Davison that itwas part of our job to take occasional abuse 15 from irate craftsmen." Does that reflect a significant 16 concern in your opinion?
17 A. I can't say off that statement.
la Q. Do you know whether that concern has been corrected?
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I' A. I don' t know.
20 "I have been called an S.O. B. by Lewis Lowery for Q.
21 rejecting some of his work. I was told by Charles Baldwin 22 .just to push it aside. A significant concern?
23 A. I can't say from that.
24 Q. " Upper management does not seem to want to retai'n good . .
25 help. I personally have been told that someone off the 55
' ~' I street could fill my job with less money. If that is the 2 case, do it; but let it be clearly known that the quality 3 of the QA Department went to the dogs and that the NRC 4 and the press of news will be interested to know of this."
5 Does that reflect a significant concern in your opinion, 6 Mr. Henry?
7 I couldn't say from that.
8 Q. Do you know whether that concern has been corrected?
9 A. I don't know.
10 Q. " Larry Davison has informed me that as an inspector it 11 is of no concern of mine as to what a resolution says. He 12 has also told me and other inspectors in the past that 3 13 he was as far as the problem (whatever it was) would go. "
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14 A significant concern?
15 A. I couldn't say from that.
16 Q. Do you know whether that concern has been remedied or 17 corrected? .
18 A. I don't know.
19 .We the are professionals and take pride in our job, Q.
20 but. it is hard to do when our people cut our throats and 21 don't give u s any support in our QA procedures, construction 22 procedures, harrassment and money among other things. .I 23 don't know who will read this letter, but I hope whoever does
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24 read it takes it seriously because I do. I also hope they 25 give it their deepest conside' ration for Duke Power and myself. "
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f.T s' 1 A significant concern?
2 A. I couldn't say from that.
3 Q. Do you know whether or not those concerns have been 4 corrected ?
5 A. Specifically, no.
6 Q. I'm going to mark another document as Exhibit Eleven, 7 John R. McCoy, have ycu heard the name?
8 A. I don't recall that I have.
9 Q. Mr. McCoy's name is listed among those identified on 10 a list of documents provided by -the company entitled 11 " Handwritten notes from QC and QA Inspectors which set 12 forth their specific pro blems and concerns." Item and notes e 13 of John McCoy. The first page, I will read, The biggest (b.
14 concern that I have as far as not being supported in is implementing the QA program is the fact that at times 16 resolutions and general gray areas have been watered down 17 in order for craf t to meet scheduling deadlines. A lot 18 of these . occasions have been exactly opposite of procedure
! 19 requirements, yet the problems being ' brought up were to be 20 ignored because at this point quality didn't matter, only 21 deadlines." A significant concern?.
22 A. Not off just that. . statement. It would require investiga-23 tion before I could say.
i 24 Q. You don't know whether that concern has been corrected?
25 A. No.
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l Q. How was that concern and the other concerns that we have 2 just touched on, how was that investigated and corrected, if 3 - it was?
4 A. If it was investigated as far as the Welding Inspector li Task Force, then it was reviewed by that Task Force and 6 if it was a specific concern that could be determined valid 7 or invalid that was done, and whatever corrective action a the Task Force recommended would have been taken on that.
9 Q. Walk through, if you would , sir, the specifics of how 10 that concern was addressed?
- 11 A. I don't know how that specific concern was addressed.
12 Q. How was 'the concern raiscd by welding inspectors addressed
- 13 by the Welding Inspector Task Force or otherwise, if it was?
khd 14 A. The concerns raised by the Nblding Inspectors were 15 requested and received and given to the Task Force who inves-16 tigated all of those concerns and reached a conclusion and 17 made recommendations.
Is Q. If that concern was raised by welding inspectors today, 19 how would it be handled; what procedures?
20 A. It would depend on what form and forum it was raised 'in.
j l
21 Say, it came to your attention, sir, in writing much the l Q.
22 same as the . writings we have been examining; handwritten l
l-23 notes from Mr. McCoy, from Mr. Godfrey or from anyone of 24 the dozen or more welding inspectors who did just that, came 25 to your attention, sir. How would it be handled?
?
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x< 1 A. I would direct it to appropriate levels of supervision, 2 and if it came directly to me in all likelihood I would 3 advise my supervisor of it also.
4 Q. Who would be the appropriate levels of supnrvision?
5 A. Depending on from whom the document was received.
6 Q. It Comns from Welding inspector, would you send it to 7 Larry Davison?
8 A. Larry Davison would be notified, yes.
9 Q. How about Larry Davison, if Larry Davison is the su bj ect 10 of the complaint as in the case of a number of the items 11 Mr. Godfrey raised?
12 A. I can't say without a specific example exactly what T.
13 would do.
p 14 Let's take a specific example. This is again Mr. Godfrey, Q.
is his complaints or concerns that are identified as Exhibit 16 Ten. "I have had several NCI's that I have written, got 17 approval from Beau, yet trash-canned by Charles .Baldwin or 18 Larry Davison, etc'." You look at it. That complaint comes 19 to you and you are the first person to see it and your job 20 is QA Manager Technical Services. Who do you refer it to 21 and what do you do?
22 A. I would probably inform my supervisor that I have 23 received this written information stating that.
24 Q. Mr. Grier?
25 A. Mr. Grier. -
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- Q 1 Q. Who would you inform on the other end, appropriate super-2 visor of the man complaining?
3 A. I, in all likelihood, would discuss that with my super-d visor before taking any further action.
5 Q. Would you inform Mr. Davison?
6 A. I might.
7 Q. In that instance?
8 A. In thatinstance, I can't say that there is any written 9 procedure, so I can't say exactly what I would do, a procedure 10 that .I'm required to follow.
11 Q. But, how would you handle it?
12 A. As I stated, I would inform my supervisor and we would 13 discuss it.
v s ..
14 You don't know whether you would tell Mr. Davison or Q.
15 not?
16 A. Certainly, if the supervisor told me not to, I wouldn't.
17 If he told me to, I would.
18 Q. You just do what you are told. Mr . Henry, the tenor 19 of complaints that I have seen and which these are just a 20 handful and you have seen most of these, haven't you?
21 A. Yes.
22 Q. You have seen the same documents in. f act?
23 A. Yes.
24 Q. The tenor of many of these complaints is that things looked 25 fine on paper, sir, and it's my representation. 'If you 60 L~ .
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(' I disagree, that's what I'm trying to solicit is your reaction, 2 is that things look fine on paper. The procedures look good 3 as written. The policies look fine in the policy manual, 4 but as Mr. McCoy points out, it's in the implementation that 5 perceived problems exist and that in the judgment of a number 6 of these welding inspectors, the grality of the inspection 7 work suffered as a consequence of implementation failures.
8 Would you agree that the focus of many of their concerns 9 was not on specific procedure as written, but on the 10 implementation of the procedure?
11 I would agree with that, yes.
A.
12 Q. The affected implementation of these procedures, quality 13 assurance and quality control procedures, is a pre-requisite 14 an effective quality assurance program, wouldn't you agree 15 with that?
16 A. I Will agree implementation is important, yes.
17 And, the bottom line is that assuring that the as built Q.
18 condition of the Catawba Nuclear Plant is adequate to provide l' that public health and safety will a reasonable assurance 20 not be endangered depends on effective implementation of 21 these procedures, wouldn' t you agree?
22 A. That is an important factor, yes.
23 Are you sure that the procedures are being effectively Q..
24 implemented ?
25 A. To the best of my knowledge, they ar e.
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- 1 Q. Were they being effectively implemented at the time 2 related in the welding inspector complaints that we have 3 looked at just now?
4 A. Yes.
5 Q. You have no concern either now or then that these procedure s 6 Were not effectively implemented such that the conditions 7 of the plant was in doubt?
8 A. I have no concerns.
9 Mr. Henry, that's all I have for you, sir, and I appre-Q.
10 ciate you bearing with me and responding to my questions.
11 MR. JOHNSON: No questions.
12 MR. GUILD: Counsel, only one thing, I only have 7
13 a copy of one document and it's two pages and that is Mr.
s.
14 McCoy's which has been identified as Number Eleven. I 15 wonder if I could make a copy of that.
16 MR. GIBSON: During the break here, we will pull 17 it. I take it you don't want to lose it from the stack.
18 We will pull it, copy it and do that. I just have a question 19 or two for Mr. Henry.
20 EXAMINATION: (By Mr. Gibson) 21 Q. Mr. Henry, are you aware of anything that would cause 22 you to quei tion whether the Catawba Nuclear Station is safely 23 built?
24 A. No. ,
25 Q. Mr. Henry, Mr. Guild asked you about some of the items e 62 (J -
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1 mentioned in a memo of Mr. Godfrey and I think a memo of 2 or written document by Mr. John McCoy. What is your under-3 standing of how these items or documents were treated by 4 the Task Forces?
5 A. It's my understanding that the Task Force did receive 6 those items and did review those concerns and reached a 7 conclusion that there was no safety significance in those a concerns and I had answered that I had no specific knowledge 9 of the certain ones as to whehter it had specifically been 10 corrected, and I did not; but it's my belief that all of 11 those concerns were addressed by the Task Force and reached 12 a conclusion that they had no safety significance.
13 Q. Any further questions based on that, Mr. Guild or Mr.
14 Johns;n?
15 RE-EXAMINATION: (By Mr. Guild) 16 Q. Mr. Henry, do you know whether or not the ibiding Inspectot 17 Task Force identified, reviewed and corrected all of the 18 problems of safety significance at Catawba?
19 A. To the best of my knowledge, they reviewed all areas 20 that had any potential significance and reached a conclusion 21 on them.
22 Thank you.
Q.
23 24 W. O. HENRY
, 25 -
63 ,
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1 STATE OF NORTH CAROLINA )
) CERTIFICATE 2 COUNTY OF MECKLENBURG )
3 4 .
5 I, the undersigned Commissioner and Notary Public, 6 in and for the State of North Carolina, do hereby certify 7 that the foregoing sixty-three pages constitute a true 8 and accurate transcript of the evidence given by the said 9 witness in the continuation of his deposition as taken down 10 and transcribed by me.
11 This the fourth day of July, 1983.
12 13
!; f BARBARA V. HAAS 14 Commissioner and Notary Public ,
My Commission Expires:
16 April 23, 1987 17 18 19 20 21 22 23 24 25 64 k_i
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'- w b i INDEX 2
Direct Examination by Mt. Gu ild Page 2; Line 1 3
Cross-Examination by Mr. Gibson Page 62; Line 20 4
Re-Direct Examination by Mr. Guild Page 63; Line 15 5
6 Exhibit Six Page 31; Line 17 7
Exhibit Seven Page 31; Line 17 8
Exhibit Eight Page 47; Line 1 9
Exhibit Nine Page 4 9; Line 5 10 Exhibit Ten Page 51; Line 13 11 Exhibit Eleven Page 57; Line 6 12 13
('
- 14 15 16 17 18 19 20 21 22 ,
23 24 25 S
0