ML20079S460
| ML20079S460 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 01/30/1984 |
| From: | DUKE POWER CO. |
| To: | |
| References | |
| ISSUANCES-OL, NUDOCS 8402030340 | |
| Download: ML20079S460 (338) | |
Text
{{#Wiki_filter:ORIGINAL UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION M-In the matter of: DUKE POWER COMPANY, et al Docket No. 50-413 OL (Catawba Nuclear Station, 50-414 OL Units 1 & 2) O Location: Charlotte, N. C. Pages: 11922 - 12259 Date: Monday, January 30, 1984 J L. f Liv /AL s tiV Y l U' e iv- 12 9 - ,&%4R : 72 o/ \ l) TAYLOE ASSOCIATES (j'T ( Court Reporters to:5 i simi. N w soie loos wasningion. D C. 210o6 8402030340 840130 : 02) .%pse , PDR ADOCK 05000413 T PDR
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~11,922 Sim~ l g UNITED STATES OF AMERICA l
~} 2 NUCLEAR REGULATORY COMMISSION
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3 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4 5 - - - - - - - - - - - - - - - -X 6 In the flatter of: :
- Docket Nos. 50-413 OL 7 DUKE POWER COMPANY, et al. : 50-414 OL
- ASLBP No. 81-463-01-OL 8 (ritawba Nuclear Station, :
its 1 and 2) : 9 : , _ _ _ _ _ _ _ .. _ _ _ _ _ .x i 10 BB&T Center 11 Fourth Floor Carolina Room 200 South Tryon Street 12 Charlotte, North Carolina 28202 13 Monday, January 30$1984
- 14 The hearing in the above-entitled matter -
15 reconvened, pursuant to recess, at 9:50 a.m. 16 BEFORE: 17 JAMES L. KELLEY, ESQ., Chairman Atomic Safety and Licensing Board 18 U. S. Nuclear Regulatory-Commission: Washington, D. C. 20555-19 RICHARD F. FOSTER, Member 20 Atomic Safety'and Licensing _ Board U. .S. Nuclear Regulatory-Commission 21 Washincton, D. C. 20555~ f 22 PAUL W. PURDOM, Member Atomic Safety and Licensing Board a U. L S . Nuclear Regulatory Commission Washington, D. C. 20555' 24
)
( Ts _,) a / 4 l 1
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i 11,92 3 Sim-2 , 1 APPEARANCES:
'(v ) 2
'On Behalf of the Applicants:
3 J. MICHAEL McGARRY, ESO. ANNE COTTINGHAM, ESQ. 4 Debevoise & Liberman. 1200 17th Street, N. W. 5 ' Washington, D. C. 6
- and -
7 ALBERT V. CARR, ESQ. RONALD L. GIBSON, ESQ. 8 Duke. Power Company 8 422 South Church Street Charlotte,~ North Carolina 28242-in On Behalf of the NRC Staff: 11
-GEORGE E. JOHNSON, ESQ.
12 Office of the Executive Legal Director U. S. Nuclear Regulatory Commission Washington,.D. C. 20555-s 13 (s.../1 On Behalf of the Intervenors: 34 ROBERT GUILD, ESQ. 15 Palmetto Alliance P. O. Box 12097 16 Charleston, South Carolina 29412 17 JESSE L. RILEY-18 Carolina Environmental Study Troup 854 Renley Place 19 Charlotte,-North-. Carolina 28207 t 20 On Behalf of the State of South Carolina: RICHARD P. WILSON, ESQ. l 21 Assistant-Attorney. General P. 0.' Box 11549 j 22 - Columbim,. South Carolina 29211 23 ' l 24 '
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(,_ -.
11,924 Sim 3 C_ O N T_ E, N T S_ 1 WITNESSES- DIRECT CROSS REDIRECT RECROSS BOARD x) 2 Panel of: 11,952 11,963 12,035 11,958 JOHN P. AKERS 12,039 3 JOHN M. McCONAGHY RONALD RUTH LARRY R. BARNES JOHN CAVENDER , LAWRENCE W. RUDASILL DAVID LLEWELLYN 4 JOE SHROPSIRE l 7
- NICK ECON 0MOS 12,086 12,149 12,074 8 12,152 9 HOWARD S. NUNN 12,165 12,159 12,181 10 Panel of
i MORGAN'DANNY RAY 12,215 12,232. 12,222 11 MALCOLM YOUNG DAVID BUCK HENRY 12 KEN WEBBER HARRY BARKER 13 J. R.~ WILSON N>} DAVID LLEWELLYN 14 JOE SHROPSHIRE ED MC KENZIE 15 LARRY RUDASILL. RON BARNES
, 16 WILLIAM ROGERS 17 l . ,
18 4-18 20 - E'X.H I B I T S 21 . EXHIBIT NO. IDENTIFIED RECEIVED 22 Applicant's.No. 110 11,954 12,053 23 Applicant's No. 111: .11,957 12,053 t Intervenor Palmetto No. ..134-139 12,097, 24 -Staff No'. 22 & 23 12,073-Staff No. 24 12,157 12,157 D[')( 25 Applicant's No..112 -12,220- 12,220
11,925' Sim 1-1 1 PROCEEDINGS p/ q_j 2 JUDGE KELLEY: Shall we go on the record. 3 Good morning on behalf of the' Board. There 4 are a lot of familiar faces back here. We all trust you
- 5 had a Merry Christmas and a Happy New Year. We can all 6 -cross our fingers and say how delighted we are to be back f
7 here in the conference room.at the BB&T Building. 8 A few procedural matters before we get to the 9 business at hand. We initially scheduled the other day a ICF piece.of time right at the' beginning on the subject _ of diesel 11 generators and now it looks more convenient to put that over ) 12 till perhaps after the next break. But we expect to do'that (" 13 later in the morning rather than right now. It_is primarily , N.s 14 for Mr. Guild to present rebuttal on the oppositions to the 15 diesel generator contention. 16 A separate point entirely, but one which we might 17 spend a few ninutes on tomorrow is that we have pending 18 before us a motion from the applicant to bifurcate the case 19 and establish a separate Board in the interests of the more 20 expeditious hearing of the emergency planning questions. 21' Now the parties,.namely the staff and Palmetto, 1 22 and CESG are free to file the usual pleading, but it just 23 occurred to us that maybe they would just as-soon speak to
~
24
, this on the record sometime tomorrow. That would be accept- -l 'm 25 able to us. In-fact,_in the interests of just hearing where l
11,926 Sim 1-2 you are on it, it might be better. So if that sounds like p 2 a favorable proposition _we would be happy to take some time
^
tomorrow. 3 Let me just say to the staff in particular on that point that we would want from you and you would probably
-assume.this anyway, but we would want from you your current
-7 best estimate of where all the FEMA matter stand and when FEMA is going to come up with a set of interim findings or g testimony or whatever it'is they are going to come up with J
10 so that this matter can go forward from _their standpoint. g Alternatively, on the basis of the staff's g independing review of the facility and where-it stands and u what the staff's projection is now of fuel loading. time, g and beyond that the time between fuel loading and assention g over five percent power. It occurs to us in terms of fuel 16 loading-if tha plant is now looking at about the 1st of 17 February and the applicants see it loading in May, there 3g ought to be time to make a pretty accurate-projection-of g that and we would just like the staff's view. g We owe the parties a couple of. evidentiary-21 rulings that got put over from_the proceeding last December. 22 One of them pertains to an engineer's statement attached y to an NCI and the other one' pertains to some tables'in a what.came.to be called the Sandia Report. _ I think we can
-( 7 _ g give'you both of those tomorrow. That.would put'you_in some L ,I . _ - _ _ _ _ _ _ _ - _ _ _ _ - _ -_ __:__--____ . - - ____:_- = _ _ _ _ _ _ _ - - - - _ _ - -
11,927 Sim 1-3 1 kind of shape to address them in your proposed findings (~^) 2 and conclusions. \v' 3 Our primary Purpose here today is to complete 4 the hearing process on the concerns that were raised 5 initially last November by the In Camera witnesses. We have 6 referred to them collectively as the In Camera Witnesses. 7 We are going to focus today on two of those 3 concerns and then the remaining three tomorrow. The two 9 that are before us today are laminations and the containment p) plate and the concern about foremen override. Those are 11 both shorthand terms, but the parties know what we mean. 12 Both of these particular concerns were raised 13 initially by Mr. Howard Samuel Nunn. t \ r~ i t 14 Did I get that exactly correct, Mr. Nunn? 15 MR. NUNN: Yes, sir, p3 JUDGE KELLEY: I got your name right, Howard 17 Samuel Nunn, Jr. 18 MR. NUNN: Yes, sir. 19 JUDGE KELLEY: At that stage tir. Nunn had come 20 in in response to the Board's commitment to hear information 21 on a confidential basis and he and several other people did 22 so. Mr. Nunn has decided that he no longer desires 23 confidentiality. So this hearing this morning is un open 24 hearing. i ; \ / 25 I am. assuming you will let me confirm, Mr. Guild, l
11,928 l
- Sim 1-4 p that this also has the effect of making public the prior testimony of Mr. Nunn- the prior appearance? I
) 2 3
MR. GUILD: Yes. sir. Mr. Nunn submitted an affidavit, Judge, in support of a pleading to the Appeal 4 Board that I hope w.xs circulated to you and the other panel 5 me ers. 6 7 JUDGE KELLEY: 'I believe it was. 8 MR. GUILD: It included Mr. Nunn's 4ffidavit i 9 that stated that he desired that. henceforth he would be 10 public and that retroactively, if you will, the record should 11 be open ot the public of what he said and what the company 12 and the staff have responded to as-well. 13 JUDGE KELLEY: Thank you. Well, that is now {~'} m 14 made a matter of record. I guess it already has been in 15 'the affidavit you referred to, Mr. Guild, and I appreciate 16 that. That is cenerally preferable that we run public hearings 17 and that things are in the Public Document Room, and we will 18 see to it that transcripts primarily that were heretofore 19 treated on an In Camera basis are released to.the Public-20 ' Document Room when we get.back home. 21 MR. JOHNSON: ' Judge Kelley? 22 JUDGE KELLEY: Yes. 23 .MR. JOHNSON: - If you are going to move.off that 24 subject, there is one thing-that'the staff would'like to
. (D \~ ' 25 bring to your attention. We: filed some' materials'with
1 11,929' Sim 1-5 1 the parties and the Board on the assumption that the protec-2 tive_ order applied to them and we still need to protect 3 some of those materials.. 4 So that if you are going to treat the proceeding 5 on these matters that were raised by Mr. Nunn as open, 6 then we still have to deal with the question of whether there i 7 is some confidentiality that still has to be protected. 8 JUDGE KELLEY: Is it a matter of segregating 8 pages and lines and things like that? 10 MR. JOHNSON: It is mainly one document that there was an attachment to the testimony that we filed last week. JUDGE KELLEY: Okay. Well, I certainly don't I# mean to imply, and to put.it a diffeient way, we want to 15 be careful in making Mr. Nunn's materials'public that wo 16 don't compromise confidentiality on someone else who 17 doesn't want to waive the confidentiality feature and what-18-ever we need to do to accomplish that and.what counsel 19 need to do should be done.
~
20 - You are look for sort of a general statement 21 of principle on that? 22 i MR. JOHNSON: Well, we do have to do something 23 specific.-EIf we can get an order ---
^ 24~
r
, g- JUDGE KELLEY: Is this-something before us? Is
( )
' M this a document before this Board or the Appeal' Board?
- _ . ._ . - _ . _ _ - _ , _ . - . ,. - u-. .. _
J _j. 11,930 Sim 1-6 MR. JOHNSONi Attached to one of the reports , 1
. -~
) that was circulated to the parties was something called 3
2 3 " Summary-of Investigative Interviews." 4 JUDGE KELLEY: Yes. _5 MR. JOHNSON: It is a 25-page document and it 6' is that document that needs to be protected. If the protec-7 tive order that has been in effect up until now regarding l 8 Mr. Nunn's allegations is not going to be in effect, then 9 we need something else to protect this. 10 JUDGE KELLEY: That reflects the staff's invest'i-11 gation, does it not, of the foreman override point? 12 MR. JOHNSON: Yes, and other matters.
'~') 4 13 JUDGE KELLEY: And you have a reason for keeping ,
1 14 that confidential quite apart from Mr. Nunn's view on whether e i 15 he should be kept confidential or not,-right? 16 MR. JOHNSON: That is true..-There were inter-17 views done on a confidential' basis. 18 JUDGE KELLEY: Okay. Well, again, the Board' 19 doesn't mean to say anything contrary to that either and 20 I think we can work-that out. , 21 -MR. JOHNSON: Okay. 22 MR. GUILD: Judge,..n o that point,.and-it doesn't-23 need to be addressed now, but'when the staff gets ready
~~ 24' to present a case that' includes that issue, we would like
L 25 . to be heard on that claim of confidence.
____________--__:_-____ ____:-_--- ____-___-_---______-_a_-_---___x-___-_=__
11,931 Sim 1-7 1 JUDGE KELLEY: Right. I think that should be
' 'J 2 spoken to.
3 MR. GUILD: Than}. you. 4 JUDGE KELLEY: Jt .t another administrative 5 point. We indicated earlier in- December that in the: case 6 of Board witnesses, whether they are In Camera witnesses i
- 7 or whether they are public witnesses, I never did, and maybe 8 it is my fault, but I never got'a mileage statement from
; 9 Mr. Nunn or I think Mr. Langley or anybody.
10 MR. NUNN: I would like to give that, yes, sir. 11 JUDGE KELLEY: Sure. Well, I would likeLto 12 have it.
'( ) 13 MR. NUNN: Yes, sir.
14 What we need, JUDGE KELLEY: I raise it_here. 15 and I will just say it now, we need it for any and all 16 witnesses that'come in, basically what is your mileage and 4 17 what is your full name'and'home address so.that you:can 18
- picture this government voucher that after a few~ months i '
18
~ ; is' going to work.through the. system and it wil'1 produce 20 ~
a pay check-presumably, not.a very large one,'but there is-
. 21 that debt and we would'like to pay it. So I need that'
' data'
. Socif counsel'or someone could' provide it to them,- -
"' we can:put it in the mail.
We' indicated.in one of(the orders leading up f'
\_-
to_today's' session'that we proposed _to followLessentially. T
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1 11,932 i Sim 1-8 ! i g the same format that we followed on the In Camera hearings l l l before Christmas. (,,/ 2 We do in this instance have-two panels to be 3 heard from today instead of one. We were hearing then from 4 5 ne applicant panel and now the staf f has a panel on these 6 subjects. So at least the two today. 7 There will be two panels on each of the two 8 subjects today. Tomorrow there will just be the staff 9 panel on the three subjects as we understand it. But it 10 is our intention to call the applicant's panel first and 11 through the questioning process, call the staff's panel 12 second and go through the questioning process and then call
/\ 13 the witness, as we did last time, the primary purpose being-N.]
14 for the witness to do, wel'., two things, to state his 15 evaluation, having heard the presentation and having 16 heard the submission, what the witness-thinks, and- whether i 17 Mr. Nunn being the witness today, whether your concerns have us been answered or whether they haven't been answered and up -why. 20 Then there would also be an opportunity for 21 counsel and the Board to ask Mr. Nunn follow-up-questions 22 on his earlier statement if they wish to do'that. 23 The time.and sequence that we propose to E 24 follow is as follows'. We are now looking.just at the
,/_NI \ 2. first order-of' business, namely, laminations,'and we are
11,933
.S m 1-9 1 lookinc at the times for the panels and the sequence of (3
( ,) 2 questioning and the times for each party or'the Board to 3 ask questions. 4 Our sort of overall estimate is that laminations 5 would probably take a bit longer than foreman override. It 6 is the issue that has drawn more attention and concern from 7 the Board. 8 We propose to cut out for the laminations 9 question from, and here we are at 10 o' clock, till probably 10 around 3 with a' lunch break in there. That means allocating 11 four hours on the point which-in turn means-breaking down 12 time for the two panels and then having the concluding time 13 for the witness, Mr. Nunn.
,/'"g) \_J 14 I don't have on here right now the for Mr. Nunn's 15 appearance, but we did do a breakdown of_the panels and 16 we would like to do that and then we will get to the time 17 allocation for the witnesses appearance finally.
i 18 It would run like this. I believe this is 18 essentially the same sequence we used'before. ThisfMr. Nunn 20 is coming as a Board witness. The Board would be first. 21 I will read the sequence and then go back to U the times. The Board would.be first, followed by the-staff,. E followed by. Palmetto, followed by the State of South Carolina , 24 7- , followed by the applicants and completed by.the' Board, and N"'I 26 the times are as follows.
11,934 Sim 1-10 1 The' Board's lead off time is 15 minutes, the j
-s 2 staff's time is 20 minutes, Palmetto and CESG -- and, Mr. %-l 3
Riley, are you participating in today's sequence? 4 MR. RILEY: If possible, yes. 5 JUDGE KELLEY: Well, this will be combined time-6 for Palmetto and CESG of 30 minutes, the State five minutes, 7 the applicants 15 minutes, and the Board completing with 8 20. We expect to have more questions on the end than on 9 the front. 10 That allocates about 105 minutes and if we 11 multiply that by two with two panels, you come up with three 12 hours and a half for that process. That does not include 13 Mr. Nunn's appearance nor does-it include coffee breaks.
.s_/ 14 So we see that as pretty well taking care of i 15 the day and using such time as we have available.
16 Now those are our preliminary matters and we 17 would be prepared to have Mr. McGarry call _the company's 18 panel if there are not other procedural things to discuss. 18 Mr. Guild. 10 MR. GUILD: A couple of things, . Judge. If we' 3 21 can just speak to this scheduling point a moment. The 22 , way I calculate.it it boils down to a Palmetto cross of 2~ four' minutes per. Duke . Power witness on the question of M' :- laminat' ions. e-L 3 {L )s Judge, you know, you have heard us on.this point
I
- 11,935 Sim 1-11 1
before, and that is just. totally inadequate to be'able to 2 do the job at hand. V. ' 3 Be that as it may, if the Board would entertain 4
'some flexibility between the laminations and the foreman 5
override issue, we would certainly be of the view that.the 6 best of all possible worlds-would be to'take virtually all 7 of the foreman override time and put it into the laminations [ 8 issue. 9 I say that reserving our objection to the time 10 allocation piinciple at the outset. What we would like to 11 do I guess it this. We would like to try to see if we could 12 shift some of that time back to laminations to try' to get 13 us a little more flexibility if that would be open to the O() 14 Board. 15 JUDGE KELLEY: Well, the record will show we. 16 have been saying from day one of this case'that if you want - 17 to shift your time around generally speaking you can do it. 18 1 l If you want to shift some time away from foreman override - 19 i toward laminations, you can do it. 20 I don't know if you want to say right now if 21 22' you want to add 10 or 15 or-whatever or if you want to go ahea.d with your 30 and see how you stand.- 23 - I might be better I-think to go ahead and 24 - ; cet underway with the understanding that you can do an add - . 25 J on, and 'we-.will n' eed to tie it down to time frames. j El
l 11,935-A Sim 1-12 1 MR. GUILD :-- Let me then add this point. Sitting l [ 2 2 ' \~' next to me is Mr. E. Earl Kent. Mr. Kent has come in at 3 our plea and request from California last night in the late 4 night and he is a Senior Quality Control Engineer in the 5 nuclear welding field with an extensive background of work 6 in six nuclear facilities. 7 I told'Mr. McGarry or Mr. Carr who were standing 8 that we here a moment ago and introduced them to Mr. Kent 8 intend to offer Mr. Kent as a witness on the technical . welding to subjects, laminations in particular, but probably also the II tig wire' issue and the radiography points to be addressed 12 later.
/N 13 I have his resume and I want to distribute it (pf 14 at the earliest so that the parties and Board will have it 15 ~
available to them. I don't think we-need to take that 16 up right now, but I wanted you to understand that our. 17 desire would be to have a time for-Mr. Kent to address the 18 technical points that have been raised. 19 Secondly, when the panel is offered, I.would 20 seek to have Mr. Kent qualified as a technical questioning 21 or expert' examiner'.I guess. I can cite to the specific provisions when we get to that point, but I would hope that with leave of'the' Board'I would be able to do as we did with (g ' the'other. panels and have Mr. Kent and I share some of the
'n/ y limited' time and give;you.some advance ~ notice of how much-
11,936 i Sim 1-13 3 time I would.take and how much time.he would take. We would divide our total time between the.two of us to question the ( . 2 i 3 panel. - 4 So I wanted to alert you to those two points. f~ 5 He is an expert witness later and we can-go through his. 6 qualifications then, but at the outset we would seek to { qualify him as an expert' examiner. l 7 8 JUDGE KELLEY: Do you have a bio on him? 9 MR. GUILD: Yes, I do. 10 JUDGE KELLEY: The first thing to get to is the-f gg expert questioner points, it seems to me, and if you have i 12 a bio you can hand that out. 13 (The Bio Material was handed to the Board and 4 . 14 Partie s .') 15 (Pause.) 16 i end Take 1 Sue fols
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esmsTh 11,937' 1 ~ JUDGE KELLEY:' Mr. McGarry, Mr. Johnson, have f- 2 you had a chance to look over Mr. Kent's resume? \s 3 MR. McGARRY: We have briefly, Your Honor. , 4 JUDGE KELLEY: Let's take the second question 5 first. Maybe that's all we ought to take now. 6 Do you have any objection to Mr. Kent's serving 7 as an expert questioner in assist'ance to Mr. Guild? 8 MR. McGARRY: We are trying to determine that' ! 9 point right now. I am looking at 2.733 for the standard. 10 JUDGE KELLEY: All right. 11 MR. McGARRY: And looking at the resume, it 12 appears that -- let me just amend my statement. Mr. Guild
~13 not only gave me a resume, he also handed Mr.-Carr and my- ) 14 self a three-page document that's entitled " Education and 15 Job History",
and if one were to look at this job history 16 , it appears that Mr. Kent has had experience as a welder , 17 and har had experience in welding inspection.- 18 Now,
.the question we are trying to mull.over-is, 19 does that qualify him as an expert'. witness for purposes'of' 20 12.733.
21
'MR. GUILD:
Judge,-while Mr. McGarry.is looking- _ 22 : at _that,' the' other document .th'at he referred- to that I gave 23
-~him earlier, while the short form was .being copied, thisiis.
24 in sort-of a little moreidetail. I.can. distribute:that to O v 35 the parties'as'well. -It might-beLhelpful.
. l.
_ - . -- _ _ __ _ ~ . - . _.,
st'l/2 11,938 1 JUDGE KELLEY: Okay, n< x_, 2 -MR. McGARRY: I think we are prepared to address 3 the issue. 4 JUDGE KELLEY: Okay. 5 MR. McGARRY: It seems there are two matters 4 6 that we need to address. The first is whether or not Mr. 7 Kent satisfies the requirements of 2.733, and the second
- 8 involves Mr. Kent's ability to testify in this proceeding.
9 JUDGE KELLEY: That's a separate point. 1 10 MR. McGARRY: That's a separate point, and we 11 recognize that that will be taken up at the time, if and 12 when Mr. Kent is proffered. However, we do want to make a.
, 13 statement with regard to that, because I think it has been 14 past experience in this case with Mr. Riley and Mr. Riley 15 served as an expert cross-examiner, and the Board then bore 16 in mind the nature of his cross-examination in determining 17 whether or not he was an expert.
18 We think that Mr. Kent's ability to testify is 19 indeed a separate and distinct question, should not be 20 tainted by the quality of his cross-examination. .At the
' 21 appropriate time, we will take a position that Mr. Kent's M appearance is' wholly untimely.
23 JUDGE KELLEY: Okay. How about the questions? 24 p_ MR. McGARRY: Now, with respect to 2.733, l [
'~# 2 there are threeLtests. The first' test, 2.733 (a) is that
ss E/3 1 11,939 1 the individual is qualified by scientific or technical train-(~') G 2 ing or experience to contribute to the development of an 3 adequate decisional record in the proceeding by the conduct 4 of such examination or cross-examination. 5 It would appear to us that Mr. Kent does have 6 experience on the face of the documents that we have seen 7 in welding and welding inspection. 8 The second item, item (b), is that the individual 9 has read any written testimony on which he intends to examine 10 or cross-examine and any documents to be used or referred to 11 in the course of the examination or cross-examination. To 12 that, we haven't the faintest idea. 13 l'] Item-(c), that the individual has prepared him-N'# 14 self to conduct a meaningful and expeditious examination or 15 cross-examina tion. To that, we do not have any idea. ~ 16 JUDGE KELLEY: Have you read the material, Mr. 17 Kent, the testimony-that has been-offered? 18
!!R. GUILD: I sent him -- I can tell you what I 19 ;
sent him and then'he can tell you whether he' read it. I 20 . sent Mr. Kent the testimony by Applicants, and the NRC 21 reports on the question of laminations, and Mr. Howard 22-Samuel Nunn's affludvit, and the inspection report on the 23 subject of, I guess, welding related matters, the last of 24 the several inspection reports that have been sent. In x_,) 26 addition,. e number of documents that were distributed to me a
I at 1/4 11,940 1 very early this week by Applicants in informal discovery, ( ,, 2 some of the procedures of the Company for repair of lamina-3 tions, a number of mill reports from the supplier of the 4 plates, some 7.udit reports that were given me by Duke. 5 I think that's sort of a general outline of what 6 I gave him. He can tell you whether he read them or not. 4 7 JUDGE KELLEY: Have you read that material he 8 gave you? 9 MR. KENT: Part of it was cursory reading and to some of it in-depth reading with questions and things of 11 this nature. 12 Relative to my background, I would like to mention 13 that if you look in the Welding Encyclopedia, you will see (GT 14 my name there and this is proof positive that I know what 15 I am talking about relative to welding. And if you look 16 at the engineering data sheets, you will see my name in 17 there under different engineering data sheets I have de-18 veloped over_a period of years and have been published. 19 If you look in the Welding Engineer magazine of 1961, June, 20 you will see the one engineering data sheet in that issue 21 ' is'mine. The-September issue is also mine. I had two out 22 of twelve that year, in 1961.
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23 And again'in.1974, I had two out of twelve that f-, 24 - year. And, then I have.been extremely fortunate in approach-(' M ing my own idea, my own research and my own_ work in welding
st 1/5 11,941-i and engineering data sheets.
) JUDGE KELLEY: Thank you.
- CNJ 2
3 MR. McGARRY: Your Honor, that's interesting-but i 4 it'hasn't answered-the question, has the individual read 5 any written testimony.
- 8. p NR. KENT:Yes, I have.
-7 MR. McGARRY:- 'What testimony did you read?
j . 8 MR. KENT: Mr. Nunn's: testimony, and at great 9 depth with questions. And then also the reports relative 10- to the mis-stamping, for instance, on plates where they had 11 mixed up the stamp numbers, for instance. This is appalling 12 because there is excusei foi mixing up numbers and identi-13 fication. 14 JUDGE KELLEY: Let:me ask this question. Have
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15 you read the-Applicant's testimony? That's what these ] 16 people that are going to come on' and they are going to - pre-17 sent this testimony. M question is whether you have read
~
18 it. t 19 MR; KENT: Mr. Nunn's testimony, yes. 2 20 JUDGE KELLEY: That's not the Applicant. The-21 Duke Power Company has two pieces of testimony that they 22 ~are putting forward, an'd I just want to know whether'you 23 . have read the testimony?. 24 '- MR. McGARt..: These pieces of testimony, Mr. Kent. _{,N ~
%- 25 I have. handed Mr.: Kent-two pieces of-testimony that'the
/,'
f. v f e - ., ,. n n- - , , , . - -
st'l/6 ' 1 Applicant proposes to introduce concerning lamination. () 2 MR. KENT: I have yet to read this one in depth, 3 but Mr. Nunn's I have read not only in depth but -- 4_ JUDGE KELLEY: Very well. Staff, comment on Mr. 5 Kent serving as a questioner? 6 MR. JOHNSON: We also are trying to deal with 7 this as best we can, looking over-the criteria. It does i i 8 appear that the gentleman has some background in welding, 9 the welding area. It's not clear that he does have the 10 experiance and expertise on the question of the significance 11 of laminations and raw metal. He is.not a metaller. I 12 don't see anything in here, in his background dealing with 13 metallurgy. So, I don't know if he is qualified to speak 14 to examine in that area. Perhaps'just in welding. 15 If he has not read the testimony of the App _icant, 16 I think that is perhaps a fatal problem. 17 JUDGE KELLEY: Is it terrible? 18 EMR.. JOHNSON: Well if the Applicant's are going- ' 19 to be put on now, I would say so. 20 JUDGE KELLEY: You would so so,'or not? 21 MR., JOHNSON: -I would'say so, unless it's -- I M would say that it's_not terrible at this point. 23 JUDGE.KELLEY: Or you would say no? i 24 MR.-JOHNSON: That'stright. I would say'no.
/
- l. "' N ~ JUDGE KELLEY: He can't go out in the-other room n
, - -,s. , ., , 4--, . . , - - 4.--- -
r
11,943 et 1/7 1 and read it while the Board'is asking questions? 2 [O') MR. JOHNSON: Oh, yes, he could if he so desired. 3 JUDCS KELLEY: Well, look, this is not the 4 biggest issue we have had to wrestle with. Why doesn't the 5 Board just take a couple of minutes and see what we can do? 6 MR. GUILD: I just really simply said I wanted 7 to offer him. I haven't had a chance to speak to the merits 8 of it. 9 If I could just say, under the very limited time 10 constraints we have spoken to Mr. Kent on the phone. We ' 11 have expressed mailed him a package of materials, and he 12 read it basically over the week-end and on the plane coming 13 here. I think he has done everything humanly possible to
\/
14 prepare himself, given the limited amount of time to ad-15 dress these issues. 16 Primarily, I asked him to focus on the NRC Staff's 17 report and on the witness' statement. But he was provided 18 a copy of the Applicant's testimony, and I think, as he I9 said, he skimmed it. Now, I think that's plesty. 20 Frankly, I think it's clear from his qualifica-21 tions that he can offer meaningful assistance to develop
! 22 the record on these highly technical issues. .He was a 23 senior quality control engineer in the welding area; he has intimate familiarity with the subject matter. ~
'I think 25 that really overwhelms the question of wh' ether or not he
+
11,944 I et 1/8
\
1 has memorized or poured over in detail the Applicant's !
/^ N l, ) 2 testimony.
3 MR. McGARRY: Your Honor, we have two observa-4 tions. One is, our testimony has been available since 5 December the 13th. The fact that this gentleman just got 6 it several days ago is not our fault. That's a burden 7 that the Intervenors must shoulder. 8 second of all, if this Board says that this 9 gentleman can go out of the room and read it, then it has 10 to ask itself what will it find with respect to the third 11 category, the third requirement of 2.733, which is will he 12 be able to conduct a meaningful cross-examination. This 13 (~~')' is not a skilled practicioner in the law. This is a gentle-i _/ 14 man who is a welder and a welding inspector. 15 And I think we would have serious reservations, 16 given his ability to read a document in the back room that 17 he would be able to prepare himself for a meaningful cross-18 examination. Those are our observations. 19 JUDGE KELLEY: Thank you. A short break. 20 (Whereupon, a recess is taken at 10:21 a.m.) Jim follows 22 23 24 x 25
11,945 T3JRBsjrb fis Sue 1
. JUDGE KELLEY: We are back on the record, b 2 The Board has considered the pending motion by 3
Mr. Guild that Mr. Kent be allowed to participate in the 4 questioning as an expert pursuant to 10 CFR 2.733. 5 And the Board's decision, subject to one possible 6 condition that Mr. Kent, on the basis of his background, 7 experience and what's been said here, is qualified to parti-8 cipate in that capacity. 8 i However, we are going to make the findings called 10 for by 2.733, and we think his resume clearly shows that he 11 has the requiste background and experience and--to qualify, 12 certainly, in the welding area; and we just assume that 13 somebod'y who's been welding that long knows something about 14 laminations; and we don't think it's feasible to split the 15 two in two pieces. 16 So we think on that basis, Mr. Kent could proceed. 17 i We have some doubt about preparation, finding-numbe r i 18 two: The Board is supposed to find that the individual has 19 read any written testimony on which he intends to examine or 20 cross-examine,~and so on. 21 And you have indicated you have given it not much 22 more than a cursory look at the Applicant's testimony; and 23 our allowing ~you'to testify is. going to be conditioned:
~
if~ 24 you want to question'this upcoming panel on the Applicant's h. w/ i 25 testimony, you.are going to have to excuse yourself and l
I 11,946 l 3-2 l
\
l 1 bone-up while we're on the first couple of sets of people o
- i. ,) 2 who put their questions, so that you would then be ready 3 but, with that understanding, we would permit it.
4 And finding-number-c speaks to preparations, it's 5 largely an outgrowth of a and b; we don't think it's j 6 separate. A statement on that's not required. t 7 So we are ruling that Mr.- Kent, with that under-8 standing and in conjunction with Mr. Guild, and pursuant to 9 the time limits established for the parties, will question 10 the Applicant's panel and, presumably, the Staff panel after
)
11 that. 12 Now, we would simply say in that connection.that 13 in making this ruling we are by no means implying anything $ 14 with regard to the question of whether you might be allowed i 15 to testify at a later time. 16 It is not at all clear to us that you should be 17 allowed to testify, for various reasons; but we can hear 18 argument on_that later on when we get to-it. And that means 19 after we are through both. panels, Mr. Guild can speak to that 20 question if Palmetto desires to' proffer Mr. Kent.
~
21 With that, we would like to get our first panel 22 into the box. 12 One more, Mr. Guild?-- 24 -
' HR. . GUILD: I'm~sorry,fJudge. -
M I would like at this point, if I may, to. introduce m - , y - p .- w w , ,,,-w-- - - ,
11,947 3-3 1 Mr. John Clewett of Washington, D. C., sitting at the table (A) 2 with me. 3 And Mr. Clewett has some written materials, 4 several motions, that I think he'd like to distribute; and 5 ask that he be heard. 6 JUDGE KELLEY: Well, why don't you distribute-- 7 now, are these matters that have to be heard right now? Or 8 can we take them home and read them tonight? 9 MR. CLEWETT: These are matters which--well, first 10 of all, for the record, you Honor: 11 My name is John Clewett. That's spelled 12 CLEWETT. My address is 236 Tenth Street, Southeast, 13 Washington, D. C. 20003. My phone number is area code Os I 14 202-547-8323. 15 These motions are motions that we feel are 16 pressing, but they are probably not so pressing that there is 17 a particular reason that they would need to be heard now. 18 These motions have to do with our desire, based 19 upon our understanding of what the law is that governs the 20 actions of Licensing Boards to' engage in further discovery 21 of the underlying bases from_which some of the'se conclusions 22 that we are about to hear.from the Staff'and Applicant are M drawn upon. 24 So I'would like to be heard on these relatively b\ ,/ 25 soon, but there is no_need that it'be.right at this moment. i
l 11,948 3-4 1 It could be, for. instance, after lunch today might be a () 2 convenient time, or.at-the pleasure of the Board. 3 JUDGI KELLEY: Motions as a general nature, as I 4 am sure you know, were made several times by Mr. Guild back 5 in December. Argument was heard and rulings were made. 6 Are these new, different, ideas? Or is this-- 7 MR. CLEWETT: By and large these are new motions, 8 yes, your Honor. ' ' i 9 JUDGE KELLEY: Well, I think we better read them 10 overnight. 11 So why don't you distribute them. 12 We are down here to hold a hearing. It's 10:35, P 13 and we don't have a. witness in here yet. And, you know, is t 14 there any good reason why it is that-these motions could not 15 have been amde-before this?--last week, the week before? 16 14R. CLEWETT: Well, there are only so'many hours 17 in the day. It is always, I suppose, possible- - 18 JUDGE KELLEY: I know that. 19 MR. CLEWETT: --that'anything could have happened' '
# sooner.
But I assure you thatI have had a series of nights 21 in which I've not gotten enoughLsleep:because I've been
~
~
~M working.on trying to formulate these statements and I am 2
bri~nging these forward asusoon as possible. M
~ JUDGE KELLEY:
Well',7why don'tfyou serve them, and
~ -A 26 we'll read them tonight.:
l f v ~,ma , a q > .+ gy qy- - n-- -- ,--. -, , e --
1 3-5 '94E 1 How long are they?
/
(3) 2 MR. CLEWETT: Well, there are several motions, 3 i one of which has two affidavits or attachments to it; the 4 overall thing, if I squeeze the pages together, appears to 5 be about an eighth of an inch thick, perhaps more. 6 JUDGE KELLEY:There isn t any way we are going to 7 look at that today. 8 I mean, do you think we're just going to stop and 9 read your stack of papers? We didn't come down to do that 10 Mr. Clewett; we came down here to hold a hearing. 11 I got a post office box in Washington, you can file 12 motions up there any time you want to. ()
\ )
13 MR. CLEWETT: Well, the point of asking for some 14 expedited treatment on these motions is that the position 15 of the Licensing Board itself seems to be one of seeking a 16 very expedited closing-down of these hea;;ings altogether; 17 since these motions deal with matters which would be moot 18 if the hearings were to be closed down, it is important 19 that we have a chance to be heard on these before that final 20 curtain is drawn. 21 And I am certainly not asking, and I think it wculc. 22 be unfair if I were to ask that'the Board drop everything 23 else and, you know, we'd all sit down and read through what 24
,_ 1 have prepared'right now.
, 25 But.I would-like to get a hearing'and a' ruling on
11,950' 3-6 1 these as soon as.is possible; and I would be perfectly . 2 a \_- agreeable to the notion of going forward on this tomorrow, 3 I can' distribute them-- 4 JUDGE KELLEY: Why don't you distribute? 5 I just think coming in here today with a stack 6 of motions is--I don't know what the word is. 7 If we get time to talk to you tomorrow about this 8 i Mr. Clewett, we'll do it. And if we don't, we won't. And 9 that's that. 10 I think you are untimely and out_of place, frankly. 11 So file your paper. Hand them out. 4 12 MR. CLEWETT: Where else are motions to be filed 13 I if not with the Licensing Board, sir? O) (m 14 JUDGE KELLEY: If all you want to do is hand them 15 out, and we'll get around to them whenever we do, that is 16 fine. You go ahead and do that. 17 It's this business of walking into a hearing and saying, let's talk about motions 18 today or tomorrow, that I find just off the page. i , 19 So, why don't you just hand out your papers and 30 we'll move on. 21 MR. CLEWETT: Very well, Judge. Thank you. 22 (Mr. Clewett distributing documents to Board and 23 parties) : 24 MR. MC GARRY: fs I will call our panel'so at-least 25 (
\_/
Y theyccan get seated.
\
. . - .-~ _
3-7 11,951 1 JUDGE KELLEY: All.right. I rs ( } 2 MR. MC GARRY: Gentlemen, take your places. 3 i (Pause) 4 MR. MC GARRY: Now in the box is our panel to speah 5 on laminations. This panel will sponsor two pieces of 6 testimony: 7 The Applicant's testimony of Mr. Llewellyn, 8 McConaghy and Ruth pertains to Mr. Langley's allegations; 9 and the testimony of Mr. McConaghy, Barnes, Akers, 10 Cavender, Rudasill, Shropshire and Ruth and Llewellyn with ' 11 regard to Mr. Nunn's allegations concerning laminations. 32 Mr. Akers--would you raise your hand?--Mr, Akers, 13 ( Mr. McConaghy, and Mr.. Ruth, have not been sworn. The 14 4 rest of the witnesses have; and I ask that those gentlemen r 15 be sworn at this time, your Honor. 16 JUDGE KELLEY: Gentlemen, good morning. 17 1 Whereupon, 13 JOHN P. AKERS 19 JOHN M. MC CONAGHY M and
. -21~
RONALDJRUTH, 22 took the' stand aus members of a panel of witnesses for E-
' Applicant and, having. been first duly sworn lar .the Judge,-
24 were examined and' testified as.'follows;Eand, 25
3-8 11,952 1 LARRY R. BARNES [ 2 JOHN CAVENDER 3 LAWRENCE W. RUDASILL , 4 DAVID LLEWELLYN 5 and 6 JOE SHROPSHIRE 7 took the stand as members of a panel of witnesses for 8 Applicant and, having been previously been duly sworn, were 9 further examined and further testified as follows: 10 DIRECT EXAMINATION XXXXINDEX 11 BY MR. MC GARRY: 12 Q Gentlemen, let me take the longer document first: 13 Do you have a document entitled " Testimony of J.,M. 14 McConaghy, L. R. Barnes, J. P. Akers, J. Cavender, L. W. 15 Rudasill, J. C. Shropshire, R. P. Ruth, and D. H. Llewellyn," 16 before you? 17 , A (Chorus of "Yes, sir.") 4 18 Q Gentlemen, do you have any corrections or additions 19 to make to that testimony?- 20 A (Witness "lelellyn) Yes, sir. 21 Q Mr. L? r..ellyn) 'Page 8, line 9, the number. shown 22 there is incorrect; that number should be 1-M221. 23 . Q Are-there any other. corrections.or additions to 24 this testimony? e
)
k_/ # A~ .(Witness Ruth) .Yes, sir. i'
3-9 11,953 , 1 Q Mr. Ruth? i 2 A My name is misspelled on page 3, line 9, and on 3 Attachment C, there is a spelling error in the company that 4 I worked for. 5 Q Can I just stop you? On page 3, it shoudl be 6 " Ronald P. Ruth"? 2 7 A Yes, sir. 8 Q Okay. 9 As opposed to " Ronald R. Ruth"? 10 And then on page--what's the next? 11 A Attachment C on the back. 12 Yes, sir? Q 13 A The com'pany I worked for in 1971 to '74 was 14 Blenate, BLENATE, and it's spelled several times with 15 a "G". 16 That's all. 17 Q Any other corrections or additions, gentlemen? 18 A (No response). 19 Q Gentlemen, as corrected, do you adopt the testimony 20 of J. M. McConaghy,oet a.,-as the testimony for!use in this . 21 proceeding? 22 A (Chorus of."Yes, sir."). 23 Q And if I were to ask you the. questions set forth-24 in'this document today, would you respond as set forth ini 25 this' document today?. l
10 1 A (Chorus of "Yes, sir.") m 2 m, Q All right. 3 MR. MC GARRY: Your Honor, at this time we request 4 that the testimony of J. M. McConaghy, et al., pertaining 5 to Mr. Nunn's allegations concerning laminations, be marked 6 for identification as Applicant's Exhibit 110. 7 MR. GUILD: Mr. Chairman, we would-- i 8 JUDGE KELLEU: So marked. 9 (The' document referred to was XXINDEX. 10 marked Applicant's Exhibit No. 11 110 for identification.) 12 MR. . GUILD: We have an objection. We would seek 13 an opportunity to voir dire the panel if we understand they 14 are being offered as experts; and I might just suggest that 15 following the prior approach to that, given the Board's 16 prior rulings, that my voir dire time can only come out of 17 my cross time--sort ofl anticipating your ruling and not press 18 the point; although it would be my-desire otherwise to.voir 19 dire them at this time. I 20 JULGE KELLEY: We-do have.the resumes attach'ed, 21 do we not?' , 22 MR. MC.GARRY: Yes, sir. 23 Those gentlemen who have just been sowrn, the 24 O resumes of.tne.other gentlemen were attached to previous
'. 25 testimony. But it's briefly identified in the documents,.
11,955 3-11 ' I that is, the qualifications of each individual. I 2 JUDGE KELLEY: Yes, and I believe you have 3 identified initials after paragraphs as to who sponsored 4 l what? f 5 MR. MC GARRY: Yes, sir. j 6 JUDGE KELLEY: Well, your time is 30 minutes, plus 7 whatever you draw on against the other one; and the rule will 8 stand: if you want to voir dire these gentlemen, you can 9
.use your time accordingly.
10 MR. MC GARRY: And, your Honor, then, at the 11 completion of the testimony we would move the evidence-- 12 move the document into evidence. () 13 14 JUDGE KELLEY: All right.
, MR. MC GARRY: Now, with respect to the second-j 15 document:
16 -- BY MR. MC GARRY:- 1 Q. Gentlemen, I would now like to turn my attention 18 to the Testimony of David Llewellyn,-John McConaghy, Jr., II andTRonald P. Ruth pertaining to Mr. Langley's allegations 20 concerning the detection of lamination _infa grinding goudge; I 21~ do you have that testimony before you, gentlement? 22 i A. (Chorus of: "Yes, we do.")- t 23 Q 1Do you have any~corredc' ions or additions to make
; to that-testimony?.
A_. s 25 ~ A (Witness McConaghy). 'Yes, sir.
-l
, - ,e, , - , , . ~, e..- . - - ,,
3-12 11,956 1 With regard to Attachment A, my professional (]N 2 qualifications-- 3 g ye37 4 A My business address is reflected as " South Street,* 5 it should be " South Church Street." 6 Yes, that's on the second line? Q 7 A Yes. 8 Q Any other corrections or additions, gentlemen? 9 A (Witness Ruth) Yes. 10 On Attachment B,- the same correction we made on the 11 other testimony, the spelling of the company I worked for. 12 Q Any other corrections or additions, gentlemen? 13 A (No response.) 14 Q As corrected, do you adopt the testimony of 15 David H. Llewellyn, et al., as your testimony for use in 16 this proceeding? 17 A (Chorus of: "Yes, sir.") 18 Q .If I-asked 7ou the questions set forth therein 19 would you' respond'as set forth therein? 20 .A (Chorus of: "Yes, sir.")
-- 21 MR. MC GARRY: Your Honor, at this time I would- -
22 request the testimony of David -H. Llewellyn,'ot al., 23 be marked for identification as Applicant's Exhibit' 24 :lli,
.f~'
26 MR. GUILD: Mr. Chairman, we would have the same
i 11,957 3-13 1 basic position and objection, without restating it, as we k,,e 2 did with the last' subject matter. l 3 JUDGE KELLEY: Very well. ' 4 MR. GUILD: May I add this, also, Judge: 5 I think we have established a sort of approach 6 that the witnesses only sponsor that portion of the testimon) 7 to which their initials are affixed; is~that correct?--I 8 think the gentleman alluded to that--and to the extent that 9 there are any places where.there are not so identified 10 sponsors, I would anticipate a hearsay objection. I'll hold 11 that until my turn comes up, if that's all right? 12 JUDGE KELLEY: We'll take it as it comes. (~N 13 (The document referred to was i 14 marked Applicant's Exhibit No. 15 111 for identification.) xxxxINDEX 16 MR. MC GARRY: The panel is now available for 17 JUDGE KELLEY: Thank you. 18 Gentlemen, you may have heard earlier that we are 19 going to go through a sequence of questioning, beginning with F 30 the Board, followed by the NRC Staff, and then followed by
~
21 Palmetto. 22-Mr. Guild will'have some assistance from Mr. Kent,
.23 who is-out of the room right now;:then followed by the State 24 7- -sof South Carolina and then.the Applicants, Mr. McGarry;-and A\,] 15-then the Board. And we will begin now with the Board
3-14 11,950 1 questioning. 2 UhXINDEX EXAMINATION BY THE BOARD 3 BY JUDGE PURDOM: 4 Let's see, "JMM" is Mr.-- Q 5 A (Witness McConaghy) McConaghy, sir. 6 Q McConaghy. 7 In the testimony with respect to laminations at 8 page 6, there's a paragraph there beginning at line 12, 9 about surface routings and stresses on the containment; 10 and you make mention that the stresses on the plate are 11 parallel not perpendicular to the surface. 12 Could you outline.for me the nature of the surface 13 ( loadings that produce these stresses, and why it is that ther 14 would be parallel and not perpendicular? 15 A Yes, sir. le The dominant loading zones on the st' eel containment 17 vessel are internal pressure on the containment vessel, 18 the dead weight of the containment vessel, and its attach-19 ments; these would produce the dominant stresses.in the 20 containment, which are the same as those in any pressure 21 vessel. 22 And it's-designed for membrane-loads only. A-23 pressure vessel would be like a filled balloon, so'that it 24
,s functions by stretching, rather than by bending.
25 Q So what you would call shear stress is '
+9
3-15 11,955
\
I nonexistent? I
.f x '
(s,) 2 A They are extremely small, sir. The stresses 3 transverse to the shell are extremely small, because of the 4 thin geometry of the containment vessel shell; it's very 5 large in radius compared to its thickness. 6 Q Why is it that laminations, then, would not be 7 affected by these kinds of loads? 8 A Loads in the containment, then, sir, would be 8 radial and longitudinal. They would be parallel to any 10 laminations present in the containment plate, since by 11 definition, a lamination is virtually parallel to the exposed 12 surfaces of the containment plate. 13 (; Q And the fact that you have a lamination, why would 14 that not affect the strength of that? 15 A The flow of stresses around'the laminations are-- 16 it's as if the laminations weren't there; the stresses would 17 flow around the laminations. 18 Q Well, does that mean, then, that that part of the I8 steel shell is not'f'inctioning? A No, sir. 21 Q Explain that a little better for me?' 22 A The stresses which we are discussing are membrane 8 stresses which are virtually uniform'across the thickness 24 , of the shell. Jf'~) s-8 What would. carry,them would bc the area ~of the i 8 s
I 3-16 11,960 i containment plate. i And the area of the laminations does not 2
]< significantly decrease the area, the cross-sectional area, 4
3 of the containment to carry that load. 4 Q "his kind of stress wouuldn't tend to pull the 5 fold out? 6 A No, sir. 7 The kind of stress which would tend to open the 8 laminations would be a through-thickness stress on the 9 containment shell. Those stresses are virtually nonexistent 10 i. in the Catawba containment. 11 Q And what do you' base this opinion on? 12 A Based on-- 13 Q Is this research you've done or studies you've i 14 done? 15 A Based on the design of the containment vessel, IO sir. 17 We--since it is a thin-shelled structure,~we I8 ( closely monitor all attachments to it, the 19 containment' vessel shell. -And that is the~only kind of 20 mechanism by which a through-thickness load would be applied 21 to the vessel shell. 22 And.we require that these attachmennts be spread 23 out over a large area so that the through-thickness stresses END T3 are virtually negligible. REfls 25
,J - , _ - - ---, ,- + ..- y ,
.- . ~. - - . . - .. ..- - -. . . .,
11,961 REE Take'4 " Page.1 1 Q- How many of these laninations could a shell I
/"N .
i like this have and not be weakened by it? ( 4
\--) 2 3 A Sir, the presence of these laminations is 4 irrelevant. It has no degrading impact on the structure, 5 so it could have as many laminations as were present to 6 withstand pressure loadings and dead weight loadings.
7 BOARD EXAMINATION XXXXX 8 BY JUDGE FOSTER: 9 Q This containment vessel is built to withstand 10 uhat kind of pressure? t 11 A It is built to withstand the postulated, the
' 12 pressures which would result from a postulated accident
's 13 resulting from a rupture of a coolant pipe in the lower i
14 containment com"artment. 15 The design pressure for thic contain2. cat 16 vessel is 15 psi. ( 17 Q And how much additional stress doc 3 that put 18 on the plate? A-19 The stresses which result from the accident 20 pressure are on the order ~of 13i000' psi in the hoon 21 direction on the containment' vessel and approximately-half
'22 of~.that in the.meridianidirection.
23 ~ Q When the containment-would fail at something
~
24 15. pounds or greater, where in the coatainment.is'that A 1_,l- 25 cfailure. expected'to take placei? .Is this-'on a weld?' 'Is f .
11,962 4/2 1 it around the penetration? Is it the plate itself? () 2 ~What breaks? i 3 A The ultimate capacity, if you will, the i 4 ultimate internal pressure capacity of the steel 5 containment hasLbeen determined to be 72 psi which is 6 well in excess of its design pressure; Its failure was e 7 initiated through a general yielding of the shell plate 8 in a membrane state, 9 Q Yielding of the shell plate? i
! 10 A Yes, sir.
11 0 Does that mean a break in the middle of'the l 12 plate or does that mean a break at a weld or -- which is i 13 stronger? The welded connection between the two or the 14 plate itself? 15 A Generally the weld itself is stronger. , 16 HcwcVer, the interface bet *.reen the weld and the containment 17 plate is where the break might occur. 18 0 I didn 't quite - follow that, Could you say that 19 again? , 20 A The. weld metal itself is generally stronger: 21 oit has higher mechanical properties than'the containment 22 plate would have,. 23 0 . When you put-this kind of an internal-pressure 24 on the plate, are you still saying:that the stress is (O_s/ 2s ' dominantly parallel to..the laminations as contrasted with
11,963 4/3 I through the thickness? p) 2 A Yes, sir. (_ Yes, sir. Especially, once the design 3 loads or the design pressure is exceeded, the containment
;- 4 vessel tends to behave more and more in a membrane fashion.
1 5 The stresses becone virtually 100 percent membranous, 6 parallel to the exposed surfaces. 7 Q Did I understand you to say that you are 8 expecting then if you get a break, 75 pounds or whatever, 9 that this break is going to be somewhere in the middle 10 of the plate as contrasted with a welded connection ] 11 between plates, or in a place where penetration is made? 4 12 A The limiting factor on the containment capacity fx 13 analysis was at U the circumferential stiffeners on the contain-14 ment. There are 13 circumferential stiffeners at various 15 elevations through the containment vessel, and they. i 16 are like belts that sit around the containment. They 17 make sure that the vessel doesn't get larger. 18 The failure of the vessel was caused by a 19 general instability of these stiffening' plates. When the _ 20 stiffening rings begin to yield, then'there was nothing to 21 restrict the vessel,from'gro~ wing larger. It was at.these H stiffeners that the. failure began. 23 '
.Q _ That's helpfu1~. \
24 ! n Backfto the laminations themselves,.I was ( ) N ,/ -25 unsure from the testimony of whether there were laminations I
11,964 ; 4/4-i I 1 both in the containment plate and in the material which ! 2 was used for penetration or whether this was only on the 3 containment plate? Which is it? 4 A It is both, sir. The explanation for that is 5 that we specified that the containment vessel be constructed
- 6 of SA516 carbon steel. We specified also that whenever 7
possible, the penetration sleeves would be made of carbon 8 steel pipe, SA533, schedule 100, 9 When schedule 100 pipe wasn't available in the 10 large diameter penetration sleeves, we specified that the 11 slames should be fabricated from SA516 plate steel. So 12 in the case of larger penetrations l containment plate 13 {~}) material was rolled to a pipe configuration and used for
's.
14 containment sleeves. 15 0 Where were the laminations the worst? In the-16 penetration-sleeves or in the containment plate? 17 A As our testimony reflects, the presence of 18 laminations is of interest only where you make a welded 19 joint because the -- the laminations are of interest 20 insofar as they.would effect you getting an acceptable 21 product of radiographed. weld at that joint'.- 22 Q So where the procedurefhad to'be used for 23 repairing the~or fixing the-laminations, where was most of' 24 -
.t f3 '
the. work' concentrated? On/the penetration sleeve? t V 25 A .It was' noticed mostly:on the. penetration sleeves
l 11,965 i 1 because for containment plate assemblies in general 'f there , w i 2 was a lot of investigation prior to erection in the yard 3 to detect laminations before they were -- the assemblies 4 were installed in the buildt g and field welding was actually 5 done on them. 6 So sua avoided the problem when we were doing the 7 erection of the containment plate and it was not possible 8 to identify all the -- it was not possible to indentify 9 all the laminations in the penetration sleeves before they i 10 were set in-place. So ycu might say that more field problems 11 were encountered because-they were already in place. They 12 hadn't had proper measures taken before they were set in
,m 13 place.
N, 14 JUDGE FOSTER .That is all for now, XXXXXXX 15
-BOARD EXAMINATION 16 BY JUDGE KELLEY:
17 Q Is the upshot of your testimony that laminations 18 in the plate itself as opposed to a connection with a Isr weld are just irrelevant? You don't care whether they are 20 there or-not? Is that right? 21 A. Yes, sir. 22 - Q They have no safety-significance? 23 A They have'no safety significance except as they 24 would effect your getting a good quality. weld at..that
\m /. 25 joint.- '
i
4/6 11,966 1 Q At the joint, But right smack in the middle
\
[} U 2 of the plate r there 's a lamination there, I don't care. 3 Is that right? 4 A No significance at all in the middle of the plate, 5 sir. 6 Q Someplace here I thought you said that you 7 actually X-rayed these plates to make sure there weren't 8 big.laminations in them. Am I misrecollecting that? 9 A At the weld locations, the welds were -- 10 O only at the weld locations? 11 A Yes, sir. 12 Q You don't -- 13 A (Witness Barnes) Judge, I think you might be 0~3 14 thinking about there were certain plates in the base of 15 the containment that we ultrasonically examined to assure 16 that they didn't have laminations in them because of the 17 loading on those specific plates, I think Mr. McConaghy 18 could probably specify which ones you are talking about, 1 19 A (Witness McConaghy) Yes, sir. At the base 20 of the interior structure, the concrete interior structure
- 21 for the' reactor internals, the vertical reinforcing steel 22 of the crane wall has to go through the containment bottom 23 - liner. Rather than penetrate the'containmont vessel bottom-24 liner,-what we did was, we installed-plates at'the base of the
(,,, 25 crane wall. -The_ reinforcing steel for the crane wall'was
4/7 ,96' 1 cad welded to the bottom and the top of these plates, () 2 and we ultrasonically examined these plates to insure that 3 they were able to carry this tension loaded through their . . 4 thickness, make sure there weren't any laminations here 5 that would nake it impossible to transmit that load. 6 O Those plates are on the horizontal and you i 7 ::have got structural steel coming down like that (indicating), 8 A Yes, sir. 9 Q That kind of force would create a stress for 10 which lamination would be a concern? Is that right? 11 A Yes, sir. A tensile load which would tend 12 to open laminations in that plate would be a concern 13 because you are talking reinforcing steel which is' designed 14 to function with tension. 15 Q So there-are a few places in the' reactor where 16 1 those kinds of forces'are'present and anticipated? 17 A Anticipated. 4 18 Q So you do take, you x-ray -- j 19 A We ultrasonically test them, sir. 20 g- Ultrasonic. X-ray isn't-the right word. 21 You'do have a. test procedure which would expose a significant. 22 lamination?' Should.I use"thattterm? 23 A. Yes. 24 g Little' bitty ones,'I assume, wouldn't show-up? (s, ()N 25 A There'are acceptance standards stated in the codd.
. ~
4/8 11,968 1 0- So then the concern is at the weld points, and D (_) 2 did I hear you say that the concern was because the preaince 3 of the lamination might prevent you from getting a good 4 x-ray shot of the weld? i 5 A Sir, I think some of our welding people should i 6 address that. The concern is that the lamination might i 7 open up with heat input. 8 0 So it isn 't -- did you indicate earlier about g you can't get a good x-ray because of those laminations? 10 Did I hear that? 11 A (Witness Llewellyn) Llewellyn is my name, , 12 Perhaps I could answer that, Judge, What happens in the 13 course of making a weld.<the weld goes through a number 14 of thermal cycles as it heats up and cools down. That has , 15 a tendency to open up the lamination, When.it does, slag i 16 can become entrapped in that lamination. So when we do 17 the x-rsy, that slag would show up as a defect, 18 So the intent of looking at the laminations 19 before we Weld, and then grinding them back and sealing-them 20 would prohibit the slag from get ting .into the lamination _and 21 showing up as a defect, And if it didl open tu?_ in response to .the heat,
~
n 0 23 for one reason or'another you didn't'get the slag out, 24 it could be a weak point; is that right? ( O
\ ' # 25 A l(Witness . McConaghy) . No, sir,- Wefx-ray the welds.
-g -
_ . _ _ _ , m .._ _ . _ _-- _ _ v f 11,969
-4/9 1- We radiograph the welds.
And if you had slag in there,
- ( ,f .2 it would show up as a rejectable defect.
3 Q So there is a procedure there in place. 4 But the concern is, suppose your x-ray broke, the concern 5 is the guy'wasn't feeling so well that day. You get an 6 r opened up lamination. For one reason or other it isn't 7 caught. Then that could be a weak weld, right? 8 A (Witness Barnes) Barnes. There are very
) 9 stringend acceptance criteria _ established for radiography 10 which we do on the penetrations and on: the vertical welds .
11 that if you'have any indication of slag or-lack of 12 fussion longer than a certain length, you automatically {d~*g 13 reje6t the weld and repair it to remove-that indication. i 14
, The fact that you might be-picking.up the1 edge 15 of 'a lamination, our structural people say it is of 16 no real concern-structurally. In fact, if'there were 17 I
i a way to m'ake. : the weld where you could maintain . the f 18
' lamination going all'the way.through the' weld and being 19 a continuousLla'nination, from a structural-standpoint, 20 it would be no problem.
21 ' But'the fact that it'is' picked'up by radiography 22
~and is identified.during;certain radiography requirement's 23
- t. would just mean that,, you'would have to." repair-it.
i ! 24 l So.our. main concern'in construction was to seal. ( }~ ;
'~:-.
25
./
t the laminations off(to keep them'from showing up on. 4
,y .
'^
r -
, _ s m4
11,970 - 4/10 1 radiography even though our structural people say it () 2 is not a structural concern. 3 Q That is what I am really trying to get at. 4 4 Accepting for the moment that there-is an x-ray procedure 5 that would pick these things up, just. laying that to one 6 side, if you do have one of these laminations open up 7
-and some slag from the weld process gets in there and 8
it isn't caught for whatever: reason, then why should I 9 worry about that? You are indicating you don't think it is 10 a safety concern, is that right? 11 A (Witness McConaghy) It is not, sir. 12 Q It is not? 13 A No. The concern is that it is going to look 4 14 like a lack of fussion,-so that you would reject a 15 weld. 16 Q Are you saying that that situation with a 17 lamination opening up and slag getting into the crevices, 18 I guess, is just as good as a weld where that~didn't 19 happen? 20 .A Yes,1 sir. 21 A (Witness Barnes)
~
But it might-mask another-4 22 indication. That11s the reason we want to go in _ there-2- and remove those so that'we could~1ook for other' indications 24
'in.the welds.
c
-{/
s,
, 25 0 Other 'pdications of defects?
~
.l j
4/11 .
-11',971 l
1 A Possible defects, l
, \
s 2 A (Witness Cavender) Possible defects that- l
\
3 might be lying down inside of the indication'shown 4 from the results of the lamination type indication. 5 Q But the opening of the lamination in and 6 of itself is dot a structural defect, if I hear you 7 correctly, and you are saying, for example, it might mask a 8 lack of fussion? 9 A (Witness McConaghy) Yes, sir. 10 Q And that is a concern, safety concern? 11 A (Witness Barnes) Yes, 12 A (Witness McConaghy) Yes , ' sir ,- 13
' JUDGE KELLEY:
That is all we have for right () 14 now. We will be revisiting the-gentlemen, 15 Mr. Johnson? 16 CROSS-EXAMINATION XXXXX 17 BY MR. JOHNSON: t , 18 G Gentlemen,.I would like to clarify what the 19 loading stress is on the plate itself and the term
.m through-thickness stress was used. I would like to. clarify
.I 21 -.
exactly what these stresses are;s 22 i hen you are'. talking about loadings,- you are . . 23 talking about dead weigh loadings on!the wall. There are , 24 L such' dead weight loadingscon.the containment'well that'
. T'N 25 '
s w)
-l awe.areL. talking about? ;Are there any?
s .
- ~
f
,. g'.
L -v- - . g. W - T 4 e T T
- .=.. .. . _
1 l 4/12 11,971 1; A (Witness McConaghy) Yes. O 2 Q Are there also similar loadings on the sleeve?
\/
3 A-There are dead weight loadings on the sleeve. 4 0 Could you describe what those are as to the . 5 containment plate, as to the wall, and as to the sleeve? A 6 The gravity loadings on the containment vessel 7 are vertical. 'They are due to the weight of the 3- 8 hemispherical dome on the top and.the weight of the 9 cylindrical shell itself. 0 10 So you are just talking about the weight of 11 the wall and the structure itself? 12 A Yes. 0 33 So you are just talking about the weight of the O) 1 ,
\_/ 14 structure?
15 A Yes, sir. 16 0 What about attachments? Are there any l'7 a ttachments ? 18 A There are attachments to the containment ~ vessel, g, They are monitored very closely and kept to.a minimum . 20 The attachment loads are very small, . t. 21 . 0 What are we talking about? What is it.that 22 is attached to the wall?
- A-i 23 There are some piping systems. . There are some
~
24 . able: tray systems. There are'some minor platforms,-some
-frN g.
l (..) hoists which;are_ supported.from the containment. vessel 1 proper . 3
4/13 11,973: 1 Q And how are those controlled? I assume that there
T
(] 2 Lis some limit in terms of loadings of that sort that can 't be 3 exceeded'? 4 A Yes We have done analyses of 1ccalized areas 5 around containment attachments, and we have established 6 what would be an acceptable attachment and what-is an 7 unacceptable attachment. 8 In order for the craft or for another discipline 9 to make an attachment to the containment vessel, they 10 must first have the approval of'the group that is 11 responsible for the containment design and analysis. 12 Q Who does the. testing of what those stresses 13 can exceed? l C'/ s- . 14 A It is done by analysis in1the design engineering 15 group. 16 Q At Duke Power._ Company? I 17 A At Duke Power Company, yes. , 18 Q Is that done after you get the plate'and it is 19 done on the; plate? 20 Or is that.done on,a paper ~ basis? l 21 LA -It is on a paper basis, We do. design calculations. t
.n for various sized attachments;with..various' sized loads m and various combinations'of forces-and moments applied j
~
24-to the attachment points. - And we have determined- what combina tion h-w 25 of these forces and' moments wculd be. acceptable to the I
*v - g W y v 93-- vt er ** t
11,974 4/14 1 containment vessel, (D
'y, j 2 And would you say that there is a significant Q
3 amount of conservatism built into what you allow versus . t 4 what the wall can take? , 5 A Yes,' sir, 6 Q When we talked about those loadings on the wall 7 or on the sleeve, we are talking about pulling outward 8- types of pressures, right, something that is attached to 9 the wall is going to sort of pull out on the wall? 10 A Yes, sir. 11 Q' And that is not the same thing as the when
- i. .12 we were talking about pounds per square inch, the 15 psi 13 <n: 72 psi. We are talking about a different kind of
("")g
\_
14 stress? 15 A 'ies , you are . 16 Q Are we. talking about compressive stress, 17 pressure? 18 A Well, you can be talking compressive or tensile 19 load from attachments. If this were --.if the containment
- 2. shell were;such, the dominant loads.--
21 MR, MC GARRY: So the record can understand Z2-
-what you are saying,:maybe' describe the example.
. 23 !
WITNESS-MC CONAGHY: 'The dominant loads.on
' 24
- the containment plate are vertical due to'the pressure on the i -73 i 1
\> M' l containment dome that the cylinder must hold'down. -And l t I
, .~ -
4/15 ll,97S 1 circumferential also due to the internal pressure on [m}'
\ /
2- the containment vessel. These are membrane loads. They 3 are due to overall effects. 4 You may get some local effects due to a 5 concentrated attachment such as a pipe hanger, 6 That is a very concentrated load. What is of -- overall 7 it has very little influence on the vessel. But locally, 8 you need to insure that stresses are -- 9 BY MR. JOHNSON: 1 10 0 s Which way is the stress;on that if you have a. 11 hanger attached to the wall? 12 A The applied load is transversc to the wall 13 'usually. 14 Q Okay. For a layman like me, I am not familiar 15 with the term " transverse." Can you explain what that means? 16 A It is in the thin direction, 17 0 You mean through the wall? 18 A Through the wall. 19 Q Okay.
-M Is~that area in-which you make such attachments 21
. tested forLquality of' material?
22 'A The entire-vessel is' tested for' quality of' 23 material, 24 Q. 'I1 guess what I was looking for is,'do you do-A
'q )
25 t any additional testing for that area when-you determine that I
11,976
-4/16-1 you are going to attach something at that point?
2 A No, sir. But there are requirements that are 3 pieced on the attachment themselves. If a material is. 4 .to be attached to the containment vessel pressure boundary, 5 f we require that the material be impact tested to determine I j- 6 its impact properties so that the wall and the attachment
-END 4 7 could not propagate into the pressure. boundary.
4 REE I 8 9 4 10 11 12
-14 1
15 16 17
! 18 19 -
20 .
. 21 l 22 24 m n 2.
5
11,977 l 1 l Sim 5-1 !'
. O I can understand how if you have laminations 2 that are essentially parallel to the surface of the metal 3 that'if you have pressure coming on either side inward, l 4 from a common sense point of view it wouldn't seem to make 5 any difference if there is a liminar indiation.
6 I also understand that it is different if you 7 are pulling out on the wall that you might have a different 8 effect and it is important to keep the pulling out effects
- within certain levels.
j 10 Y u said that there was conservatism built into it how much outward pressure you will allow in terms of what i 12 it can hold there? 13 A (Witness McConaghy) Yes, sir. b'~# g 0 Now with regard to-the dead weight pressure 15 of the dome what I don't understand is if-you do have 16 liminar indications one would think that if the stress is 17 I coning down through the wall, so to speak, and you did have-18 vertical laminations extending through the pipe, why that L 19 kind of pressure doesn't exert the same sort of problem 20 y u would have if you were. welding and you intend to open-21 .up-a. lamination if you came in from the. side? 22 Why isn't a lamination that-is vertical become
- n. important when you have a dead weight coming 'typ from ' the
- 24. top'since-it is going in a sense in the same direction as (p.) 25 the. lamination?
II,97El S hm 5 .2 1 A (Witness McConaghy) The stress flows around the O
\s,/ . 2 laimination. As~I was saying, there is a given force and 3
there is an area which-resists it. The area is still there. 4 0 Yes. 5 A (Witness McConaghy) The area of the lamination 6 is insignificant. So the force over a given area is not 7 changed by the lamination's presence. 8 Q I see. So you are relying on there being an 8 insignificant percentage of the thickness of the wall being 10 laminar? 11 A (Witness McConaghy) Yes. 12 O And how is that checked? At what point do we 13
- ( ) - assure _ourselves that the amount of laminations in the' plate 4
\m/
I4 itself is enough so that that woa't be a problem? Am I l*' clear? 16 A (Witness McConaghy) Not really, sir. 17 Q Okay. Well, I assume that if the wall were. 18 all laminations and you just had a little think shell and 18 everything else;was hollow that wouldn't-be enough. There 20 doens't have to be some standard that if you' looked at 21 the cross-section of the_ wall that.you would have to have 22 - no more than a certain amount-of voids.or laminar: indications? 23 l Mr. Barns. ' l 24 ! A (Witness Barnes) I think you'have got to l
\_/ 25 -
recognize that.what'we are' talking about here is rolled. ' i
. . _ - _ m ... - . _
o Sim 11,979 l 5-3 i plate and the laminations cren't like voids, rounded voids
's l
) 2 like swiss cheese in a piece of metal.
3 We are talking about you start with a great big 4 ingot of steel and through extreme pressure you roll it 5 flatter and flatter and flatter. So we are talking about 6 just paper thin, not even paper thin, but much less than 7 tissue paper thin separations, slight separations where if 8 you have had a gas bubble and you have got it just compressed 9 and it is terribly fic.t. There is no space between the metal. 10 The metal is just pushed together. 11 0 I understand what you are saying. 12 A (Witness Barnes) The thickness of the plate (~] 13 is the thickness of the plate. You don't have air pockets
\m/
14 in there inside the plate. You have metal that has been 15 compressed. 16 Q What I am asking is what kind of testing or how 17 do you assure yourselves that it is so insignificant that 18 it is compressed? Is that something that the vendor does? 19 A (Witness Ruth) I might be able to add a little 20 bit in light of this. The steel plate that we u. 3 in the 21 containment vessel is in the order of three-quarters of an 22 inch thick. Now what they start with at the steel mill is 23 something in the order of 12 to 13 to 14 inches thick. They
,_ 24 cross roll it down to the thickness of three quarters of l
25 an inch. So you have got in excess of a ten to one
~ . ,
11,980 Sim 5-4 1 reduction. The type of lamination that we are talking
,R .
k ,) m 2 about here that are commonly found in rolled products is 3 a mechanical' interface. It is not a void. It is not like 1 4 you have got an opening where there is a gap in there. 5 You have a mechanical interface where the two 6 of them touch each other. Now from testing in the steel 7 industry from years past, we have found or the steel industry 8 has found that these laminations with loads as we apply to 9 them are insignificant'. 10 The way the loads are applied on the Catawba 11 containment, they are not through thickness loads that 12 would pull the lamination apart. What you are seeing is
/~')
NJ 13 even if there are a number of laminations in there, you 14 stiil have an essential through thickness sction there. 15 You don't have.a reduced thickness section, if that helps 16 you any. 17 MR. JOHNSON: Yes, it does. 18 WITNESS BARNES: One more point. The key to 19 this is this plate is manufactured to recognized national 20 standards that were referenced'in the testimony and the-21 presence of laminations is an expected condition that you 22 find in rolled plate manufactured like this. Therefore, 23 itLis not something that you go out and worry about because 24 r~s when'the designer selects his material-for the application lns) .g5~ of a pressure vessel design, he selects this material knowing l C-- _ _
l 11,981 , l ^l Sin 5-5 1 its properties, knowing.that there may well be laminations 1 ( 2 in there because that is just the nature of rolled plate. l 3 But he makes his application of these materials in such a i 4 fashion that that characteristic of the material is not. 5 significant, and that is what we do and we are assured 6 of those characteristics by the quality assurance programs 7 of ourselves and our vendors and the steel mills. 8 MR. JOHNSON: Okay, thank you. 9 That is all I have. 10 JUDGE KELLEY: Mr. Guild.
~
11 MR. GUILD: Mr. Chairman, can we take about a 12 10-minute recess. , Mr. Kent was out of the room'when the 13 Board cuestions were being asked and it would be helpful 14 for me to confer with him. 15 JUDGE KELLEY:
; This is not a. bad place for a 16 break. Let's take 10 minutes.
17 MR. GUILD: Thank you. End Sim III (Short recess.) end 5 Sue fois 19 20 21 22 23 24
.?
\- / 26:
4 nt h/1 -1'# I
'l (Whereupon, the hearing is reconvened at-N 2 11:32 a.m.)
i I 3 JUDGE.KELLEY: Before we get into this, let's 4 just go over the time situation so you and the Board under-5 stand each other. 4 6 MR. GUILD:. Yes, sir. 7 JUDGE KELLEY: Now,.what we had said was that 8 you had as an-initial allotment when you got thirty minutes 9 on this panel and we. figured, thirty. minutes on the Staff's. 10 panel, now if you want to you canLborrow back and forth i 11 between those two. I don't know whether_you want to.. But
- 12 that's an hour in total on this. subject that's alloted.-
1- 13 ~ Now,-beyond that, what you. indicated was an t 14 interest in borrowing-against-foremen override. Foremen.
'15 override we see as taking'less. time than this-lamination lI j 16 matter. But we see, then, on - the two foremen override 4
- j. 17 panels for you, twenty minutes _ apiece as_ opposed lto thirty 18 :
j ' minutes. [ , 18 So, if you add'it all1up, you get an hour-and a 20 r half _plus ten, I think.- And you can use it as you wish.. z 1 21~ Maybe, what you want'to do, if you_want to go-ahead with L 8 your' thirty minutes and see where you are, and then make r 23 ~ a judgment' at _that _ point ~, you can do- that. N , - - '.s . MR.EGUILD: Yes, that would be fine, Judge.':And' L-(\') let me t just i say this. = What we are . going to :try. to do-_ is, i.
. - . . _ _ . . . ,_ _ .- .- .. .. _ . ~ . . . . . . , _ _ _ , , . _ . ,
11,98 1. st.h/2 i given that limited time, I will ask some questions first 2 and then Mr. Riley is going to ask a very few brief questions , 3 followed by Mr. Kent. And perhaps if someone could call 4 time for me, that would be helpful. I would like to try tc 5 do ten minutes' worth. 6 JUDGE KELLEY: Well, I will call it after thirty 7 in-any event. But you want me to call -- 8 MR. GUILD: If you would call me at ten, it would 9 be helpful. 10 JUDGE KELLEY: I will tell you. Okay. We will 11 all be telling you sto stop. (Laughter.) 12 MR. GUILD: I'm sure I can trust tbTt. Gentle-
~'\ men, who-is most knowledgeable on the subject of CP-88?
l-(d 13 14 Mr. Llewellyn? 15 MR. LLEWELLYN: Yes, sir.
-16 CROSS-EXAMINATION 17 BY MR. GUILD:
18 0 I have a copy of CP-88 that reflects that for a 19 period of-time, it was a deleted procedure. How long was 20 it deleted, sir? 21 A (Witness Llewellyn) It was deleted-from-the 22 -program January of 1983 and was reactivated July-of 1983. 23 . Q Why, sir? 24 .A .The reason for that was in the -course of working 7 g. 5 ,) 2 at Catawba 'we generated a number ctf construction procedures,.
- .. - - . . ~ . .
11,984 st h/3 1 somewhere in the magnitude of probably seven hundred. We r 4 ks 2 do an annual review of construction procedures to see if r 3 they are still being implemented and still necessary for 4 construction. 5 It was our opinion, in the case of CP-88 that 6 it was no longer necessary for construction. We essentially 7 completed all the containment plate. There are areas that 8 addressed.the need for doing inspections, say, cleaniless 9 inspection,.and M-4 and M-19 procedures where you judge 10 cleanliness that gets you to look for type of indications 11 in play. 12 i The reason for CP-88 is only to address,,once () 13 14 those have been discovered, how to handle that. An.alterna-tive to CP-88 would have been generating what ye will call 15 Form F9-B in each and every case. CP-88 was used just to i 2 16 minimize the need for a Form NE-12. 17 Q All right, sir. If I can ask'Mr. .Lowe to hand 18 you a copy of a document I believe to be CP-88 th'at was 19 _ provided to me by. Applicants this week in' formal discovery, 20 and_perhaps, Mr. Llewellyn, could you identify that as the i 21 current version of that document? . 22 A -Yes,.that is the one that's now. 23 Q All right, sir. If you look at the cover sheet,
/- 24 .
- ( g_
)
please,--it reflects the dates of the various revisions; does-26 -
' it'not?
111,985~ .q l + [ st k/4. 1 A Yes, sir. 2 Q All right, sir. Now, I thought I understood ~you i . 3 to say that the quality assurance program at Duke requires 1
- 4 an annual revision of procedures, does it not? i i
5 A Yes, sir.
- - 6 Q A review, if you will. Review is the term, i
i- 7. A Yes, sir. 4 . l '8 Q Well, I see that there-is.a revision that was i-9 dated.3/7/77, and that's Revision 3. - There is a revision 10 that's dated 7/21/78, and that's Revision 4. And the next-11- revision,. Revision ~5, is 7/13/83. + l 12 A Yes, sir. 13 Q' And the 7/13/83, Revision 5, is what reinstates
; 14 CP-88 1 from deletion; isn't that right?
1 J l 15 A. Yes,; sir. , j 16 Q What happened during each of the intervening-17 years betweenE1978 and 1983? f 18 . MR.-SHROPSHIRE: Mr. Guild, may I: speak tcr that?. I- . . e ' 19 MR.~ . GUILD : Let'.s see-if Mr'.' Llewellyn can answer
-2 the question first.
l 21- ~ WITNESS LLEWELLYN: 'Okay. The a'nnual ' review'is-j _. 22 ljtist a reviewj: of the ' document. - The~ review may findI that 23 the revision 7of the procedure is.not.necessary. .
'So,: if:
l-I 24 that's-the; case, the: revision would not'be generated. 1The ls r , 25 -revision 1is onlymade when it's found that,there is some g t. l, . 4[ I- 4 _j
> . . .: . .- . _ .i-
. , , _ . . , _ - _ _ , _ . . . - , , . - - . , - _ _ . _ , _ , . , _ , ...J .,
11,986' sth/5 p change required to the procedure. The annual review is 2 O' - 3 something.we've not done since the beginning of Catawba. Mr. Shropshire, I believe, could tell you exactly 4 how many years we have been doing an annual review. 5 CROSS-EXAMINATION 6 BY MR. GUILD:
, (Continuing) 7 Q Okay. How about that, Mr. Shropshire?
8 A (Witness Shropshire) We've been in the annual 9 review prccess for construction procedures now for about a 10 year and a half to two years. It doesn't mean that the 11 construction procedures ~ prior to that time were any de-12 ficient at all. 13 Q All right, sir.
) 14 A It just means that we now have a pro' gram that's 15 on a yearly basis. ~
We look 'at each procedure to do, as 16 Mr. Llewellyn says, to evaluate the.QA requirements, to 17 evaluate the need for that procedure; and,.if so, eliminate 18 it from our books. 19 Q All'right, sir. Can we look. at Page 1 of-CP-88? 2 21 I see that Revision 6 seems to have an affect on a line of . the procedure which' reads: l LIn accordance with NDE procedure, 22 NDE-41, the location and extent' of- the. . . and that's 'it. 2 j i What's the: significance of that latest revision. 24 T to CP-88? w
+* -g sg _w. E e w
11,981 st h/6 1 paragraph?
- t
\m,/ 2 MR. GUILD: It's Number 6.
3 WITNESS SHROPSHIRE: Sir, the significance of 4 that particular. revision was to include the NDE procedure 5 number. There had been a change in the NDE procedure manual 6 in terms of numbering, and that number was corrected at that 7 time. And that was the update. 8 CROSS-EXAMINATION J . 9 BY MR. GUILD: (Continuing) 10 J Q Is there any substantive significance to that 11 revision? 12 A No, sir. () 13 14 Q Why was CP-88, then, reinatated in July of 1983?
- A (Witness Llewellyn) At that time, we were in-15 stalling the equipment hatch in Unit 2, -and when we install i
16 the equipment hatch there are a number of containment plates II that have to be re-welded around the equipment hatch once 18 its fit in place. We had discussed with the craft, both-I8 steelworkers and welders, how they intended to do business
- 20 in that respect.
21 It was their feeling, instead of coming up to 22 the technical support group and asking for'an F9-B form-23 in each case, they would like to use CP-88 and use~the.in-
'24 formation that was contained in that. So, at their request, x '1
. 25 we reinstated the CP.
11,988 I q sth/7
' l- Q Did Mr. Nunn's involvement in the use of the
\_s/ 2 procedure specified in CP-88 in performing the repair work 3 that he has performed have any impact on the reinstatement 4 of the procedure?
5 A No, sir. No, sir. . 6 Q All right. Are you familiar with the repair work 7 that was performed on weld number CN-2NI-15? 8 A Yes, I am. 9 Q Are you the right person to answer questions , 10 about it, Mr. Llewellyn? 11 A I should be able to. 12 Q All right, sir. Now, I'm looking at a detailed i (
\_s) 13 process control sheet for that particular weld, and can 14 we generally agree that that prc* rides for repair of 15 laminar indications that were found there?
16 A Yes, sir. This is a Form F9-B that I'm refer-17 ring to, and that was generated by one of the people in my 18 grode. 19 Q All right, sir. Was'there a CP-88 at the time 2 that that repair work was performed? 21 A Yes, sir, there.was, 4 22 o' Where on that weld repair dccumentation is the M 'use of CP-88 indicated,' sir? 24 p .A Okay. We did not.use,CP 88'in this particular
\,,i{ .#. case. :CP-88 was used in-the correction of most of the
m _ .___ _ . . . .. - l l 11,989 I l
.st lp/8 1 containment welds which was done on a Form M-19.
./ 2 JUDGE KELLEY: Are we going to have a distribu-3 tion of that? l I
4' MR. GUILD: No, sir,~I'm afraid we are not. 5 This is one of those many stacks of papers that I don't.
- 6 .have copies of.
4
- j. 7 I'm showing the. gentleman a well. process control .
t ' 8 !. sheet from a weld that Mr. Nunn apparently worked on, and i 8 perhaps-it would be clearer if I could reproduc'e a. copy of , _! 10 ~ that particular document and submit-it up. I apologize. 11 JUDGEI KELLEY: I think you.should provide copies.
. 12 l
MR. GUILD: I would be. happy to. Mr. McGarry () 13 14 has a copy _he provided.- The.StaffLlooked at-this document, } presumably they have~ copies, .too. They say they looked at i
- 15 it.
4-16 WITNESS LLEWELLYN: .If you'look here-on.the-last~ 1F line of the first; paragraph of'CP-88, it says: .' Repair, 18 j; 'should be documentedLunder theLappropriate M-19 form.-lOkay.- 18 ~
.This is written basically for~the correction'of all the.
"- vertical ~and horizontal welds:in the containment': plate.
$- 21 2 What happened'in this~ case,3we.are dealing with the penetration., It's actuallyLbuilt to'ASME code, to
. Class B' standards. You note theLforms:we'are using are an
' u~
- l. F9-B. If you will turn ~back to the front, it"says Form F4-A.
%-c ~as ~
Okay. 'Myftechniciantinfthis case ~ felt that e
"~
# A , _.
;.a ,, . $ ,. . _ . - - . e e -- . J. - . . - - - - -'
--mM- - 4---- - ~ ' ~ ' - ~ < + - ~
11,990 st (V9 1 because the CP-88 referred to Form M-19A that perhaps the n() 2 CP should not be used in that particular case. So, if you 3 will read through what he has actually detailed out for 4 this one particular weld, it mostly follows what's in ac-5 cordance with CP-88. But he has done it on Form F9-B in 6 this particular case. CROSS EXAMINATION
~
7 8 BY MR. GUILD: (Continuing)
-9 Q Now, I'm turning-to a second page which should 10 be -- I was showing you Sheet 3 of 4, that weld repair; 11 is that right?
12 A (Witness Llewellyn) Uh-huh. 13 Q Okay. Now, on -- it has been altered. 14 A As they added more to it, the sheet numbers are 1 15 changed. 16 i Q All right. Now, I'm showing you Sheet 6 of 7, 17 also specifying repairs for lamination on that same weld, 18 right? 19 A Uh-huh. 20 Q Following on.down, after there has been a QC 21-
. inspection of the weld prep area and marking of. indications, H Step 1-D, Step 1-E provides for the performance of UT 23 '
. examination to' determine the extent of-lamination and notify 24
~
g, welding tech support.QC to NA this' step is not needad.
. \ -} l 25 Was-that step performe3?
11,991 st h/10 i A Yes, sir, it was , m) 2 Q How was that step performed? How was' ultra-sonic 3 testing done of the extent of that lamination? 4 A There is a report in here that shows that. Here , 5 it is, sir. 6 Q All right. Now, you are showing me an NDE 7 inspection record. , 8 A Form M-30A and the inspection is the UT of those
- 9 laminations.
10 Q All right, sir. And tell me just roughly what 11 does the exteat of the lamination that that UT indicated 12 axisted?
-w 13 A- Could I ask Mr. Cavender?
v 14 O Mr. Cavender, if you'could look at that, please. 15 A (Witness Cavender) The UT' inspector, as you.see, 16 noted four indications, number one,. number two, number three, 17 i number four -- 18 Q Yes,7 sir. 19 A Here he has detailed these. Indication, I would 2 suspect, is number one. 21 Q Let's look'down at indication number four. What 22 is the size of that indication? 23 - A PointL2 inches'in length. Point 2 inches in 24 -
. length. Point'4' inches ~in depth.
f~% . I -- 2 0 All right, sir. Now, what further was done after
11,997 st /11 1 that took place? What other repair work, if any, was per-() 2 formed for those laminar indications? 3 A (Witness Llewellyn) Those laminar indications 4 were then ground to a depth of one-eighth into the bevel. 5 They were then sealed and then we continued welding the 6 joint. 7 Q Generally speaking, what is the acceptance 8 criteria for laminar indications that do not appear in the 9 weld prep surface? What are in the base metal it' elf? 10 A (Witness Cavender) For this particular thickness 11 of plate, Mr. Guild, there is none, j 12 Q Is that consistent with the code? (~N 13 A Yes, it is.
\
14 Q Is that consistent with CP-83? 15 A I would think so. 16 Q Mr. Shropshire, would-you answer that affirmativel-r? 17 A (Witness Shropshire) Yes, it-is. 18 0 So, regardless of the size of the lamination-that-- 19 - is indicated on the mapping by ultra-sonic, there would be l 20 no further need for any repair measures consistent with 21 your judgment about the code requirement? 22 A (Witness McConaghy) No. l The lamination is of [ M interest in only..how it affects the weld you are. going to 24 make in that location. l
\ ' s) ~
25 MR. GUILD: All right, sir. .Mr. Chairman,.I
11,99: i st 6/12 1 see my ten minutes is up, so let me pass to Mr. Riley. I
~%_[ I'/ 2 CROSS EXAMINATION XXXXXXXXXX 3 BY MR. RILEY:
4 Q In referring to plate material, laminations have i 5 no affect on tensile strength. What about end wires of 6 tensile strength? 7 A' (Witness McConaghy) No, sir. Again, they don't 8 detract from the area of the plate. 8 O What is the relationship between resistance to 10 buckling of the column and its diameter? 11 A The thickness. 12 Q I'm asking you what mathematical function is 13 it? Is it an R-4 function? 14 A It's an R-square function. 15 . Q What about -- if we have a solid board here 16 that I'm holding up, that 8 by 11 notebook, which is 17 approximately three-quarters of an inch thick, its tensile 18 strength would not.be affected if I pulled on it as opposed 19 to a similar thing that saw these pages bound together. 20 i On the'other hand, resistance to bending and to ! 21 buckling.is extremely small. The reason it is is-because 22 pages are thin. Is that not'also true of-a laminated sheet 23 as compared to a sheet with no laminations? 24 A The laminations that' occur typically in plate
'( g x_ / 8 do not significantly affect the bending. strength of the
r
- 11,994 1
st,6/13 containment. 2 Q On what basis do you say that? 3 A Experience, sir. 4 Q Based on what? What testing? 5 A The mechanical properties of the centainment l 6 plate have been tested. O All right. Let's talk about the laminated plate. 8 Nhen there is a normal penetration, a penetration which is 9 now symmetrical in terms of the loading it imposes on that 10 plate. Does that not introduce a moment which tends to separate the laminations? 12 A No, sir. The penetrations -- 13
/)-
(, Q Would you say bending it'like this is not going , 14 to put stress on those laminations, it tends to separate? 15 A The moment-is distributed as a normal force 16 around the periphery of the containment-sleeve, That is 17 normal to the surface and the normal forces die out extremely 18 fast around the concentrated 11oad. 19 i . 20 21 Jim follows 22 23 24
"'l 26
-,W
- w M - y h1 'w y-p '
& ey-g c= --- e g+ -tgy+ Yw& T 'lTw-f T-m
T7JRB jrb- l 114995 f1sSue 1 .Q What is the gravitational deadweight load at the 2 base of-the containment in terms of the psi?- ppunds per s 3 square inch? 4 A It's on the order of 1,000 psi, sir. 5 Q What is the altitude of the containment?--the top 6 of-the dome? r 7 A 728, approximately, feet above sea level. l 8 Q I'am talking about. structural height, now? S A Okay. 10 The base of the containment vessel is at 552 11 feet and the top of the dome is approximately 728 feet. 12 Q You are talking about 125, 130, feet higher? i - 13 A Yes, sir. 14 Q I think that figure on psi is low, i
- 15 What's the density of steel?
16 Approximately 500 pounds per~ cubic 1 foot. A. 17 Q All right. ., 18 On that basis that's--would you-kind'of--would j 19 you recalculate that? J j 20 A I'm not clear. 21 -Q. What about the psi pressure base? i ZI Let's pass on. 2 What will'beithe effect-of a seismic acceleration.
- 24. -on'the loadingbin compressionIintermittantly of that plate,
~
! x:- - 25 thatriaminated plate, now,_..that we-have in-the containment f l-L
1 ! l 17-2 11,996 l I wall? () 2 A Sir, the-- 3 Q Bearing in mind the fact that there are a number 4 of penetrations in the wall? 5 A Yes, sir. 6 The seismic loads on the containment vessel have 7 a very small effect on the overall stress level. The 8 containment vessel is stiff for a roc .ing motion, which is 9 the dominant method of response to the containment vessel. 10 And the seismic stresses due to an OBE or an 11 SEE are very small. 12 Q They are very small: can you quantify? 13 A I remember the number in the neighborhcod of 1,000 14 psi to 1,500 psi, containment base. 15 Q Thank you. 4 16 MR. RILEY: That will be all. 17 MR. GUILD: I think we probably.used--we got about 18 12 minutes of our-half-hour? t 19 JUDGE KELLEY: Yes. 20 MR.. GUILD: Mr. Kent will go now. 21 JUDGE KELLEY: Okay. ' 22 BY MR. KENT: 23 Q Gentlemen, ch) any11aminations still exist in. steel
~ 24 i 'O plates in either Unit 1 or Unit ~2 that are larger than ASME.
Aj 25
- code allows?
7 11,997 1 A (Witness McConaghy) There is no code standard x,,) 2 for laminations in plate. 3 Q Are you saying, sir, that you have a lamination, 4 you could have it 12 feet long or 15 feet long, 20 feet 5 long; and that's acceptable? E A Yes,-sir. 7 It is not uncommon to design laminated pressure 8 vessels. 9 Q Were.you aware that the U. S. Navy, for instance, 10 does not allow any lamination in exce;s.of 1 foot in 11 diameter, but what the plate is rejected and replaced with 12 another plate?
s 13 A' No, sir, I wasn't aware of that.
J 14 Q Were you aware that in steel you can have lamina-15 tions without oxides?--with no trace of oxides?--no trace 16 of intrusions--no visible oxides to the naked eye? 17 A: (Witness Ru'th) I am not sure I understand the 18 question. 19 Would.you rephrase that, with regard to the 20 oxides? 21 g wel3, I.had heard a comment earlier, results of 22 larhinations and slag inclusions when they find the lamination s 23 of that order? 24 O A We're-thlking about welding,~then? s' 25
- Q. Laminations, where you find laminations--someone
.g
,l'
- l i
7-4 11,991 :7 l 1 mentioned slag, inclusions in the laminations? (M () 2 A Again, we're talking because of welding process. 3 Q Okay. 4 Are you aware that you can have laminations 5 with no trace of oxides, visible to the naked eye, the way 6 it looks absolutely clean? 7 A You're talking appearing on the edge of the plate? 8 Q I mean internally in the plate, in the plate, towar d 9 the center, toward the mutual axis of the plate? 10 A I am at a loss at how you would see them with the 11 naked eye through the middle of the plate? d 12 Q I'll give you an example: 13 In punching steel it is not uncommon to punch 14 right through a laminated area and' rip the bottom of the f- 15 holes out, very jaggedly so; and when you look in with a j 16 light to the interior of the plate, very often you'll see 17 shiny surfaces with no visible oxide in that' area of the 18 lamination. 19 I've seen many places where you didn't have any 20 trace of oxides in the lamination. 21 A You're talking about the area-- 22 MR. MC GARRY: Your Honor, I am having a little 23 b'it of difficulty:- 24 b'N 2 I~ haven't said anything while Mr. Riley asked'his' M questions, and now Mr. Kent--there's been a bit'of testifying l i h
- e. 7-5 11,99ll F
1
,_s gone one with the questionner. 3 '~' 2 I think now this last question has probably gone 3
too far, so I have to object. 4 MR. KENT: All right, I'll-- JUDGE KELLEY: The Board will just state a 6 caution. I agree with the point. BY MR. KENT: Q Are there any laminations in any safety-related 9 equipment in any place or pipes to your knowledge?--can you 10 list one or two existent today? 11 A (Witness Ruth) I'll answer that: Yes. 12 Q Of what order? (s,) A Our procedures directed us, if we find a laminatior , 14 4 to remove a certain amount of material, and weld it back. 15 up. , 16 We do not necessarily remove the laminatio'n'.
- So I would say, yes, there are-some laminations out~there 18 that were per our CP88, welded up.
19 Q . Including SR equipment? ~ 20 A Including what? 4 21 Q Safety-related equipment? 22 A _ (Witness McGonaghy)- Would you' define thel term 23
" equipment," please, sir?
24 (~S What do you mean by that?
w_/ 25 Q Anything that's safety-related, whether it's 4
7 11,999 1 welded to valves or any equipment of any nature or any other 2 equipment in the besc sense, or plates or piping? 3 A (Witness Ruth) Well-- 4 MR. MC GARRY: Your Honor, I am going to have to 5 object. 6 That question is going now to a topic that's 7 well beyond this contention, where we're just talking about 8 plates and penetration. 9 Now we're talking about valves and all pieces of to steel in the entire plant. That question is beyond the scope 11 of the contention. 12 MR. GUILD: Mr. Chairman, I think he said plates 13 and piping, and I think if the answer could be restricted 14 to those two features, that would satisfy it? 15 JUDGE KELLEY: That's correct, plates and l ~ 16 l penetrations; that's what Mr. Nunn testified to. 17 MR. GUILD: If those two gentlemen could address 18 that point? 19 JUDGE KELLEY: The question could be understood as restricted to ' containment plat;e penetrations. 21 ~ WITNESS MC.CONACHY: Could you-restate the 22 question? 23 BY MR. KENT: 24 Are you aware of any laminations that.still exist
~
Q 26 in'any. safety-related equipment or plates or pipe?
7-7 12,000 1
, A (Witness Shropshire) Your question is with regard
( } 2 to plater and penetrations, now: 3 We are not aware of any. There could be some 1 4 that exist because of the way we handled our welding process 5 in preparation of joints prior to welding. 6 i As Ron--Mr. Ruth--mentioned a minute ago to you, 7 we would merely trace the lamination out and when we would 8 4 go oack we would seal-weld that particular area for welding: 9 and we may leave an additional portion of that lamination ICF But as far as the plate in the structure, as far 11 as the penetration and structure, they are all acceptable 12 in accordance with the code. 13 Were you aware that--especially if heat is O 14 Q introduced in any area in that vicinity that these 15 indications can grow and can progress and can exit at a 16 surface, either t.: inboard or outboard surface? .f 17 A .(Witness Shropshire) I am aware of that fact; yes, 18 sir, e 19 Q Is it possible to have a catastrophic accident
- 20
! because of these laminations going to one surface or the 21' other? l
\
- i 22
' MR. MC GARRY: Your Honor, I think we'll have~to' 23 object to that question. l 24 !
~x MR. GUILD: Our time is limited, Mr. Chairman, we j
! (,)' WF willEjust withdraw the question.- i t a I i
M
.7-8 12,001 1
JUDGE KELLEY: Okay. 2 BY MR. KENT: 8 Q Was all steel used in units 1 and 2 of domestic 4 manufacture? 4 5 l A (Witness Akers) I believe so, I can't think of 6 any place we'had any foreign material in there. < 7 j A (Witness Ruth) To.the best of our knowledge the 1 8 material was furnished through Newport News, and that 8 material was furnished by Phoenix Steel, which is a domestic 4 i 10 manufacturer. , 11 Q- 100 percent domestic to the best of your knowledge, 12 sir? j 13 A To the best of my knowledge; yes. 14 Q Do you have certified mill test reports on all 15 this steel? 16 A (Chorus of: "Yes, sir.") 17 Q All the pipes, plates? 18 A (Witness Ruth) Yes, sir. I 19 Q All the pipes with regard.to the containment? E 'A' Yes, sir,~we'do. 21 ' Q Have you reviewed the certified mill test reports 22 for chemical analysis, mechanical properties?. 23 A' Yes,.si.r, we have. 4 24
.A (Witness Shropshire) Yes.
25;
.Ql Thoroughly, 100 percent?
1 4 7-9 12,00.2 I 1 1 A Yes. ! 2 Q They all passed? 1 8
- A So f ar as I know, sir, we have found no rejections.
4 Q And all conform to the required code? i 5 Yes, sir. j A i 6 Q All right. 7 Coes rimmed steel exist in either Units 1 or 2? 8 A I'm sorry, spell that? 8 Q Does rimmed--R I M M E D--steel exist in either 10 1 or 2, units 1 or 2? 11 MR. MC GARRY: We're talking about the containment 12 plate and the penetrations in that containment plate--is 13 that-- 14 MR. KENT: All I'm talking about here is- the = 4 15 containment plate and the containment penetrations? l 16 BY MR. KENT: 17 , Q Is that--do you know of any area that rimmed 18
-steel exist in either Units 1 or 2?
4
'I8 A (Witness Ruth) I'm not sure.
Q Why aren't.you sure?-- 21 , 3 -It is not a requirement to state that on the. 22 mill. test report, whether the steel is rimmed ~or not; and
- 23 our; review of the documentation that?we receive on the 24 ~
-s material would'not yield this information, whether it's 25 rimmed or notfin-the steel-making-. process .
7-10 12,00:, 1 rs You're talking about the rimming of steel in 2 steel-making; are you? 3 Q Basically. 4 ~ But can I have your opinion as to the uniformity 5 or nonuniformity of the rimmed steel? 6 A I am not sure I understand your question. 7 Q Could I have your opinion as to the uniformity 8 or lack of uniformity of the rimmed steel? 9 A Uniformity of what? 10 Q of any rimmed steel, per se. 11 A With respect to what? 12 Q With respect to-- s 13 \ MR. MC GARRY: 'Your Honor-- 14 MR. KENT: With respect to its-through-thickness 15 direction or respect to the uniformity or nonuniformity of 16 i the composition, chemical composition. 17 MR. MC GARRY: --if I could again interpose an 18 objection? 19 I think the record is not clear whether or not i 20 these containment plates involve rimmed steel. 'If they 21 don't involve rimmed steel, then I think the question is 22
. irrelevant.
23 MR. GUILD: 'The witness has said he doesn't know 24 the' answer to the question, and so he can't demonstrate its 25 irrelevance.
_. _ .___..____ . __ . ~ _ _ . . . . . _ - ._ . _ _ _ . _. 12,006 . 7-11 1 I .The point'is,Lassuming it's rimmed steel, is he i l l_ 2 aware of the significance of that characteristic. And the i 3 l s question as posed, it seems to me, Mr. Chairman, is i 4 relevant and proper. 5 MR. MC GARRY: That's a valid question. 6 JUDGE KELLEY: All.right. 7 i [ Can we establish, just.for my sake, if nobody 8 else's, just what rimmed steel is? 9 Steel with a rim on it, I assume, but... L 10 (Laughter)
- 11 BY MR. KENT
1 i i 12 Q Do you know what rimmed steel is, sir? i 13 A (Witness-Ruth) I would like to hear what you have ; 14 for a definiticn. 15 f (Laughter). ' j 16 MR. GUILD: Mr. Chairman, he can come back this 17
' . afternoon and see what Mr. Kent has to say, himself on this 18 subject.
18 ] But perhaps the witness could-say if ha understands ! the term means 'anything, and if.he does, what he-understands
-21 it means?
22 JUDGE KELLEY: ~Would you, please? - 23 ~ WITNESS RUTH:' I.have come across that'~ term in M
~the-' steel-making process.
25 It is. L a method of cutting .off -iri some cases, f and.
- t.
.~.. - . . --. _ . - - . . . ... . -- - . - -- .. - - - . . - . .. . . . .--. --- . .
7-12: , 12,005 ! l 1 adding material in others to.the ingot as it is poured.to () 2' give you certain properties, certain--or to eliminate s 3 certain inaterial in there. To the best of my knowledge, that's what the term t
-4 1
5 means to me. I ; 6 GY MR. KENT: d 7 Q Any other comments, please? l 8 A (Witness Ruth) I'd like -to qualify that.
, 9 MR. GUILD: ' Sure. Mr. Chairman, the witness has l
'i 10 not completed his answer.. 11 WITNESS RUTH: I didn't work in a steel mill, and i
- 12 my. knowledge is from what I have read and has been written.
i 13 . BY MR. KENT: 14 Q But do you not have the burden of knowing the 4 15
. conditions of the steel?'
16 A (Witness Ruth) . The steel is certified 1to the. j- 17 ASME code,-thattit was manufactured in accordance with the-
- 18 'ASME code, Section 2'.
( 19 Yes, we do have a. responsibility to. check that
' 20 -
-the material was made'to that code.
~
21 . Q. . Now, other:than the certified mill. test reports, 22 has anyone.at any time everfdane.-'spectroanalysis.on':any of 23 r-the-fsteel-Land actually determineditheitrue chemical-ana' lysis-
-2 t
a.of that' steel, and whether orinot it conformed;to;the. . 1
- 2 specified ASME numbers'insthe. spec?
i
;\
'r.
.i 4, y, e m9 g 4 ,,,,.,,m,,g y y 9 ,
g jq _g 9 ,..,,99 g , .g , , m ,. ,,, y,
7-13 12,006 1 A With reference to Duke Power?
-O
\s,/ 2 ! Q ,
In reference to Duke Power, Units 1 and 2? In 3 reference to our areas where we are discussing? 4 A (Witness Shropshire) I think naybe Mr. Akers could 5 answer this question. 6 A (Witness Akers) I don't remember any physicals 7 on any of the-- i 8 REPORTER: Please speak up, sir? 9 WITNESS AKERS: I don't remember any of any 10 chemicals or physicals being run on the material at Newport 11 News. That would not, unless it was questionable, I do not 12 think they would run a chemical or physical analysis. 13 WITNESS RUTH: I am not aware of any tests that (} 14 were performed by Duke Power. I think that was your 15 question--in the area'of mass spectrometry. 16 BY MR. KENT: 17 And at no Q time did you even check 1 percent of 4 18 the steel to actually make sure it conformed to the require-19 ments that the paper showed it to be? 20 l Is'it-possible that the paper could be wrong in 21 certain areas? E _A (Witness Ruth) You have two questions'there: ( L ! ' 23 D'id we ever randomly,,1-percent-inspect? i l 24 l d Q Even randomly, even at 1-percent, as low as that? (g)
'~
h i 15 A At~ Duke Power?< t l
~ . . - , ,
E 7-14 12,001 1 Q At Duke Power? (- 2 Spectro-analysis or chemi- analysis to determine 3 the true composition relative to the prescribed composition? 4 A (Witness Shropshire) An inspection was not 5 performed by Duke Power Company. We did not make that 6 particular check. We had'no reason to question the plate 7 at receiving or even in installation. 8 Well-- Q 9 A What we do have with regard to the plate, itself, 10 we require from the manufacturer a certified mill test 11 report. That in fact certifies that material to be made in 12 accordance with the code which we specified. 13 Q Were you aware that some of the people get mixed 14 up and some of the steels get mixed up and they do put 15 different certified mill test reports on different steels 16 that are not truly those steels? 17 MR. MC GARRY: ' Objection. I 18 Again, that's testifying; there's no basis for.that 19 statement at this point in time in the record. 20 JUDGE KELLEY: Could you rophrase that just as'a-21 question? 22 And I'll note that the time is up, unless you want 23 to borrow some more?- 'Want to borrow some more' time? 24 g MR. KENT: .Yes. M MR.' GUILD: Yes, a few more minutes, Mr. Chairman.
7-15 12,008 1 MR. GUILD: Yes, sir,
- 0) 2 BY MR. KENT:
i 3 Q Has anyone at any time in any of the particular 4 areas we are talking about in Units 1 and 2 checked the ASTM 5 grain size on any of the steel to see if it was a fine-6 grained steel or coarse grained steel? 7 A (Witnesc McConaghy) The material is certified to 8 SA516 wnich means that it is fine grained steel. 9 Q And what ASTM number would that be, sir? 10 A SA516. 11 g. What ASTM number would it be? 12 A 516.
-~ 13 Q %/ Yuh, I know that; A516;~but the ASTM number?
14 J What grain size would it be, sir? Would it be 1, 2, 3, 4 ,- 5 , 15 6, 7 or 8? 16 A It would be fine grained material.
- 17 Q Yes.
18 But how do you define " fine grained" by the ASTM 19 i number? l l 20 - A (Witness Ruth) I probably would be in a better 21 position to do that, but today, right at this minute, to give 22
- a. specific reference standard to look at--I don't believe I U-am in a1 position to do that.
24 O The steel-making process requires that it is a fine-V 25 grain material, and-it is certified to'that.
7-16 12,009 1 Q And how will you number fine grain, sir? What
, 2 ASTM number would be the finest grain?
j 3 A I repeat: I am not-- 4 Q If you-- 5 A Again, I just repeat it: I'm not familiar right 4 6 now with the numbering system that would yield a fine grained 7 number, whether it's a low number or a high number, I can't 8 remember right now. 9 JUDGE KELLEY: You two gentlemen are talking very to rapidly; I wonder if you could slow down a little; and we 11 will give you a couple of minutes free of charge; but slow ' 12 it down, please? 13 MR.-KENT: All right. 14 JUDGE KELLEY: Thank you. 15 BY MR. KENT: 16 Q If someone told you it was ASTM No. 2, would you 17 accept it as fine grain, sir? 18 A (Witness Ruth) I could accept it if I had the 19 proper information to check that on. 20 Now, if'I found that that "2" vasn't, I'd say 21 no. M
- What I am telling you is, I~ don't.know whether 2 Mb is or.is not, whether~5 is or is not,.or-whether 8'is or'ia
. fw 24 not.
25
-(Witness Barnes): I think the pertinent
'A if act'is
7-17 ^ 12010 1 when we receive material certification reports we have s [%/ } 2 established criteria to check them against, against standards 3 ( established; we have acceptable chemicals, physicals, ! 4 grain size. 5 When those are certified on materials test reports 6 our oeople don't operate off of memory; they compare the 7 documents. r S Q Very often in the industry I've seen cases where 9 the paperwork had been mixed up, and they have put different 10 numbers on different steels; because basically all steels 11 are the same? 12 MR. MC GARRY: I would object, and ask that that. 13 be struck. b 14 JUDGE KELLEY: Sustained. 15 MR. GUILD: Mr. Chairman, the witness is trying 16 to pose a question, and if we just preface this statement 17 by saying "have they ever seen that phenomenon" he's just 18 described, that's the significant point we are trying to 19 inquire into. 20 JUDGE KELLEY: Want to try it again? 21 BY.MR. KENT: M Q When you look at mild steel can you tell the 23 difference between ASTM 87 and ASTM A36 or ASTM 242 or 24 A572, or any of.the others, just from the1 surface appearance? 25 lA (Witness Ruth)' You mean' physically ~looking at.it?
7-18 12011 l 1-Q Yes? 2 A' Not likely, sir. 3 t. Not unless that specific specification required a 1 l 4 product form that~wouldb 'e different from a different product 5 form, being a forge or bar.versus plate. 6 g , Do any of you know of any_ case where anybody has 7 1
-ever changed any test reports, certified test mill reports, 8
to downgrade it.or upgrade it from one ASTM numberi or 3 8
-ASTM number or grade?
10 MR. MC GARRY: Objection. 11 The question is now-in the'-proper form; however, 12 we say the question is irrelevant to the issue which is 13 before this Board, which is laminations. 14 And I don't se'e any relevance between that question 15 )
- and the issue of.laminations.- So on that. basis,.we object. I 1
16 MR. GUILD: Mr.. Chairman, the-relevance is 17
-apparent: if in fact what they're getting is. rotten 18
' steel, as Mr. Nunn seemed to be of the opinion. based on his 19 observations, it.doesn't make any dif'ference what the paper:
8 says about.its quality; . the question is:. -have they ever-had. 21 4 any experience with'the paper not reflecting the' accurate.
. 22 grade of the steel that they were using.
i 23
' JUDGE KELLEY: . We'will allowLthe question' .
'4 -
WITNESS RUTH: ' Repeat your question one more: I ' 26
' t im+. , please?-
i _ _ , , _ . _ _ = s_ ,,m..~.'.., '., . , , . . . - . , . , _ . , , -
.. ..,_,,,.,-,..m.I
7-19 L 12012 1 MR. GUILD: Let me phrase the question:
) 2 BY MR. GUILD:
3 i Q Have you ever seen steel that, in your experience, 4 gentlemen, does not reflect the pedigree, that its actual 5 quality is not reflected in the paperwork attached to the 6 steel?--either upgraded, or downgraded? 7 A (Witness Shropshire) With regard to penetrations? 8 Q No, with regard to your experience in working in 9 this area? 10 MR. MC GARRY: Your Honor, I will object. Our 11 position is that it is related to the containment plate 12 and penetrations.
~
13 MR. GUILD: Mr. Chairman, our point is this: 14 a if they can say with great firmness that it's never happened 15 that the paperwork wasn't--didn't match the quality of the-16 steel, the, you know, that's the end of the inquiry. 17 But to know that simply it.actually--they actually 18 had experience with it, being defective paperwork on plate, 19 and penetrations, doesn't end the inquiry; because we 20 maintain that there's a likelihood that the paperwork is 21 defective in this case. 22 JUDGE KELLEY: Your objection goes to any kind of 23 steel whatever received at Catawba? 24 MR. GUILD: .That's right, sir; yes.
%. 25 JUDGE KELLEY: Well, that calls for a yes-or-no
7-20 12013 J 1 answer; it's pretty marginal, but, all right.
) 2 Why don't you answer it?
3 WITNESS SHROPSHIRE: With regard to containment i 4 and penetrations to the best of my knowledge we have not 5 received or not heard of any confusion in paperwork--is 6 basically what you're saying. 7 We have in the past seen some manufacturers who 8 due to our program, they identified the problem, we picked 9 up on that particular problem. It's either been identified H) through our vendor surveillance, it's been identified, 11 also, through NRC reports and bulletins to us to do research 12
.in certain areas. ,~ 13 This did not affect our containment and penetra-14 tions that I am aware of.
15 BY MR. KENT: 16 Q Do you know of any area where ASTM A7 or ASME, 17 ASME A7 exists, and either used one or two? 18 A (Witness Shropshire) No, sir. 19 A (Witness Ruth) No, sir. 20 Q None whatsoever? 21 A No, sir. ZI ! Q No safety-related equipment at.all? I
%3-
'A That's right.
24 MR. MC'GARRY: Related to the plate in-the (,
%~-
)
25 containment, not to additional equipment.
7-21 i- 4 12014 1 JUDGE KELLEY: It's been answered. 2 I think the time is up, fast expiring. 3 MR. KENT: Could I ask another couple of questions? 4 JUDGE KELLEY: What? One question? 5 MR. KENT: Several more, if you don't mind? 6 JUDGE KELLEY: Well, one is one; several is 7 several. How many do you want? 8 MR. GUILD: Judge, can we borrow another five 9 minutes? 10 JUDGE KEILEY: Fine, go ahead. 11 BY MR. KENT: 12 Q In your work in looking at laminations do you , w 13 1 (b 14 at any point leave laminations in excess of 1 inch in width on any surface, weld surface prepared, or anything like 15 this? 16 A (Witness Shropshire) In accordance with our 17 CP88, basically what it says is we will follow guidelines-- 18 Q In accordance with what it says, have you ever 19 left them without repair of them? A There may have been instances in which our welding 21 tech support and group has evaluated-a particular lamination 22 and made'that decision to leave the lamination since it 23 will not be effective in the weld zone itself, will not have 24
.( an ultimate effect on the weld.
25 MR. GUILD: -Mr. Chairman,-if . sn have ten
F, . . 22- * * -
- - 12015 i
). I minutes,-then I'll wrap up this panel for our side? ; 1 , j 2 1, - JUDGE KELLEY: Okay, that's borrowed on foreman i j , i 3 override, I take it? I t l . I 4 End 7 4 ,
- MR. GUILD
- Okay.
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\
REE Tako 8 Pago 1 12016 1 1 BY MR. GUILD: 2 Q [ l Gentlemen, you reviewed the allegations by I 3 Mr. Nunn, did you not? 4 A (Chorus of ayes by the panel.) 5 Q Did all of you read Mr. Nunn's testimony? 6 A (Chorus of ayes by the panel.) 7 Q j So you read his affidavit? 8 A .( Chorus of ayes by the panel.) 9 Q Everybody has? 10 Are there any factual crrors that you found 11 in Mr. Nunn's allegations? Any of the things he said 12 he saw, you established were not-in fact true? And if 13 so, I want you to flag the significant ones for me and 14 sort of run from most significant down to least significant, 15 if there are any factural errors that you identified in i- 16 what Mr. Nunn had to say? 17 A (Witness Barnes) Mr. Guild, we vere not 18 able to -- our reading of his testimony and affidavit 19 indicated that he had pointed out a pinhole, as he 20 characterized'it, in what we interpreted his words to say, 21 a weld where a penetration sleeve had been welded into the ~ 22 . containment plate? 2 Q This is the vendor weld? 24 A Vendor weld which we interpreted to be manufactured
^q_,y ('\ M by the containment plate manufacturer. :nnd his. testimony was
8/2 12017 1 that he pointed it out to his foreman, Mr. Rudasill, I () 2 believe, and to a QC inspector -- he couldn't remember 3 which one. He said possibly Harold Eubanks. 4 I talked to Mr. Rudasill, and he is here 5 with us, and he does not remember such a weld with such 6 a pinhole. He does remember a pinhole which Mr. Nunn 7 pointed out on a penetration assembly manufactured by 8 another company called Tempflex which is not part of 9 the containment that we are talking about here. In fact, 10 it was not a pressure boundary weld. It was purely a 11 structural attachment weld. 12 I talked with Mr. Eubanks, and he doesn't 13 recall anyone pointing out to him a pinhole in any < 14 vendor welds. 15 Q Mr. Rudasill, might that have been a void 16 that Mr. Nunn pointed out to you and not the pinhole? 17 A (Witness Rudasill) I don 't remember any. 18 conversation about a void. I do remember a pinhole. 19 around a shroud that-Mr. Nunn was'actually making the-20 x-ray weld ca.the penetration and noticed the pinhole 21 i -and brought'it to my attention and we made a repair on it. i 22 i i Q Gentlemen, try to focus on things that you 1 M' l ( found by affirmative evidence were not true in what 24 p Mr. Nunn had;to say. And, Mr. Barnes, you_ identified k-, 25
-something that the gentleman.can't recall and perhaps.it.was.
.l l
8/3 12018 1 another matter, the void or a pinhole in another weld. i I l Q' T 2 Are there any other factual errors or things 3 that you found to be untrue in reviewing Mr. Nunn's l 4 allegations? 5 MR. MC GARRYr Your Honor, I want to make 6 an observation here. I don't know if it is in the nature 7 of an objection or not. What we are talking about ~is 47 8 pages. These gentlemen aren't here to sponsor Mr. Nunn's 9 testimony as to whether it is right or wrong. They 10 are here to sponsor their testimony. 11 If they can answer the. question, so be it. But 12 I don't want the record to reflect that only two people 13 answered saying, we have this problem and this problem 14 with Mr. Nunn's affidavit, and then that this Board should 15 conclude that the remainder of that affidavit is true and 16 correct and contains absolutely no error. 37 That is not the function of this panel. ig MR. GUILD: Mr. Chairman, we have our_ ten ig minutes, and I would sure like them to do that. _That is 20 _my question. _Because I think that otherwise this 4 21 witness' testimony does stand as written, and I see nothing 22 in their documents that suggests that they have refuted 23 anything the gentleman has had to say. 24 I would like to understand if that is_ correct.
\
/ 25 If there is anything that you found that. refutes what'Mr. Nunn
8/4 12019 1 has to say in terms of what he saw with his own eyes or 2 (] V what he did, I would like to hear from you. 3 I would like to hear the most significant first, 4 working on down to the least significant. 5 WITNESS BARNES: I think we have clearly 6 refuted his characterization.of the containment steel as 7 being rotten steel. We have demonstrated that it is not 0 rotten steel, that it is steel as expected for this 8 application which had laminations. And the term " rotten 10 steel" is just not applicable. 11 BY MR. GUILD: 12 Q With perhaps extensive lamination? 13 A With lamination. 14 Q Anything else, gentlemen, please? Time is 15 limited. 16 A (Witnecs Ruth) I would have to look at his 17 testimony again, and go through it. Like Mr. McGarry 18 said, I am not prepared to speak to his being accurate in 19 all areas. Q Anybody else prepared to speak to his-not being 21 accurate? . 22 A I (Witness Shropshire)- Nith regard to his repair 23
.or the repair of weld'lSal, he indicaten that we failed 24 to follow -- if I remember. correctly, we failed-to follow 25 - v) CP88.
As Mr. Llewellyn-has said before,-we did repair-f L s
8/5 12020 1 that weld in the proper manner, using the F9 procedure in
/ 2 accordance with M4 And there is nothing in error with 3 regard'to that repair?
4 Q But you did not use CP88 for that repair? 5 A We did not need to use CP88 in that case, sir. 6 Q You did not use CP887 7 A We did not use CP88 and didn't need to. 8 Q Were any violations of due quality assurance 9 procedures disclosed in your investigation of Mr. Nunn's 10 concerns? If so, would you tell me about them, please? 11 MR. MC GARRY: I am going to object to the 12 broad nature of the question. What we are talking about A 13 here is to the containment plate and to the penetration.
\s,) 14
-i With that-narrowing, I think that question is appropriate, 15 Your Honor, t 16 JUDGE KELLEY: I think it should be narrowed i 17 as suggested by Mr. McGarry. 18 WITNESS SHROPSHIRE: We have identified one 1 19-violation that may be as a result-of Mr. Nunn's complaints. 20 BY MR. GUILD: 21 Q And what was that, Mr. Shropshire?
' 22 A That was the: failure to document in accordance n ;with the QA-program a-weld that was made by the craft..
I 24 However,.the weld was documented,.was performed in accordance
- (n
" J.
i 25 with the QA~ program. ~The gentleman who" chose-the method of-
-l
8/7 12022 1 I don't have my numbers, Mr. Chairman, but I would like ^ l ) 2
%J to have CP88 marked as a hearing exhibit, and we have
- 3 distributed that, have it admitted. And likewise I would 4
like to mark and have received this NCI. I will 5 distribute copies later to the Board and parties. l 6 JUDGE KELLEY: It will be marked sequentially 7 and received. 8 NR, GUILD: I will find the next number. 9 } BY HR GUILD: 1 10 Q Has Duke Power Company noted any significant 4 11 deficiencies in the quality assurance program at Newport , 12 News Industrial, the supplier of the plate in question here? s 13 A (Witness Akers) No. Not significant. U 14 0 Isn't it a fact that your own surveillance did 15 note that they had an unusually high number of nonconformances , 16 Mr. Akers, for a period of time? 17 A Most of those weren't of' safety significance. 18 I believe you will find most of those were of.a-19
~ dimensional nature and which has no safety significance.
20
.It-was the tolerance factor that was installed on there 21 was specified within our specifications.
22 O Did you find that-there were deficiencies in 23 Newport News ' own L internal audit procedures? 24 A That 'is correct. . - (~X I
- ( ,) . 26 Q Quality assurance? l l
1
8/8 12023 1 A That is correct. Two, I believe. One of ,m, ( ) 2 , them wasn't done at the proper time limit that was 3 required. After we noted it, I believe it was done the 4 next week. And there was one at one time that wasn't done 5 with the checklist that was outlined in the quality 6 assurance manual, However, the internal audit had been done 7 not using that checklint. And we wrote that up. 8 0 And aren't there other areas where you found 9 that Newport News had been deficient in various 10 programmatic aspects of this quality assurance program? 11 If we were to take the 18 quality assurance 12 criteria of appendix B, such as documenting nonconforming r's 13 items and having procedures for performing safety-related ( ) 14 work and having procedures for assuring the quality of 15 the materials that they received to fabricate. Each one 16 of those 18 criteria, didn't you find, Mr. Akers, that they 17 were deficient in a number of those areas, sir? A 18 Well, would you cutline deficiency, your 19 definition of deficiency. Did I find minor mistakes, yes, sir , 20 I found some minor mistakes that you are going to find 21 everywhere. But you said significant. And no, sir, we 22 did not find significant deficiency. 23 0 You found minor mistakes. And would you agree 24 that there were many minor mistakes as you characterize ( ' 25 minor?
. . . _ _ _ _ _ _ . . . _ _ _ _ _ _ _ _ . - . ~ . _ _ _ _ . . . _ _ _ _ . . _ . _ . . . . _ _ _ _ _ _ _ . _ . . _ _ _ . . . _ _ - - . . . _ _ . _ _
i 8/9 12024 i i 1- A Yes, sir, But percentagewise, with the amount 2 of fabrication and the amount of, steel coming out, I would i i jEND TAKE'8 3 consider it a very small percentage, REE 4 5 9 6 , i i 7 ! j. 8 l k i' 9 ! }' ! ! 10 11 j- , . 12 1 . 1 13 14 , l- 15 < i j i : i 16
- 1 1
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.. ._______ ___ s_ .._..._ . _ ...,_ _ .,-_...._ ,.... ___..__....- __ . ,- _.~.,_...s.~.-_;.
12025 Sim Sim 9-1 1 Q Gentlemen, let me ask you, and my time is ( ) 2 almost up, on CP-88, the second paragraph, it states "When
, 3 a liminar type defect is suspected to be the cause of an 4 RT indication outside the weld and no laminar type indication 5 was discovered prior to welding, the radiographic inspector 6 interpreting the radiograph shall request that the entire 7 area in question on the adjacent base metal be ultrasonically 8 examined for laminar indications in accordance with NDE 9 procedure NDE-41. The extent of the indication shall be 10 mapped and a tracing of the area shall be made showing the 11 location and extent of the indication, edges of the weld,
~
12 radiographic location markers and other features'which are 13 used for locating the area in question." 14 Why do you do that? Why do you perform that 15 NDE of the NDE of the base metal? 16 A (Witness Cavender)- I can tell you part of 17 it. It is to determine the - extent of the lamination at the 18 weld edge or the welid prep areas. . What we have done.is 19 applied a fairly conservative acceptance criteria for these 20 things._ The code requires that all laminations that' exceeded 21 three inches-in diameter would be removed-or sealed =and for 22' greater thickness of plate we have applied that criteria 23 to'the thinner' material.and_we have mapped this:to determine 24 the extentiof this and does'it'excee'dLthat limitation and, em
's / M' _if not, the--lamination would:bd. sealed off and then the I
-4.
12026 Sim 9-2 1 weld joint made.
-s
) 2 Q Well, sir, if the extent of laminacions.outside.
3 the actual weld prep surface are irrelevaht,'why do you waste 4 your time and money performing ultrasonic tests and mapping 5 the extent of the laminations in the base metal? 6 A (Witness Cavender) To ensure that when we do 7 make a weld that if the slag and so forth from the weld
- 8 would run back into the lamination.it would be rejected by 9 the radiograph. It is more economical to take care of this 10 before we ao down to make a bunch of welds that are going 11 to be rejected by radiography which has more strick acceptance i
12 criteria than the lamination criteria.
,r~) 13 Q All right, sir.
sg 14 Yes, Mr. McConaghy. 15 A (Witness McConaghy) The paragraph following that
, 16 in CP-88 explains why you go back and do the UT. It gives 17 you a means to accept the weld as is if in fact the indication s 18 -
on the radiograph correspond with the indications for the 19 liminar type discontinuities. If the indications are due i 20 solely to the laminations, then the weld can be accepted 21 as-is. 22 Q All right, sir. 23 Would you agree that the~likely point'of maximum 24 i .CN. vulnerability in the containment plate is along the heat (_,,/ . 25 affected zones adjacent to welds? Do you agree with'that?
~12027 Sim 9-3 1 A JWitness McConaghy) That has the potential A.s ,, 2 of being one vulnerable-point. I don't know that that is 3 the most fragile point of the containm'ent.
4 Okay. We could find places where there are O 5 particular penetrations that might go through that might 6 have particular design. specific vulne'rabilities, but if there 7 were a continuous plate and there were no penetrations would 8 my statement be.likely correct that the heat affected zone 8 would be the most vulnerable point? 10 A (Witness McConaghy) Again, that is one of the 11 t most volnerable points. 12 Q How big is the large is the. heat affected zone? 13 A ( (Sitness Llewellyn) The size of the heat 14 affected zone is' depending upon several variables, the heat 15 input involved in the weld and the fitness of the weld. Those 16 are things that are considered. 17 In the case of the three-quarter inch containment 18 plate with_the welding procedures we use, it is probably 19 in the maen tt. a of a quarter inch maximum to a h61f ihch 20 i 1 away fre thm . w. ld . 21 20 All right, sir. I could be greater than three-eighths of an - 23 inch to which you grind and rep,'.ir;71sn't thatcright?
~
~
! 24 : JA (Witness Llewellyn) .Yes, I. guess that possibility . s_- a u
. exists.
t
12028 Sim 9-4 1 MR. GUILD: Mr. Chairman, I appreciate borrowing 2 a little bit of time.. What I would like to do, and I have 3 no further questions given the time limits, but what I would-4 like to do is I was given a number of materials from the 5 applicants in informal discovery, and I would like to sort 8' of make sure that I have got a set that is complete as they 7 .gave it to me. 8 I would ask that.it be identified and marked 9 and received as a hearing exhibit. It was presented to me 10 by cover letter-from applicant's counsel representing that 11 it was the supporting documentation on the two subjects, 12 the ene of laminations and the second of foreman overrides. f'd \ 13 Those are the two areas in which I was given documentation. 14 But I would like the record to reflect the full 15 set of documents that the company purports as supporting 16 their position. 17 JUDGE KELLEY: In principle that kind of thing l 18 sounds okay. Have you talked to the other counsel about 19' their amenability to that? 20 MR. GUILD: -I haven't.actually. 21 3p,,. McGARRY: We don't think it does sound 22- ~ like a good idea, Your Honor.--We are talking.'about a. stack 8' of material.that.is probablyfabout eight inches thick.
.' "x) 24.
JUDGE KELLEY: Eight inches. _.) - 25 MR. McGARRY:- 'And'we don't think we'should clutter 2 _ __ - - - - - - - - - - - - - - - - - - - _ . . _ _a._--_------u- - - - -- - _ _ u - - - _
12029 Sim 9-5 1 up this record with that type of material. We acknowledge O( ,/ 2 that we gave this material to Mr. Guil'd and indeed it is 3 the backup material supporting this panel's testimony. But 4 to manage this record, we think that this i: not an appropriat a 5 matter to clutter the record. 6 JUDGE KELLEY: All I was going to explore was 7 the possibility of whether there couldn't be an agreement 8 among consel as to all or a portion of these documents, and 9 can't you gentlemen get together sometime later today and 10 see if you can get anywhere on that? If you don't agree, 11 come on back tomorrow and we will give you a ruling. 12 MR. GUILD: We will try Judge. 13 JUDGE KELLEY: You might-try to be a little
}
14 selective, Mr. Guild. 15 They are in the record already in the sense 16 that they are discovery. Are they informal discovery? 17 MR.~ McGARRY: Yes, sir. 18 JUDGE KELLEY: I suppose another way would be 19 to. serve a. copy but just call it discovery rather than stick 20 it in the record. I don't know,:but you might just talk 21 about that and if you can't work something out, we will do-22 it for you. 23 ' Our intent' ion, by the way is-to forge ahead and-js -24 finish with this panel before lunch. c .t )
.2 Mr. Wilson-for the. State is next.
i
+
12030 MR. WILSON: Thank you, Judge Kelley. Sim 9-6' 1
/] CROSS-EXAMINATION V 2 1 INDEX BY MR. WILSON:
3 Q Mr. McConaghy, I guess you are probably the 4 individual to answer the question, but if somebody else 5 has the answer, please don't be shy about piping up with it.
- 7 As I understood you talking with Mr. Johnson 8
earlier there are dead weight loadings on the containment 9 plates. Is that the same thing as what you' were mentioning being vertical loads on the plate? A' (Nitness McConaghy) Yes, sir. It-is loads due to gravity. O 13 14 Q Okay. Did we ever establish whether or not there was any rimming that had occurred on those plates? A (Witness Ruth)- No, we did nbt establish that. Our documentation as submitted to us, to the best of my knowledge, when I reviewed it it does'n6t' indicate._that, nor g does the ASTM' specification that it is specified.to. require l that it be stated that it is rimmed or unrimmed material. 21 O Okay. 3 A (Witness Ruth) I just-stated.what I thought' g my understanding of--rimming was. I am not so-sure I_was-24 correct in that.
'/O,
, i ,/ 0 Mr. Akers,-do you know.whether or not it is? 3 -
. . . , =
12031 l l Sim 9-6 3 .(Witness Akers) No, sir, I do not, t n( ) 2 Q Okay. Does it make any real difference to-3 you, Mr. McConaghy, from your standpoint? 4 A (Witness McConaghy) From my standpoint, no. 5 O These vertical loads.that we-talked about,. I 6 believe, Mr. McConaghy, you said these are controlled, and 7 I translated administratively. You have got basically in 8 your judgment an insignificant additional loads such as 9 hoists or hangers or cable trays or whatever. 10 A (Witness McConaghy) Yes,' sir. Those loads 11 are controlled administratively. Prior to their erection 12 we require that we be advised of those loads and approve a (} v 13 those loads. 14 In addition, during the testing phase, we physi-15 cally inspect all accessible interior and exterior surfaces 16 of the vessel and we have seen no loads that are applied 17 to the vessel that we didn't know about. 18 1 O Okay. Now the overall administrative controls 19 that you put.on those kinds of. loads, the vertical loading 20 on the walls, do those also take into.aconsideration or 21 factor in somehow the extraordinary loads which may be 22 at any given~ point added'to it? I.know your'. containment, 23 for-instance, is designed'to survive certain-impacts from ,
- 24 exterior objects and seismic occurrences and this sort-of
'^' 8 ' thing. Are those generally worked into it as well?
12032 Sim 9-7 1 A **' * #* *"*## * (Witness McConaghy) Y 2 attachment loads that are reported to us are maximum loads 3 which would include a seismic disturbance or other postulated 4 accidents. 5 O~ All right. Gentlemen, to the best of your 6 knowledge, is this steel plate that has been used in the 7 containment at the Catawba plant, has it been fabricated, 8 to the best of your knowledge, in compliance with your g specifications? 10 A (Witness Akers) That-is correct. 11 A (Witness McConaghy) Yes, sir. 12 Q And you found none that is really outside of 13 that; is that correct? O 14 A (Witness Akers) That is correct. 15 Q Now, Mr. McConaghy, this is my last question and 16 maybe you can answer it, but I am having a little bit of-17 difficulty along the lines of what Mr. Riley.was asking 18 you about with the pieces of paper when they are together. 19 Did you have more~ load than it can hold if.these laminated 20 surfaces are bonded together? Is that the thrust of what 21 he was asking you about versus just placed together? 22 A (Witness McConaghy) Yes, sir,'and it depends 23 on the kind of load that it is trying to withstand also. 24 There is a bending load as. opposed to an-in plain load. (_,1 2 O All right. -The in plain. load I guess is what _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ _ _ _ = _ _ _ _ _ - _ _ - _ _ _ _ _ __
Sim 12033 9-8 1 I am really looking at. Will lamination in the interior O(,,r 2 surface cause it to buckle a little more readily than if they were fused together? l 3 4 'A -(Nitness McConaghy) The size of the laminations 5 that we would expect, no, sir,. 6 0 okay. And those are controlled by the manu-7 facturing process if I recollect that correctly? 8 A (Witness McConaghy) That is correct. 9 Q Well, one more question, and that is to lo _ Mr. Rudasill. When you weld these plates together, do you 11 just take one plate and lay it on top and slap a wcid across l 12 the surfaces? 13 A- (Witness Akers) No, sir, not_quite that easily.
)-
14 (Laughter.) 15 A (Witness Rudasill) Normally the plates will 16 be, both will have specified bubbles.on them and craftsmen 17 will clean up the weld area and then say like the welding 18 inspector will come and he will check:the plates to make. 19 sure they are the right plates and he will check the weld 20 prep _ area to make sure it is clean and he will check 21 the. bevels to make sure they are correct and he will sign
~M the paperwork and then atLfit-up the inspector will be 2 called back-again and he will; check to make sure that the
,- 24' proper gap, the' proper bevel, the. proper lay-in, that the 25 : welder was qualified,Lthe filler material is proper, that' q l
l 1
'.t
12034 Sim 9-9 i the proper data sheet was used. All these things will be
) 2 checked before the weld will actually be allowed to be 3 welded.
! 4 0 Okay. Say for purposes of argument if you had 5 a sufficient load vertically applied to that plate and there 6 were actually some kind of propagation of a void, would this 7 mounting processs interfere or hinder that propagation or ? 8 not? 9 A (Witness Llewellyn) The weld Tna are looking at to here, the plates are fit in parallel and the weld is a full 11 penetration weld. It is the double bevels referred to that 12 we weld. 13 Q Excuse me. When.you say full penetration, it
\
14 goes clear through the --- l 15 A (Witness Llewellyn) Okay, one plate, if it is -i i 16 the horizontal, it is stacked on top-of the other and there 17 is a three-quarter inch thickness which is the thickness ! of the plates. 18 Then the weld is joining those two plates-19 together for that three quarter inch thickness. The same 20 holds true for the vertical welds as they are put'around 21 the containment shell. 22 'O Would that then hinder.the propagation of a-Zl. void if sach were'to occurifrom the7 amination 1 in an excessive [ 24 . load for some reason?
/T -
(_,/ 25 A -(Witness :Llewellyn) If:you have a lamination; 4 1
. *~
r ( Sim'9-10 l 12035 i i running through the plate, it won't pass past that weld 2 because you have a weld at the end of that plate. (\_/) 3 Q Thank you. That is what I was looking for. , 4 A (Witness Llewellyn) It would be contained within 5 that one plate. 6 MR. WILSON: Thank ou, Mr.-Chairman. 7 JUDGE KELLEY: Mr. McGarry. 8 MR. McGARRY: Thank you, Your Honor. I e 9 REDIRECT EXAMINATION XXXXXXXXX 10 BY MR. McGARRY: 11 Q Mr. McConaghy, there was some discussion with 12 Dr.-Purdom concerning the membrane stress, and I believe 13 .that you testified that the' membrane. stress was uniform'and O 14 indeed it was. carried by the containment plate. 15 You also stated-that the through stress essentiall:( 16 was non-existent. You summed up by saying that the lamination 17 'was thus inconsequential. 18 Dr. Purdom asked you what you based'that opinion 19 upon and-you.said the' design. 20 I ask you have there been.any analyses performed 21
.to substantiate your testimony today?
Zl~ A '(Witness McConaghy) Yes, sir. The containment
.1 2 vessel has.been designed and fabricated in accordance with
-]
24 the'ASME code.
.O #
( ,/ 'O And'.have-analyses been performed to assess the
12036 Sim 9-11 I stress that would be placed on these containment plates?
\ \_j 2 A (Witness McConaghy) Yes, sir.
3 Q Were you involved in that analysis? 4 A I was a work leader for the subgroup 'which was 5 responsible for the design and analysis of the Catawba 6 containment. 7 0 So is it fair then to say that the basis for 8 your opinion is not'only the design but also the analyses 8 that back up that design? 10-A Yes, sir, that is accurate. 11 Q Can you clear up an area of confusion for me. 12 The design pressure-you stated was 15 psi; is that-correct? () 13 14 A Yes, sir. Q And then the question was asked by Dr. Foster 15 how much additional stress and you said 13,000 psi in a 16 hoop and half of that in the meridal. Can you explain how I l 17 the 15 psi relates to 13,000 psi? I
'A Yes, sir. The 15 psi is the maximum internal I8 pressure in the containment which would result'from a' postulated 20
. accident. That is pressure which is normal to .the contai c 'nt l
21 plate, the. pressure on the inside of'the containment trying. 22 to get out. 23 The 13,000. psi'and 7,500 psi are stresses in 24 f-~g the containment plate which_ hold.the 15 psi back. t /
- %s Mi O And you also stated I believe, you made reference
~
4 1 12037 Sim 9-12 g to a 72 psi as an ultimate stress factor; is that correct?
/~ '
;v) s 2 A Yes, sir. That 72 psi represents the maximum 3 internal pressure to which the containment vessel could 4 be subjected before it would see unduly large distortions.
5 O Would it fail at 72. psi? 6 A It would distort to a great degree. Its shape 7 would change drastically at that pressure, but that is not 8 saying that it is going to fail or that it is going to leak. 9 There is a criterion established by the American Society 10 of Mechanical Engineers for defining such a load, and that 11 is the load at which distortions'become large. 12 O Now there was some discussion of hanging assembles ,
.rg. 13 ' hanging components and hanging cable trays on the wall and 14 you made reference to a transverse stress; is that correct?
I. i 15 A Yes, sir. f 16 O Does that transverse stress compromise the 17 'intecrity of the containment plate? - 18 A No, sir, it does not. .The transverse stresses. 19 which are applied to the containment plate are normal to 20 the surface of the plate on the one side at which they
, 21 are-attached. By geometry there is absolutely no stress 22 on the opposite side of:the. plate. There is no attachment 23 on the opposite side of the plate. LSo you must go from 24 an applied stress transversing this side to a zero stress /)
- k. 26 - on.the opposite side'in.the thickness of the plate-which i
f _ - . . . -- -- -
Sim 12038 9-13 is approximately three quarters of an inch. 3 Therefore, (~'% .
. - Q}
c 2 the transverse stresses.have to be extremely small. 3- Q And I believe you stated that the company closely 4 m nitors the additional loadings that would be hung on the
$ walls; is that correct?
4 6 A Yes, sir. As I stated in reply to the South 7 Carolina representative, we monitor all significant attachment.s 8 to the containment vessel by approving them prior to their 9 erection. In addition, during the testing phase of placing 10 the plant into operation, we physically inspect all exposed 11 exterior and interior surfaces of the vessel to ensure that 12 the attachments comply with our guidelines which we as 13 designers have estabiished.
~
14 0 Have you see that-that has been carried out?' 15 A Yes, sir. 16 0 Have you personally seen it? 17 A I have.done that personally end with my 18 representatives. , 19 (Pause.) l 20 MR. McGARRY: Your Honcr, if we could just 21 have one second. 22 (Pause.) t
- 2 MR. McGARRY
- One more question, Your Honor.
l t 24 BY MR. McGARRY: 13 1 (_,,/ 2~ .Q There was some discussion at the end, and I
Sim 12039 9-14~ 1 believe it was with you, Mr. Llewellyn, and I ask this of 2 any member of the panel, concerning the heat affected zone. 3 I believe you stated it could be a quarter of an inch up 4 to a half an inch; is that what you said, Mr. Llewellyn? 5 A (Witness Llewellyn) In this case I will be happy 6 to do some calculations to try to determine that. 7 O As I understand it, Duke Power Company, if they 8 see a lamination at the end of a plate, would grind that 9 lamination to three-eighths of an inch; is that correct? 10 A (Witness Llewellyn) Yes. 11 Q And is that done pursuant to a procedure? Is 12 that CP-88. 13 A CP-88 would be correct. 14 Q And what is the basis of arriving at the 3/8th 15 inch number? 16 MR. GUILD: Mr. Chairman, excuse me, I just 17 missed -- he trained'off with the last number. CP-88 would -- - WITNESS LLEWELLYN: It is the directive that 19 would do that. That CP-88 is based upon code requirements and those code' requirements' exist in SA-516, SA-20 and the ND subsection of the code, the ASME code. 2. MR. McGARRY: No further questions,--Your Honor. BOARD EXAMINATION 24 (INDEX
'\ XXX BY JUDGE FOSTER:
\ / 26
's Q We have. heard this. lamination compared to sheets
___ --._mm__ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ ___-__ _
12040 i Sim 9-15 3 of paper in a tablet. I also have gotten the impression [} v 2 that this results from the' rolling process with'small, let's , 3 say, imperfections of material contained within. I am trying. 4 to get a little better feeling for what this_really looks 1 5 like. i 6 Let me make an analogy and see if you gentlemen 1 7 can tell me whether it is right or wrong. If we were able
- z. 8 to see through this steel plate as though it were a piece 9 of glass or a piece of plastic,-would these lamination J
10 discontinuities look something like, let's say, confetti 1 11 which was distributed throughout this glass lamination of 12 course all lined up in a plane? o If that:is a fair analogy, how much confetti ' O 13 14 would be in there per square foot and how big.would these 15 little pieces _of confetti be?- 16 A (Witness Ruth) I guess I can speak to.that. 17 Let me walk you through rather quickly how steel is made 18 and how they get in there and then maybe this will' explain 19 it . . 20 Steel from.theLmolten stage is poured into an i 21 ingot or -into -a continuous casting method which from' there 22 .you-can have inclusions in the mold. It can beLanything j 23 . from gas ~ bubbles tornon-metallic inclusions _from several 24 sources, but the. bottom analogy is that there are inclusions
' f3 k.,/ 25 in there.
y __ e -w -
-12041
'Sim 9-16 1 ey an a e se era eren rms. Once y u take your ingot that you have poured and rolled it into A) 2 3 a slab,'then you are starting with material that is in the 4 neighborhood of 10, 12 or 14 inches thick. You roll.it down 5 to three-quarters of an inch think and everything in that 6 steel, in that slab gets reduced down and stretched out.
7 The analogy of confetti, I have never thought 8 f it that way I guess. I guess one way you could look at j g it is if a steel plate had a lamination that was completely 10 through it from side to side'and end to end, I guess it would 11 be comparable to that table top.with the formica on it and 12 underneath you have I assume a wooden surface and there is 13 an interface between the two_of them. In-that sense-you
-2nd 9 g4 could call that a lamination.
End Sim. Sue fols 15 16 17 18 19 20 21 22 23 24 . O -
12042 st 10/1 Q i Yeah, but is that what we are thinking about 2 here? I was thinking of these conclusions here as being I 3 a smal1' thing. 4 A 'i tness Ruth) They are. I'm not trying to 5 postulate that Snat we have are through a complete plate. 6 A lot of laminations are literally of a microscopic size. 7 And some can get up on the order of inches in diameter, 8 that are rolled out flat. 9 Yes, they are randomly oriented in the plate. 10 It's not that they have -- they are all right in the 11 middle or all right on the edge or anything. And because 12 of the way the steel is, and the molten poured in the 4 13 ingot and poured out in the slab, they can be closer to ( N. 14 the surface, in the middle or close to the other surface 4 15 of the material. 16 So, they are not all right in the center of the 17 plate for that point. I don't know if that helps you any. 18 Q Well, you say some of these -- let's call them 19 voids. I realize-they are not voids, but it is continuities M between the salid metal -- 21 A
-Uh-huh.
M Q Are you saying some of these voids may be 23 several inches in diameter? 24 - A That's possible. Yes, sir. O _() 25 Q Can you give me a feel for a typical -- the kind
12043 st 10/2 1 of steel which is in your containment plate that you O) ( 2 ordinarily expect to find? Are most of these the size 3 of your fingernail, or are they the size of a dollar bill? 4 A The ones that I have seen -- and I haven't seen 5 everyone that we've had, and maybe somebody else might want 6 to speak to it, they generally are not that large. And 7 when I say not, qualifying that, I've never seen one over 8 an inch and a half in diameter. That's not to say there's 9 not one there. 10 I'm just saying the ones we've observed, I've 11 never seen one on the edge where you saw it to be more 12 than an inch and a half in length, n s_- 13 14 WITNESS LLEWELLYN: I guess if I might say a point here, it might help to clear it up for you, Judge. 15 a When these laminations become visible for us to 16 see, they are on the prep, on the weld edge of the plate. 17 What is inside this plate, so to speak, we cannot see with 18 the naked eye. 19 CROSS EXAMINATION 20 BY JUDGE FOSTER: -(Continuing) 21 Q I realize that. 22 A (Witness Llewellyn) When we are looking at the 23 edge,'if you think maybe of looking down-on the earth and 24
~~
seeing a lake of a certain configuration,' depending on where
'- 3 ~
you chop that lake, you get a certain width of.that. ___. _._.-_._--u--_ _.-_---__-.--__.---_x--
12044 st'10/2 1 Now, we may see one that's-at the very narrow ('(s,) O l 2 edge of the lake; we may see one that's out in the middle, I l 3 that's on the wide edge.
'4 WITNESS BARNES: Judge, if I may. When Mr.
5 Guild was asking why did we map them and that sort of thing, 6 there were four laminations that had been mapped on that 7 ticket. And the dimentions, if I recall from looking,-were 8 about two-tenths of an' inch in diameter. 9 So, those boards you are talking about, you know, 10 they are -- were two-tenths of an inch in each length and 11 width. type. 12 CROSS EXAMINATION ( } 13 BY JUDGE FOSTER: (Continuing) 14 Q So you are back to confetti size? _ 15 A (Witness Barnes) Yes, sir. 16 Q In that particular mapping,.were these distributed 17 throughout the depth, or were they all in one particular 18 plane of the -- 19 A (Witness Llewellyn) In that penetration, which 20 was what we were talking about, they were at all different 21 levels through there. They.are disbursed randomly through-- E out.
- 23 Q So, it's like.the sheets of'a tablet, then?
24 t
<s A some might be on Page 5 and some may be on Page 10 V )' 25 and so forth,-all-the way through.
l 12045 st 10/4 1 WITNESS RUTH: There is nothing in our particular
) 2 steel, because of the steelmaking process, that would 3 preferentially locate the laminations with regards to close 4 to the surface versus being dead in the center of the plate.
5 CROSS EXAMINATION , 6 BY JUDGE FOSTER: (Continuing) 7 Q Does this make a difference relative to the 8 kind of strength we are talking about, if they are not 9 all in the same plane?. 10 A (Witness McConaghy) No, sir. It makes no dif-11 ference on the load-carrying capability of the plate for 12 the pressure vessel loads. 13 0 -One other question. If you have a seismic stresse,s [~J') 14 on the vessel and ith penetration, would you-expect to see d 15 the first failures at the point where the penetrations were 16 welded on to the containment vessel? 17 A Sir, that's a point of stress concentration, but 18 it has also-been reinforced to ensure that it would not be 19 a point of failure. No, sir, I wouldn't think anymore E there than -- 21 Q But the stresses are greater there? ' " A Yes, sir. But there are code provisions to 23 reinforce that area to make sure that's compensated ' for. 24
-w JUDGE FOSTER: That's all'I have.
N' 25
._. - . , ~.
12046 st 10/5 i CROSS EXAMINATION i 2 BY JUDGE PURDOM: [ l 3 Q Mr. McConaghy, in response to questions by r 4 Mr. Johnson and Mr. McGarry, I gather there are things 5 like pipe hangers or table tray hangers that might be 6 welded.to the containment wall? 7 A Yes, sir, there are. 8 Q And that would produce this transverse stress 9 and the welding itself might cause some more separation 10 at the lamination; is that true? 11 A The transverse stresses from attachment loads -- 12 Q Wouldn't that tend to pull lamination l apart? 13 A Those transverse loads very rapidly dissipate (v~ 14 under the overall membrane load carrying action of-the 15 structure. 16 Q If one was placed where there was lamination 17 that you could not see, what would be - the effect- of that? 18 A .The transverse stresses are extremely small, 19 sir, and the only method that the structure has to carry 20 the load is by overall membrane action. So, the transverse 21 load goes back into memberane action very quickly. 22 Q The welding which might tend to cause it to 23 open up, if I understand correctly, and-the transverse 24 stress wouldn't have_any-undue effect there? [)
\ - 25 A At the weld, sir, the:laminations, where.they
m- - - - "" 12047 st 10/6 1
'were detected, have been sealed so that they won't have an 2 adverse effect on the strength of the weld. And once they 3
have been sealed, once the weld has been made, the presence 4 of a lamination adjacent to the weld is no different than 5 one being present in the center of the plate. 6 Q So the one in the center of the plate, the act 7 of welding wouldn't have any adverse effect? 8 A - No, sir' 9 CROSS EXAMINATION
// y, 10 BY JUDGE KELLEY:
11
.O I just have a question about the significance 12 of laminations for accident conditions. And I guess this-13 was implicit in a lot of the things we talked about before, 14 .
but I believe one of you said awhile ago that the contain-15 l ment would fail around 75 p.s.i.? 16 A (Witness McConaghy) Approximately 72 p.s.i., 17 sir, we expect or anticipate that there will be gross v 18 distortions. 19 Q Not fail. It may not break?- 20 A It will get a lot bigger. 21 Q Very plastic? 22 A Yes, sir.- 23 Q And I assume'that would happen in a very-severe 24
-accident environment; is that right?
25
'A' No, sir. We've come up with no accident that' v y ,
-m--
12048 st 10/7 1 would even approach such a condition. The design accident 2 is 15 p.s.i. internal pressure. 3 Okay.
~
Q I don't mean in any sense to get into an 4 accident discussion. I don't know that much about accidents. i 5 People that have.come here talk about accidents. 6 But I was trying, in a very general way -- my 7 real question is this: If you got up -- maybe you can 8 drop the accident out of the question. If you-got up to 9: 72 or you were heading in that direction, and you had a 10
;. plate that was extensively laminated, would that plate give 11 in at 68 or 65 instead of 72 because of --
12 A No, sir. As you exceed the design limits of 13
) the containment, you force it to behave more like a balloon, 14 which has carried the load in a membrane fashion.
15 ' Q The plate that I hypothesize, which-for.one 16 reason or_another, has a_ lot of laminations in it, big 17 ones, we will say, you say that that would behave like the-18 other plates? II A Yes, sir, because -- l Q Because.the fact it's laminated extensively,
- 21 perhaps you wouldn' t have put it in there if you had known 22
- that; but, it's there. It wouldn't matter?
23 L A ~It won't degrade.the strength of the structure. l 1
^
24
"% Q It won't?- Does everybody agree with'that?
\' 25 '
A, (Witnesses nodded in the affirmative.) l
12049 1 st 10/8 MR. GUILD: I have a brief follow-up, if I 2 V may. XXXXXXXXX 3 CROSS EXAMINATION 4 BY MR. GUILD: 5 Q Isn't there a construction procedure, 89, that 6 calls for repair of overlapping laminations of containment 7 plates? 8 A (Witness McConaghy) Yes, sir. 8 Q Doesn't that construction procedure differ from 10 CP-88 that.only relates to repair of single lamination? 11 MR. McGARRY: Your Honor, I object. He could 12 have asked questions about that. I think it's inappropriate. 13 JUDGE KELLEY: We don't have a format for follow-Of 14 up, Mr. Guild. A question or-two, okay. You asked -- 15 MR. GUILD: The question arose because there 16 was testimony about what happens if they are all like 17 sheets of paper, liko stacked up. We have an overlapping 18 lamination. 19 JUDGE KELLEY: My point is that we don't have
- factored in our format rebuttal and surrebuttal, redirect 21 and all the rest. We set it up this way and we thought for 22 -
good reason. If you want to ask a question just for 23 clarity, okay. But a . line 'of questioning, -it's not in the. program. (#)
' . 25 MR. GUILD: Judge, I'm.trying to respond. The
! I 12050 1 st=10/9 1 Applicants have now had two bites at the apple, because ( 2 'they put up direct testimony. Then, they got another whack 3 at direct testimony here. Our time is very limited,l Judge. J 4 I'm asking for a limited opportunity to respond to questions 4 5 raised by Mr..McGarry. 6 JUDGE KELLEY: 'How much time were you asking for? 7 MR. GUILD: Five minutes, Judge. 8 JUDGE KELLEY: You want five minutes? Borrow 9 it against foremen override ~. 4 10 MR. GUILD: Judge, no. It's just not fair to 1 11 allow the Applicant to put up a panel of one, two, three, 12 four, about eight witnesses. [ 13 JUDGE KELLEY: Okay, Mr.. Guild, hold it a minute. 14 We came in here this morning, and we established a procedure. 15 I said that guy, you, that guy. That's.the way it was going-16 to be. You didn't say a thing. Here we are at 12:50 and 17 you want surrebuttal. There is something in-the-timeliness 18 of a point. I8 And I really think to.come.in here now and want-3 more time without even borrowing itfis unwarranted. I gave 21 you two-questions. If you want.the answer to.that. question --
; 22
- MR.. GUILD: Yes, sir.. 7md I would most respect-t 23 .
fully'suggest iflyou want to hear all of my objections to 24 this procedure, we would'have. spent-four hours this morning;
\,_)' - 25-before we started witness.one,..and you can't hold me in k \
84 - l a
,n.e w w ~ v <
~
12051 st 10/10 1 fault for not having a complaint about.this one, Judge, 2 because I will if you want to hear my complaint, sir,_about w l 3 this whole seat of the pants procedure. q ) l 4 JUDGE KELLEY:: Let's keep to one point and be 5 ' careful with your characterizations, Mr. Guild.
- 6 You can get an answer to your second question.
7 Do you want to restate it? 1 8 MR. GUILD: Yes, sir. 1
'. 9 CROSS EXAMINATION 10 BY MR.-GUILD: (Continuing)
~
11 Q Why do you have a separate procedure overlapping i 12 laminations if.they are all^ insignificant? -Why do you 13 have a different procedure for. overlapping laminations, 14 gentlemen? i 15 A (Witness Llewellyn) The second structure _ pro-16 cedure is written to try to give better clarification of how 17 to evaluate those laminations. The point needs to be made
- 18 here that in a' plate under two inches thick, there is no.
~
5 19 reason to evaluate any of the laminations.
~
20 Both of those construction procedures are done '
- 21 by Duke Power as a conservative measure to try,to better~
- 22 the standard of thefplate we are using.
23 4
' JUDGE KELLEY:- Thank you.7 24 4 :- .
MR. GUILD: Judge, ~ I' found a: document I would. 26~- justflike_to have identified. I-don't have-any questions L
~
p -- + er -tdWy-9 og -ge i-
'W-e t t y T'-sq &
12052 et 10/11 1 from it,. but I would like to have it received. This is 2 a document, it's entitled "A Memo to QA Vendor Files with 3 Respect to Nonconformances at Newport News Industrial". I 4 would just like to have this, if it can be identified by 5 the gentleman responsible for vendor QA, I then would ask 6 it to be received in evidence. 7 I won't ask any questions about it.- It came 8 from the Company. I-just put my-hands on it. 9 JUDGE KELLEY: Any objection? 10 MR. McGARRY: We would like to look at the 11 document. Also, at this time, Your Honor, we would move 12 now that Applicant's Exhibit 110, Applicant's Exhibit 111 13 be received. t U 14 MR. GUILD: Over our objections, Judge. 15 JUDGE KELLEY: Could you restate them here? 16 If we are going to act on this, your objections.are es-17 sentially? 18 MR. GUILD: The objection is. lack of discovery. 19 JUDGE KELLEY: I understand that one. 20 MR. GUILD: Lack'of opportunity to voir. dire the 21 panel. independent from cross examination. 22 JUDGE KELLEY: Right. 23
.MR. GUILD: 'On those'two bases.
24 JUDGE KELLEY: Fine. Pursuant to our' earlier A.j' 25
. ruling.andLconsistent-therewith,:those objections are over-
12053 st 10/12 1 ruled and those exhibits are admitted into evidence. 2 MR. McGARRY: Than): you. XXXXXXX Appl 110,1118 MR. GUILD: If I might, Mr. Chairman, if Mr. 4 Akers, can you identify that, sir? March 19th, 1976. 5 Judge,{while they are looking at that, may I j 6 have also ident'ifidd t p CP-897 1 s . 7 MR. McdARRY: Just so I'm clear, this document 8 relates'to the Aiscussion you,had with Mr. Akers? 1 9 s M . GUILD: Yes, sii , it does. N , 10 y MR. McGARRY: About Newport News? - 11
,) MR. GUILD: Yes, that's correct.
~ '
, s ,
12 JJDGE KELLEY: No objection? s
- N ,; ,
I'm still EttId'ying it. O 13 14 l 4 M. . JGHNSON: H,R., GUILD,3.; : 3-Mr.,
- i. ' s. .
Chairman, I ,think Mr. Llewellyn 5\ _ , I s' has,justidqntifie'dC?-8.,9lN'if I could'gave' that marked a 15 s % t 16 , , thi nextj ;>,exh'lbit?
*, j , ~ 3. ~ .\-
s
,, a
.g, 17 _ J,UDGE K5I.@Y: ,That's the procedtxe,.is it not, o , s s. s , - ; .
'18 - CP-89?-
Nb ' " 3 i ,-
. -d ., 1 -+
15 1- MR. GUILD: - hs . ~,
? ' q\
?
4.* - 20 s giDGE KELLEY: Mr. McGayry, CP-89 is a proposed
,, i /,
'* 'xhibit.-
21 e Any# objection to Ehat?t, y % e
- 22. MR. McGARRY: 'No o,bjection. 4 sS
, XXXXXXX 1- JUDGE KELLEY: That's admitted. Cp-89. 24 % MR. GUILD: 1 x ~. r Mr. Chairman,-then having identified _A.
-' Ol .>. %\ -
l 25 - ' March-19, 19_76 memo'to QA vendor files, Catawba Nuclear-t ( i
. e
't~
J. l
. _r , - y%
12054 st 10/13 1 Station Containment Liner Plate, Newport News Industrial ,~ ( ,) 2 Corporation, may I ask that it be marked and received? 3 JUDGE KELLEY: Does that relate to QA practices 4 at Newport News? 5 MR. GUILD: Yes, it does. Quality assurance 6 surveillance visit. 7 JUDGE KELLEY: Do I hear any objection? 8 MR. McGARRY: Your Honor, there is no objection. 9 I had sought clarification that Mr. Guild provided, that 10 that document indeed relates to the inspection concerning 11 Newport News. 12 MR. JOHNSON: The Staff has no objection. 13 ('~'} JUDGE KELLEY: Hearing no objection, the Board K ' 14 has no question about the relevance of it. We are going 15 XXXXXXXX to admit it. 16 Which brings us, I believe, unless I hear any 17 suggestion to the contrary, to thanking this panel and 18 excusing them. Gentlemen, thank you very much. Appreciate 19 your time and patience and your attendance. You are 20 excused. 21 (The panel is excused.) 22 l One hour break for lunch. Back at 2 o' clock. 23 (Nhereupon, a recess is taken at 1:01 p.m.) 24 Mi Jim follows
= - - -. .
-TllJRB jrb-fic Suo 12,055 1
AFTERNOON SESSION (g-')s .2 (2:05 p.m.) a 3 JUDGE KELLEY: We would like to resume. 4 We are back on the record and we will be moving 5 directly to the Staff's panel on the lamination issue. 6 But we have two or three things to at least mention before 7 we get to that. 8 In the first place, I was handed a phone message 9 just a few minutes ago from the Appeal Board, and I will to read to you what this note says; and then you will know as II much about it as I do. 12 s It says this: "The Appeal Board has denied ge 'g 13 Intervenor motion for directed certification of the 14 z Licensing Board's December 13, 1983 oral ruling." 15 That's all~I know. 16 It doesn't sound like it's on the merits, sounds 17 like they didn't think it was worthy of directed certifica-18 , tion, but that's just a guess. II
.Obviously,"you're free if'you'want to call up 20 there and' find out more information- go ahead.
21 But I guess I just consider I alerted counsel to-22 the fact that it appears some' ruling has been made; and that' s 23 311-I know about it. 24 On a separate. point, we had said earlier.that
~A f"e . 26 l s-we would.take-some time to hearcrebuttal on the oppositions 1 ;
,- - w-- - - , -
11-2 12,056 I to contentions concerning diesel generators. And I am not 2-necessarily suggesting that right now is a good time. Maybe 3 we ought to go ahead with this panel. 4 But I'd say this, it seems to the Board generally 5 that there may be a little more flexibility in tomorrow's 6 schedule than there is in today's. And we would be--if 7 Mr. Guild wants to address it today, I suppose we could 8 put it'on today. 8 \ But I think we'd just as soon do it tomorrow 10 sometime. 11 I do have one concern, though, in that regard: 12 and that is--correct me if I'm wrong--in.looking back over 13 d the transcripts of varior's discussions of this matter, and 14 your original motion and the opposition over the phone and is all the rest, it appears that we don't have at.this point ,, 16 1 the text of the contention,-itself, you'know, 100-words-or-I less, that sort of a contention. 18 I think I know why that is: at some point there 19
- was some discussion about maybe we can stipulate one. And 20 that'didn't work out.
21 But, beLthat as it may,.the Board thinks that we ~ 22 ~ i ought to rule-in~or rule-out on this contention'. -And we are
~
~
23 pretty close to doing that. And-we can't:do that if we~ don't 24 have a' contention to rule on. 25 '
-What we.would ask, i f you don ' t have .one, you kn'ow, m - = - -
11-3 12,057 1 right now--am I correct that there's nothing before the-s (,,) 2 house in terms of a contention as it's normally understood? 3 MR. GUILD: Judge, I think I formulated one on } 4 sort of an ad hoc basis at the point on the record where 5 we--the discussion first arose. I we tid try to dig back 6 through that and find what there is of a text that I read. 7 If not, what I would suggest and maybe what you 8 were going to ask is, I could formulate a text that, you 8 know, embodies the arguments that have been made, and do 10 that; and be prepared to address that tomorrow. 11 JUDGE KELLEY: Yuh. I think one or tne other 12 would be fine. ' 13 And if there's one somewhere back there in the 14 transcript, you know, that's fine; and if not--and given the 15 general nature of the contention, I think if one isn't 16 drafted now, one could be, you know, without a great deal 17 of additional research and the like. 18 It's just that we can't rule on a contention 18 that ain't there--so to speak. 20 MR. GUILD:- Judge, since you might take this up 21 tomorrow and not'this afternoon,-I was informed that there 22 was a meeting between Mr. Denton and perhaps Mr. .Eisenhut i 23 of the Staff, and various applicants, including representa-24 tives of Duke Power; and' representatives of_Transamerica-
25 Delavall last week.
11-4 12,058 1 And George Johnson and I spoke about this on the
) 2 phone. I was unable to attend, although I happened to be 3
in Washington earlier that day. 4 I don't know what the outcome is, and I thought 5 perhaps it might be useful, since that's the first record 6 meeting that I am aware of on this subject, that pethaps 7 the Staff would be able to tell us something of what trans-8 pired, or give us a status report, in any event? 9 That would be helpful, it seems. 10 JUDGE KELLEY: Comment, Mr. Johnson? 11 1 MR. JOHNSON: There was a meeting last Thursday 12 with the owners' group on the TDI matter that TransAmerica-n 13 Delavall-- 14 JUDGE KELLEY: Who, exactly, is the " owners' 15 group"? 16 MR. JOHNSON: It's the. group of utilities that , 17 have these generators. 18 I was not in attendance there. I heard second or 19 third-hand reports abcut it, and.it may be there's somebody 20 from the utility here who's in a.better position to report 21 on the meeting than myself. M But I understand that Mr. Denton did make a state-U ment at the beginning that--which was something like, !: 24 i O "until the matter is resolved there will not be further-(s/ 25 licensing of facilities with those generators." l-
11-5 't 12,059 1 JUDGE KELLEY: Would there be at some near point 2 would you think some memorandum reflecting this announcement 1 3 MR. JOHNSON: Yes, sir. 4 I believe there is a paper that was forwarded to 5 the Commission which will be available this week. 6 JUDGE KELLEY: The Board has been getting that 7 kind of thing routinely, it seems. 8 MR. JOHNSON: Board Notifications. 9 JUDGE KELLEY: Right. So the parties would be 10 served, also. 11 MR. CARR: Sir, I may be wrong on this, but the 12 l meeting was transcribed, and the minutes of the transcript ) 13 will be-- , i 14 JUDGE KELLEY: In the PDR? 15 MR. CARR: Yes, sir. 16 JUDGE KELLEY: Okay. i 17 11R. JOHNSON: That's right, there is a transcript, 18 but I haven't been able to get it yet. 19 JUDGE KELLEY: Thank you. Well, that gives a little more information, Mr. Guild. 21 MR. GUILD: Thank you, Judge. 22 JUDGE KELLEY: Okay. 23 Now let us give you an idea of what we envision 24 ['\ for the rest of the day. We tried to map things out over 25 the lunch hour. .And it's a quarter after two or so.
11-6 12,060 1 We envision a couple of hours, hopefully no less, (_,) 2 on the. Staff's panel with similar breakdowns of time and 3 some break in the middle; so that it would in all likelihood 4 get us past the Staff's panel somewhere around quarter after 5 four. 6 We would then call Mr. Nunn for about an hour. 7 I don't have exact breakdcwns now, but we're thinking of abou t j that time range. 8 We had an indication, Mr. Guild, earlier that you l 10 wished to present Mr. Kent for--as a witness on the topic; 11 and we could hear your proffer and any discussion.on that 12 at that point. (] 13 V I am correct on that, is that right? 14 MR. GUILD: Yes, that's our intention. I 15 JUDGE KELLEY: All right, that's your intention. 16 Then we'll hear argument on that. II And then we'll make rulings on any objections and 18 we'll then go on to the Applicant's foreman override panel, 18 provided--it seems to make-sense to do so--given the hour 20 when that comes up. 21 If everything goes along pretty smoothly, we 22 think there's a shot at getting to that panel; and.if it 23 doesn't and it takes us longer to do things, we hear from 7-~ l ! Mr. Kent er we don't, then we'll see whether we don't just
~
have to-put that over.
I 12,061 i l I We are prepared to go a little longer today; (- t 2 we.re free to work until seven or so. So don't think that 3 we see going very late in view of what we think we can get 4 done tomorrow. 5 But we envision making a judgment on that later 6 this afternoon, and we'll just have to wait and see. 7 Now, Mr. McGarry, you may have a fair number of 8 people here for that subject; but I guess that's the best 8 guidance we can give, though. It's rather uncertain 10 guidance at the moment. 11 MR. MC GARRY: Thank you. 12 JUDGE KELLEY: But we thought it was better to 13 state whatever we could state. 14 Okay, Mr. Johnson? 15 MR. JOHNSON: At this time I would like to call 16 Mr. Nick Economos of the NRC Staff. II The Staff did state I think earlier on in the 18 telephone call we had that we would be presenting a panel; i 19 but the way in which the material is presented and as Staff
^
8 had a breakdown of the contention on.laminations and other
. issues, it turns out that Staff's testimony on laminations 22
-is only by Mr..Economos;-and, therefore, he is offered 23 individually rather than'as a panel. Other individuals are 4 ,24 not testifying:as to that matter.
25 Is.there anybody who needs a copy of the inspection
11-8 12,062 1 report that is attached to December 29, 1983 letter? 2. (Mr. Johnson distributing documents to Board and 3 parties.) 4 I am giving copies to the Intervenors and 6 Applicants, so I don't have the three copies to give to the 6 reporter. 7 But I would like the report itself, which I believe 8 starts the third page with this item, to be marked as 9 Staff Exhibit 22. It has the Nuclear Regulatory Commission 10 Region II heading and is entitled "50-413/83-53 and 11 50-414/83-40." And it's signed by Nick Economos and 12 J. J. Blake. 13 / And I would like this to be marked and received b 14 as Staff Exhibit 22. 15 MR. GUII,D : Mr. Chairman, we object. 16 JUDGE KELLEY: Does this--let me, so we understand 17
--Mr. Johnson, the report itself, which;was prepared at 18 least in part by Mr. Economos,-is his written testimony?
II MR. JOHNSON: . Yes, sir. JUDGE KELLEY:. It does serve as his written 21 testimony? 22 MR. JOHNSON: I--let me_just--maybe:I was a-23 little premature--back up~just a' couple of steps: ; Mr. Economos,.you have this document I am 'O 'd 26 referring to in front of you?
11-9 12,063 1 MR. ECONOMOS: Yes, I do. ; 1 C% 2 MR. JOHNSON: Was this document prepared by you? 3 MR. ECONOMOS: Yes, it was. 4 MR. JOHNSON: Are there any additions or correc-5 tions to be made in that document? 6 MR. ECONOMOS: There may be one or two 7 insignificant typo errors, but I--basically this is accurate. 8 MR. JOHNSON: If I asked you these questions 8
--if I asked you questions concerning these matters would 10 you give the statements that are contained here, today?--
11 in this docu:r.ent--would you give the statements today? 12
.MR. ECONOMOS: Yes, I would.
13 MR. JOHNSON: Do you adopt this report as your 14 testimony in this case? 15 MR. ECONOMOS: Yes, it is. I do. 16 MR. JOHNSON: I would then offer it now for-- 17 to be marked and received as Staff Exhibit 22. 18 JUDGE KELLEY: Let me just clarify a little: did 19 I understand you correctly that Mr. Economos and certain-20 other Staff people worked on this report? 21 MR. JOHNSON: No. 22 JUDGE KELLEY:. I misunderstood that?
'23 MR '. JOHNSON: Yes, sir.
24 p; t s It was just'Mr. Economos, that's why we didn't 25
-offer a panel.
- c. -
11-10 12,064 1 JUDGE KELLEY: Okay. So this report, signed by 2 him, and he's the person who did the inspection; is that 3 right--went to Catawba? 4 MR. JOHNSON: That's right. 5 JUDGE KELLEY: Okay, thank you. 6 , Now, Mr. Johnson has offered--do you have 7 objections, Mr. Guild?
- 8 MR. GUILD
- Yes, we do.
9 JUDGE KELLEY: Okay? 10 MR. GUILD: Mr. Chairman, we object on the grounds 11 primarily that this document is being presumably offered 12 as reflective of expert opinion by, presumably, Mr. Economos 13 b to the conclusion that one should not concern oneself with 14 safety significance of laminations or Duke's failure to 15 properly respond to laminations in containment _ steel and 16 penetrations. 17 The document--we would seek an opportunity to 18 voir dire the witness as to his qualifications to reach a 19 number of the conclusions that he purports to reach in this 20 document--I would ask that now. And I understand the 21 Board's general approach is, you know, if I want.to voir 22 dire a witness I have to do that on my limited time in 23 chief for cros's. 24 JUDGE KELLEY: That's right. I (D g) 25 l
\
MR. GUILD: And if that's the Board's view, then
11-11 12,065 1 I want you to understand I do have an objection to that 2 approach. 3 Secondly, we object to--on the grounds of 4 Mr. Economos' qualifications to express the expert conclusior s 5 that he purports to express. 6 Secondly, we object on the grounds that as 7 previously stated for the last panel, that we were deprived 8 i of any discovery opportunity to adequately prepare, to ' 9 confront and cross-examine Mr. Economos or the substance of 10 this inspection report. 11 The deprives us of a right to due process. We 12 are unable to probe the basis for his report in any 13 intelligible way; and it's improper to receive it as 14 evidence, substantive evidence, to the bottom-line effect 15 that it is offered. 16 Third, Mr. Economos purports to base his conciti-17 sions upon a record review, a record review of records that 18 are not described in any detail, nor, presumably, are 19 available to the adversary party--in this case, Palmetto Alliance--to be able to probe the basis for his purported 21 conclusions from that record review. 22 Applicants have those record, they are Applicants' 23 records. The Staff got'to look at them;.we didn't. 24 And it's objectionable to permit expert conclusions on 25 the_ basis of extra-record documentation that was l
11-12 12,066 I unave'lable to one party. s 2 And, finally, to the extent that there are 3 matters in here that are based what are sort of classic 4 hearsay foundations, and that is, statements, conversations, 5 expressions of opinions and others, perhaps including the 6 Duke people that_are referenced as participating in his 7 inspection effort--I refer to the " licensee employees" set 8 out in his paragraph 1--those persons either are not 8 a available or right before us to be able to be questioned 10 themselves; or, if coincidentally, they happen to be the 11 same witnesses that Applicants offered, we were forced to
- 12 spend what limited time we had in cross-examining them 13 on their testimony and not on the nature of their contribu-I4 tion to Mr. Economos', which may be substantial.
15 END Til RE fis 16 17 18 19 4 Y 21 22 23 o 24 gi (_ > 2-
REE 12067 TAKE.12, Page { So on those grounds, we object to the 2 receipt of this as evidence. 3 JUDGE KELLEY: Mr. Johnson. 4 MR. JOHNSON: I just find it surprising to 5 hear Mr. Guild object to the Staff's input having, I believe, , 6 argued -- agreed with us that we should hold the record 7 open to hear what the Staff has to say on this matter. 8 And we are now offering Mr. Economos to address that matter. g We seem to be doing that partially at the Board 's request 10 and partially at Intervenor's request. It seems contradictory 11 for him to be objecting to it right now. 12 .It is certainly premature, before he has D 13 had the opportunity to cross'-examine him and to determine 34 exactly what Mr. Economos is relying on, if that is not 15 clear to him. He is arguing a lot of points that are 16 tangential, are generic, don't pertain to this material as g7 such with respect to discovery. 18 I think that row has been hoed pretty thoroughly. gg We don't have to go into that, but no further discovery. 20 was permitted by the Board. And_ documents as we had them 21 were turned over.during the period between the last hearing 22 and this testimony today. 4 g I-would like-to, in addition, point out that-24 I haven't'had a chance-to distribute the-next-document
) which is the statement of qualifications-of Mr. Economos..
v 25 _ - _ _ _ - = -______=_--_____-_-_:a
12/2 12068 1 He has them, but I haven't had a chance to introduce them (} 2 for the record. 3 If Mr. Guild wishes to challenge his qualification s 4 and his expertise, what have you, he certainly has no 5 basis that he has offered for challenging that. Mr. Economos 6 is employed by the Nuclear Regulatory Commission to 7 perform tasks as an inspector, as a metallurgical 8 engineer. And we represent that he is eminently qualitied i 9 for the task that he has undortaken. His report speaks 10 for itself. 11 I would at this time like to offer as Staff Exhibit 12 23 the sta t ement of Qualifications of Mr. Economos, 13 Office of Inspection and Enforcement, Region 2. I ask 14 that it be marked and received as Staff Exhibit 23. 15 MR. GUILD: I don't have any objection to 16 his qualifications being offered, but I would just state 17 that we received absolutely no discovery with respect to-i 18 this subject matter from the Staff. There'were no 19 documents given to us. 20 JUDGE KELLEY: Have you asked for any? 21 MR. GUILD:
. Yes, sir. Ne certainly did.
22
. JUDGE KELLEY: Maybe you could elaborate a little 23 bit.
There were some informal discovery-attempts? What 24 did you do? O g ,/ 25 MR.LGUILD: We asked, prior to the adjournment l
l 12/3 12069 1 of the December session on the record for informal (w, ) 2 discovery on each of the subjects which was refused by 3 both Staff and the Company, 4 The Board then issued an order on generally 5 the subject of scheduling of this hearing today and of 6 the findings, and in that order said, in order for 7 Interventors to prepare for this hearing adequately, 8 we think they have adequate time to review the Staff 9 reports and they can engage in informal discovery. 10 We got that order, We called up the Staff; 11 we called up the company. We said, We would like what you 12 have. Both acceded to that request in part. The Staff 7--) 13 only, however, provided documents in support of one V 14 subject mat ter and that is the matter of honeycombing 15 to be reached tomorrow. It claimed to have no documents 16 whatsoever to support any of its other inspection reports, 17 including this one. So we got no documents, although we 18 asked for them, on this subject. 19 The only documents we got from the company, 20 most of which have been alluded to previously, were no 21 the subjects of laminations and foreman override. But 22 documents on the other subjects were refused. So that is 23 basically the status of the informal discovery efforts and 24 the responses. 7_ i L_)i 25 We do have -- I should note that there is a __ _J
12/4 120701 1 pending freedom of information act request to the NRC 7w 2 V) i 3 Staff for all documents underlying these inspection efforts . That response is, in our view, late at this point and 4 no documents have been forthcoming under that request. 5 JUDGE KELLEY: We are . talking about laminations 6 and not several other things. 7 MR. GUILD: Right. 8 JUDGE KELLEY: There wau a request, Mr. Johnson, 9 is that correct, to the Staff for their underlying documents 10 on laminations. How did the Staff respond? 11 MR. JOHNSON: I will let Mr. Jones respond. 12 JUDGE KELLEY: Thank you. 13 MR. JONES: There was such an informal' request. 14 I went to the individuals, Mr. Economos, Mr. Harris , 15 Mr. Uryc, that were involved', and asked for any documents 16 they had that they had relied on in their reports. t 17 JUDGE KELLEY: I am just talking about laminations 18 now. I am trying to keep it simple. 19 i MR. JONES: All right. 20 I went to Mr. Economos. and asked for any documents, And he indicated that there 21 were no. documents that he'had, th'it the ones reviewed.he 22 reviewed at the site and did not make copies and bring them 23 back to the NRC. They are notLin the NRC' possession. And 24 that the inspection report itself-was his record of the
'25 s_-'J inspection and that that was'the only document he-had ,
1 12/5 12071 1 JUDGE KELLEY: So if the Staff doesn't have '/g ( / 2 the document -- Mr. McGarry, did you turn over lamination 3 documents? 4 MR. MC GARRY: Yes, sir. 5 JUDGE KELLEY: Of what nature? 6 MR. MC GARRY: We turned over to Palmetto 7 Alliance the documents that were relied upon by the panel, 8 the lamination panel. 9 MR. GUILD: .That is the stack we offered this 10 morning, Judge. I think'there is one sitting in front 11 of Mr. McGarry that looks like.about four inches. That 12 .is essentially what we got, and it is on the subject of 13 laminations and foreman override. {)) 14 JUDGE KELLEY: .It seems to me to be boiling down 15 to the fact that you got a fair amount of paper from 16 the Applicants, none from te Staff. But the Staff said 17 they didn't have any except'their report. So what are 18 .you' missing? 19 MR. GUILD: The bottom line, Judge, is all this 20 subject arose because-I'have an-objection pending to 21 Mr. Economos on expressing conclusions as an expert on the 22 basis-of a document review which includes none of:those 2- documents. 24
,, Now, I' don't doubt his honesty in saying that t
\ /~ .3W he doesn't-have any documents. I just find it incredible that
12/6 12072 1 someone expresses an expert opinion on the basis of a
~
2 document review and as a matter of science doesn't append 3 or attach or have available for inspection -- 4 JUDGE KELLEY: Well, then you have got some 5 questions to ask on cross along those lines. 6 MR. GUILD: Yes, sir, But I have an objection 7 pending to him being seated and his testimony being 8 received as an expert. Along that ground among others, 9 that is, he provided no supporting documentary basis for 10 his document review and the conclusions of that, it is ; l 11 objectionable in our view, sir, j 12 JUDGE KELLEY: A brief recess. l 13 (Board conferring.) 14 JUDGE KELLEY: On the record. 15-We find no sufficient reason to exclude this 16 report that is being of fered' as Mr. Economos ' testimony, 17 The objections, in large~ measure it seems to us, go 18 to what cross is for, to probe the-man's_ underlying 19 basis, to probe the reason he did things. But-the fact he 20 didn't bring a briefcase with him doesn't keep his 21 testimony out, as we-understand it. 22 _It seems to us that the informal discovery-23 concept did' work to some extent in-this case, and suggests 24 .g that it'is a workable idea' . The other reasons tie in-
) 26 very much with the previous arguments we-have' heard on-
- _____.___.____.__.__i__.._____
L 12/7-12073 1 discovery and I think we have been over that ground. I fv ') -2 see no reason to go'over it again, 3 The notion that formal discovery hasn't been . i 4 courted, therefore, his testimony shouldn 't be received, i 5
~ this matter should not proceed, has been rejected by'this 6 Board time and again. And we will reject it once more today a
7 and go ahead with Mr. Economos' testimony. 8 MR. JOHNSON: 1 We then offer Mr. Economos for I 9 crocs-examination. 10 -JUDGE KELLEY: Thank you. We will proceed in 1 f 11 the same sequence as this morning. Since it is just 12 Mr. Economos and not a panel, it does seem to us-that i g 13 although we will' follow this morning 's time as sort of. a s. 14 guideline, hopefully things could move a little more - 15 expeditiously. I 16 MR. JOHNSON: For the record, both Staff i 4 17 exhibits have been received? 18 JUDGE KELLEY: Both the report plus.the 19 qualifications, yes, both received. M (The documents referred to were 21
'. marked Staff Exhibits 22 and 235 M
.for identification'~and were
~
XXXXX)X .2 rece'ived in evidence.') - 24 MR. JOHNSON _ 'Zhe witness needs to be sworn. As ,[ M JUDGE KELLEY: Will you ' raise 'youriright hand, : plea se? 1
'r9 'yn
, - - , m y e y +-n tv s,-v-,--g c y --
12/8 12074
- 1. Whereupon,
['\ 2 NICK ECONOMOS
\ XXX X 3
was called as a witness and, having been first duly sworn, 4 was examined and testified as follows: 5 BOARD EXAMINATION XXXXXX 6 BY JUDGE FOSTER: 7 Q Mr. Economos, as I understand it, you looked 8 at the lamination problem in light of existing codes that 9 this material was supposed to meet, is that correct? 10 A That is correct. 11 Q Do these same codes, I presume, apply to 12 other plants in other places? ! 13 A I can't answer that for sure,'but I would 14 suspect that they do. It is generally the same material, 15 I would suspect, is used. 16 0 In your experience, do you -- have you made 17 similar comparisons of quality at other locations, or is this 18 - confined to Catawba? 19 A Yes, I have, other locations. 20 0 Have-you seen anything different at. Catawba than 21 you saw at other plants? 22 A With'regards to what? Material itself? 2 O The lamination, quality of; material? 24 A Basically the material is similar_ quality. !() s I.wouldn't find anything radically or drastically different'th.in i
~
12/9 12075 1 at this plant than at other plants. 2
) Realizing that this plant has come along later 3 in time than other plants that I have looked at in the past.
4 Q Did you expect to find lamination of this nature 5 in the Catawba plant in these locations? 6 A Yes. 7 JUDGE FOSTER: I think that is all I have. 8 BOARD EXAIIINATION 9 BY JUDGE PURDOM:
~
XXXXX 10 Q Mr. Economos, I gather from the last couple 11 of paragraphs of your report that you agreed with the 12 discussion of the Staff witnesses this morning -- 13 MR. JOHNSON: Applicants' witnesses. 14 BY JUDGE PURDOM: . 15 Q -- Applicants' witnesses this morning and 16 the last couple of paragraphs', would ,that be interpreted 17 that you agree with their testimony-on that subject?
?
18 A Yes, sir. 19 Q Other than the conformance with the codes, 20 doLyou have any other basis for.saying that you think 21
.the strength of this material will be satisfactory?
Zt. A- As my resume would-indicate,-I worked for 2 a; period of about 12 years in the private sector in stee1< p 24 mills. One is Timken Steel-Company and the other one-25 . was-Joncs and Laughlin. And at'Timken we did melt. And I:
12/10 12076 1 was in part involved in the quality and process control s,j 2 of these materials,' of alloy steel material, observed 3 the melting practice] observed the rolling practice, 4 observed the nondestructive testing that went on, And I 5 was involved in the quality control of the material, and 6 I am familiar with the lamination issue or the existence 7 of laminar type indications in rolled material, 8 Q Are you saying -- 9 A So I am basing my conclusions on -- not on 10 solely on the review of the quality records at the 11 site, but also basing it on my experience and background, 12 Q And you are saying, some of that experience 13 involved familiarity with test methods and_ testing this 14 kind of material for strength? ~ 15 A Yes,' sir, Melting it, rolling it. 16 Q On that basisj you conclude, as well as the code 17 ~ requirements, this is satisfactory for the purpose used? 18 A Yes) In addition to that, the application of 19 the material or this particular type of application. 20 Q Specifically when it comes to mounting hangers 21 on:the plates by welding,-do you--see any problem with that " 22- if the mounting takes place in the vicinity of a-lamination 23 ~ that is not visible on the surface?- 24 A It depends _on the size of the -- if we are talking about'an excessively large structuralLtype hanger, 25
1 I could have a concern, But here we are not talking 2 about this other thing, So the type of hangers and the O 3 type of' structural members being attached to the liner, 4 I would conclude that I wouldn't have any problem with tha t . 5 Q What type hangers are being used here? 6 A Well, I am talking about the size, basically 7 mechanical type hangers. They are not the snubber types 8 or the heavy l extremely heavy type hangers that you see 9 elsewhere that require much more support. 10 O In other words/ you wouldn't have supports 11 for flowers and things like that attached? - 12 A Heavy equipment, really heavy equipment, 13 steam generators and reactor coolant pumps, that sort of 14 thing which are several, several orders of magnitude 15 much, much larger than what we are talking about here. 16 Q What is your conclusion concerning the quality 17 of the welds if they are treated in the way the Applicant 18 described their methods for penetrations and things like that? 19 Nould you see any srfety problem related to those? 20 A The welds that I have seen meet the code, the 21 code requirements. And therefore are acceptable. And 22 based on that, I have no problem. 23 Q Do you have any personal experience with those 24 the way you have with the rolling of the steel? 25 A Other than the fact that I have been inspecting i
T 12/12 12078 1 welds of this type for the past 11, 12 years, and [~'i kJ 2 based on that experience,plus meeting the code requirements 3 and looking at them, I would say,' no; I don 't have any 4 problem. 5 Q Did you have any occasion when the welds that 6 you happened to inspect involved laminated material that 7 later on they gave any problem? 8 A Could you rephrase that? 9 0 You say you have been inspecting welds for to 10 or 12 years. Did any of the welds that you inspected 11 that involved laminar material that appeared to be 12 satisfactory give problems later on because of the fact
- 13 that it was laminar material?
14 A I don't recall any. 15 Q If you had had problems, do you think you 16 would have recalled them? 17 A I suspect I would'. 18 JUDGE PURDOM Nothing further. XXXXX 19 BOARD EXAMINATION 20 BY JUDGE KELLEY: 21 Q I think, Mr. Economos, just a general question 22 and probably at least implicit in what you have already 23 said, if you would just state in summary, if you were to 24 make a statement about why one is concerned about laminations
/N.
t, _) 's in linerplate, what.would you say? Why is this a-safety concern?-
.. .. ..~ _ . . _ .. - _-- - . - _ _ _
i l 12/13- 12079 l 3 A It is not a safety concern. I wouldn't have L () 2 that problem. The way the material is applied and 3 what it is intended to do, the design, taking into consideratian ,, 4 the design considerations, which I am not a designer, but 5 reading through'the FSAR and understanding what the postulated
- 6 forces and stresses are, that that containment, based on the 7 material, based on the results of the certified mill 8 test reports and the fabrication practices and that ,
9 whole thing, the testing of the welds, the testing of the 10 material, I don't have any problems. 11 0 on the weld points, if I understood the 12 testimony earlier, there is a concern about a visible 1 lamination at the weld surface? 2ND TAKE f2 A The weld prep, sir. < REE 15 J 17 18 19 20 21 22 , , D 24 e J.J 2s -
#- -~ , , , ~ -, 4
_. __ _. - ._ __ ._ _ - __ _ __ .- _ _ m- _ . - . 12080-Sim 13-1 i 1 The weld prep _ surface, okay. O That was' expressed 2 by the earlier panel. Are you sure of that, sir, and how 3 would you describe it? What worries you about laminations 4 in the weld prep surface? 5 - .. A Well, if they were left unrepaired, in that case 6 ' you weuld run into an unacceptable weld based.on radiography. 7 O Unacceptable in what sense? 1 8
'A In that it would contain an indication in there, 9
, a non-metallic indication that would not be acceptable by 10 . the code, and therefore that weld would not be acceptable . 11 in that form. It would have to be repaired. 1 4 12 . O Is that because the lamination condition is ( itself unsafe? Is that why? t 14 , .
- A Because it contributes, . the lamination contributes 15
, to a quality of a weld that is not acceptable tar code. It 16 is not a sound weld by code in that it will be lamination,- 17 I . as was stated before,.and because of the heating cycles 18 it will andLclose and it will allow tne entrapment of'non-i 19 i . metallic material in'there which will appear and you will' l 20 be able to pick it up on a. radiography.- i 21
- _ Q You say'non-metallic.1 - The word " slag" was used H .
! before. 23 A It is the same,. interchangeably slag material. 24 , (O) 26 This is non-metallic. l- -Q- ItEis non-metallic? f' g - m $ N -4= g
y , e.. r - __ r.' o
- +
" "s N
%, 3 12081 Sim 13-2 1 A That is right.
\
(n Well, if I underst!co'd correctly before, the 1
) 2 Q u,/ t.
, 3 concern that came across to.me,was that when a lamination 4 opened up and sidg got in the crea. sos, so to speak, I thought
, ,, ~
. .5 I was told it wasn't that in and 5;f itself_that is a safety
}l I 6 concern, but rather that that condition might mask the
.N ' . s, a
7 existence of some oth} s-
' problem sucM ac lack of fusion. Do T . 8 you agree with Cha h ,
i, ,N 9 A I agree'sith that. 3t could \ possibly do that
,( t 10 also. '
l'
.s .1 % 4 . t ,v . s ,. ,
,1/ '
"O The ~~
v'ery fact that. 1 Aave got'aflamination openinc ~ p y * *
- E 12 5, up some and{ssome slag getting.in -
w there, now that Day not
%4 13
' s.
pass code;,, but is,it safe or is unsafe?h ,
] t, 4, , , . ., -
i 14,
'f 4 Asw$s$tatedbefore, it could possibly mask ~
i 15 othbr'-- ' i s, 4 y ,
; 4 . %
=, -
l' ,% = , 16 ON ~ Forget' the m$skb1<;r- tNough. Is it unsafe?' t / _
-17 I am trying to narrog dbwn why',should '
> g-I care about masking?.
18 Whocareswhenthe.pnlythingthatcomesoutfitfthistome g . N y s - ,, I8 iE that it might~ mas % some other defect. l
~
Oam a layman 1, \. , ( n an,d m I; don't underst'and these; et ,
- r s
- s. t s
things so quickly-and sometimes-
,21 ',
^ n6L soLwell. sBut I am trying to focus on')why,I should worry.
I 1 s -', 22 "Now:f;hould I worry about'.anything.other than l
\r i
- ., g
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l 23 4 themasingof--anotherdefhet,inyouropinion?;t
~ y~ -
. . x .. . ,
24
- l. g.
a slf N o . -;170,fyou should:nol. "2 would.not' worry. y8 ,. . 25'
'- 5 Lookingat7yburre'po'rtonpage;2atthebottom,'
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w '
- :4 m - -
l. 12082 i ,Sim_ 13-3 1 you cite two particular welds, 2M-406 and 2M-407. Now I 7 [V 2 were those the welds, to the best of your knowledge r that 3 Mr. Nunn had referred to in his statement? , 4 A Yes, sir. 5 0 h:d that is why these were looked at? 6 A Yes, sir. 7 0 The paragraph.which refers to them appeared to me 8 to reflect a document type check as distinguished from the 8 physical hands on inspection. Is my impression correct? 10 Is that what was involved there? 11 A I went down there and observed the welds. 12 O You did look at them? 13 A Yes, sir, in their completed stage which at that 14 time, you know, you are just looking at the surface of the 15 weld and that is all you can do. 16 It is more conclusive if you look at the fabrica- , 17 tion history which is the M-4A's and the repair sheets and 18 all the rest, and also the radiographs of those welds which 19 also provide you with an indication of the soundness of the
# weld.
21 g .Did you look at the radiographs of.those particular 22 ' ' welds? 23 A Yes, sir, and it is mentioned here on the top 24 of page 3 I believe. Fabrication type defects. The laminar 25 type is.that both joints were radiographed'and found acceptabl e.
12083 Sim 13 I am sorry, where are you? g Q
!L ) 2 A On the top of page 3: the bottom of that first 3 paragraph.
t 4 Q _ Well, I read'this and I thought it just meant 5 _ you were just reciting the. facts that they did radiographs
~
6 sometime in the past. Did you yourself look at the radiographa?- 7 A Yes, sir. I say "Also the review revealed that 8 -following repairs," and so on and so forth. That is how 9 the sentence starts. 10 0 Just one moment. 11 (Pause.) 12 .-It doesn't say that to me. I'am glad to hear i 13 you looked at them, but to me-this says you found out they ( 14 had been'radiographed. 15 A Yes, sir. 4 16 Q But it doesn't say that_you looked at'them. I'. A I.. looked at the. radiographs also. 18 Q- Lokay, could you describe the results'of bat-19 review? m A The welds, the fabrication records -indicated there
=!l .
21- had been severalirepairs performed. The rejectable' type 22 indications were identified'by radiography,'they were repaired i-23 and reradiographed_and[re-repaired _until they. finally came
, g 24 - up;with aLsound_ code acceptable weld'.,
' ~
-( 'ic .
4' 'M Q_ D'oes(radiography-of a weld -- let's suppose-that-
,N'
' ' y i
s+ ' y
.si g ef: ,
l 12084 Sim 13-5 '1- Lyou suspect'the weld of having lamination problems and the
/~h
(_,/
- 2 possibility that it would have opened up and slag got in 3 and so forth, l.
4 A Yes. 5 Q Does the radiography show that? 6 A Yes. 7 Q It does? 8 A -Yes. 9 0 'And you say there were no indications of that 10 on these particular welds? 11 A -That is correct. 12 O I was' confused in the next paragraph where it 13 says '"Other penetration sleeves designated as spares by the ( 14 licensee" and.so on. Then there is.this. column, stage of 15 fabrication and tack and complete. I thought when I read , 16 spares:it meant they were lying-out in the warehouse and 17
~
.then I see they are tacked. I thought tacked. meant you have 18
.itt up on the wall and.you are. ready.to go.
18 A These are. penetration. sleeves in the~ containment 20 - that'.were put.there either by.. design. I suspect'they~were 21 put there'by design in the event.that they were3 to.be used 22 ~
;during the constructionlof'the plant.
23' iQ -It.'is an-extra' hole in the' containment. 24 g' og g. That is, correct.-
- ( l
'6
'- 25 -
It~is-not'out in the warehouse. Q
..: +
_ _ . . ~. 12085 Sim 13-6 "
- g A No. They are referred to as spares.
() 2 Q Okay. I understand. Thank you. 3 A' So we did look at those for laminations. 4 O Just as a sample, so to speak? 5 A That is correct. 6 Q Is that the idea? i 7 A That is' correct. 8 0 You say you performed magnetic particle inspection i 9 on'a particular one. 4 to A Yes, I had. 11 Q What does that tell you about a lamination? Is 12 that a way of detecting lamination?
~5 13 A Yes, sir. It would show on the cut surface v
14 if you are looking at a cross cut. Provided the sample or 15 that surface is properly prepared, if there were any lamina-16 tions there, the magnetic particle inspection should indicate-17 it. 18 JUDGE KELLEY: 1 hank you. 19 Let'.sLsee, we are reversing order here1in 20 some sense it seems-to me. I gather you would prefer to 21 come after the applicants? 22- MR. GUILD: Yes,: sir. 23 JUDGE? KELLEY: Right. M- Mr. McGarry,'are you ready? (~m -
-t ) ^ ' - 25 -I thinkfI misstated this, but obviously we.had-L w
w w
l 12086 Sim 13-7 i different sponsors and that would dictate a somewhat different
/%
.i i 2 sequence.
~d 3 MR. McGARRY: I would be glad to go forward, 4 - Your Honor.
5 JUDGE KELLEY: All right. 6 CROSS-EXAMINATION INDEX 7 BY MR. McGARRY: a Q Mr. Economos, are you familiar with the code. 9 requirements concerning laminations on two-inch steel? 10 A Yes, sir. 11 Q And as I understand it, that code requirement sets 12 forth soecific cnditions that one should look at with_ respect 13 to laminations; is that correct? 14 A Yes, sir 15 Q Now Duke's containment plate isn't two-inch 16 steel, is'it? 17 A No, sir. 18 Q It is three-quarter inch steel; isn't-that 19 correct? N- A At certain parts it-is, yes. In some parts it 21 is heavier'and in some-pa'rts it is-lighter. 22 Q- But'it doesn't reach the two inch ---
'M .A 'That is-correct..
24 _O 'O 'And are you. aware.of any code requirements. con-i b A./- 25 - cerning=laminations.'to.. steels less than'two lnches?
~
}
_,,,u.
12087 Sim 13-8 A No, sir. Q Now as I understand it, Duke Power Company has v ' 3 taken the code requirements applicable to two-inch steel and made them applicable to~three-quarter inch steel or thereabouts; is that correct? 5 A That is a true statement. 6 7 Q And cuch being the case, would it be your opinion 8 that Duke by implementing the code requirements that are _9 apriicable to two-inch steel to a lesser fixed steel, that 10 such action by Duke is conservative? 11 A That is true. 12 O Now just to discuss this steel-somewhat, p 13 Mr. Economos, as'I understand it, based on the testimony _ this morning, a 14-inch ingot was-taken and was rolled 14 15 numerous times to finally result in a three-quarter inch 16 steel; is that correct? 17 A I don't know what the size of the ingot was or
~
18 the billet was, you'know, but it could be correct. 19 0 _I believe-I heard'14 inchec. Based on your 20 experience of_ steel' fabrication-and the making of steel, 21 ' is that how the process works? You take an ingot'and then "22 you' roll it and roll it and roll.it until you get the-23 desirable --- 24 : A Yes, and let me.go back one more step. Basically-l (/ (D.
'. 25 --
nowadays material, especially.this type of material, would
. 1
Sim 12088' 13 g be melted in an electric furnace and then normally it would f)
%,/ 2- be degassed in which case you would get rid of a lot of the 3 oxides that would give you this type of a problem.
4 In the past years before we used to have more 5 f this problem, but because of the melting practices or 6 rolling practices, et cetera, that type of thing, you minimize 7 the likelihood of lanination. 8 S while I cannot confirm this~from the certified 9 mill test reports, based again on experience I would strongly to suspect that this type of material was electrically melted, 11 degassed, poured and then subsequently rolled into slabs 12 and put into place.
s 13 -0 Now if it was a 14-inch ingot that one. started g4 with, based on your experience, how many times do you have ui to roll it to get down to three-quarter inch? Would it be y; done about 10ttimes or 100 times? I am just not familiar 17 with the-process.
ul A At least I would say 10 times and-then they would 19 probably put in an intermediate heat treatment. 20 Q Am I correct in assuming that to get two inch 21 thick steel you would roll it fewer times than to get three-n quarter inch steel? 23 - A- It is possible. It depends on the amount of. 24 reduction per. rolling per roll. (/ N 25 0 I am sorry,-I.didn't hear you. r
12089 Sim 13-10~ 1 A I say it depends on the percent of -reduction
^
~ (' j T 2 per roll.; 'There is no fixed amount. You wind with a product 3 and you know where youfare going. 4 Q. If one were to assume, Mr. Economos, the same
-5 billet size, and one would then have to roll more times to 6
achieve 9 three-quarte'r. steel than a two-inch steel? 7 A That is a true statement.. 8 Q And there were laminations in a three-quarter 8 i inch steel, they would be thinner, would they not, relative 10 g_ to 'a two -inch steel? 11 [A Yes. 12 MR. McGARRY: If I may just have one moment, 13 Your Honor.
~J .
14 (pause.) 15 MR. McGARRY: One quick area, Mr. Economos, and 16 that has to do'with your._ qualifications and I have read them. 17 Do you have a copy of those in front of you? 18 THE WITNESS: Yes. 18 BY MR. McGARRY: 20 j 0 As I understand it,~you'have been~ working in 21 the areanof'metallurgyf from at least 1958; is that correct?
-A That is correct.
23 0- -And you indicated you worked.forLtwo steel 24 , . .' Ci o c'mpaniesLin the first' instance. 25
-A Yes, J&L andLTinkin.
e L i
12090 Sim'13-11 1 Q And then you moved to the NRC in 19772. ( 2 A That is correct. 3 O And you have applied your metallurgical expertise k i 4 in your role as a member. of the Nuclear Regulatory Commission; 5 is that correct? 6 A- That is correct.
- 7 Q And you have_ set forth how you have applied it, 8 as I take it in your view, at various license applications 9 and inspections; is that correct?
10 A Yes.
- 11 MR. McGARRY
- - No further questions, Your Honor.
l 12 JUDGE KELLEY: Mr. Guild, do-you want to carve (~) 13 up your time again? V 14 MR. GUILD:- Yes, sir. How big is the pie? 15 JUDGE KELLEY: Well, your pie is intact at this i 16 point for this panel.. It is-'a~ half-an hour and you have 17 gone to the bank for 17 minutes against foreman override 18 at this point. i 18 MR._ GUILD: Let me try 10 minutes for myself 20 and Mr s Riley I know has a few questions and then.I know 21 fMr. Kent'would like to follow. So let me try ten for 22 now if:I might. 23
~ JUDGE KELLEY: :All right.
24 Oi LU # l i l 4 - g , y , 4-~y < ,m -w- ~ v <
~ . _ - . . -
Sim 13-12 12091 1 1 CROSS-EXAMINATION I T
, ,_,3DEX XXXX2 ,
BY MR. GUILD: 3 Q Mr. Economos, you are aware, aren't you, that 1 4 the NRC took the position that Mr. Nunn's testimony with 5 respect to lamination should be stricken from the record 6 as irrelevant to the quality assurance contention. 7 MR. JOHNSON: Objection. 8 MR. GUILD: Are you aware of that, sir? 9 MR. J O liN S O N : Objection. 10 JUDGE KELLEY: 1 have an objection'. What is 11 the objection, Mr. Johnson? 12 MR. JOHNSON: It is irrelevant to the substance () t 13 14 of the testimony whether we took a position. Mr. Economos doesn't know anything about the legal positions.that the 15 staff took with respect to Mr. Nunn's testimony. 16 MR. GUILD: The answer.will supply the'information 17 of whether he does.or doesn't know, but our position is that 18 the staff's objection to Mr. Nunn's testimony bears on the
'I8 integrity-and validity of this man's~ inspection. report. .They 20 said there is nothing to this and then they'do an inspection.
21 To say there is nothing to it suggests that perhaps they 22 started out with_a prejudgment about what they were. going' 23 to find. I' submit that it is' relevant,
u Let me-make a-transcript reference, if I can,
\_/ 25 Judge.
L 12092 i
-Sim:13-13 1 JUDGE KELLEY: Go ahead. I \_, 2 MR. GUILD: It is 427 of the In Camera transcript ,
3 "Mr. Johnson: Well, it is difficult to address this all in 4- one ball of wax. If this were going through a normal 5 procedure, we would have a chance to make factual representa-6 tions. I move for summary disposition," and so on and so 7 forth. 8 "But it is our feeling notwithstanding all of 8 that, and perhaps it goes to the merits to some extent, that 10 CP-88 is the proper procedure and that it was followed. 11 There is no allegation that it wasn't followed, and that-12 the questions Mr. Nunn raised beyond that are design issues. I3 This is basically our position that it is beyond the scope I4 of the QA contention." That is Mr. Johnson's quote at 427 from the transcript. My question to Mr. Economos is.is he aware of 18 that staff position? 19 JUDGE KELLEY: I will sustain the objection. 20 It seems to me the witness'is here to testify to the merits. 21 Let's talk about the merits. 22 ~ l MR.. GUILD: All right,. sir. 23 - - - We make that an offer'of proof on'the question i 24 I
. g) of impeaching theLcredibility.of the staff's' review of this- \
25 i subject. 1 i I i
J 1209342094 Sim 13-14 g JUDGE KELLEY: I think you point is in the record,
~
2 'MR. GUILD: Thank you. 3 BY MR. GUILD: 4 O Mr. Economos, did you have occasion to talk with 5 Mr. Sam Nunn about this. subject? end 13 6 A Yes. Sim Sue'fols 7 8 9 10 11 12 13
-14 15 e
16 17 18 : 19
'20 21 22 23
. 24 .
O 2. I 0
et 14/1 12095 1 Q When did you do that, sir? 2 A When I interviewed him some-time ago. 3 O' How abou'c November 17, November 16, 19837
. You 4
have to answer yes or no. 5 A Fine. f 6 Did you do that by yourself? Q Who else was there? 7 A No, Mr. Uryc. 8 Mr. Brund Uryc of the Staff? Q 9 A Yes, he was. 10 Q Who else? 11 A That's it. Oh, wait a minute. It was Ms. Billie 12 Garde. 13 Q Ms. Billie Garde and Mr. Nunn? ' 14 A Yes. 15 Q And I was there part of the time. Do you-16 remember that? 4 17 A No, I don't. 18 Q Okay. Let me show you - .do'you recall' discuss-I8 ing the subject of laminations with Mr. Nunn?'
" A Yes, sir.
21 Q And do you recall discussing what you were going 22
.to do to investigate his concern?
23 A Yes.
\
24
- . 0 Let me.show you a diagram. : It's;a sketch made~-
v . -by Mr. Nunn. ~Mr. Economos, let me see if'I can-get.you to-i -l 1
> --:+,- -- -
v , , -, ,
12096 ct'14/2 1 look' at this and tell me if that's a rough representation -- m 2
) Mr. Nunn 'just did that sitting here at counsel table -- of 3
the containment penetration where the weld number 2NI-15 4 and 16 were that are referenced in your inspection report? 5 Is that a representation of the layout, to the 6 best of your knowledge? It has got a note at the bottom; 7 I will ask you about that in a minute. 8 I'm looking at the diagram right now first. 9
'A The diagram, it's a mechanical penetration, yeah.
10 0 It looks like what Mr. Nunn was telling you 11 about? 12 A Yes. I don't know about this note down.here. _p 13 Q Well, I will ask you about that in a second. 14
.But the diagram is all right as far as you know?
15 A Yeah. 16 MR. GUILD: Judge, I would like this marked, 17 and I will make copies for the parties and the Board. 18 JUDGE KELLEY: Could I take a look.at it?- MR. GUILD: I think it indicates what directions 20 . are out and in.- 21 JUDGE KELLEY: Okay. MR. McGARRY: Your Honor,.just so we don't lose track of things, I've got Palmetto Alliance's last number, 24 so we've got four exhibits that have already been. identified t
\> ani received. Can I just put that.on the record so that_we l
12097 at 14/3 1 can catch up? The first I believe was CP-88; is that right, 2 Mr. Guild? N/ 3 MR. GUILD: I'm listening. 4 MR. McGARRY: And that would be 134. And the 5 next one was NCI-17-511. That would be Palmetto 135. The 6 next one was a March 19th, 1976 memo-concerning an audit of 7 Newport News, and that would be Palmetto 136. And the last 8 one I have is CP-89, which would be Palmetto 137. I think 9 those.are the four documents. 10 MR. GUILD: 'And we didn't offer a number, Judge, 11 but we did ask that the informal discovery materials on 12 the lamination issue be received as an exhibit, and that 13 was to be discussed. But we can just assign that a, number. - \' 14 It would be 138. 15 MR. McGARRY: 138. 16 MR. GUILD: Mr. Chairman,- thank you. If we. 17 XXXXXXXX could mark this diagram, then, as Palmetto 139 for identifi-18 cation? 18 JUDGE KELLEY: All'right.- CROSS EXAMINATION 21 BY MR. GUILD: '(Continuing) U Q All right. Now,-I understand, Mr. Economos, that 23 the two welds that were.in question essentially,Lthey are 24
- the condition of the weld _ prep surface orL the end of 'the
" ~
pipe, if you will, the end of .the penetration sleeve is 1 1
12098 et 14/4 1 obscured because the sleeve has been joined with another 2 cylindrical piece of metal. 3 Is that a fair statement? 4 A That's right. 5 Q Now, isn't it true that you and Mr. Nunn talked 6
-about trying to determine the state of laminar indication 7
in that penetration sleeve itself by going-to the other 8 side of the containment plate, since'the penetration goes 9 through it -- it's about two feet long -- and looking at to the condition of the pipe edge on the other side to deter-11 mine whether or not there were extensive laminar indications 12 that went all the way through the pipe, in essence? 13 Did you discuss that? 14 A I don't remember whether I did or not. It may 15 and it may not have come up. And-that's the only. answer 16 I can give you at this point. 17 Q Let me ask you more'directly. Isn't it fair 18 to say, Mr. I:conomos, that you promised Mr. Nunn that you 18 would go and look at'the other side of that penetration and do a -- I think Mr. Nunn's note says here, promised to 21 grind this end and run PT test to find out integrity of. 22 penetration. 23 Didn't you promise to'do that for Mr. Nunn? 24 A Mr. Guild, I would have to look at the record ~' 25 and see - .look at our notes and see what we -- if, as~ you Au
12099 I st 14/5 i say, we promised and we did not promise. ! l (Oj 2 Q How about a tape recording of the session? 3 A That may be in there. I would have to listen to 4 it and find out. 5- Q .You just don't recall whether you promised Mr. 6 Nunn that or not? 7 A That's exactly right. 8 .Q You didn't do that, though, did you? 9 A No, I did not. 10 Q When you got done with your record review, Mr.. 11 Economos,- and you got done' looking at whatever you did look 12 at out there, and in exercising your engineering judgment, ( V} 13 did you go back to Sam Nunn and say: Mr. Nunn, here is 14 what we are tentatively concluding here, and here is what 15 we think? Can you give us a little more help, or do 16 you want to give us some feedback? 2 17 Did 'you do any of that, Mr. .Economos?- Or, did 18 you just publish the piece of paper that said there is no 18 - problem? 20 A No, I did not go back. We just issued ~the. 21-report. 22
-Q All1right. Now, who did you' talk to from.the 23 licensee when you were. reaching your engineering judgment '
24 about the'significanceiof these things? I see:a bunch of 25 names of persons contacted.. Did.you talk'to all of'them?-
r 12100 st 14/6 1 A Yes, sir. 2 Q All right. And who -- who did you talk to on 3 the point about -- well, let me just make reference to the
-4 bottom line. I guess this is your last paragraph before 5 you say there is no problem, no-deviations or violations 6 are identified.
7 Look at the last paragraph on Page 3, where you 8 say: Therefore, any existing and anticipated loads on-9 the Catawba containment'-- in that -- excuse me. In that 10 ' existing and anticipated loads on the Catawba containment
, 11- produce stresses in the pipe that parallel to the surface i 12 - of these discontinuities, their presence would not be 13 expected to compromise integrity, et cetera.
14 Who did you talk to to reach that conclusion, 15 Mr. Economos? 16 A I looked at the specification. I looked at.the 17 drawings and -- while it's not in there. And I looked at 18 the FSARs. 19 Q Did you talk to anybody about that?
# A; No.
21 Q. So, those are the sole sources of your input, if 22 you will, or the basis for..you reaching that conclusion, t 23
. based on your expertise or experience?
24 ' O A. That's right. It's based on the design drawings,
^
25 on the FSAR and fab'rication records and visually inspecting y- .a,. . w, - r,. , ,, - ,-- - -. ., y , ,
12101 et 14/7 1 the steel, or the container. ( 2 Q All right, sir. Are you familiar with the des-3 cription of the stresses placed on a structural member, in 4 this case a plate as XX, YY, ZZ? 5 A Not like a design engineer would, no, I'm not. 6 0 Do you know what I'm talking about when I say 7 that? 8 A I have a good idea. 9 0 Take the vertical axis and call it the XX axis, 10 horizontal is the YY, the through-thickness of the plate 11 would be the ZZ. 1 12 A' Yeah. 13 Q Okay. Using those-descriptions, you don't mean 14 to suggest by your last paragraph that there are no ZZ 15 stresses that play on the containment plate, do you? 16 A Now, are you talking about compression stresses, 17 or end stresses? 18 Q End stresses. You don't cay there are any. In 19 fact, you say the only-stresses on the plate'are XX and YY. 20 A What we are talking about there is significant 21 stresses -- 22 0 'You don't say that. E A - that would come out as a result of heavy 24 structural loads on the containment liner.
'~/ 26 Q That's what stress now.
12102 ct- 14/8 1 A .Now, you are talking about the Z --
', g 2 Q ZZ, okay. But, how come you only talk about the 3 stresses that are parallel to the surface of the --
4 A -That's a summary statement. I didn't go into 5 detail about every vector of stresses anticipated) In 6 other words, as I said before, looked at the FSAR, looked 7 at the drawing, looked at the containment itself, looked 8 at the specifications and drew my conclusion from that. 9 You agree that there are ZZ stresses that play Q 10 on these plates, don't you? 11 A There may be some. 12 Q All right, sir. And those ZZ stresses would tend 13 to have an effect on the steel if the steel were subject o 14 to laminar indications, wouldn' t it?. 15 A No. You have to qualify -- you would have to 16 have excessive, heavy load-type stresses in the -- in thd 17 through thickness or dimension -- 18 Q How about -- I'm sorry. 19 A -- and they would have the tensile -- excessive ' " tensile stresses -- 21 g - Okay. 22 . A -- before.you would-have any kind of indication 23 of the problem that you are talking about. 24 0 -Let me put'it this way. If.I had'a piece of 5
's ~ 25 paper.and put a pressure on it going against the piece of
12103 at 14/9 1 paper, it doesn't take much pressure to move the paper, 2 right? 3 A That's right. 4 0 or if I'm holding it rigidly, to put my finger 5 through it, right? . 6 A That's right. 7 Q Okay. So, it's kind of a compound function of 8 the amount of stress you put on it, how much pressure I 9 put on my finger and the integrity-of the surface, okay? 10 A That's correct. 11 Q Well, they sort of work together. And, in this 12 case you have a lot of laminations in'the plate,_ comparativel:r 13 less stress working'in the ZZ direction'would produce a 14 failure perhaps; isn't that correct? 15 A No, I don't agree with that. 16 0 What's wrong with that formulation, Mr. Economos?L 17 A Because you have to consider also the type of 18 stresses and the extent -- the magnitude of the stresses 19 you are applying over a particular area. M Q Okay.- You-would concede, won't you -- I 21 JUDGE KELLEY: I want to_ alert you that you are 22 between 10 and 15. 23 MR._ GUILD: .All right, sir. 24 CROSS EXAMINATION I-26 BY MR. GUILD: (Continuing)
- tY
12104
\
st 14/10. 1 0 You would agree, won't you, that there are places I 2 on the containment where there are ZZ stresses and there 3 are places on the containment where there are more stresses i 4 in the through thickness of the plate than others? 5 Take, for example, a place comparatively in the l 6 middle of a large plate that has no penetrations as compared 7 to a plate where there may'be a penetration or a heavy hanger 8 load on a plate. There are differing ZZ stresses in those 9 two positions, aren't there? d A That's a fair statement. 11 Q AlI right. And where there are penetrations
- 12 or dead weight loads such as from a - hanger- or something on 13 the plate, the ZZ stresses are great?
V 14 A No, it's two different things you are. talking 15 about. They are not the same. 16 0 I understand. I 17 A You are putting them both in the same sentence. 18 Q Well, you.tell me now, aren't there ZZ stresses 19 that are induced by those kinds of discontinuities in the 8 otherwise, you know, cylindrical form of-the containment? 21 A One, you are' talking about a penetration where 22 you have dead: weight loads and.you are liable to_have some 23 ZZ stresses. O Right. L 25 A But here you.are talking about'a small -- relativel y.
l J 12105 st 14/111 small hanger in a concentrated area. 2 Q Did you make any analysis of what kind of hangers 3 there were out there? 4 A Through the inspection' time, yes. Ten years, we 5 looked at them. 6 0 Where do you talk about that in your inspection 7 report, ZZ stresses that are induced by hanger loads? 8 A As I said before, this is-a summary type state-ment. Q Right. II A And it doesn't' include every inch of the way-that we looked at. Q Okay. A Every area of the containment. 15 0 All right, sir. Are you a certified radiographic film reader? 17 A No, no, I'm not. 18 Q You don't purport that your reading of those 19 films would reflect a qualified opinion as to the absence 20 or presence of these laminar indications or any other-kind i 21
-of indications on those RT film, would you?
l A I have taken the training-from Kodak in radiography ! and during the twelve years in'NRC, I ive taken several train-(~) A.) ing courses in. radiography. During the twelve years, I have j been looking at radiograph. And while I do not have~an ANTC
_ - - - - - - - . _ - - - _ . - - - - . - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ~ - ~- 12106 st 14/12 1 certification as a Level 2 or Level 3, et cetera, that type 2 of thing, I feel well qualified, and the NRC feels comfortable 3 with me looking at radiographs and coming up with interpre-4 tations. 5 Q Well, put it this way. Your view of those radio-6 graphs would not pass muster if you were employed by Duke 7 Power Company and offering yourself up as the person who 8 is certifying the absence of rejectable indications -- 9 A You would have to ask Duke Power that. 10 Q Nell, I'm asking you. You are the one who 11 inspects -- 12 A I can't answer for Duke Power. 13 Q You are not certified in -- 14 A No, I'm not. 15 Q -- doing radiographs, are you? 16 A I don' t have a Level 2 certification. But, 17 7.m telling you what I have. 18 O Right. I heard you. 19 A Fine. E Q Okay. You spent thirty-six hours on this project? 21 A That's correct. 22 Q Is that all your time? 23 A All my time. 24 Q How much of that time was reviewing records, Mr. 9 25 Economos?
12107 st 14/D3 A I don't know. 2 How much of that time was talking to licensee 0 3 personnel, the ones listed on the -- 4 A Enough time for them to retrieve certain records 5 for me. 6 How much of that time was talking to Mr. Nunn? Q 7 A During that time? 8 Yeah. Q 8 A I -- none. 10 Q Okay. How much of that time was actually look-11 ing at welds? 12 A A good percentage of the time. 13 Q How much? Half the time? 14 A I would say seven, eight hours. 15 Q Okay. Did you seek any expert guidance from 16 anyone else at the Commission Staff and say NRR about the 17 design issues involved in laminations? 18 A No,. sir. 19 MR. GUILD: Mr. Chairman,'that -- my time is
" over, so I will pass the hand-to Mr. Riley, then. Thank 21 you.
22 Jim follows 23
- 24 O ,,
. ,. -- - . .. . ~ _. . . _. . . . - .-.. . . ..._..,. . .-..
T15JRB jrb: f1s Suo. 12108 t 11 1 BY MR.-RILEY: 2 Q Mr. Economos,fdid I understand you to say 9 a f- that in-your experience you worked on stainless steel? l l
'l
,' 4 A' Yes, sir. ' 5 And. alloy steel.. 1 6 Q And alloy steel-- 7 A And tool steel. 8
-g- Tool steel?
4 8 { A~ Yes, sir. { 10 i- Q Are you familiar with the. composition chemically II of mill scale? 12
-A Of what?
1 1 13 Q Mill scale? 14 A Mill scale? 15 . Q' Yes? j 16 L A' I'm not a scale expert, if that's what'you're II
' talking about.
i 18 .i Q Are you familiar'with-- 18
.A Basically, yuh.-
I # Q. _You; pointed out" earlier that'in the-electrical 4 21 heating. process,': talking about. degassing, you have less . 22 tendency for. inclusions?-
. 23 -
{ A That's correct. t
. 24 ~
- g Q- 'In the rolling processEfor?this steel--is rolling- -
8 dEne'infan inert-atmosphere?. '[ ~ ,
..:-, , - . _ I .,,_.._m._ , _ . . . , . _ . - , _ . , , , , , , ., ,,
15-2 , 12109 1 A No. 2 Q Will stainless steel oxidize under rolling 3 conditions?--and form a scale? 4 A Yes, sir. ' 5 Q All right. 6 Will ordinary steel also do it? 7 A That's right. 8 Q All right. 9 Now, in the rolling process one includes a thin-10 layer of oxide; how thick will that layer have to be to 11 interfere with structural integrity of pieces of steel at 12 Catawba? s 13 A CA All right, first of all in stainless, doing the 14 het rolling as we talk about, or, to go back, when you 15 are rolling tne slag, you don't concern yourself with 16 controlled atmosphere. 17 Basically when you are looking at that steel 18 ~ you couldn't, for all intents and purposes to a layman, 19 you wouldn't be able to tell whether it was carbon steel 20 or stainless. 21 Now, when you get into the alloy areas, or mild 22 steel, low carbon steel, that steel is rolled in at rolling' 23 mill in the--in open air, while it's still hot. 24 Now, you may have some fine scale ~on the surface. 'l (,,) 25 which eventually'is pickled; it's pickled out during the
7, v -
~
t 'R]i 15-3 "?& < a
\
1
. 12110 I
pickling process. g , S ., s 2 v' And'thisa{pliesalsotothestainlessmaterial. ,
.t '
'h ,
3 ~ 4 But*that's not done intil way at the"end.s
> 4 If'you do have severe mill scale you--first of 5 '* '^
all, you get-i't g out before you get s to the slag n condition, 6
.but ifyoudohaveitintheslagcondi) ion, they perform 7[ aprocesswhich'dscalled"scarping".
, . ~
i 8 ' Q I' don't wish to interrbpt, but, the , thing I 8 was4 inquiring about was the presence of he scale-type icomposition internally to Meel making for lamination? 11 p go, sir. It's highly unusual to get that type 12 of a lamination ' of the type that we're talking about through I8
, . ,~',
the rolling; process. " %~' ' g , II ' s^ . What if it does happen?
, Q J
~ 15 - t A oI would say inymy own--my opinion and background,
, , ~ , _
16 would say that'you would be least-likely, very,.very--I 17 . T would say'-no: c it pouldn't haopen. ,' % v 18
~ A< .
3 Jf I"Were ' to ' have ,to ' bet . I wc,u.ld say no, it
~
wouldn't happen.3 3 g5 s Q 'If it did happen,do~you think it'.would be apparent A
' 21 by looking at , ground and the prepared steel', that^it would 22 s -
be visible in the same way that the laminations-- 23
.A- You would*probably pick,up mill scale waysuo 24- ' -
-in the nearest--at 4j
'or ~^ near the surface of the plate, if- that v ;
. 25
+
is the.. case. ,
. a Vx , s
( y .
15-4 12111-A 1 And that, we address it as mill scale, not a i h s_/ 2 lamination. 3 Q Incidentally, have you ever welded this type of 4 steel? 6 A oh, no. 6 Q When you were in the steel industry did you roll 7 to a range of--what was the thinnest steel that you rolled 8 to? 9
. Did you roll to as thin as three-quarters?
10 A In stainless we rolled it down to a razor blade 11 material. 12 Q Razor thickness. 13 Now, when we talk about these attachments, is I4 o the attachment essentially normal to the containment plate 15 and secured there by a weld (demonstrating)? 16 MR. GUILD: Mr. Riley, indicating a right angle? 17 4 BY MR. RILEY: 18 Q I am indicating-- - 18 A A right angle. 20 ' Q I am indicating a perpendicularity and a-right~-
- 21 angle..
22 Now is it true that in this situation that if Z3 there is.any-load here (indicating), if there's any weight-24 - ~ here (indicating), that'you'll have a rotational--you'll
~
" have a' torque applies here-(indicating)?
i
15-5 12112 1 A yes. 2 Q , Is it not true that that will exert a tendency 3 to separate layers if they are layered and compress them? 4 A If the stress was of such-a magnitude, that's 5 right. 6 Q Right. 7 A And if you had--yo,u would also have to have a 8 certain type of lamination, a gross lamination; the steel 9 would actually have to be almost separated, away from it; 10 the lamination would have to be out in the--near the surface 11 before it would--what you're referring to. 12 Q Right. 13 And you just referred to loadings on these 14 { brackets as light loading;1could you translate that into \ 15 the number of pounds or the degree, the number of foot 16 pounds that would be exerted there? 17 A No,.I could nob. 18
'Q Are some of these brackets reaching' appreciably 18 '
away from the containment? 8 A What do you mean.by " appreciably"? 21 Q Well-- 22 3 What.is " appreciably"? 23 Q --I would say that if it's within 6 inches of 24 being appreciable, I'would say 3 or.4 feet or more, it's x 26 ' appreciable.
'r, :, q IIh n
.t
.: (
t(s
- 15-6 12113 1
A No, it's not that. O(s / 2 Q . No braukets reach that far? 3 A I wouldn't think so. I would--no, I wouldn't 4 think that they do. They may be some, but offhand I would i
+ 5 say no. I wouldn't expect to have some three feet 6
coming off that. 7 Q You are familiar with the notation per torque 8 of foot pound? 8 A Yes. 10 Q And that the further out the given load is, the II greater the torque can be? A Yes. I3 i (g~3-
, Q How many radiographs were performed on the containment welds?
A All of it. 16 Q Yes. How many in numbers?
'17 A You'd have to count the plates, you have to count
'I a seamer for every--in that whole containment; you'd have I'
to count the number of plates and multipt:f .t times-- 20 Q Is it a very large number? 21 A 'Oh, heavens, yes. Q How many did you.look at? A' .How'many-did I look at? 24
.Q Yes?
.At this time-I' looked at'the penetrations, welds,.
'A'
15-7 12,114 1 that Mr. Nunn referred to, the sleeves. , I i Q , All of them? 3 A The two--the radiograph of the two sleeves, 4 the two penetrations, 406 and 407. Anyway, 2NI-15 and 5 2NI-16. 6 Q In other words, the--your examination of radio-1 7 1 graphs was specific and not a representative sampling 8 of the welds? 8 A That is correct. 10 Q And that would also apply to these brackets that 11 are welded in other places, you did.not examine radiographs 12 of that? 13 A For the brackets? 14 Q For the brackets? 15 , A The brackets are not radiographed, sir. 16 Q All right. 17 Well, I mean the welds. securing them? 18 A That's.what I am saying, too; chey are not--those 19 do not require radiography.
# ~
f Q They don't require it? Okay. 21 Would you accept some earlier--testimony that you 22 cannot detect laminations, per se, unless they have slag 23
'nclusions i by X-ray?
24
. A Yes, t 25 Q Did you perform any ultrasound tests;on any of the
15-8 12,115 1 material in question of the possibly laminated pipes here? () 2 A I didn't, but I saw records where UT was 3 performed. 4 Q How extensive are these records? 5 A Of the two penetrations that we looked ~at. l 6 l One of them was repaired and unless--I'm pretty 7 sure that that area in question was.UT'd and the indications 8 mapped. 9 Q All right. 10 Now, with respect to pipes that don't have Il penetrations, is there any UT done on them? 12 A No. ()
%)
13 Q You described making magnetic particle examination; 14 would magnetic partical examination on the surface of a 15 plate show anything about lamination on the. interior? 16 A No, sir. 17 JUDGE KELLEY: It's about ten-to, Mr. Riley; do 18 you have much more? 19 MR.'RILEY: Thank you. 20 JUDGE KELLEY: Do you have some questions, Mr. 21 ( Kent? 22 MR. KENT: I do. 23 JUDGE KELLEY: We had a half an hour allocated,- 24 ~
]
7g but.you can take ten minutes.
]
26 4 MR. KENT: Okay. ,
.15-9 12,116 1
BY MR. KENT:
-( ) 2' Q Sir, do you know of any violations of any 3
applicable code, anywhere at Cattwba? 4 MR. JOHNSON: Objection. 5
. JUDGE KELLEY: Just as a general proposition I l
6 think questions should be focused-- 7 MR. KENT: Relative to liner plate and places we 8 have been discussing? i 9 THE WITNESS: Would you rephrase that? j 10 BY MR. KENT: 11 Q Do you know of any violations of any applicable 12
, codes relative to liner plates and the area that we were <
13 discussing today?--that still exist, or anything that has 14 been documented differently than what it.should have been 15 documented as? 4-16 A I lost you. 4 17 I lost you. _ ll 18 There may have been--now, historically spesking? 'l 19 Is that what you--
- 20 Q I am not talking about historical. I am--to your 21 experience with liner. plates out here"at Catawba, Units.1 M .q and 2, and related areas,~do'you know ofLany violations 1 l
23' of any applicable codes at any time? 24
/~N .
A
- Well,E th'ey started building--unit 1 I think was l L)_ -
24 -
-in76. J 1
i
]y
15-10. 12,117 1 And you want to know if there were any violations 2 since--from '76 to '83? 3 Q Going back to the very beginning of construction? 4 A I couldn't answer that. I--it--there could be; 5 there could be; but I have not done a detailed record 6 review of the entire construction program of the vessel. 7 Q Then do you know of anyone who knows of any 8 violations of any applicable codes out there in Units 1 and 9 2 and adjacent to them? 10 MR. JOHNSON: Your Honor, I would object to this 11 question. It seems to me that it doesn't deal, focus in 12 on the issues that are in question here. 13 MR. KENT: Just relative to the issues, 14 THE WITNESS: Well, it's pretty hard to interpret 15 your questions. 16 MR. JOHNSON: And it's also a request for hearsay-- 17 MR. KENT: That's a valid question. 18 MR. GUILD: Mr. Chairman, I think the question 19 as it's put is clear enough, and that is.' does Mr. Economos 20 l know of any violations of applicable codes limited to 21 liner plate and penetrations--does h'e know of any?
- l. 22 If he doesn't know of any, the answer is a simple l .
23 no. If he knows of some, we'd like to hear about it. l 24 l MR. KENT: Yes. 25 JUDGE KELLEY: I think it's too broad. I -mean, 1- ~ _
. _ _ . ._=
15-11 12,118 I ! we came here today and we're talking about some particular '
.O 's ,) 2 complaints Mr. Nunn brought forward. He can't answer that 3
question. He can't go back ten years. 4 You've read his report. You know what he's 5 talking about. Ask him about that. 6 Sustained. 7 BY MR. KENT: 8 Q. Do you know, sir, of any RT. falsification or any 9 other NDE falsification? 10 MR. JOHNSON: Okay, I object to that, too. I 11 JUDGE KELLEY: Sustained. 12 MR. GUILD: That's limited to the containment 13 liner. U,o 14 MR. KENT: Containment liner plate and related 15 areas that we're speaking of. 16 JUDGE KELLEY: Sustained once more. This man isn't 17 here to testify about'that. 18 MR. GUILD: Mr. Chairman, the man represents 19 that the RT record review should stand as evidence that-20 there are no uncorrected laminar problems in weld prep 21 surfaces.
-Now, we maintain that that evidence may not be 23 credible i5 there is: contrary evidence of--that impugns 24 L- .x the integrity of that system.
p: %, 26 t Now, we have a contention'in here, or an-issue-in i
15-12 12,119 1 here about the adequacy of the radiography. (O s/ 2 JUDGE KELLEY: I'd be happy to stand corrected 3 if I am wrong. I didn't know that this gentleman was talkin a 4 about the entire history of radiography on this containment. 5 MR. KENT: Well, relative to what happened on 6 the Alaska pipeline, I think it's very germane question. , 7 JUDGE KELLEY: Could you point me to the portion 8 of this man's' report which'is germane to this question? 9 MR. GUILD: Well, let's find'that, Judge. 10 We have him saying--okay, I'm just taking the two penetratior ,s 11 he looked at--because he only looked at two things--two 12 pieces of_ record, packets; okay? [\_/') 13 THE WITNESS: Um-um, I also looked at the spares. ' 14 MR. GUILD: 'I don't want to get into an argument, 15 Mr. Economos. 16 Two penetrations. And the two penetrations i 17 4 record packages or the two that Mr. Nunn mentioned; all 18 right? 18 THE WITNESS: Yuh, I'm with.you so far. i MR. GUILD: Now, he represents that the RT d 21 results reflected in those record packages should stand 22 I for the fact that there are no uncorrected laminar defects. 23 That's what he says in his report. 4 3 JUDGE KELLEY: Can you tell me where that is? 25
'MR. GUILD: Let me-go~back~and-find it.
l
( ! 15-13 12,120 l 1 (Pause) (h Q 2 Let's look at page 2, the last paragraph. 3 JUDGE KELLEY: -All right. 4 MR. GUILD: Then--okay, I'm trying to find--okay, 5 the last sentence, and it goes on, also the review reveals 6 that following several repairs for the fabrication type 7 defects and lamination type discontinuities, both joints were 8 radiographed and found acceptable per ASME code requirements. 9 The man--let's move on to page 3 now--the man 10 relies on the results of radiography to represent that there 11 are no uncorrected laminar defects--as to those two places. 12 JUDGE KELLEY: Okay. 13 MR. GUILD: So it seems to me it's a fair 14 question, Mr. Chairman, for us to ask: does he know of 15 any instances where NDE techniques--where the integrity of 16 NDE techniques is questionable, falsification--does he? 17 JUDGE KELLEY: In the entire history of when 18
--the instruction of-Unit 1 and Unit 2?
19
-MR. GUILD: Sir, if he knows of any; that's the-
^
" point. I mean, if the answer is he doesn't know, that would 21 be fine.
22
-But our question is--you are gol'ng to make a. finding 23 on this that's going to say there are no problems anywhere 24 . ,-w) in the containment. And he looked at'two, things. -(v a JUDGE KELLEY: I'm'not aware we're going to make Q ._ __ _
I l 15-14 12,121 ! i 1 any such findings. 2 MR. GUILD: All right. 3 JUDGE KELLEY: I assume we'll make a finding 4 on Mr. Nunn's concern. I r:ertainly haven ' t looked at the 5 entire containment, nor do I intend to. 6 Objection sustained. I Please narrow your questions. 8 BY MR. KENT: 8 Q All right, sir, you worked in steel for a number 10 of years; would you please tell me the maximum carbon in 11 mild steel in percent by weight?--relative to the areas that 12 we're talking about here today, in. mild steel, would you 13 tell me the maximum carbon that is in mild steel, the range 14 in mild steel; and then would you tell me the maximum 15 carbon in medium carbon steel? 16 MR. MC GARRY: M I L D? 17 MR. KENT: MILD, mild steel. 18 BY MR. KENT: 19 Q Will you tell me the carbon range in mild' steel 20 , and--
=21 A Mild-steel, you can have anywhere'from -
.0, .05, 22 to, say,.a couple'of. points.
23 Q To where, sir? 24 - A' I say, from .1 or practically no carbon,'all'the ()' N' , way up to maybe-2 points. i r
15-15 12,122 1 Q 2 points? Is that 2.0 percentage? 2 A. Yuh- .2, .2. 3 Q 2 percent, sir? 4 A Yes. 5 Q 2 percent total? 6 A 2 percent. I Q Let me mention to you that mild steel runs 8 from five-hundredths of 1 percent to-- 8 MR. JOHNSON: Objection. 10 MR. KENT: --to 30 hundredths of one percent. 11 MR. JOHNSON: Objection. 12 THE WITNESS: I'm in the ballpark, that's what 13 I told you. 14 JUDGE KELLEY: We have an outstanding objection. 15 Gentlemen, when somebody--a lawyer says, 16 "I object," everybody else has to stop; and then we'll hear 17 from the other lawyers; and then the Board will decide. But you have to stop when this whole sequence starts. 19 Mr. Johnson? MR. JOHNSON: I object, he ought to make his state--
'ments in.the form of questions rather than to start 22 '
testifying.about the_ qualities of various' steels. Okay? MR. KENT: Well, I=want-to determine his 24 expertise. D 25 MR. JOHNSON: .. Well, that.'s fine,-but if you want
15-16' 12,123 1 to do that, then ask him questions. ("h
\m,) 2 M2. KENT: Well--
l 3 JUDGE KELLEY: All right, now it's my turn. 4 Do you have any comment, Mr. Guild? 5 MR. GUILD: Oh, yes, I'd say, it would save us a 6 lot of time, Judge, if we'd just understand it--is he aware 7 of that in fact being the range. Mr. Economos answered the 8 question. We're just playing word games here. 8 JUDGE KELLEY: Well, I think it's a little more 10 than a game when we get into a rather long statement of 11 fact, and then only to find a question way at the end.
- 12 MR. GUILD
- Are you aware mild constitutes .05 t 'S 13 to .3?
U 14 THE WITNESS: That's what I said before, .25. 15 MR. KENT: You said 2. 16 THE WITNESS: No, no, .25; I said from practically 17 nothing we could go .01 to-.25. And that's generally I8 considered mild steel. 19 Now, you can go another half a percentage e _at 20 and it isn't going to make any difference.. It's still I within the range. 22 BY.MR. KEND: 23 Q Okay. r-24 f What would be the maximum in any steel'for carbon,
\~~/
25 l then, as a maximum in solution before~it goes-into I i
- - c--
y.. - - . , . , - - - - , - . -
- 15-17 12,124 1 vapidic form?
2 A .8 probably. 3 What? Q 4 A .8 probably. 5 That's right. Q 6 A .84, somewheres around there. 7 No, that's incorrect. Q 8 A What is it?- 9 JUDGE KELLEY: Gentlemen, please! You can't 10 argue with the witness. If you're going to be a questionner, , 11 ask questions. 12
-If you don't like his answer, that's fine.
13 MR. KENT: Okay. 14 JUDGE KELLEY: That's going to be in the record. 15 BY MR. KENT: 16 Q What is your opinion of elongation in the zz 17
. direction, the through-thickness direction, in these areas 18 -
we were just talking about here now today-- 19 A Um-huh? 20 Q --do you agree or disagree that elongation is 21 comparable in the zz direction as it is in the xx direction 22 or in the yy direction? 23 A' No, it's not comparable.- 24
- p. Q What would be be percentagewise relative to the k,)
25- others? Would it be--
15-18 12,125 1 A I can't give you percentagewise, but it's much
.' 2 less than the zz direction.
3 (Simultaneous dialogue between Mr. Kent and the 4 witness) 5 REPORTER: One at a time, gentlemen, please. 6 JUDGE KELLEY: Now, you've got two more minutes 7 here and you can use them, but let the witness finish what 8 he has to say. 9 Go ahead,.Mr. Oconomos. 10 THE WITNESS: Okay. 11 In the zz direction, or the through-thickness 12 direction that you're talking about, it would be significant] y. 13 less depending on the cleanliness of the material and 14 the grain size of the material. 15 BY MR. KENT: 16 Q Okay. 17 Were you aware that failures-have occurred due'to 18 objectionable laminations? 19 A What have occurred now? 20 ~ Q Are you aware that failures ~have occurred due to 21 objectionable laminations? 22 MR. MC GARRY: I can't understand. 23
.MR. JOHNSON: Objection.
24 4 ' Would you pleas'e pin it down to.something?
~25 Otherwise it's~ objectionable.
, ,. _ _ _ _ _ _ _ _ _ _ _ _ _ _ ______u--~-----=---- - - =- d
15-19 12,126 1 MR. KENT: Yuh. I 2 BY MR. KENT: 3 In plate or pipe, are you aware that failures Q 4 have occurred due to objectionable laminations? 5 MR. JOHNSON: Objection. 6 JUDGE KELLEY: I think it has to be tied more 7 directly to the issues here. If you want to find out about 8 lamination--I'd certainly like to know, if you know about 9 lamination failure in a nuclear' power reactor? 10 MR. KENT: There have been many, many-- 11 JUDGE KELLEY: But if it's not tied in some way 12 to this case, he can't answer the question. 13 f~'i O MR. KENT: Okay. 14 MR. GUILD: Judge--Judge, here's the question: 15 And if there's an objection, we'd like to be heard. 16 It seems to me that we're talking about metallurgy, 17 that it has to be viewed as a science without the specific 18 - application in order for us to establish the general 19 principle of the plate. 20 Now, if it's the Staff's position and the 21 Company's position that laminar' indications in steel plate E are not a problem--okay? Now, it seems to me the' question 23 as posed'is fair; .and that is:- 24 Is he aware of any failure in plate duxe to fs 1 M laminar indications? Either he is or isn't.
. _ _ ~ _ , __
15-20 12,127 1 JUDGE KELLEY: The objection has been made it's 2 too broad, isn't that the basis of the objection? 3 MR. JOHNSON: Yes, and--he's also mischaracterized 4 the record, but I'd like him to make a statement that 5 Mr. Economos can answer in terms of the question that's 6 before the Board, laminations on those particular welds. 7 JUDGE KELLEY: Objection sustained. 8 MR. KENT: Okay. 9 BY MR. KENT: 10 Q You made the statement, sir, that electric 11 furnaces as used in this type of steel, earlier, in this 12 room, just a little while ago, would you say that electric 13 furnace steel is more common than, we'll say, open hearth? 14 A In--again the answer is too broad. What are you 15 talking about? 16 Are you talking about the nuclear industry? 17 Q Well-- 18 A Or are you talking about application at large? 19 Q The material as manufactured here, it was from 20 electric steel--from your comments--are related.to that, 21 that most likely it was electric furnace steel. 22 Are you maintaining that that steel that we are 23
. discussing today in these applications came. essentially 24 form electric furnaces and not from open hearth or from V) 25 we'll say other steel-making processes?
. . . . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _______________u
15-21 12,128 f 1 A This type of material in the nuclear industry ( 2 most likely came from-- 3 Q Do you say most likely, sir-- 4 MR. JOHNSON: Excuse met 5 Would you please let him finish his answer? 6 THE WITNESS: Most likely came from electric. 7 BY MR. KENT: 8 Q Would you-- 8 JUDGE KELLEY: I'd like to just interject a note 10 that we can an extra ten-plus minutes; now,'if you're going 11 to take a little bit more, it's going to have to be 12 borrowed rather than donated. time. 13 You want to borrow some? 14 MR. GUILD: Okay. 15 JUDGE KELLEY: Okay. 16 BY MR. KENT: II Q Now-- 18 JUDGE KELLEY: Sir, I.have a question: do you want 19 some more time? 20 MR. GUILD: If we could have about five minutes, 21 Judge? < JUDGE KELLEY: Five minutes? Okay, go ahead. 23 BY MR. KENT: 24 O 25 Q There was a comment on Mr. Nunn's sketch here, where the laminations weresfound here on his sketch. My I'..- .. ..m '
.r.. .. l
....s _ _ _ . __ - -- - - - - - - - - - ^ - ~ - -
1 ! 15-22 12,129 l l i 1 question to you, sir, is: why wasn't this essentially l I 2 defective steel replaced with adequate steel? j 3 A Are you talking about the two penetrations? 4 Q Talking about the sketch that Mr. Nunn gave you? 5 A Yuh? 6 Q And on that sketch he said over 30 laminations 4 7 down here. 8 My question to you, sir, is: why wasn't this 9 essentially defective steel replaced with adequate steel? 10 A First of all you have to deem that as defective 11 steel. And it's not defective steel. 12 It meets every ASTM specification that it was (s 13 purchaced to. We have the mechanical testing. We have 14 the chemical test. And the material definitely is not 15 defective. 16 So I can't answer that question. 17 Q You can't answer it. 18 Were you aware that through connections are 19 warranted in certain applications where tension is on the 20 base of the plate in the zz through-thickness direction, 21 in example, in street structures-- 22 A Street structures? 23 Q Yes, where you nave structures like cooling waters, 24. a pipe, and it supports two of them' things of this nature?
'~# #
MR. MC GARRY: I'll object to that question as
15-23 ' 1 being irrelevant. r\ \ ,) 2 MR. KENT: Well, this is very germane to the 3 laminations, because there are numerous places where they 4 will not allow the plate to land on that plate that could 5 have a lamination back of it, they cut the plate and run 6 the section through it, and weld it on the back side. 7 MR. GUILD: Can the witness answer the question? 8 JUDGE KELLEY: It seems somewhat removed, but the 9 witness can answer it--do you know--do you know about 10 street construction? Can you answer the question? 11 THE WITNESS: No, I don't know anything about 12 street construction, sir. [~ V
} 13 It's called " strength" construction.
14 JUDGE KELLEY: I misunderstood, I thought-- 15 THE WITNESS: STRENGTH. 16 JUDGE KELLEY: Then I misunderstood. And I don't 17 want to misstate the question. 18 BY MR KENT: 19 Q Are you familiar with what through connections 20 are, sir? 21~ A Through connections? 22 Q Yuh? 23 Where you actually cut the plate and run the _ 24 structural member through~it? 25' A I can't answer that.
. . - 4
15-24 12,131 I Q What is your opinion on all steel welds in 2 isotropic conditions? MR. JOHNSON: Objection, that doesn't seem to be j related to this-- 5 MR. KENT: Well, it is related to this, and is O related'to laminations; yes. 7 l JUDGE KELLEY: Would you explain to the Board 8 why that is so? MR. KENT: Yes, because I would like to-- 10 (Messrs. Kent and Guild conferring) MR. GUILD: .He will rephrase the question. 12 MR. MC GARRY: Your Honor, I know we're almost () finished. But I have been-sitting here trying to make a 3 motion for reconsideration. 4 15 I think it is clear we are wasting a lot of time 16
--this gentleman is not qualifiad to ask the questions; 17 b) he is not prepared; clearly he is not prepared; he's 18 wasting the time of this Board and the parties.
19 I move this cross-examination be halted at this 20 point, your Honor. ond T15 REfls 21 1 . 22 23 24
't 25
+w e e + - M *gm 3
TAKE 16 PAGE 1 12132 1 MP. . GUILD: That is all well and good, Mr. Chairma n.
-s 2 s
We are now at the end of our rapidly evaporating time . 3 But you'know, it is funny. When Applicants turn out a panel 4 of eight witnesses to tell us we shouldn't be worried, 5 we endure hours of them talking, but when we find somebody 6 that might be a little bit helpful to our position and 7 might just offer something to this Board on the safety 8 significance of laminations, suddenly we get Mr. McGarry 9 all insensed about whether or not we are wasting time, 10 JUDGE KELLEY: Mr. Guild, Mr. McGarry, the 11 minute or two that we alloted, I think the most sensible 12 course here is to just finish up, Why don't you go ahead. 13 BY MR. KENT: f% ( ,) 14 Q Can I ask you, sir, what your definition of 15 anisotropic conditions are in -- 16 A What do you want to know about -- 17 BY MP.. GUILD: 18 Q The question is, can you define the term. 19 Mr. Economos? 20 A Yes. It is the ability of the material or the 21 properties.of the material in various directions or-roll, 22 whether in the1 longitudinal, the transverse, or the-2 through-thickness dimensions, the properties of the 24 material in the various dimensions, whether they are (N 25
\j - uniform -- or the opposite would be ' uniform. They are.
12133 16/2 1 anisotropic or they are uniform. BY MR. KENT: (7 s) 2 3 0 What decay would you have in the zz direction 4 where you have a lamination in this area? 5 A What decay? 6 Q Yes,decayin'/ cay l elongation,decayin 7 strength, percentagewise? 8 % It would be significant. If you have a g pronounced lamination in the through-thickness, if you 10 applied a force intention in the through-thickness 11 direction and you do have laminations in there, your 12 strength would decay, as you call it. There is nothing 13 new about that. 14 JUDGE KELLEY: Your time has expired, If you 15 want a final question, go ahead. 16 MR. GUILD: Mr. Chairman, may I have five minutes
, 17 borrowed, and I will wrap this one up, please?
JUDGE KELLEY: Okay. 18 19 BY MR. GUILD: 20 Q Mr. Economos, I wanted to understand in a 21 little bit more detail, if you could identify,-please, sir, 22 what records you reviewed with. respect to the ultrasonic mapping of laminar indications in containment plate steel 23 l L I 24 and in the penetration-steel?' { 25 A Mr.. Guild, it is in the report. .
12134 16/3 1 Q How about helping me find it and maybe 1"'N ( ,) 2 answering the question, saves a little bit of time if it 3 is in there.
~
4 A When I say, "The record review of the weld 5 process control records, M-4A, indicated the lamination 6 indications were found in the weld prepped surface of 7 both containment penetration sleeves." All right. 8 one of them -- I can't tell you which one I think it was 9 15-1 -- had these rejectable or had these laminations to which were investigated by UT and they were mapped. And 11 I think the results are in that package that you have on 12 215-1A.
/T 13 Q Is that the only mapping of laminations-that D
14 you reviewed, records of map laminations? 15 A Yes. 16 Q How many records of NDE examinations at 17 Catawba for the containment plate reflect the existence 18 of laminar indications l Mr. Economos? 19 A I would.have to go back and start from day one-20 and follow it each package that you have over there in 21 order to come up'with answer. 22 Q You didn't do that, did you? 23 A No. 24 Q Have you started to do it? O
.25 A No.
i-
- 16/4 12135 1 Q Why haven't you done it?
() 2 A It was outside of the scope of the inspection. 3 Q The scope that you set? 4 A of this particular inspection. 5 Q The scope that you set? 6 A I followed the allegations or the contentions 7 of Mr. Nunn. 8 Q He says there is rotten steel throughout the g containment. 10 A And if I had found problems in that area -- 11 in other words, if I had found the laminations that he 12 talked about in t'es welds and they were still there, 13 believe me, we would have expanded the investigation. We [
; 14 did not find them. Therefore, I saw no reason for 15 expanding the investigation.
16 Q Let me ask you this: 17 A Go ahead. 18 Q How were those laminar indications ~ originally 19 found in the weld that you did look at? The two. 20 A By radiography and UT. 21 Q When, before the weld or after the weld? 22 A .At the. time'of the fabrication, after'the
- 23 weld was fabricated.
7 24 .Q- They weren't found on the surface of the weld ( )
'N /
m- prep area before the weld was made, were they? i l
16/5 12136 1 A I don 't know. (% q) 2 Q Did your record review reflect that they were? 3 A No, they did not. 4 Q They reflected they weren't even found until after 5 the weld was' completed, correct? 6 A That is correct. 7 Q And then all of them weren't found on the first 8 shot, were they? 9 A I don't know. 10 Q Well, did the record review reflect that they were? 11 Didn't it take several shots to find all -- to chase 12 all the laminar indications? i 13 A Let me have a look at the 215 -- 14 Q You don't recall? 15 A No, I don't. 16 JUDGE KELLEY: Let's give.each'other enough 17 time, gentlemen. 18 MR. GUILD: I will do that, but what I am 19 interested in is, won't you agree, Mr. Economos, that it 20 took several shots to find'all of the laminar indications 21 =even on 15-1, the'one that you looked at that_hadn't been
~
, 22 mapped for.UT? Won't you agree with that?
I j 23 THE WITNESS: On recollection, I would say no.- , 1 ' 24 MR. GUILD: Okay. Let's find out. f%, -
. M- Mr. Chairman, I appreciate the time this may 1
1 i
16/6 12137 1 take, but it would be interesting and helpful, I think, if 2 I could establish this particular point if I can get my 3 hands on it. 4 (Pause.) 5 MR; GUILD: Perhaps I can ask for assistance 6 from Applicants, if they have that package. 7 MR. MC GARRY: We have it, but we are looking at 8 it, quite frankly. l s MR. GUILD: a Well, gee, I hate to interrupt or 10 interfere -- 11 MR. MC GARRY. It happens to be our document. 12 MR. GUILD: It is your nuclear plant, too. 13 MR',' JOHNSON: O I think I have a copy of it.
's 14 What are you referring to?
15 MR. GUILD: The weld in question. How about that? 16 Do you have that, Mr. Economos? 17 THE WITNESS: 3 I-have it in front of me. 18 Okay. Now, I have to get back -- 19 BY MR. GUILD: 20 0 While you are looking at it, let's hear the 21 question on the table. How many welders worked on zt repairing that thing and how many times did. they have to 23 reshoot it before they finally got it right, before they 24' finallyLfound all the laminar indications that you'say have-t (m () 25 been fixed now in that particular weld?
..m I
.L,+ <
l .,_Q, l 16/7 . e
.m 12138
(
- l 1
A Whild I answer th'at, can somebody research ( \; !( 2 and see how mAny' times this thing was shot? r, -
~'
c 3 I' can 't do both. 4 0 EI cthought it would all be in that same packet
- s
+
\ 5 right ther.o. - -
6 A It is, but it takes a little time to -- you 7 would have to look at this,cthinq and' see how many times 8 it was shot and how many times it was repaired. 8 JUDGE KELLEY: Could that be just supplied
'10 '
later on today? . - . i , . o ( 11 MR. GUILD: \Would you accept five or six? Mr. 12 ~ Nunn says five or six times? g -t 13
. THE WITNEOS: Five or six what?
14 BY MR. GUILD:
- 4
, ,s \
15 0 Five.or six times
. s,
_ it was shot before.they finally
.w . ,
16
' tracked all the lami6aritndications?
s U],
- a, A No,s L don 't agrSe with: that.
1 18 ' i' 1 MR. GUIL'D:" Well,,why don't we do that, Mr. Chairma n, 3 ,
.V 19
[why don't we have( him look and maybe' supply that information 20 '- *
.1ater. -
> [, .
.e s , q ,
21 JUDGE KELLEY: Is Mr. Economos3Eoing to be-22 3round the rest of the afternoon ^and can figure it out later, 23 ' come-backan{.tell us?: g 24 - 4 , THE, WITNESS:- Yes.
.J %
25 .
.4 J: .
-BY MRPGUILD:: . .; N JN ' ' 't
,~ 3,*K .
,0{\ . , , t :' U -
;$. : ,- , - m'y
, , ,, 3 b -t -
I 16/8 12139 1 Q My point is this, if that is reflective 2 V] t'" 3 of the experience of finding laminations, Mr. Economos, how -- and they don 't do an RT on a weld prepped surface 4 to look for laminations before they weld, how do you have 5 any confidence that they even found all of tne laminar 6 indications that are right at the wold prepped surface , 7 in all of those plabs3 out there in the Catawba containment? 8 How do you have any confidence of that? 9 A The code does not require you to take an RT 10 on that weld prep before'you do a weld. 11 Q That is not the question. The question is, 12 how do you have any confidence -- 13 A O
\/ 14 That is the answer to the question.
Q No, sir. How do you have any confidence that 15 there are not rejectable laminar indications even on 16 the weld prepped surface if you haven't done that? 17 A They prepare the weld. They do the weld prep. 18 In terms of angle, in terms of crudiness, and in terms of 19 the visual inspection. If you do not see anything there of 20
. that ' nature, not visible -- not open to the eye 'cn visible, ,
21 then you go ahead and do the weld. Upon completion of 22 the weld, you will radiograph. Now, that radiography 23 will tell you the soundness and.the condition both of the 24 ' - f-s, - weld joint and the adjacent area.
.- ( ) 26
%d In this-case, it is the' service pipe And at that
)
16/9 , 12140 1 time you will be able to tell.whether you do have an 2 indication or not. 3 Now, it may be in the weld prep. And as we 4 said earlier, during the welding process, the cooling and 5 the heating process, these laminations will open up, 6 trapped slag;and alb,that. And we all talked about that. 7 ' ~ So-you do have the checks and balances. You will find 8 whether there is a 1 Lamination .in' the weld prep, 8 Q You are not prepared to state, are you, 10
, Mr. Econonos, that the first time you do an RT after 11 that weld is completed .you will f.ind all of the rejectable 12 laminar indications?
13 A Chances arebvery good to excellent that you will. 14 O If.Mr. Nunn's testimony is correct that it took
< 15 five or six times to trace -- to chase them, c-h-a-s-e.
16 chase them all. down in this particular weld, and if that 17 ~ is indicative of. Duke's experience with the rest of the 18 containment plate,,it sort of_ suggests that maybe we'mirsed
- -19 a bunch out there, rigbt?
i.- 20 ,- A ,No,' sir. Some of~the -- if you'look-at the 21
- j. bl4-A and' you 'go to , zero , you willj see that the bevel or -
22 the orig ~inal1was, rejected _for lack of fussion'and slag..
' ' , ; , , 3, ' -
. 23 This has,ndthin'g to do with laminations.
- n 24 9Q 4Then they found the laminations, right?
,Q ,/
i ?/ 25 g It-;~was rejected for slag,-okay? 'And then you go n sw- .
." \ .
l 16/10 12141 1 into repair -- that was the original one.
- ~'N
[V 2 Q They were done the laminations -- 3 A Wait a minute. That was the original. They 4 completed the weld, and they radiographed it. And when 5 they radiographed it, they found the laminations. 6 Q How.many did they find? 7 JUDGE KELLEY: Your time has expired. 8 .THE WITNESS: You go back here and you will
, 9 find it.
10 Right there (indicating). 11 MR. GUILD: I don't know what you are showing 12 me. 13 JUDGE KELLEY: Could you indicate what you 1 14 are showing, , , 15 THE WITNESS: It is on form M30-A. 16 MR. GUILD: That is the UT. 17 BY MR. CUILD: us Q What about-the RT? 19 JUDGE KELLEY: Mr. Guild, I said earlier that 20 time has expired.- Do you want to borrow some more',' or do t i 21 you want to stop? 22 MR. GUILD: Mr. Chairman, this is the end of i't,. 4 23 but;the question that I had was whether the-RT found them all. L 24' He has'now found an. ultrasonic mapping which:is not the..same-0
- (/ 25 thing at all..
7
16/11 12142 l 1 THE WITNESS: It was rejected by -- 2 JUDGE KELLEY: I am simply making the point 3 here that you started at 3:00, Palmetto, it is now 4:00. 4 'And you borrowed ten minutes, and we gave you another 5 15. And it is time to wrap up or borrow some more. 6 Your pick. 7 MR. GUILD: Since my credit has expired, 8 let me get Mr. Economos, if we can, to agree on this. 9 We will look at this particular weld pack and we will both 4 to come up with some intelligible reading of what it says or 11 doesn't say and supply that for the record. I have 12 offered that as a document -- 13 JUDGE KELLEY: I thought.Mr. Economos was going 14 to go and figure out'how many: times they had to shoot that 15 weld. 1 I 16 MR. GUILD: From that weld packet. 17 JUDGE KELLEY: And that iscwhat he'is being 18 asked 1to do'and no more than that as I understood'it. L 19 On that basis, okay. . 3L MR. GUILD: We will get you the'information. 21' JUDGE KELLEY: .Why don't we take'a little H five minute.or-so break at this~ point.
-END 16 23 (Recess.) .REE-24 f'\ '
( )-
%,- 25 N
1
12143 Sim' 17-1 1 JUDGE KELLEY: Back on the record. 2 This is a good subject for penetrating questions, 3
- Mr. Wilson.
4 (Laughter.) 5 CROSS-EXAMINATION 6 INDEX BY MR. WILSON: 7 Q Mr. Economos, you mentioned earlier that the 8 two-inch steel lamination standards that applied for 8 i repair for say two-inch steel had been applied to three- l 10 quarter inch steel. is that right, I mean for Duke, and that 11 that=was a conservative effort on their part? 12 A Yes. 13 [)
%_d Q I was trying to understand that.- Now if we had I4 about, what, about an inch'and a half -- what is the standard, 15 the cut-off for repairing in two-inch steel a. lamination?
16 How big does the lamination have to be before it is' required 17 to be reapired in two-inch steel approximately? 18 A It.would be similar to what we have now.
'19 Q .Can you give me a. figure, something like an 20 inch and a half or-two inches? Is it more than that or 21 less or what?
22 A Well, right now we are talking about a one-inch 23= maximum or three-eighths, whichever is less. 24 Q Is that'the general standard?
'n.J n A
Yes. That.is what we are' going by. f - - _ _ _ _ _ _ _ _ _ - _ _ _ _
w (- 12144' I. 'Sim 1 2 1 Q And the one inch.to'three-eighths, is that l 2 what you-said would be applicable 7 then.also for the three-3 quarter inch steel; is that correct?- 4 A- That is what is applied at Catawba, yes. 5 Q In three-quarter inch steel, and we are talking I 6 about the thickness, aren't we, as-opposed to say two-inch 7 steel? 8 A Yes. 8 0 1sn't a one-half inch lamination in'two-inch t 10 steel' plate-less of-a significant characteristic'than in 11 a - three quarter inch: steel plate? 12 ~ A Yes. 13 Q. How then is that application. conservative that 14 you only repair say those o'f that size? 15
'y A Your objective is to remove the. lamination is from the area-where you are going to;be1 welding for' obvious- -
17 reasons because if you do welds it willfopen up. So.you 18 want to have a weld prep as .cleanL as' possible andidevoid-19 of any'laminations. 20
-Q. Doesn'tlthat though,.:the application in this-
-21 '
manner'that'we;have'been discussing, doesn't that:though'
'22 -
~
really.; permit a greater proportionLof._ lamination in the
' 23-
-three qudrterLinchjsteel setting than=it would.say?in^a-
~
24 - , - two-inch steel. setting l proportionately?'
'n'~
E'N A: I am not sure;I:. follow:you'.: \ t ( '- N I
-..o -
iC-- '-----i-----"
4
'12145
?- 1
- Sim 17-3 .1 Q My' question really was:how is that-conservative j.
'} 2 if you are applying a higher standard for a thicker piece 3 of steel and supposedly a stronger piece of steel with, say,
- 4 for instance, a half-inch defect or lamination' defect perhaps-r 5 and you apply it to three-quarter inch which is a weaker 6 piece of steel or11ess strong. The same length would be ;
7 proportionately a more sizeable defect. I am just curious e 8 how that could:be conservative. 8 A I think it should be just the other way around, 10 you know. l 11 0 That they are applying 3/8th inch standards to 12 .1 inch steel? fD U 13 A Oh, no. 14 Q Well, this is_why I had trouble with the' testimony 15 before. I understood that was conservative. But my time . 4
. 16 is running, too, so let's keep, moving-on here now. We will 17
. come back toEthis in a second if time permits.
18 A Okay. 4 18 l Q The-investigation that you conducted of Mr..Nunn's ! 'E- allegations,:you~went.out'at-least at some' point'and examined 21 i the' areas:in1the. plant.with him,'did you-not?' i E 'A With'Mr. Nunn? 23
.Q Yes.
# A No . .
+X E Q -- .All right. Did!anyone do that'that reported i~ S -
- _ , ,m., . -- ,
_-7.--.~i-
12146
.Sim 17-4 i
to you and-identified the particular areas he was concerned 2 with? 3 A Did anyone --- 4 Q Do you know of anyone who did that and then-5 reported to you which areas he identified as being concerns? 6 A I went out and looked at them myself. 7- Q How did you know they were the areas though? Was 8 it from the-testimony before? 9 A He identified the penetrations. 10 Q Okay.. You did meet with Mr. Nunn at some point, 11 did you not? 12 A Yes, a couple or three days. 13 Q Okay, but you didn't go out in=the plant, but you v 14 got the necessary data to' locate --- 15' A I got the necessary general information, and he 16 I think at the time we talked about it, he talked about 17 - 216 1, and I went out looking for 216-1 and I'also' looked 18 at the drawings, at the sketches and saw that 215-1-and 216-1 19 . were in- the same relative area. - So we looked at both of 20- them. .Iralso looked at the records trying to-find where 21 ' Mr. Nunn was involved, at what-part of.the fabrication process Zt and/or repair process was Mr. Nunn involved in this. 23 0 And'where there any other areas that he had reported' 24 that were; examined that yod were able to confirm that he [1 x_- k 25 had~been.-involved.with;that you therefore examined? i
12147
'Sim 17-5 1 A Yes, I did, but that is not within the scope p)s (s, 2 of this questioning.
3 0 Okay. But as far as the containment and the. 4 penetration sleeves, this was it, these two welds on the 5 penetration sleeve? 6 A Yes. 7 Q Have you in your experience noticed any such 8 failures in penetration sleeves in nuclear plants due to 9 lamination or laminar loading such as we have been discussing 10 here today? Have you ever seen anything like that? 11 A ~ You have to understand that these are penetration 12 sleeves. They are for protecting the safety related piping () 13 14 that goes through them. Now these-also serve as a boundary,-a pressure 15
-boundary, a containment pressure boundary. So they don't 16 see any operating loads as we think of in terms of reactor 17 coolant or-other safety related piping, you know, coolants
-18 that safety related piping sees. There is noffluid running 18
~
through those. 20 Q Okay. So you hadn't observed anything like that 21 ~ you;wouldn't expect to; is that right? 22 A No, sir. L Q Let's back up a little bit now to this two-inch-l- 24 rN steel lamination thing because.I am still very confused about j i
\_ / 25 ~
- that. Thestwo-inch. standards, you don't-have any two-inch
12148
=17-6 steel in the containment,-do you?
A No, we don ' t . 3 0' So that is not what-we are talking about, is it? 4 I mean you are not talking about a three-eighth standard 5 being applied to two-inch steel, because you don't have 6 any? 7 A That is right. 8 Q So it wasn't the-other way around. -Is that - g what was testified to? 10 A It is mostly three-quarter inch material and down 11 at the bottom.it is, unless I am wrong, I think it is around 12 one inch for the first couple rows. 13 0 Okay. But I guess'as the bottom line of your 14 testimony, you consider laminations,such as we have been 15 discussing of safety significance in this type of containment 16 plate? 17 A No, I don't. 18 Q- And from your actual experience there~at the 19 Catawba plant and in observing the areas that were identified 20 to you by the testimony, are.you satisfied that there are 21 no such defects there and that this plant is safe? 1 22 . A- Yes,-sir. l 4 23 MR. WILSON: -All right. Thank you. 24 JUDGE KELLEY: Mr.' Johnson. [Y!
' x, 25 "MR. JOHNSON: Yes,'I am going to have a few questions..
L:-
'1 12149 Sim 17-7 REDIRECT EXAMINATION 7
(~%. 1 () INDEX~2 BY MR. JOHNSON: Q Just for the record, I would like to ask 3 Mr. Economos a- few questions because he was not sworn 4 when I introduced him. 5 Mr. Economos, back to the-inspection report 6 7 that is marked'as Staff Exhibit No. 22, you prepared that 8 inspection report? 9 A Yes. 10 Q And are the statements contained therein true 11 and correct to the best of your knowledge? 12 A Yes, sir. 13 O Thank you. N/ g4 Now when Mr. Guild was cross-examining you.I 15 believe he asked you whether you promised,Mr. Nunn in an-16 interview with him to do a liquid penetrant test at the-g7 'far end of the sleeve. Now assuming'you did, and it 18 wasn't established and you couldn't recall whether.you did gg or you'didn't, but assuming you did, what was the significance
- 3) of that request and did'it have.any: safety significance?
~
21 'A I would suspect, and as I say,-I don't recall,. n I may or I may not have. The contention 1was,.as fer. Nunn 23 was saying,.that this was rotten-steel.and that thisJpenetra-24 tion was - 'in. order to' prove that this'materialiwas rotten
-\~4[) !
25 steel and that it did have laminations, which we'say-it does, l i i w e- c - = e ,
12150-Sim 17-8 and I assume that that is at least what we said, that we 1 ((" %) 2 would back on the other end of inside the containment and 3 try to PT that cross-section on the surface to see if there 4 was any indications to verify what he was talking about. 5 Obviously we didn't. 6 . What we did was to look at the fabrication records 7 and basically what'we found was that yes, these penetrations did have laminations in the weld prep area and they were 8 9 identified and they were repaired and the weld was. finally 10 made and radiographed and it was found to have sound metal 11 consistent with code requirements and that was the end of 12 - it. So I felt at this point that it wasn't.necessary. ("')
\)
13 14 I would say if somebody said why didn't you do it, and 15- obviously I don't recall making that promise, but if I was i 16 to say well, go ahead and do it, I would see no' basis or 17 what we would gain by it. ut Q The question was whether at- the place where the l l 19 welds were done, do you question whether there are still.
- l. 20 laminations in the' weld area?
21 A There.are-not. n Q. And the determination of whether there are 23 laminations in .some other -place were not relevant to the
,_s 24 determination of-whether there were any.laminations in the
( 'e
# 25 area-of the' weld?
1
12151 Sim17-9 g A That is correct. (h 0 Okay. Now you didn't go back to Mr. Nunn, and V 2 3 that was another point that Mr. Guild raised in his cross-4 examination. When you finished your review, did you feel 5 it was necessary to speak to Mr. Nunn to complete your 6 review? 7 A No. At that time I felt it was not necesary. g We had the report and the report basically investigated g Mr. Nunn's concerns. .We came'up with our conclusions and 10 that is the record. I.believe that this went to the PDR 11 or was accessible to the Board and Mr. Guild and if they 12 wanted to see it, they could see it. p 13 Q Was there any doubt in your mind that you had (^- 14 addressed Mr. Nunn's concerns with respect to the laminar 15 indications? 16 A No, there-was no doubt in my mind. I think 17 I addressed his' concerns. 18 Q Now you also.said that your conclusions were 19 based on a number of items and areas of inquiry, including 20 visual inspection, the-FSAR, various records,. including 21 .the 1adiography.and drawings. 22 Do you believe that'that review, those different 23 *ypes of reviews that you did were adequate to reach the 24 conclusions.thatJyou did? 0 k.) 25' A Yes, I believe so. .If_I had found areas, if I
l Sim 17-10 12152
~
1 had found defective welds' or if I had found any indications 1 O i 2 both in the radiographic reader sheets as we call them or
' s' l
3 any kind of a discrepancy in the records, both the applicant' s 4 records _and-the vendor's records, then we would expand the 5 investigation or the examination. I found none and therefore 6 I felt that there was no point to going on further. 7 MR. JOHNSON: Thank you. g One second, please. 9 (Pause.) to Okay. Thank you. 11 That is all.I have. INDEX 12 BOARD EXAMINATION 13 BY JUDGE FOSTER: I (_j 14 O A couple of quick questions. Mr. Wilson asked 15 a question here on standards developed for two-inch steel' 16 and applying these to three-quarter steel. Those standards 17 that are for the two-inch steel, are those' written for the tg purpose of' welding and welding quality? In other words, j 19 is the original base on the assumption that there-is going 3) to be a weld in.that spot as contrasted with strength? 21 A-Your. Honor, there the code gives specific 22 _ guidance-on what to do with regards to repairing material Z3
;where:these types of indications are found.
24
-Q . Repairing for what reason? ~[ 25 A '\_/ For platef type _non-metallic or. plate type defects
12153 Sim 17-11 1 such as laminations, if you please, or other types of () 2 non-metallic or indications that may be found in the plate. 3 0 I have gotten the impression that your main 4 concern with laminations here is associated with welds being 5 made on.perhaps the edges of this as contrastqd with the 6 actual strength of'the material itself. 7 A- Yes. 8 Q What I am then asking you is whether.the coder 9 which applies to the degree of a lamination in two-inch 10 material is_ based.on a weld being made or whether this is 11 for some other reason like' strength? What is the purpose 12 of the code? (~T 13 A Well, basically you' want to . have a weld and ' l
\_s) i 14 the material r.ixed with the weld as close or adjacent to 15 the weJd be of sound material and to be as void free as 16 you can have it for the purpose of strength, yes.
17 0 Let me try again. If you had a plate with
~
18 lamination in it two inches' thick and no weld was; going to 19 be made, would'you apply the code? M A Just a plate by itself where.you~are not going 21 to use it-anywhere? 22 Q Well, let's say.it'is an area where it is 23 being used for containment, but it is not in an area where 24 itiis going to be welded.
.(s)'
# A .If it was in the surface where you could see the
~ _ _ ___-__=__._-________ _ . _ - _ _ _
12154 Sim 17-12 g indication by a visual inspection, yes, you would repair A 1,
) 2 it and the code.would be applicable, yes. You do have the 3 guidelines of the code.
4 0 I still don't have a clear picture of the purpose 5 of the~ code being there,.whether this is for strength or 6 whether it is for some other reason. 7 A I imagine it is for strength. 8 Q One.other question. I recognize that you were i g not involved with the design here on the basis of your 10 past experience with steel and this sort of material. In 1 i i 11 designing the containment vessel, the designers came out' 12 with plate that was essentially three-quarters of an inch (~') V 13 thick and I. gather it is a little thicker at-the base and 14 a little thinner at the top. Do you believe that that design 15 consideration recognized that steel going into that would 16 have laminations in it? 17 A My own opinion? 18 Q Well, since you had --- 19 A Yes, I would say that they would because they
~
20 did assign.516 material, SA-516 material and it addresses
-21 laminations in.there. If you are going to get rolled plate, 22 as.this is, you are bound to have laminations in it.
2 JUDGE FOSTER: That is all I have.
,,,q 24 CUDGE KELLEY: That: brings us through the cycle i'A Y '
25 . of questions to you,-Mr. Economos. m._ -- .._--_--.-a
12155 Sim 17-13 g Now I think you were going to check through r 2 that paper and find the number of times that that particular 3 weld had been shot with.laminations; is that right? 4 THE WITNESS: Yes. 5 JUDGE KELLEY: Were you going to be around for 6 a while anyway? 7 THE WITNESS: Yes, I~am. 8 MR. JOHNSON: He'is on the staff's next panel. 9 JUDGE KELLEY: a0h, okay. Well, maybe you could 10 tell us that when you return. 11 THE WITNESS: I.can tell you right now. The 12 weld was shot originally and it was rejected because of the g-s 13 lamination issue. Then it was repreped and the weld prep NJ 14 was repaired per procedures. Then it was accepted and then 15 it was rewelded again and now you are gettting fabrication 16 type rejections like lack of fusion and slag. 17 Mr. Nunn comes into the picture here on 4/8, 18 which is April 8th, '81 and.he was involved in the repair 19 of the weld prep. , 20 Again it was welded by Mr. Nunn and his weld 21' or portions of his weld were rejected for porosity.and 22 lack of fusion. And unless I am wrong, I think finally and Sim 23 on the'fifth'go-round the weld.was acceptable. Suo fols. and-17 24 p q W # J
12156 st 18/l 11 JUDGE KELLEY: I think -- what was the question, () 2 3 how many radiographs,were taken? MR. GUILD: Five or six, I think was.the positive-4 number. The answer is five or six. 5 JUDGE KELLEY: Does that seem to answer your 6 . question? That sounds about right. 7 MR.' JOHNSON: If I may, the-question'had to do 8 with how many times did it take to get rid of all of the 9 laminations. And that's not exactly what happened, as Mr. 10 Economos indicated, some of the rejections were for lack 11 of fusion :and' for. non-laminar problems. 12 JUDGE KELLEY: Is everybody satisfied that'we-13 have explored that. point sufficiently?' O I4 MR. GUILD: Mr. Nunn is prepared to address-it. 15 JUDGE KELLEY: All'right. We can hear from HI Mr. Nunn later. 17 Mr. Economos, thank you very much. You are' NI
. excused.
18 WITNESS ECONOMOSE Thank you, sir. 20 (The. witness' stood aside.) 21 MR. JOHNSON:- It's.my. understanding that we were. going to offer.this package, the. weld package for 23
- weld 2NI15-1. But I. asked Mr.? Guild if this was not'what:
24 he intended to_ offer as.138. He said he intended to do-so. I\ A f. 26 ~ MR.. GUILD': Letime check,lMr. Johnson,.to make-
)
l _ _ _ - _ _ . _ _ _ _ . _ _ _ _ _ _ _ . _ _ _ _ _ . _ _ _ _ - - _ _._-._._...m__..-_.m___ _ _ _ _ - _ . - _ _ . . _ _ _ - _ _ _ . _ -
l 12157 st 18/2 1 sure that's the right number. I do intend to offer it. 2 MR. JOHNSON: If it would be possible for me to 3-offer this as a package, which is the subject of the 4 testimony -- specifically, it looks like about a dozen or 5 fifteen pages, which is represented in the record as 6 welding repair, this particular weld that Mr. Nunn had 7 in his allegation and which Mr. Economos was testifying to, 8 if we could get copies made of this and supply it, we could-9 make it Staff Exhibit Number 24. 10 JUDGE KELLEY: So that would be a separate Staff 11 exhibit, may or may not be included eventually in 138. - But 12 we-can cross that bridge.
, p 13 Is there any objection to Mr. Johnson's proposal, b
14 Staff 24, I believe that was? 15 MR. JOHNSON: We will supply this. We'are 16 going to get some copies. 17 JUDGE KELLEY: Thank you. 18 MR. GUILD: As long as it's reflected we have I8 offered it. JUDGE KELLEY: It would be a part of.your 21 package and'you were going to come back later on the status 22 ' of negotiations on that. MR. GUILD: -Yes, sir. p JUDGE-KELLEY: Okay. 'So, Staff 24 has,been admit-
-( ) 26
^ XXXXXXXXX' ted.' - Copies will be supplied.-
, . - - - , -- , -n
12158 st 18/3 1 That brings us to the point of calling Mr. Nunn, O'
\,,/
i 2 the Board's witness. And we have jus a couple of things 3 about procedure which we have in mind, which I think it's 4 essentially the same as last time. Mr. Nunn, you have 5 been through this once before, so it's nothing very new. 6 What we h'ad in mind was roughly an hour for the 7 process. You would take the stand and begin as the Board's 8 witness and use a piece of Board's time, maybe ten minutes 9 or so, roughly, and we would ask you to use that time 10 basically to state whether or not your concerns have been 11 either answered, partly answered, not answered, or whatever, 12 but give your reaction to what you've read in the prepared
/N 13 testimony and also what you've heard here today. \~-]
14 And, then following your sort of summary state-15 ment -- by the way, stated as best it seems to you. I would 16 just say I don' t think you need to try to go down sort of 17 a line by line, every single line of the testimony, sort 18 of approach. If you want to cite examples, fine. 19 And, what we want I think is really sort of the 20 . substance of whe:s you are now and what you think of the 21 situation. And we would then go through what sequence of 22 questions by different parties. We have it this way. And M I think this is roughly the sequence we used with Mr. Hunn 24 before. I'm not certain. I couldn't find it easily in
'/ 25 the transcript. But we were thinking of ten minutes-for the I
12159 ct '18/4 1 Staff,' ten minutes for Palmetto, fifteen minutes for the f/ s_ T 2 Applicant because the testimony is basically adverse to 3 them, five for the State, ten for the Board. And, so 4 that's our approach. 5 So, we would like to call you, then, Mr. Nunn, 6 as a Board witness for that purpose. 7 MR. GUILD: Mr. Chairman, Mr. Nunn said it would l 8 be helpful if he had that weld package we were just refer-9 ring to. 10 JUDGE KELLEY: Sure. .Just a note on formality. 11 You were sworn.in before, Mr. Nunn, so we don't have to 12 repeat that. You will be testifying under oath. 13 Uhereupon,
' XXXXXXX 14 HOWARD SAMUEL NUNN, JR.
15
. was called as a witness by the Board and, having previously 16 been sworn, was examined and testified as follows:
17 DIRECT EXAMINATION 18 BY. JUDGE KELLEY: 19 Q You may go ahead.
- 20 A Am I just' extemporaneous right now?
21 Q Yes. I just think as bestLsuits you. I'm sure M you have thought about it. If you could just make'extempo -
'M raneous comments, if-.you want to refer:to your. papers, do .
114
- that, however.it works ~best.
i (j 25 -A Yes, sir. Mr.'Economos, Mr. Uryc,-Ms. Garde and f
+
- s - , .-4 , ..-v- , g. 4 .. y y e y
^
4 12160 st .18/5 1 myself met at the Ramada Inn, oh,.mid-November, I'm not 2 sure of the' exact dates. But we met one'particular night, 3 which I did not tape with a tape recorder. And, then we 4 met the next day, which I did tape record. 5 I was particularly disappointed with Mr. Economos' 6 report, in'that he did -- and I have a tape, a copy of that 7 one particular night, where Mr. Economos and I got into a 8 rather heated discussion, and I was saying quite possibly 9 Duke Power could have painted over the stiffener problem, 10 and he could not see the porosity that.might be left,'the-porosity coming from this possible 1 amination problem that
~
11 12 existed in the walls. () 13 .Mr. Economos assured me'that he-was going down, 14 'he-was going to have the people remove the paint and:have 15 the adequate test run. He also assured me about going 16 back into the pipe chases I had suggested. Now, keep in 17 mind that this penetration is only about two feet'long. 18 - This is just'a' conservative guess, on this~one end~wei 19 found over thirty laminations. 20 In previous' Duke Power testimony,-they_have said 21' 1that'the pts that were run were not documented.- -Judger 22 Kelley, in fact,'what_did happen ,~;I suggested to-Mr. 23 5 Rudasill.the endlof this one hadishot bad.- Mr.tEconomos-- 2 i
'N' didn't mention.this now,7but it was. cut back;:off;thefwall.-
N- M. Now,-I'm not'sure if.this?is 15-1 or116-1,:but.one was cut
'1 1
I
l 12161 ! l st 18/6 1 all the way off the wall because they had not been able to ! A' ( ,) 2 get it to shoot. I suggested to Mr. Rudasill that we run 3 the very critical PT test to see if possible laminations 4 could be the problem. 5 As I have testified I think in my affidavit,.Keith -- 6 and I do not remember-his last name, but he was the boy 7 that was doing the PT at the time, and I was working in close 8 proximity to this gentleman. He called me over and he said: 9 I have never seen anything like this. We had over thirty 10 laminations in prep surface. 11 So, for several days many welders of Mr. Rudasill' s 12 group would go down and Keith would stay with them, and 13 Keith would circle here and circle there. We would grind to {/}. s_ 14 the depth of three-eighths of'an inch, fill 11t back up with 15 metal. I say "we". I was not part of this process. Roy_ 16 Grady is one, I can tell you for sure, that was part of this 17 process. And Roy would come up at the end of the day, and 18 I would say: Well, Roy, how did it go today. Well, we 19 started with thirty-one laminations. We got it narrowed M' down to twenty-four. And maybe the next day we started with 21
-twenty-four-and got it down to eighteen.
22 There are several days that are not documented, U of tests that.were run on this prep surface. Now, this.is 24 ,-- the way the prep surface was finally determined to be ac-
> 8
.ceptable to once again put the bellows back up to it and
12162 st 18/7 1 reweld it. At this point, it shot bad again upon cutting i 2 into it.. 3 To the best of my ability, I tried to see the 4 laminations and once again, this time not a PT but an MT 5 test was performed. And if I'm not mistaken a UT was also 6 performed. I wondered at this point, we have said that the 7 only pertinence or the only relevance that a lamination in 8 a crept surface has to the safety of the plant is that it 9 might mask something else. Then, why -- why are we mapping l l 10 anything with UT? If we found these, why not use the part 11 of CP-88 and just grind into it again and fill it back up 12 until.it. meets CP-88 criteria? What is the purpose of the 13 UT in determining the length and the width and the depth 14 of these particular laminations? 15 When according to, I believe, Mr.. Ruth earlier -- 16 I believe it was you, Mr. Ruth, said that maybe there could 17 be some as long as twenty feet in the plates but as long 18 as they did not appear at the edge,'that didn't make any 19 difference, that wouldn't affect the integrity of the vessel. 20 But Mr. Economos did promise me that he was going down in 21 there, he was going to look firsthand. . He was not only 22 going to look there, but he was going to look in adjacent. 23 areas to find.the --.the word I believe he used, trend -- 24
,b trend in the matter. He was going to talk to all the people 25 who were concerned in making these welds. =. _ _ _ _ _ _ _ _ _ _ _
-~.- - - ..-., .. -. .. - - - - - - . - . .- -_. . - . - . ~ - .. .
( fi_ 12163 j F 1 st18/8 1 ; To the'best of my knowledge, he did not. 'We [ 2- received from' Duke affidavits from. welders a through what- , j: 3 ever number, twenty-two. There were twenty-two documents.
~4 I would like for-you to look at those.some time. Anyone l' . .
7 6- who testified to having welded to this containment vessel l I 6 did mention a-problem-with porosity. ! 7 This would indicate to me that/perhaps this mill 4-8 . scale issue that Mr' Kent. brought up, and Mr. Economos said j 9 though thatLwould be very rare to have it that close to the 4
, 10 - surface, why was everyone picking up porosity?.
1 l' 11 One of your welders -- I can't give you.the 'l 12 _ letter number, but one of your welders. testified'that he was l i
- 3. ,
13
.part of an entire' crew that was sent in to-fix the porosity t ,
, 14 in the stiffeners.- Now, if everybody was getting all;these. . 15 problems everytime-they welded to-this containment, and-16 this was supposedly good metal, then where were these1problemk { 17 coming from? - i 18 That'stmy opening, sir.- i 1 [ 19 JUDGE KELLEY: Thank you, Mr.:Nunn. I have a i i
- j. 20 . question, but that's not the : sequence we talked about. I-4 -
21- - guess I can bite my tongue. 22 l 1Let's go to Mr.-Johnson,7 the Staff; Mr. McGarry,. I'. 23 - are.the: Applicants ready? Do you7have; questions?
~
- 24 MR.EMcGARRY:- - I believe' Palmetto.fisfnext,.'Your F - 25 ' Honor.
I"
- h
- . - wev-; e , u'--a ese w .-en., n J- ,, ann..- , ,.n. -^s- v e n .-- m . ,e , , , .-e-..,,.--c,<,c,.- w ,w,-- r
, . . _ . . . . _ _ . . - . . . _ _ . . . _ . . ._ . . _ _ _ ..._-.~_ _ . _ __.
F' 12164 i r
'st 18/9 'I
.l JUDGE KELLEY:. I was going to ask whether-Mr.
{ 2 l
- i. Johnson,may want.to confer or not.- He seems to want~to 8
defer.. 4 . MR. JOHNSON:- If I could defer,-yes, and let 7 5 f somebody else go first. I-
- j. 6 JUDGE KELLEY: That was really the thrust cf l'
7
- my question.
8 MR. G'UILD : Judge,lyou have Palmetto after NRC' l' 8
' Staff. -We would very much-like to hear-:what the NRC Staff 10 has to say. We are clearly-adverse to that.
11
] JUDGE KELLEY: I thought you would rather. wait.
That's why I asked Mr. McGarry.. We will just wait.- You-13 would rather wait? 4 MR. McGARRY: Yes, sir. ,
! 15 JUDGE'KELLEY: 'Let's just wait; .Dozyou want a I
Efive minute break?. I i 17-f. 4 MR.' JOHNSON:- Yes. Could we,have five minutes? 18
!: JUDGE KELLEY: Okay.. Five-minutes,'not more than. ,
that.' i , 20 l, (Whereupon,la recess-is taken at:.4:43 p.m.)
~
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T19JRB:jrb 12,165 fla Sun 1 JUDGE KELLEY: Okay, we can go back on the
~ '
j 2 record. [G 3 We will go now to Mr. Johnson, of the NRC Staff, 4 to ask some questions. 5 MR. JOHNSON: Thank you, Mr. Chairman. 6 CROSS-EXAMINATION 7 BY MR. JOHNSON: 8 Q Mr.-Nunn, when you are talking about the 9 stiffeners, these stiffeners are located around the outside 10 of the containment wall? Is this where these stiffeners 11 are? 12 A That is correct. 13 Q So these stiffeners are not in the same specific 14 areas as the penetration sleeves that you were referring-15 to? 16
-Those welds, penetration sleeves, that's a 17 ' separate item; is it not?-
18 A Yes,-sir; they're in the same proximity. 19 Q But they're not the same welds that you're talking 20 about? 21 A. Not the same welds, sir. t 22 Q Now, my understanding is that you have the M containment wall, and that the stiffeners come up on the l
- 24 outside of the' wall every so often around the containment
,-\ (j 2 wall, and are attached to the containment wall by welds;.
s gg . - cs s - 4 .x. . + 19 - '
' x1 12,166
~
e- .(
]w, ,
1 and it's'h ose welds-that'.you're referring to? gy , . Q 2
-h Is - t@at correct? .
4 3 A No,' sir. 3 h s. 4 i } y . These welds were Jade-before I ever got to I
- 5 Catawba.' e tg I 6 Okay.
_ Q gs. ; s 7 When you're talking about porosity in the weids 4 8 on theistiffeners, what were you talking about? i- 9 A -I was speaking 'aboutI what perhaps may be 12 or 4 ) 10 15'other people, new friends that ,Ifmet down there, told me 11 had happened.- I also noticed with my own eye that the-12 welds were all ground, and ground,- to me, in excess. - p E 13 .g Okay. i t 14-In other:words, what,you are-relating to me about . 15 porosity iri .we.lds on"the sti,Efeners, it'wasn't something s , s % .
'16 '
that you Np.ersonall'y llobserDed.? - '
- t s , , i * .
17 .. A It was somethingfthat..was t'ld o to you'that ' 18 happened before you came-to(Catawba?
% i% *
/ '
m 19 ' A Just'the-porosity; yes,' sir. 20
\> .Q ,
Q. Do. you [have any. first- han'd s kn$vledge about
, v .m-s ,
wh' ether--what't.ecauseofthepohosity-was?
~
21.-
.w ]
1 22 ' 3 No, sir,Ljust-myown[s'pbculation,.whichI.'ve 2
- 23
. J .c already' stated. . . - -
s j, ' i' ' t .
. 24 -
-3 Q. So'you don't know -t whether%there'.s-any indication-4e. _t 25 ifrom'yourown.: personal [k'nosis5ge)Jwhether.'there's any
- -l%Q'a :i\ '; .
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19-3 12,167
, 1 connection between porosity and laminations?
! 2 A There could only be two reasons-- 3 Q.
-Of your ovn personal knowledge?
4 A Of my own personal knowledge, that's what I'm 5 telling you: 6 Bad rod--which could be three--bad rods, bad 7
- . welders, or lamination in'the vessel itself.
8 Q i But you don't personally know of your own $ 8 observations-and experi'ence what the problem was in respect i 10 to those welds? j_ I A Yes, sir,-just what I was told. Q [Just what.you were told.
- 13 MR. JOHNSON: No more questions.
14 JUDGE KELLEY: Mr. Guild? 15 BY MR. GUILD:
- I Q
Mr. Nunn, will you focus for almoment on this i 17 ' point about the ' role of nondestructive examination with ' 18 < respect to laminations?' 1 . 19 - Was it'your experience + hat some form:of NDE { 20 !- is done on the weld prep surface before theLweld is - 21 (
. performed,1and.that.that;NDE-detectsEthe presence of;1aminar 22 indications before you weld?
El LA- No, 2' sir,Jon original. weld lit'.4 never1done-tosthe i.- best.cf:my. knowledge; not'on carbon steel;;the' type-offwelds I'mitalking about. ,~~ E
. - ,,*y aa.-, ~A -3 ,, +y .. y,,73, -
p,e e, ,e m y , q w
, 19-4 12,168 1
Q So there's no UT donc before you do the weld?
.L/{'} 2 A No, s .'. r .
3 Q There's no RT, no radiography done? 4 A No, sir. 5 Q And there's no MT or PT, is there? 6 A That is correct. 7 Q All right. 8 It's strictly a visual inspection by a QC 9 inspector who says that it's clean and it stood up correct 10 and you can go' ahead and weld? 11 A Yes, sir, that is correct. 12 Q And these indications, laminar indications, 13 the ones that have been identified that you were told to 14 repair, were they visible to the naked eye? 15 A No, sir, you'd have to have a pretty good eye. 16 I think earlier testimony said they were tissue-17 paper-thin. 18 Q All right. 19 So they're visible only when you use one'of the NDE techniques? i You use liquid penetrant.or-magnetic 21 particle or your ultrasonic.or.do aLradiograph;'right? 22 .
.A
.Yes,. sir, to the best of.my knowledge.
23 Q Okay.- 24
-So you're_looking at the-bevel surface'of--the ; sj iQ - #
- veleveled weld surfabe between two containment plates, o'r
\'
19-5 12,169 I the surface between the penetration and the plate that O 2 you talked about, and as long as it's shiny and clean, i I 3 and it has the proper geometry, it's acceptable as far as 4 you're concerned, and as far as the quality control 5 inspector is concerned; is that right? 6 A As far as the quality control man it is; but not 7 myself. 8 Q Okay. 8 I don't mean to say that if you knew there were 10 laminations there, that it's acceptable to you. 11 But you can't tell any different, nor can anyone 12 else in just looking at the w6td prep curface?
) 13 %/ A Not unless I got the eye of an eagle.
14 Q Okay. 15 Sc, you weld, and there are laminations; and-in the 16 case of penetrations, there are 30 laminations or more, 17 or 30 laminations that were found; and the laminar indication s 18 only show up--how? 19 A Well, as Mr. Economos testified, after the 20 weld is completed. 21 But I saw so many of these-prior'to this'and after 22 l this, and these indications almost always ran parallel 23 . l with the drip pass of the weld (indicating). 24 Q The indication, the laminar indication by definitio n
%/ 25 is like a space'between two sheets of paper (demonstrating)--
t 1 [' . ~- ~ _
19-6 12,170 l 1 A Yes, sir. pd 2 Q --is parallel to the surfade of the pipe or the 3 surface of the plate; correct? Is that right? t 4 A It would be parallel to the surface of the pipe 5 or plate; yes, sir. 6 Q Okay. 7 So if you are looking down on the lamination, 8 down on the piece of paper (indicating), you don't see 8 anything; correct? 10 A That is correct. 11 Q All right, you shoot an RT through a piece of 12 pipe perpendicularly, it doesn't show a lamination; does g- 13 it? b 14 A Yes, sir. 15 And I got in quite an argument with a Mr. Kirby 16 (phonetic spelling) who was-- 17 Q I couldn't understand your answer. 18 Your answer is you can see it looking down? Or 19 you cannot?
" A Yes, sir; yes, sir, you'can if that-has opened 21 up and allowed molten metal to run into the crack and sealed 22 ~
- itselt back' shut; and it will appear to be lack of fusion 23 or slag.
24
. s Q Okay.
25 i
-If it's a laminar indication that's'in the thin
19-7 12,171 1 film state and has not opened up from heating, it does
>Q Q 2 not have slag inclusion, does not have any carbon deposits, 3
is it your experience that you can see it looking vertically 4 through the pipe in radiography? 5 Can you see it? 6 A Yes, sir, if it opened up enough to let the 7 molten metal in there and trap slag. 8 Q All right. 9 But if it hadn't opened up that way, would you 10 see it with RT? 11 A No, sir, you wouldn't. 12 Q So, when you do the liquid ~ penetrant or the 13 magnetic particle tests, you are essentially looking 14 __if 1.m holding these same two piedes of paper (indicating) 15 up, I'm looking at the edge, you're looking at the die or 16 the magnetic particles that would fall into that groove 17 between the two pages of paper; isn't that right? 18
-A Correct.
19 Q Okay. Now, if you look at that pipe or that plate 21 with UT, with an ultrasonic test, can that assist in.your
. opinion in indicating the presence of.a. laminar indication?
23 - g 1 am not qualified on UT and.have not seen any 24 ' UT runs.
.'y
("r 25 Q All right. .I 1
19-8 l'2,172 1 A I'm not qualified to answer that question. 2 Q , All right, sir. 3 Now, the UT was not run before these containment 4 plates were welded; correct? 5 A To the best of my knowledge, no, sir. 6 Q All right. 7 And was it welded--was a UT performed, to your 8 knowledge, after laminar indications were discovered through 8 the initial radiography of the completed weld? 10 A The initial radiography would not call them i 11 laminar indications, when they say--so, we had three 12 indications: 1-inch lack of fusion, 1-inch' slag, and we'll 13 say 1-inch porosity. 14 Q okay? l 15 A But, very strangely, they were all running in I 16 straight lines-(indicating). I'd say 9 out of 10 of then 17 all ran in that straight line. 18 Q The,-if they didn't call it laminations when 18 they RTd the completed safety grade welds, how would they. E come to mape it with u'ltrasound? 21 A To tha best of my knowledge, whichever one it was,
' 22 15-1 or 16-1, that was cut back off the wall, and.then it 23 shot bad again after it had gone through this days and days
-24 and days of PT. test that are not documented anywhere; and 25
. welded again. Thenfit. fell'in my lap.. I was to repair it.
+ . . ._- .. . - - - - - . . - . . . . . - - . .
l 19-9 12,173 l Q All right? 2
.A So I once again suggested to Mr. Rudasill that 3
1 we have a PT done on it, and I believe he went the step 4 further this time to have mapping done in-this area, yes, sir , 5 using PT, 6 g A11.right. 7 Well, what I'm trying to drive at, I guess, is: d 8 4 how was anyone going to suspect the presence of a laminar d 9 j indication if, instead of showing laminations, they : 10 radiograph of that weld just shows something that may be
- 11 1
lack of fusion or called porosity; and they don't go out 12 , and get somebody-to UT the whole base metal? () 13 14 How are they going to map the' extent of'the lamination?
.15 A They won't. They won't.
16 I'll just cut into:it and if I could find it, 17 fine; and if I can't; fine. i 4 18 But there-was too many.of those-t'imes where I 18 - didn't find anything when-I cut in there. And the fact L"- this one had had so much trouble,--trying to put my.h ands' , 21' on it here.(indicating ~ documents)--a: good' normal weldL ' E will have maybe~three or;four sheetssto the INFORA (phonetic ' 23
. spelling) and that's it; even-with one repair,.just'one 24 :
repairicoluna would be opened up.
~
.%fi.
s# " 25 We got.a' pretty good' stack ofEpaper right here l N l
19-10 12,17 4 l (indicating). s 2 Q. That's 15-1 there? 3 A Yes, sir, 15-1, 5 or 6 times that it didn't d shoot good. I'd like to count the number of welders that 5 worked on here sometime. 6 Q Do you have--is it fair to say, Mr. Nunn, that 7 you don't have any confidence that the extent of laminations 8 in the base metal in the containment plate is known at 8 Catawba? 10 A Yes, sir. 11 ~ Q And is it a fair statement also to say that 12
--well, let me ask you this: I tried to put it in your 13 mouth.
14 What confidence do you have that you know the 15 extent of laminar indications on weld prep surfaces in 16 the containment plates at Catawba? 17 A We have no way of knowing, do we? Because I'll j 18 I go back to this INFORA--look at your original column--they 19 don't have the original on top here--the original which calls for an NDE' test--do not pass steps marked as ANI 21 or QC, NDPT until blank inital blah-blah-blah'.
'22 Q Those are whole points; right?-
23 A Yes, sir. A -Q. And always on an original weld, .there's'nothing-b 25
-put;in there. .It's bust-up by the fitters and then we u
19-11 12,175 1 go get the inspector. And he comes and looks for cleanlines s 2 and then it's tacked up. 3 Q There's no whole point at the beginning? 4 A That is correct. 5 Q For that fit-up, at fit-up. 6 A Right. 7 Q And even if, then, Mr. Nunn, even if there's no 8 safety significance to having laminations, regardless of 8 extent or size, in the base metal, itself, of a plate, 10 t and even if the only safety-significance is if those 11
\
laminations occur in a weld prep surface, that region between 12 the two plates that you're going to weld from,-- 13 A Um-huh. 14 Q --is it fair to say that you don't believe that 15 we even know the extent of laminations on the weld prep 16 surface? 17 A I'll go back to the two pounds of testimony 8 from the Applicant that bear that out. Yes, sir, we do 19 not know the extent. They said it's irrelevant, if it's'20 feet, as 21 long as it doesn't appear on the edges, it's okay;'let it 22 go. 23 Q. Would you be willing to assist the parties, 24 i ' Palmetto Alliance and the Board and the Staff, in going 26 to theisite.and assisting them in locating other areas
- . - .=. -
l 19-12 12,17'6 l . l l
- I where there may be problems in laminar indications in pipes 2
and plate? ! 3 A I would do all that'I can. But I don't think i 4 Duke will let me back on-site. 5 Q Okay. 6 MR. GUILD: That's all I have, Mr. Chairman. 7 Thank you, Mr. Nunn. 8 JUDGE KELLEY: Okay. 8 State, you want to go next? 10 MR. MC GARRY: It doesn't matter. 11 JUDGE KELLEY: Seems more logical. Why don't 12 you go next? () I MR. WILSON: Yes, I'm just around the corner here. JUDGE KELLEY: All right. BY MR. WILSON: 16 Q Mr. Nunn, I believe earlier when we've been talking 17 before you indicated this made your job a lot harder, and 18 I guess all the other welders who ran into similar situa-I8 tions? 20 A Yes, sir. 21 Q And-- 22 A Because if slag was called, it's. charged to the 23 wlder.
g If there's a laminar indication that nobody -
\ 25
' detected, the wlder-makes the weld, and maybe three inches
19-13 12,177
/^N 1
show up bad where slag is trapped, they don't say "possible 2 laminar indication, welder may be exonerated," they say: 3
" hey, what's wrong with you? ~You got three inches of slag 4
trapped in that weld." 5 I got very concerned about that. 6 Q Yes, well, that crossed my mind when you were 7 talking a while ago. 8 If we put aside who may be at fault, whether it's 8 QA in that they accepted--or whoever, when they first got to the steel in, or the welder and his responsibility, this 11 system that we're talking about, it sounds like whether you 12 call it slag or whether you call it_laminatir>n, shows up 13 the defects in welds before they are finally accepted? 14 A Not always, sir. Not always. 15 Q Well, have you got any instances when it does 16 not, that you know of? 17 A The only--no, sir, not that I know of. 18 Q As far as your work was concerned, did you~ever 18 leave any work that was not acceptable, or did you know of 20 anyone else who was in a similar situation and did so? 21 A Would you please ask me that again? 22'- Q Well, did the porosity or-the rejectable item 23 ever cause you not to ultimately produce a. quality piece-24 of acceptable work?' g( ,[ 25 ~ A I didn't get that many peieces^of naw work to
19-14 12,1 78 l 1 start on, myself. I had to work on other people's repairs. 2 For which you get no credit or no discredit for. 3-Q But when you finally left the job, it was right; 4 isn't that right? 5 A Everything I worked on, yes', sir; it was right. 6 Q And I think one time before you told us you didn't 7 know of anyone else who might have not performed in a 8 similar way, at least to the best of their abilities?--just 9 walked away from a half-complete job? They weren't able 10 to complete their work--this might have made it tougher; 11 but they weren't able to complete'it, were.they? 12 A They would complete it or someone'else would 13 complete it in their stead. 14 MR.-WILSON: I believe that's all I've got. 15 Thank you, Mr. Chairman. 16 JUDGE KELLEY: Thank you. 17 Mr. McGarry?
- 18 BY MR.'MC GARRY:
19 Q: And when they conpleted it, Mr. Nunn, eventually
# they got it right?
21 A If it was an RT. weld, sir. 22 And we've got some weldsJin there-'that are not' RT. 23
.-I don'.t know where to. draw:-the line between, safety-related 24 and non-safety-related welds, sir.
O 25 : ButiI know socket-welds,.for instance,lthey are T A-- h _,_m
19-15 12,1 79 1 not RTd; I'm told you cannot RT a socket weld. 2 And yet, I believe there are safety-related 3 socket welds. I stand to be corrected on that. 4 Q Have you worked on socket welds? 5 A Yes, sir, quite a bit. 6 Q And the work you've done, are you satisfied you 7 did it right? 8 A Yes, sir. 9 Q And do you knew if anybody has done it wrong? 10 A No, sir, I think in the last testimony I brought 11 up a theoretical example of.it; no, I think eve.ibody-- 12 every welder down there tried. 13 G But you get a little disgusted sometimes. 14 If somebody's going to call 3-inches bad when 15 there's a laminar indication to begin with, Mr. Rudasill-- 16 and I hope he's still here--yes, sir, there he is. 17 rim going to look him dead in the eye,.and Rudi, 18 didn't I suggest to you that we start PTing every one of 19 those penetrations before anything was tacked up.to it? 20 I'm sorry. 'I. don't mean to be asking questions. 21 I know that's out of order. 22 Q Let's move on. 23 A But that's the truth. 24 s Q Some background questions I don't believe we have w . 25 in the record:
-l
~
.l 1
________ i__--------------------U
19-16 12,180 1 In terms of education, you odn't hold an engineer-() 3 2 ing degree? A Absolutely not. 4 Q And you're not a qualified inspector, are you? 5
. A Good welding starts with the welder. The 6
primary instruction lays with the welder, himself. 7 Q Let me ask you this: are you a certified 8 inspector? 9 A No, sir, but I was tougher on myself than the 10 inspectors are. 11 Q You have not been certified as a visual inspector? 12 A No, sir. fw 13 Q You have not been certified as an NDE inspector? 14 A I was only ever a welder. Period. 15 Q Therefore, i you were act certified in RT, UT, 16 PT or MT; right? 17 A That's correct. 18 Q Yun mentioned, talked about welds, I think you 19 were-talking about porosity; and'you said there were three 20 i ways to get porosity: 21 You said rods and welders and laminations; is 22 that correct? 23 A Yes, sir, that's the three main ways, I would say. 24 g. ! (~'i And.how do you get. porosity from laminations? 25 (_s/ A If it's close enough to the surface in these
19-17 12,18:1 1 1 inclusions, Mr. Oconomor. says in hic report that these are 2 nonmetallic inclusions. 3 This doesn't necessarily cican just gas. This 4 could mean some kind of filth or trash that, as it was 5
-being rolled, got~in there, got spread out; and then you 6
I hit these pockets, it well could cause porosity. 7 Now, the gas, itself, also could cause porosity 8 if it's gas coming from the inside-out, you would be opening 8 up an air pocket. i 10 Q Isn't that a typical type of porosity that one 11 sees in a welding process, whatever it may be--mechanical 12 build-up? 13 A We didn't see it at McGuire; and that's another 14 nuclear project I worked at. 15 Q You saw no-porosity at any weld at McGuire? I A No, sir, I didn't say that. It occasionally II happened. 18 But it happened several--hundreds-of times at 19 Catawba. MR. MC GARRY: No-further questions.
~
JUDGE KELLEY: .Thank'you. 22 EXAMINATION BY THE BOARD INDEX BY JUDGE FOSTER: 24 Q- Mr.-Nunn, I'm.trying to focus on this penetration 1 V 25 that seemed--you seemed to be mostly talking about. Do I l
.ns a --
. \
{ 19-18 12,18 2 1 understand that was a weld--2NI-15 and 2NI-16? I ( 2 A Sir, it's one or the other. 3 One or the other? , Q i 4 But this was associated with a 32-inch penetra-5 tion? 6 A Yes, sir. 7 Q And most of the problem was in the penetration, J 8 itself? 9 A Yes, sir. That's right. ! 10 Q Of the places that you have personal knowledge of, 11 would you say that was the worst one, or was it the only 12 one, what? 13 I'm trying to get a little better feeling _for 14 the extent of where the very extensive laminations occurred? d 15 A Virtually every repair that I was handling, once 16 again-had the straight-line indications going with the 17 root of the weld (indicating). 18 Q And were these all on penetrations-or,were-- 19 A Yes,-sir. N i Q --the-laminations were within the pipe penetra-21 tion as contrasted with the containmentiplates? 22 A Yes,. sir, they could have been. Now,cI'm not 23 saying'that every penetration down there is laminated. A'
- 24 welder could have left a line of slag; he could have trapped 25.
it'up against-the~ wall; that's.quite possible.
19-19 12,18 3 1 1 But I find it awfully funny that almost all of then 2 did run in that straight line. 3 At McGuire, for instance, I'd find them like that 4 (indicating) but we found them running like this way 5 (indicating) or little horseshoe-shaped things, just--you 6 know, they never were in.this straight-line. 7 And with what little bit of metallurgy I know-- _ 8 I'm no metallurgist--but what little bit of metallurgy I 8 have studied on my own, I know that this could be indicative 10 of a laminar type indications. 11 Q But you associate the problem normally with the 12 sleeve--I call it that--you put in as contrasted with the 13 containment plate? 14 A Yes, sir, that's right. Q That's all I have.- 16 BY JUDGE PURDOM: I7
.Q Mr. Nunn, a while ago-you held up a pack of papers 18 there--
I8 A Yes, sir. Q --some 5 or.6;-is that'a weld that you worked on 21 and repaired? 22 A It finally fell in my lap to finally repair it; 23 the second time it had been cut off the. wall' completely, 24 I believe--I'll have toOlook through, and I don't'want to
%M 25 take the time'right now.
19-20 12,184 I gs But in that 15-1 or 16-1, because it had been
',/ 2 shot so many times, it was cut off the wall; and it was l 3
) re prepped and that's when we ran this PT test, at my 4 suggestion to Mr. Rudasill. 5 And the PT test did reveal over 30 laminations. 6 That's why I asked Mr. Economos, I said, you 7 know, this thing's only about two feet long; if it was that 8 rotten on that side, we've got to go to the other side, 9 in the pipe chase, grind off a few areas, and run a PT 10 test and see if that thing's like a big jelly doughnut 11 rolled up with a hole cut in the middle of it--just-layer 12 after layer after layer of nonbonded metal. () 14 Q That piece wasn't thrown away, but was welded back in place? 15 A Yes, sir. 16 Q And you did the welding? 17 A I did not weld it back in place, sir; no, sir. 18 I did the repairs on it. 19 Q But when did you work on it? Was-it after that 20 or was it before that, or when? 21 A It was welded the first time and shot bad; and I 22 don't know how many times thereafter. It was cut off the 23 wall and re prepped, PTd to; remove all laminations; it was 24 -
"'} '/ -
fit back up, welded back up again by_someone else. This
- 25. -
. I time.when it shot bad or radiographed bad, then the repair
19-21 12,'185
-~ packet was handed to me.
\) 2 Q- And you went back and worked on it?
3-A Yes, sir, I worked on it. 4 Q And at that time, what was the outcome? 5 A I believe Mr. Economos said that it shot bad, 1 6 but I might interject--before I was able tv do any type 7 of laminar repairs, they came in there I believe and did 8 this mapping. 9 I was sent up the hill--this is where all the 10 main offices are; and I believe in my affidavit I called 4 11 a gentleman "Mr. Cosgrove"--C O S G R O V E--I misunderstood 12 his name.
) But he was the top brass nuclear inspector on the 14 job. But I had to get his signature--his was the last 15 signature to go back on here--to allow me to grind to a 16 depth of 3/8 of an inch, seal back over everything and contir ue 17 with my repair.
18 Mr. Koskro--and it's K O S K R O, I believe.is 19 , proper spelling--he looked up CP88 in his books. He 20 could not find it. 21 He said, "You-do what to the penetration? 22
~
I-said, "Well, I'm told you grind to'3/8 of an 23 inch and seal it back up." 24 [~') s_. He said, "That doesn't-remove a lamination; that-
'just covers it over."
19-22 12,186 1 Then he hit the ceiling and started pacing back 2 and forth. He said, "As far as I am concerned, this is 3 directly affects the safety of this plant, and.I may have t 4 to close it down. I'm going to have to take it home with 5 me and sleep on it. You go on back to your job." ,' 6 Q All right, we went over that previously. 7 A I'm sorry, i 8 Q Now, after you worked on it, it was radiographed i 9 again, and it was again rejected? 4 ENDT19 10 A Yes, sir. REfls 11 12 14 15 4 16 17 18 19 , 21. 23 24 O V . I
* .- - , . . r., a .-#e, p- ,= .~,-e
. . - - - .. - ~. _. . ..
TAKE 20
-REE 12,187 PAGE'l 1 A Yes, sir.
2 Q s Did you go back and repair it or did somebody else go'back and repair it? 3 4 A Sir, I would have to look the whole document 5 over to see, I think I probably was the final one. 1 6 0 You think you were the final one? 7 A Yes, sir. 8 Q And then it vac radiographed again and was okay? 9 A Yes, sir. I believe that is what Mr. Economos to said. 11 Q After you did it the second time or the third j 12 time, whiehever it was that you worked on it and the 13 radiograph showed it was okay, are you satisfied it was okay?- I ( 14 A
- i. I am satisfied within the weld zone that it was 15 okay because we had ground back so far. But other than that,
. . 16 no, sir.
And that-is what I tried.to get Mr. Economos 17 to do, and he promis'ed he.would do. Go over there and see
~ 18 if that piece of pipe Eis in fact rotten.
19 Q But the part that you were working on,-you are r 20 satisfied it was okay? 21- -A The weld. 22 -Q
'In your tota 1 estimate of.the problem with -
-n laminations,Lhow do you view it?-
Is it a matter.of the' l 2 o difficulty of producing a satisfactory weld orfwhat?
' /] 25 A
.[(/; That would-be;a personal problem for the. welder, i
['e W T - -* uyg- - --
20/2 1 yes, sir. It would be a reason to get a welder kind of 2 down in the dumps when he had a bunch of bad shots that 3 weren't' his fault because the metal was bad to start with. 4 But I don't know these terms, these xx, yy, zz, 5 but in talking with Mr. Kent and in talking with Mr. Rile', f 6 certain forces can cause a lamination to turn and instead 7 i of it just staying in the plane of the plate itself, it 8 could turn and actually go to a 45 degree angle or come 9 straight out. , 10 Just like a balloon. All you have to do is 11 prick it one time with a needle and it is gone. And I 12 am really worried about that containment splintering . 13 If it opens in one place under whatever pressure it is 14 going to be under, could it not junt maybe open a gap 15 20 feet vide and'20 foot high? I don't know. 16 1 am concerned that it could. 17 Q You don't have ar.y expertise in this to make 18 a judgment? 19 A No, sir. I wish I did. I am getting some. 20 expertise. 21 g-Your initial concern was_as a welder, the 22 difficulty in making _a weld?. 23 A No, sir. That was not my initial concern. 24 The integrity of..the metal itsel'f. I had'never seen anything h-a 25 like.it. That was my concern,
o 20/3 12,189 1 JUDGE PURDOM: I have no questions. ( XXXXX' 2 BOARD. EXAMINATION 3 BY JUDGE KELLEY: 4 Q Just so we are clear on this. I know that 5 you feel that Mr. Economos should have looked at more things 6 than apparently he looked at, but did he look at the right 7 weld in terms of the one you have been talking about and 8 the one he went and looked at? Is there any confusion 9 there or are you both talking about the same weld? 10 A According to his report, he looked at the 11 paperwork. He said awhile ago he went down and looked at 12 the finished product. That tells you nothing. 13 0 My question -- without debating that for the (J~') 14 moment, I am just -- I don't want to be in the situation 15 where the record indicates to me that you meant a weld 16 over here and he meant a weld over there. I mean, are 17 you both talking about the same weld? 18 A It was either 15-1 or 16-1, yes', sir. + 19 0 He looked at that, not as much as you would_have 20 liked, but he looked at the one you are talking about at 21 least, right? 22 A More or less. 23 g And your' concern, from what-I have heard 24
-carticularly-in the last 15 minutes,.is_that the plate 7-s k_) 25 itself orishould I say'the sleeve itself was bad metal? j J
12,190 1 A Yes, sir.
\ , y j 2 Q Not just the weld but the whole piece?
3 A Yes, sir. 4 Q Are you assuming that because you find a lot 5 of lamination indications at the edge you would then, if 6 you sliced the piece of metal in two, find a proportional 7 number any place else in that piece?_ Is that your 1 a assumption? v 9 A That was my hypothesis in ask'ing him to go 10 to the other side and check it two feet on down the way. 11 I think they would have appeared on the other side, too, 12 in a two foot run, but once again, I am no expert. (') v 13 Q I don't know one way or the other. I just 14 wanted to know what the assumption was. It seemed to me 15 that that must be it. 16 Now, I think you were talking about at the point. 17 in which you were working on it, there_might have been some 18 30 laminations on the weld surface? 19 A On the weld prepped surface, yes, sir, there 20 were over'30. 21 12 How big were they? 22 A- .Some;as.Long as an inch and'a half. 2-- Q _ Incl. a.nd.a half on down essentially? N~ A 'Yes,-sir. {V"') - 26 And'around the circumference of the sleeve?
~
~
'Q .
12,191 A g Yes, sir. That is correct. r' g (Pause.) N 3 Judge, it would clear everything up if you 4 just took this right here (indicating) and fold it up 5 and you are looking now at the end of something. Thre 6 are several layers right there. 7 JUDGE KELLEY: I understand. Thank you. 8 I think I had some others, but my colleagues took them g away from me. 10 That I think takes us through the cycle 11 with you this afternoon, Mr. Nunn. I think we will get 12 into a piece of foreman override a little later, and that 13 has been your concern also. And you indicated you could (~%
\% ,)
14 come back tomorrow? 15 THE WITNESS. Yes, sir. I can come back at 16 any tine. ' 17 JUDGE KELLEY: Because-there are a couple of 18 other topics tomorrow, too. We appreciate that, but 19 for this afternoon on this topic at least, we-will excuse 20 - you. 21 THE WITNESS: Thank you very much. 22 MR. JOHNSON: Could we have.a bench conference a with the atterneys off the record. 24 JUDGE-KELLEY: _Yes. We have got a' point ~or 26
.'two for the same purpose. LYou may'mean something else,ibut r e
20/6 12,192 1 why don't we call a break but ask the lawyers to come 2 on up and we will go off the record. END TAKE 30 (Discussion off the record.) REE 4 5 6 7 8 I 9 10 11 12 O 13 V 14 15 16 17 18
?
19 20 21 22 23 A V 3
I 12,193 ) Sim 21-1 JUDGE KELLEY: We will go back on the record. 2 _( Pause.) , 3 JUDGE KELLEY: We are back oa the record and 4 we can turn very shortly to the applicant's panel that is 5 here to speak to the foreman override question. 6 We do first want to take a few minutes on an 7 essentially legal issue and we would like to hear from the 8 parties about it at this point. We will not be deciding 9 it right away I suspect, but at least we will have people's 10 Positions on the record, and that is as Palmetto has indicated 11 carlier, Palmetto and I guess CESG, too, has indicated their 12 desire to have Mr. Earl Kent as a witness on the subject 13 of laminations. 14 Mr. Kent was participating earlier as an expert 15 questioner and now the q'cstion is whether he should be 16 allowed also to testify. 17 We look to Mr. Guild to present the proposition 18 and the we will hear from the other two parties on the 19 subject. 20 Mr. Guild. 21 MR. GUILD: Yes. Thank you, Mr. Chairman. 22 We offer Mr. Kent as an. expert at this point 23
.on the' subject of laminations to respond to evidence presented 24 by the witnesses, the panel for the applicante and the r _(r s' 26 NRC staff.
l l [- . l
12,194 Sim 21-2 1 We would offer Mr. Kent as an expert in quality 2 control engineering in the welding area. Parties and the 3 Board were copied with his resume this morning. 4 The general standard which we invoke is that 5 set forth in the Federal Rules of Evidence, Rule 702 on 6 testimony by experts. It establishes as follows, and it 7 is very sort. l 8 Scientific, technical or other specialized know-9 ledge that will assit the tryer of fact to understand the 10 evidence or to determine a fact in issue, a witness qualified 11 as an expert by knowledge, skill, experience training or 12 education may testify thereto in the form of an opinion or 13 otherwise.- 14 We intend to offer Mr. Kent for-the purpose 15 of' presenting his expert opinion as to the safety significance 16 of the testimony presented by Mr. Nunn with respect to 17 laminar indications in pipe and plate believed to be pres,ent l l 18 at the Catawba Nuclear Station. 19 Now we should state a_little bit of background on how Mr. Kent came to us._ 21 First, as the Chairman of the Board indicated 22 - in an earlier order on discovery matters on these In' Camera 23 issues, the issue of laminations is a technical question,. 24 and certainly the question of its safety significance. 26 While Mr. Nunn is an expert'in his' field, and
-. . . >, - _. - ...i, . . , , . . .
.c ,. iy . _ _ _ _ _ _ _ _ _ _ _ _
i l l 12,195 I Sim 21-3 I that is a qualified expert welder who knows good welds and 2 bad weld,s when he sees them, he is frank in conceding thah 8 his expertise does not extend to the engineering evaluation 4 'of the significance of what he knows and what he has seen i 5 with respect to laminations. 6 The Board Chairman observed on an ~ordei- that 7 Palmet.to has shown no indication of its ability to contribute 8 or make a technical contribution to the Board's resolution 9 of the lamination issues since they don't have a metallurgist to and they don't have a person with expertise, if you will. 11 Well, we have one, Judge and Members of the Panel, 12 and we have one that has come to us rather fortunately. 13 Mr. Kent spoke with us the last few days of last weck, and I4 I can't put my finger on whether it was Thursday or Friday, 15 but it was one of the last days last week. 16 He resides in Cyprus, California and works at 17 are remote location on a construction project and is literally 18 unavailable most of the time. I' He comes to us because he is known to the 20 Government Accountability Project since they have represented 21 him for some time. .Mr. Kent has an extensive background 22 as a nuclear industry. whistle blower. 23 He last worked for the~Bechtel Company at the 1 1 24 fO San Onofre Nuclear Station in California and there brought iV g l to the attention of the Nuclear Regulatory Commission and I f
l 12 196 Sim 21-4 1 the.public a number of problems in welding and left the (~N 2 employ of Bechtel under circumstances that in his view repre-Ed 3 sented retaliation- for his having stood up for quality 4 assuranen and stood up for quality work at that facility. 5 Mr. Kent informs me that he has a present action 6 Pending, an action for damages pending against Bechtel,
; .- 7 challenging the basis for his termination.
8 He recently testified before Congressman Markey's g' subcommittee of the United States House of Representatives to on the subject of ~ the NRC's zeal _or lack thereof in pursuing. 11 safety' problems in quality assurance at that facility and 12 the practices of his former employer in retaliating against 13 -him. i- \ 14 i I won't belabor ~his qualifications because
; 15 I think they are apparent on the surface of his-resume. He 16 has worked in a number of-nuclear facilities. He worked I 17 i at the Midland plant where because of concerns he expressed j 18 an NRC order ultimately shut down nuclear safety related 19 construction at that facility and required that welders for 20 a subcontractor be retrained and requalified and-that-other-
- 21 remedial measures-be taken.
Zt He is a. volunteer, Mr. Chairman. - Mr. Kent and M _I talked at, oh, it must have been ab'out 10 o' clock o'ur time 24 last^ night, _ and : I _ didn ' t know . that he would be a wintess
- tj , 25 '
until-that time becauseLI.franklyididn'tknow we could afford' h
- c- y A - r ,-
12,197 Sim 21-5 his plane ticket until.that hour.
/ He grabbed a plane at 11:30 last night and flew ~
2 s
\
out here and arrived at 8 o' clock this morning. I had. I previously, as I stated, sent him a Federal Express package of materials that I obcained only early last week from the applicants as part of the informal discovery made available, and including the NRC staff reports. So I will put it this way in terms of time. s We 9 had material for him to address in terms of substance beyond simply Mr. .Economos' three-page report which doesn't have much in it to deal with, if you will pardon'me. We had. that Monday mid-day, Monday of last week. _ 13 We transmitted that material to Mr. Kent and L spoke to him by phone at the end of the week after he had g 15 1 ked at it and only knew that he would be a witness at 16 10 o' clock last night. p We think that it is the dedication and interest 18 and, concern of nuclear industry workers like Mr. Kent and 3, . like the number of workers that you.'have seen in this proceeding, Mr. Nunn included, that makes him particularly
~
3 w rthy of this Board hearing what'he has.to say on this
~
21 22 technical issue.
- 23 .That.said, we.would ask that he be seated to-24 address the. question that.I stated, the safety significance 26 -of laminar'in'dications in steel.
12,198 Sim 21-6 g We also would intend, Mr. Chairman, to offer () 2 him subsequently to respond.to the other welding related 1 3 technical issues as they come up in the next couple of 4 days, but I tell you that because we may be able to solve 5 some of the qualification issues at this point. 6 JUDGE KELLEY: I think the Board may have sons 7 questions for you,~Mr. Guild, but why don't we hear next 8 from the other counsel. 9 Mr. McGarry. 10 MR. McGARRY: Yes, sir. We oppose Mr. Kent 31 taking the stand for the following reasons. 12 First, timeliness. Mr. Nunn made his position 13 know on the record, the In Camera record in early. November 14 1983. Mr. Guild was in attendance at that time and has 15 been aware of the concerns of Mr. Nunn since-that time. 4 16 Ms. Garde from GAP was also aware of Mr..Nunn's l 17 concerns at that particular. point in time. 18 The Board informed.all parties, not just the ig applicant, that if they proposed-to submit testimony.that
~
l 20' -such was to be provided by the-12th of 13th.of December. 21 : We met that date and.Palmettc didn't. n The staff was requested by the Board -to provide , .m information. The staffLindeed did provide such information.
,~s 24 Curiously there ewas some. discussion about the~ delivery of~
- i <:
' 5
') 25 . documents..from-the:. staff:-to Palmetto Alliance and that' I
r 1
+ + 4
., ~..- - -. -, -. - . . . - . - . . -. . . ~ . - - . . = _ . - . . . _ . = - _ - ,
a 12,199 1 Sim:21-7 -l1
-situation resulted---in this hearing being delayed, the under-2
. lying premise being so that Palmetto Alliance could have k_
3
-a sufficient amount of time to prepare itself for cross-
! 4 examination of the staff witnesses.
. 'end Sim' 5 *
.end 21-
~ Sue Fols 6 4-1; 7-i
- . 8 3- 9
- j. '
i- 10 - 11 1 12' 13 s [ J 14 A l 15 ' I 16 i ( 17L
-18
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'19 21 V
25 , q ' j 3 _ 1 ,
._ ir .. . . .
N - , - A- 2-
-'<-""*='"~'~'
" "~'~ " """
12,200 st 22/1 1 MR. McGARRY: (Continuing) However, so the
) 2 record is abundantly clear on this point, with respect to 3 lamination, the lamination testimony of the Staff was pro-4 vided in December. Our testimony was provided in December.
1 5 The Palmetto Alliance testimony is now proffered on January 6 30th, 1984. It's clearly late. It's clearly in violation 7 of this Board's rules, and it shouldn't be permitted. 8 Secondly, Palmetto states that this witness shed 9 some light as an expert on the safety implication of lamina-10 tions. We maintain that that shedding of light requires J 11 some denanstration of expertise. This gentleman does not ' 12 possess any engineering background. He is a welder. And [~*) 13 ne has been involved in welding QA. He doesn't have a v 14 college degree in engineering. 15 There is no indication that he has provided -- l 16 performed any structural analysis on large structures such l 17 as this. He is not a metallurgist. Yet, Mr. Guild says: 18 Gentlemen, we provide you a metallurgist. He's not one.. 19 so, therefore, he doesn't qualify as an expert. 20 Lastly, I look at Rule ~702. And one of the lynch-21 pins of 702 is- whether (nr not this gontleman's testimony will 22 assist you,fthe'tryers of fact. Now, early today I'said 9
.23 I did not want-to be bound by Mr.; Kent's cross-examination 24 7-sg in the sense of establishing his credentials as an expert. \ ).
3
'However,-I am not going to reference that cross-
201 st 22/2 1 examination. Speaking for myself, and with all dt espect f) s,- 2 for Mr. Kent, I found it totally unhelpful, totally dis-3 organized, and I submit if you ask yourself, gentlemen, 4 whether or not this gentleman's testimony will assist you, 5 you've already.got a record. It won't. It's confusing. 6 It's disjointed. 7 Going back to the first point, I neglected one 8 matter on timeliness, and that is that the Government Ac-l 9 countability Project has been representing this individual, 10 Mr. Kent, for some time. We understand, going back to the 11 - 1982 time frame. Mr. Guild acknowledged the fact that 12 GAP is representing Mr. Kent. 13 Clearly, this Board recognizes, as do the parties, 14 that there is some association between GAP and Palmetto 15 Alliance. Given the fact Mr. Nunn raises concerns-in 16 November, given the fact that GAP has been involved in this 17 issue, and he is representing Mr. Nunn, and given the fact 18 that GAP knew about Mr.~ Kent, why wasn't he brought forward I 19 in December? It's too late. It shouldn' t' come in. 20 Those are our reasons, Your Honor. 21 JUDGE KELLEY: Mr. Johnson, 22 MR. JOHNSON: Well, first with respect to the 23 timeliness of the proffer of Mr. Kent, we; feel that his.
- 24 being proferred today,:providing us with absolutely no '~'}
1 25' ' notice, tit's a surprise. I don't know-if it's a tactic or.
^"
c _ 12,202 st 22/3 1 not. I don't think it's relevant. But, it's unfair. There
) 2 is ne testimony to consider of any sort, of prefiled. Every-3 thing that Mr. McGarry has said about this history of this 4 case and the history of the In-Camera proceedings, we agree 5 with.
6 The notice, the opportunity to find witnesses, 7 et cetera, et cetera. , I don't have to belabor that. But 8 it seems to me that there is-an obvious element of surprise, 9 an unfairness, even now. We still don't know what this 10 gentleman has to offer, what kind of statements he might 11 make. 12 Secondly, I believe that Mr. Guild, his argument
/s 13 just now stated that gentleman is.being offered not for b.
14 l his expertise and to the structural significance of lamina-15 tions, but as somebody with welding expertise. So, that 16 may-be. But it seems to me that based on the statements 17 of Board and Mr. Nunn that there really isn't any question 18 about the welding. 19 Mr. Nunn said he was satisfied that the welding 20 was done as appropriate and was repaired, that the inspection s 21 and everything was okay from a safety significance. What 22 ' he was worried about was the so-called-rotten-pipe and the 23
'laminations in.the steel' plate itself, or the sleeve.
24
]-~c)
.Now,.Mr.l Guild says up front that'this man:really.
can't contribute muchlon tha't, if anything. His background
?
12,203 e 22/4 1 doesn't suggest that he could. His statements today don't 2 indicat,e that he could. And it appears to me that in terms 3 of the issue, that the Board and Mr. Nunn would like to 4 focus on, he is not an expert. He has little or nothing 5 to contribute. 6 So, on that ground we would -- we believe that 7 he doesn't qualify as an expert. The fact that he is a 8 whistle-blower, has a record as a whistle-blower, we believe 9 is irrelevant to his expertise. His cross-examination 10 questions today were of the nature that demonstrated that 11 he is not familiar with the issue, that he was not able 12 to focus on the issue. 13 (\j And in that light I would not expect that his I4 testimony would demonstrate knowledge of the issue or the 15 ability to focus on that issue. And I believe as a result 16 that a net contribution for such testimony would be negligible. I I must say that personally I would have liked 18 to have seen if Palmetto Alliance had a witness that they 19 play the game the same way that everybody else is going to 20 play it, and bring whatever expertise they had into this 21 proceeding. I think that would have been desirable. 22 I think it's too late, though. It's not fair. 23 And I don' t think we have an expert who can con:ribute to
.-- 24
( .) this record of the expertise we might liked to have seen. x_/ 25 So, we oppose his testimony.
12,204 st 22/5 g JUDGE KELLEY: I would just like to raise a () 2 . question that I would like to maybe ask all three counsel 3 to speak to just briefly. And I'm_not sure in my own mind 4 what I think the answer is. But it does strike me as a 5 procedural-question. It's a question of just what is it 6 that we are about here? 7 This is not the normal case. This is rather a 4 8 novel' exercise, in listening to the concerns of people who-9 came In-Camera. And what I wonder about is, we invite and i 10 have an In-Camera witness like Mr. Nunn. He comes in; he's 11 confidential ~for awhile, decides to drop that. But, in any 12 event I understand how that works. And we worked our way O
\)
13 through that process. 14 Now, Mr. Nunn is the. Board's witness, and.he 15 is here to have his concerns voiced. Obviously the Applicant s 16 are going to answer it with witnesses. .They.are defending 17 their obligation for a license. Beyond that,1 I assume the 18 Staff would have a case to put on, as they have. 19 It's not transparently clear to me, however, that 20 when you have this kind of a procedure set up, all parties-21 are in the posture.of' calling witnesses and' making cases, i
' 22 so to speak. I' assume we are going to-hear Mr. Nunn, and 23 we'may decide when we've heard-everything that's presented-24 that we've got a' safety concern.
,-s In our minds, weTay want
/
(W 25 to call somebody-else.-
. . - . . . . . . .. - - . - .- - - ~ - . - - - - . - -
12,205 st 22/6~ g, But it does not strike me as the normal type case. l 2 Mr. Nunn hasn't put any case on. We have asked M r. Nunn to 3 come because we want to know what his concerns are. He is
- 4 not a party. He.is a Board witness.
i
- 5 So, I gather that Mr. Kent is being offered as 6 a witness for Palmetto. - And is it your submission that l 7 all parties can put on cases in this kind of a setting?
8 I'm not so sure I. agree-with-that. I would just like some 9 comF.ent on ' it. 10 2 11 12 O 14 i 15
. 16 t
17 i , 18 . i. t .; 19 7 21 - t i N 23 4 24 i- , n 23 J a .
- w
- r'-
a 206 st 22/7 i gggg1gG gggg1gg (6 p.m.) 2 MR. GUILD: Yes, sir. I think it is clearly -- 3 the first point, you are going to be asked to decide whether 4 this plant is safe to operate. You can't c that on the 5 basis of only what the Company has to say and what Mr. 6 Economos has to say about this issue. You just don't have 7 an adequate record. You don't have an adversary record, 8 that's for sure. But I don't think you have an adequate 9 record. 10 So, the integrity of the record is at issue. 11 That's point one. 12 Second, this is an adversary proceeding, for 13 better or worse. Someone made a decision -- and it makes
)
14 sense -- to have a couple of sides slug it out and tne 15 truth would emerge. We could argue the merits or demerits 16 of the philosophy of the adversary system of justice in 17 this country. But, for better or for worse, the NRC licens-18 ing process is that. 19 Now, acknowledging the uniqueness of what we A) face with these In-Camera witnesses, and frankly compliment-21 ing the Board on having taken the step to do it, doesn't 22 alleviate the problem of when you have evidence that now 23 is not just one-sided, it's two-sided except both sides are 24 on one side of the scale, if you will, and that's the NRC 25 Staff just consistently supported this application. The-
l 12,207 st 2 2 / 81 record will reflect there has been virtually no criticism O (_) 2 of substance coming from the NRC on anything on.this record. 3 And Duke doing, I would submit, absolutely everything they 4 could, as soon as we had something of substance to sink our 5 teeth into with respect to this issue -- and by that, I mean 6 CP-88, the first time anybody has ever seen this thing, the 7 weld package in question, the description of the vendor- < 1 8 surveillance reports, the materials that came in the middle 8 of Monday. We did everything we could to try to obtain an 10 expert witness to accomplish those two points, to offer for 11 this Board a complete record or more complete record; and 12 second, to protect our-interest as an adversary party. 13 [aN So, yes, Judge, we think to protect our interest 14 under the due process clause, we have a right to be heard 15 in response to a witness adverse to my client's position. 16 Yes, Judge, we think we have a right to present Mr. Kent, 17 because we think it will provide a full record'with integrity . JUDGE.KELLEY: You may be right. I think it's a 19 debatable question, but I appreciate your position, Mr. 20 Guild. 21 Mr. McGarry. 22 MR. McGARRY: Yes, Your Honor. It's an interest-23 ing question. I'f you look at the contention, if you will,- 24
/~S or the issue, as a Board issue,-which this is, the Board L) ' 25 determines what it feels-is necessary here, because you
= _ _ _ _ _ _ _ _ _ _ _ _ _ _
l 12,208 et 22/9 l-raised it. None of the parties raised it. And, in that
. ,e~
'tu j 2 sense, none of us may have a right.to put on the witness, 3 We can seek it, but you have to make that determination, 4 determining whether or not you need to hear more. 5 Now, having said that, another approach or another 6 side of the coin, is that this is an adversary system. There 7 is an issue. .And every party should be given the right to 8 put on a case. I think we have already reached that point, 8 because I think this Board has said to the parties, loud and 10 clearly, in November when we were going'through the pro-11 cedures, if anybody wants to put on a case, you put it on, 12 you serve everybody, December 13th, and you put it on last 13
/~'g' week of December. I think this Board has said: We will (m,/
I4 give you an opportunity. 15 And Palmetto did not~take advantage of it. Now, 16 the fact .that they just got some -information from us should
~
I not have a-bearing on this issue at all, because our thesis 18 has been, I think this Board has already ruled and it has 19 been upheld by the Appeal Board, they could have sought 20 this discovery information-in November. LThey chose not to. 21- . So, I'think'it boils down,-in~ answer to your 22 : quection, I think I road the Board as already saying: -Yes, 23 _y ou have a right. And that right, no.later than December s N the 13th. December the 13th.
,\~# 25 '
JUDGE KELLEY: ' Speaking of.the Appeal 3oard, do
-.u, .._. . ._ . - . .
- r. -
12,209 st 22/10 1. any of'the lawyers have anymore' knowledge from that ruling? . -; 2 MR. McGARRY: Mr. Gibson does. p 3 JUDGE KELLEY: Could you give us a little thumb-4 nail sketch? i l .
- 5 MR.' GIBSON: Yes. I~ called the Appeal Board and 6 asked.-- I believe it was Judge.Rosenthal's1sacretary, to 7 . read me the text of the Order. Juld I will. just paraphrase 8 my notesfhere.~ It's a page and a half,-but I have about L
I 9 four points.from the notes here. ;The. Motion for direct- {.
- ~
10 certification was' denied. The AppealIBoard stated that they 11 [' . were unpersuaded'that Palmetto had me't the Marble Hill 12 standard, and that 'they were satisfied- that. Palmetto had t j 13 had an ample opportunity to obtain information prior to 14
..the hearing and that'~shoul'd the Board' ruling go against 15 Palmetto that it could be corrected on appeal, .and. that -the 16 Appeal-Board was making it clear that any Motions;for 17 interrogatory appeal'that'did not. meet the Marble Hill 18
. standards- would be summarily denied. And that-this case 19 i
fell within that. general ~ statement.
.e:
f We 'were = attempting :tolhave. a copy of 1that
- i. 21 ~
.available tomorrow,-because offits obviousibea' ring.on'the 22
_ Motions; filed.this; morning. 23 : JUDGE.KELLFY: Thanktyouifor:the summary.- If-24 l- ~you'.get [a L hold of j a copy,f I w'ould appreciate f it. LThen,- ,
- 26 .-
, we'can move on.3 l-Mr. Johnson, ILwantito. hear-your' view,[too,1 , L m _ n t 4
, J , 4
.- - - . . . - . . .=. . -, . , . ~ . ,
i 12,210 st 22/11 1 on my possible philosophical question. ('~'\ 2 ( ,/ MR. JOHNSON: Thank you. I go back to -- I l 3 think it may-be November 3rd that we had our meeting in i 4 the late Judge Heppen's courtroom, in his Chambcrs. And, 5 as I recall, the general outline of the expected procedure, 6 it was that Mr. Nunn and the others testimony was seen as 7 adverse to the Applicants, and they in fairness ought.to 8 have an opportunity to have discovery about it. And, then, 8 in general as to_In-Camera witnesses and to be able to 10 rebut it with witnesses, if they so desired. II And that the Staff, if feasible, could present I witnesses, too. I don't believe at that point in time (T y/ 13 it was discussed -- I don't remember Mr. Guild or Ms. Garde I4 raising the point that they.also wanted to put on a case.. 15 I think perhaps if they had done so at that_ time, it would 16 have been a minimal. 17 I think also, as Mr. McGarry pointed out, had 18 the opportunity to follow the scheme that was: presented. 19 I think it-is a-proposition that this is an ad hoc procedure 20 and that was what was set up. And~I think that if they had 21 done,so in a. timely manner, that-it would not have been inappropriate forfthem to offer a witness if.they could 23 find one who is qualified'and who could contribute to the
-24 --
I f-s . l record.- I don't think that's the case'here. x M 1 ! l '- But in terms of just -general proposition as to j
L 12,211
' s t' 22/12 1 whether in the abstract.they ought to be able to call 2 somebdoy, I think we are going back to the beginning.
w i.,
,' ' f!r' l '; 3 4
5
.6 7
8 9. 10 11-12 13 14 15 16
'17 18 19 -
20 21 22 : 23 J 24: 2.
.(
L__________z______.____:i:---_-L_._--___-_.-_-____-_--_ _ _ _ - _ - - _ _ . - - _ . .
l 12,212
.T23JRBsjrb fisSue NITESESSION I JUDGE KELLEY: Then I guess one crosses the bridge I ~h (Q 2 later, when somebody wants co call five or six or eleven 3
witnesses? 4 Well, I tell you, I don't think the question is 5 totally abstract; I think it's very practical. I don't know 6 how you're ever going to do this if there's no limits at 7 all on what kinds of cases get to be put on. 8 But, be'that as it may, gentlemen, I appreciate 8 your points. 10 MR. RILEY: Judge Kelley, may I be heard on this? 11 JUDGE KELLEY: Yes, briefly. 12 I think Mr. Guild is proffering, you're joining 13 the proffer; right? 14 MR. RILEY: That's right. 5 JUDGE KELLEY: Okay, so that you can be heard on 16 it briefly; go ahead. I MR. RILEY: Yes. 18 It's an imperfect world and we have to deal with 19 it: Mr..Nunn is the-Board's witness. We see the Staff 8 and the Applicant pretty much jointly.do things.that would 21 tend to impeach his testimony.as to relevance and so forth 22 and so on.. 23 I think to have balance here, we need to have a 24 7 witness on the other side of the fence, which I believe Mr. Kent is. And I wanted to point that'out to.the Board.
'l 1
23-2 12,213 1 JUDGE KELLEY:' Okay, fine.
,O. \s- ' 2 Mr. Guild, one other point I want to point out.
3 It's ten after six. When we had the Ber.ch-4 Conference there was some talk about whether you might or 5 might not have an outline tomorrow, what your timing proposa] 6 is. 7 It sounds to me that however we rule on this, 8 it may make more sense under all the circumstances to rule 9 pretty early tomorrow morning, rather than try to do it la now; we just want to talk about it. 11 Can you--you don't have'any prefiled, and I think 12 that is a problem from your standpoint. 13 (} Is there anything you can supply in the way of 14 an outline or something like that? 15 MR. GUILD: Yes, I can. 16 We can'probably do that--well, I can give an 17 outline to the' parties, you know, this evening, this 18 afternoon, when we adjourn. I.can sit down and tell them 19 what we want to cover. 20 Or I can provide one first thing in the morning. 21 If you don't care about the cosmetic aspect of it, 22 I can jot down some notes and you will have an outline, 23 something to work on.
<^S 24 If they want it typed up, then it will.be tomorrow 26 morning. But we're prepared to do either one of.those two
- .. .-__m._____m mm _ _-u_ _
23-3 l 12,214 1 1 1 things or to put together a piece of prefiled testimony. O) (s, 2 But just in effect you take, say, a panel member's 3 testimony from Duke--a whole panel: there may be five 4 members on the panel, and the testimony is three pages long. 5 And they just say, you know, we inquired into these records-- 6 JUDGE KELLEY: Let me suggest: I don't think the 7 Board wants a direct on this one way or the other in terms 8 of detail. 9 MR. GUILD: Right. 10 JUDGE KELLEY: You are prepared to'make an effort 11 to do something along those lines. l 12 MR. GUILD: Yes. 13
} JUDGE KELLEY:
O Try and get together when we break 14 here, and then-do whatever you want to do. 15 MR. GUILD: Fine. 16 JUDGE KELLEY: And I say, the more you can do the 17 more you thwart the objection of not having prefiled. Okay? 18 MR. GUILD: ' 'Yes, sir. ! 19 JUDGE KELLEY: So we would anticipate ruling on this matter if_not first thing, then pretty early on~ tomorrow l 21 morning. 22 ' I think now we'd:like to move ahead and follow 23 with Mr. McGarry's' foreman override panel. 24
. ,,,( ~ MR. .MC GARRY: Yes, sir.
1
~') -25 (Pause)
23-4 12,215 I I call to the witness stand a panel to discuss [V 2 the foreman override issue. 3 Several of these gentlemen have not been l 4 previously sworn, and maybe those gentleman that haven't 5 been sworn, if you would please stand and the Board can i . 6 then swear you in? 7 Whereupon, 8 MORGAN DANNY RAY 8 MALCOLM YOUNG 10 DAVID BUCK HENRY 11 KEN WEBBER 12 HARRY BARKER 13 L and I4 J. R. WILSON 15 took the stand as members of Applicant's panel of witnesses IS and, having been first been duly sworn by Judge Kelley, 17 were examined and testified as follows;-and, DAVID LLEWELLYN JOE SHROPSHIRE 20 ED MC KENZIE LARRY RUDASILL 22 RON BARNES 23 - and' [N. - WILLIAM ROGERS
~ k) 25 resumed the stand,as members of Applicant's panel:of witnesse s T wW9y , -
1-= i -- g + f 4 to C-
23-5 .12,216 1 and, having been previously duly sworn, were further 2 examined and further testified as follows: 3 DIRECT EXAMINATION 4 BY MR. MC GARRY: 5 Q Gentlemen, do you have a copy of the testimony 6 of W. E.-Rogers, et al., Regarding In Camera Witness No. 2's 7 Alletations'Concerning Foreman Override, before you? 8 A (Chorus of: "Yes, sir, we do.") 9
- 1 Q Do you have any corrections or additions to make t -
10 to that testimony? 11 A (Witness Barnes) We have three additional panel 12 members whose names do not appear on this testimony, and 13 they need to be added. 14 Q -Yes. 15 And that would be Mr. Ray, Mr. Henry, and Mr. 16 Young; is that correct? I A Yes, sir. 18 . 9 And, gentlemen, I ask you to answer this 4 19 question along with the other panel members who have been 8 previously identified: i 21 Gentlemen, do you all adopt the testimony of
~
1 22 W.-E. Rogers as your testimony--W. E.' Rogers, et al., 23 concerning the issue of foreman override, as your testimony I i 24 ~ for use in this proceeding?- i 25 -
.A (Chorus ~of: "Yes, sir.")
n
23 .6 12,217 1 Q And if I asked you the questions set forth in
)
\ s' 2 this document today, would your respond as set forth in 3
this document, today? 4 A (Chorus of: "Yes, sir.") 5 MR. MC GARRY: Your Honor, at this time we would 6 request that the testimony of W. E. Rogers, et al., concern 7 In Camera Witness: No. 2's allegations concerning the 8 foreman override be marked for identification as Applicant's 9 Exhibit 112,-and be received in evidence. 10 MR. GUILD: We have an objection, Mr. Chairman. 11 JUDGE KELLEY: Could we make a clarification, first, 12 I think it's probably kind of obvious.
/m 13
(\ ,/
) Witness No. 2 does refer to Mr. Nunn?
I4 MR. MC GARRY: That is correct. 15
- JUDGE'KELLEY: And we can say that now, I understard 16 it was "No. 2" when it was filed, so that i:s clarified.
17 I notice that you have initials following para-18 graphs in the fashion you have before in other testimony. 19 The three witnesses that you've added, though, do we have 20 4 additional initials'for.them? Are they here for a specific' 21 paragraph or paragraphs? 22 1 MR. MC GARRY: Yes, they are here~for the limited 23 purposes and I.believe that if we turn to page 6, at the
'24 4
yx - bottem of page 6,,we have-No. 3, that's Mr. Young. LS o, a'~') M Mr. Malcolm Young, sitting at the.back of-the row closest
23-7 12,218 I to me will also be sponsoring that paragraph. ((~ 2 Then we go over to the uottom of page 7-- 3 JUDGE KPLLEY: Essentially, have you added people 4 who are in one way or another involved in these various 5 incidents? 6 MR. MC GARRY: Precisely. These are the three 7 welders in question. 8 JUDGE KELLEY: Thank you. 8 MR. MC GARRY: And they are simply subscribing 10 to their respective pieces of testimony that appear between 11 pages 6 and 9. 12 JUDGE KELLEY: Okay. (/~N) 13 Are there other initials that we can add there-- 14 Mr. Henry? 15 MR. MC GARRY: Mr. Henry would be added to 16 paragraph number four on page 7, it runs over to page 8. I And Mr. Ray would be added on naragraph 5, the 18 bottom of page 8, which runs over to page 9. I' JUDGE KELLEY: Okay, I think that answers those 20 two questions. We thank you, - t MR.' GUILD: That was the first point I' intended i to raise, and I appreciate your clarification. 23 So do I understand the three new witnesses only
. 24.. /~] % j' sponsor those parts ofLthe testimony?
25 And ILwould just reassert the objection made-
~
23-8 12,219 1 to the testimony of previous panels, and that is as to 2 lack of opportunity for discovery. 3 And to the extent that there are, I think, in this 4 document sort of classic hearsay elements, and that is, 5 we rely on the interviews of-so-and-so, information from 6 thus-and-such, or records reviewed by so-and-so--we would 7 object to those in hearsay grounds. 8 The Board has heard that general objection on 9 previous panels, unless you want to hear some more details? 10 JUDGE KELLEY: I think we understand it, and have-11 made prior rulings. 12 It does seem to me that.this panel means quite a 13 few people, and I would hope they have enough collective
'w./
14 knowledge to address the facts. 15 But we're going to--I understand the objection for I 16 the record--and we are going to overrule it. 17 MR. GUILD: And the same objection would go to 18 Board's nosition on voir dire of.the panel members before 19 their taking the stand, and that it must'come out of our
~
limited cross time. 21 JUDGE KELLEY: That's correct. 22 I might just add, though,1this group.here are 23 experts in the usual _ sense? I dont think a foreman override 24 really calls for expertise. t%
% 25 i Do you see it in that light, Mr. Guild?
J t
23-9 12,220 f 1 MR. GUILD: I don't know, I guess it's for i p) (, 2 Applicants to say whether they intend to present these 3 people as experts. I keep seeing Mr. Shropshire and 4 Mr. Llewellyn cropping up, and if they are going to volunteer-5 they're not experts, maybe I'd have half my problem gone; 6 but they keep coming up with expert hats on, Judge. 7 JUDGE KELLEY: Personal pique? 8 Well, I don't mean to be frivolous about it. 9 Mr. McGarry, are these panel members offered as 10 experts in the narrow sense, the technical sense of the 11 term? 12 Or are they here because they know the facts of 13 certain incidents? 14 MR. MC GARRY: Your Honor, I think primarily, if 15 not toally, this is a fact issue. I'm just looking through 16 the testimony right now to see if there's any expertise. 17 (Pause) 18 In 11 they had some expertise. 19 JUDGE KELLEY: I'll-put-it' differently: is this 20 predominantly an expertise submission or not? 21 MR. MC GARRY: That's correct. 22 JUDGE KELLEY: Okay. 23 MR. MC-GARRY: We move the Board receive-24 . Applicant's Exhibit'll?.
- 25 JUDGE KELLEY- -The motion has been'made and the
23-10 12,221 1 objection has been heard; and we've ruled. 2 And the testimony, this exhibit--you got a number ) 3 on that? 4 MR. MC GARRY: 112, your Honor. 5 JUDGE KELLEY: Applicant's Exhibit 112 is 6 admitted. 7 MR. MC GARRY: Thank you, your Honor. 8 (The document referred to was j 9 marked Applicant's Exhibit-No. 10 112 for_ identification, and 11 was received in evidence.) 12 MR. MC GARRY: Thank you, your Honor. The panel 13 is available for cross-examination--Board questioning. 14 JUDGE KELLEY: Okay. 15 We did talk a minute ago about the hour and our 16 plans, and I think maybe we can say that--to those of you ~ 17 who didn't go to lunch and want to go to dinner' tonight, 18 we thik we'll quite at about seven. 19 This will mean that we won't finish it tonight, 20 but I expect.it will pick right up_first thing in the 21 morning. I. don't know when we're-going.to start exactly 22 in the morning. So you should be done in~the morning. 23 MR.-MC'GARRY: Yoar Honor, I don't want to make 24 La major issue.of it; it's 6:20.
'q) - 26 But-my understanding is that Mr. Guild has used
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23-11 12,22 2 I quite a bit of his time, and there might not be any time
, (- 2 left for Palmetto Alliance.
3 JUDGE KELLEY: Well, I was going to read the - 4 allocations in that regard. And here's what we've got: 5 We had gone on the basis that when we got to this 6 issue, again, we'll have two panels--you got a panel or a witness on this? 8 MR. JOHNSON: We have two witnesses. 8 JUDGE KEI. LEY: Okay, so you got a panel? 10 A small panel? 11 MR. JOHNSON: Yes. JUDGE KELLEY: We don't see this whole issue as 13
, being as complex and difficult as laminations and we think a little less time is warranted. We were thinking that I
. Palmetto specifically would get 20 minutes on each panel, meaning that you went to the bank--that's 40 minutes in toto 17
--and you went to the bank for 27, leaving you 13; and 18 we thought that we should give you a little more; so we l'
are going to allocate 10 apiece to you, or 10 for each 20 panel. 21 Now, here's what we've got for the whole line-up, 22 then: N The Board will start with just five minutes.
' 24 Staff gets 15--doesn't have to take it all.
.s Palmetto gets,'10.
-- - - - me-y .-, , , , ,- -
e- m--, ,,- ,
23-12 12,223 1 State gets 5. 2 Applicant's get 15. 3 Board gets 10 at the end. That makes 60. 4 Now, it won't go quite that smoothly, and, 5 therefore,'we suggest quitting at seven because that's seems 6 wise under all the circumstances. 7 MR. MC GARRY: We don't disagree, your Honor, but 8 I think as we draw near seven we might see that we've got 8 a chance to finish the panel. 10 JUDGE KELLEY: We can consider that. 11 MR. MC GARRY: The State, who has been here , 12 diligently every day, has a personal problem or personal 13 situation; and he's gone. So we've saved five minutes I4 right there. 15 So the panel is ready now. 16 - JUDGE KEI ~4Y: Well, if it's moving along we'll consider that, but it's not our fixed expectation. 18 Okay. 18 - EXAMINATION BY THE BOARD BY JUDGE PURDOM: 21 Q .Mr. Young, on page 6 and continuing over to page 22 7, it is stated that the welder--and I guess that's you-- 23 stated he was not pressured by his foreman to get the job 24 done at the sacrifice of quality. 25 Is that staterftent so?
-- . ... ~ .. _
23-13 12,224 ! 1 1 A (Witness Young) Yes, sir. ' ( 2 Q The next question I had dealt with paragraph 4, 3 and I notice there's several names on it. It deals with 4 line 20 and goes through line 22. 5 And it says that the incident did not occur 6 as described. And then in the next sentence it says 7 conversation with the welders--who is the welder in that 8 case--Mr. Henry? 9 A (Witness Henry) Yes, sir. 10 Q And this states that the welder, I guess that's 11 you, stated that he was not pressured by his foreman to get 12 the job done at the sacrifice of quality. 13 Is that statement true? 14 A Yes, it is. 15 Q On page 9, paragraph 6, there's several people 16 supporting that; and any one of you can answer it, or all 17 of you: 18 But it states there that with regard to the 19 witness' allegation concerning pressure by Mr. Radasill 20 to the foreman of tack weld fitups on pipes for Mr. McKenzie' s 21 crew that the paperwork--no records could be located. 22 But if it was done without any paperwork, why wouldn't you expect to have no records? I mean that seems 24
,, kind of a self-evident statement.
( '6 4 I just wonder what the purpose of that sentence is 4
--_c _.- . . . _ . , r _,,-.
23-14 194.25 1 and some explanation for it?
-(' 2 A. (Witness McKenzie) Your Honor, I might say 3
something about that. 4 Q Would you identify yourself for the record? 5 A Ed McKenzie. 6 To start with, Mr. Rudasill never welded for me. 7 That's the basis to start with. We went through the records 8 and we could find none that Mr. Nunn welded. 8 Q So if he didn't ever work for you, that's 10 different from saying there's no paperwork, there's no 11 records; it looks like it was done without paperwork. 12 You can see my puzzlement on that statement. (, 13 A Yes, sir. 14 A (Witness Barnes) Also, there were no 15 nonconforming item reports or deficiency reports where such 16 an event had been detected or reported as having, you know, 17 an attempt being made to violate the program; there were 18 no records of that type, either. 19 Q Well, there, again, if there's no paperwork, 20 and the allegation is that there's pressure to do something 21 without the paperwork and proper records--you don't expect 22 to find paperwork and proper records. 23 A But if he were pressured to do something he thought 24 were wrong and he reported it to someone, it's likely the 26 nonconforming item repo]rt would have been written to document __ _, . _ _ , _ _ . - , ,, . ,,, 4 -_ , . .. __
~
23-15 12,226 1 that; and there would have been a record of the incident , 2 k, not of the weld, but there would have been a record of the 3 incident. 4 5 We searched the record for such an incident and couldn't find any. 6 Q Basically Mr. McKenzie said that this fellow 7
-didn't ever work for you?
8 A (Witness McKenzie) No, sir, 9 he has not worked for me, not to my knowledge. 10 Q All right. 11 Page ll, No. 7 refers to construction hangers; 12 what are construction hangers that are referred to here? 13 What is their purpose? (. 14 A (Witness Shropshire) Maybe I can help on that 15 particular question. 16 Construction hangers are hangers that are put up 17 during the erection process, and they are generally ' 18 temporary hangers; hangers that are removed when the 19 permanent hangers go in place. A (Witness Barnes) Barnes, sir. 21 I might elaborate on that a little bit. 22 We use construction hangers--the term "construc-U tion hanger" to differentiate from design hangers. Design 24 hangers being the ones that are used on nuclear safety ( 25 related applications, where a specific, unique, design
23-16 12,22 7 1 is done for a location and an application. 2 construction hangers are put up for non-safety-3 related systems and are basically sized to typical sketches 4 and a span chart is used based on the size of the pipe 5 and the fluid it carries to determine how frequently you 6 place them. 7 So construction hangers are not safety-related 8 hangers on reasonably small diameter pipe. 9 BY JUDGE FOSTER: t to Q Can someone tell me how the schedule is establishec. 11 for completion of a job of welding? 12 I gather you have a welding cres which is going 13 to do a particular job; somebody established the schedule 14 of-how much time will be available for it. 15 How does that work? 16 A (Witness Webber) Webber. 17 I might could speak to that: the welding 18 schedule is not set per se, but the piping schedule is 18 set. Piping erection will have an index to the piping to 20 go up. And'the welding coincides with that. 21 We calculate the the fitting time and the welding 22 time into that together so that that end date reflects the 23 welding completion date. 24 Q Who supplies the information on how much welding 25 time is going to be neehed? y . e .- - - my - --- me p ,+ vnay ~ w - e e, - -- q
23-17 12,22a 1 A Okay. We have a scheduling department that ( 2 interacts with the craft; craft gives input to how much 3 time it takes for the welders to weld, or the fitters to 4 fit; and they-put that together to make the schedule. 5 Q Do the foremen get involved? Are they ever 6 asked how much time it's going to take to do that? Or who 7 is the person t t supplies it? 8 A The foreman, the general foreman and sometimes 9 superintendent all have a input. 10 Q Is that routine? 11 A Routine, yes. 12 Q Now, you 7 act a foreman, are you? 13 g yem sorry, I'm piping superintendent. 14 Q Piping superintendent. 15 I would like to ask a welding foreman how 16 frequently they have input into that schedule for a 17 9 particalar job? 18 A (Witness Rudasill) Rudasill. 19 Normally, unless we're getting close to completion 20 on a system, we are normally not under a scheduled time to 21 have each weld. 22 Q Does it eve.- happen that the, let'; say a 23 particular piping system is supposed to be campleted, and the people come down to the welding foreman and say: how 25 muchlongerisitgoingjtotakeyoutogetyourjobdone
23-18 12,229 I here? 2 A (Witness Wilson) I'm the welder general foreman. 3 I got a schedule meeting once a week and the input, a lot 4 of it comes from me as to how much time. It's like 5 Mr. Rudasill said, usually until we get down to a month or 6 six weeks before a syst:em is scheduled to be completed, 7 we just kind of work with the fitters. 8 But after it gets down to a deadline then the 9 welders' general foreman does have a lot of input and he 10 gets it also from the welders' foreman. 11 Q If you find that you're sliding behind, what do 12 you do? 13 ('~ END22 REfls 34 15 16 t' 17 18 19 . 20 21 22. 23
- 24 25 .
TAKE 24 # r:0 page 1 1 A We Sometimes will put two shifts on or ( '2 work overtime. That goes into our schedule. We either 3 schedule it for overtime, about ten hours a day or 4 six days a week, or sometimes we put two eight hour shifts 5 in order to complete it by a certain date. 6 Q Do you make it known to your welding foreman 7 that the job is getting behind and you need to get it 8 finished on an accelerated schedule? 9 A Yes, sir. We do. 10 A (Witness Rogers) Rogers, a welding superintendent. 11 I would like to add a couple words to that. Sometimes 12 if we get down to the end of a system and we are getting 13 pressed for time, I might bring another crew in to assist 14 if we ; tere to find ourselves in that situation. 15 ~ A (Witness McKenzie) McKenzie. I would like to 16 add something. .You know, we know a long time in advance 17 what this end date is, and we try to work to that end date 18 during a period of a year and a half. And we try to 19 eliminate that rush time at the end or that time that we 90 run out of'. 21~ A (Witness Barnes) Barnes. I am responsible 22 for scheduling on this Catawba project, and generally the 23 critical factor in meeting a scheduled end date is not 24 the availability of the wolder craft or the rate at which 25 the weldern are welding, g It is usually a factor of a late r , +, , . . , -, ,,,---,n- . . , , - ,- . - - - . - . . . , . - - - > , - , , , - -
12,231 1 change that we have to factor in. It is not a pure
'( '2 production thing. Usually, when you get down to the end, 3 i
.t is not just gross production. It is sequencing type things 4
f that delay the finishing rather than gross production type 5 problems. 6 Q If there is a particular crew that seems to 7 be not getting their job done, how does that work? 8 A It is looked at'from several ways. Principally 9 we look more to the pipe fitter crew in terms of getting 10 the work done, because the fitting and welding is 11 such an integrated operation in erecting the piping, and 12 we principally track fitter production more than we 13 really do welder production. ( 14 JUDGE FOSTER: That is all.
~XXXXX 15 BOARD EXAMINATION 16 BY JUDGE KELLEY:
17 Q Have you been doing scheduling for quite somc time?
.18 A Yes, sir.
19 Q It is sort of a broad question maybe, but has 20 welding ever been on the critical path?
^
21 A Not that I can recall, particularly not pipe 22 welding. We are well ahead of end piping in advance of many 23 of'the other major commodities. We have a lot of flows, 24 if you will, in most our piping work. 25 0 What are the apher major categories? Like --
^
p dUTT 12,232 1 A Cable pulling / electrical -- 2 Q I mean within welding. You say pipe welding 3 isn't on the critical path; 4 Is there some other kind of welding that is? 5 A-The most critical thing that we have had has 6 been the welding of rupture restraints inside containment , 7 and that wasn't principally because of the gross amount 8 of welding;- It is just that welding is the last thing you 9 do to them and the design changes that delayed it up front , 10 Q But you would generalize and say, I take it, 11 that welding over the years at Catasba has not been the 12 item that has been holding things up? 13 A Yes,' sir. I would say that. 14 JUDGE KELLEY: Mr. Johnson. XXXXX 15 CROSS-EXAMINATION 16 BY MR. JOHNSON:. 17 Q Mr. Henry, which is Mr. Henry? 18 I would like to read some statements made by 19 Mr. Nunn back on November 9 to you and then I would like to 20 ask you to comment on that. 21
-This begins on page 182 and goes to 184 of the 22 transcript from that day. This is Mr. Nunn talking:
23 I want to tell you about something that 24 happened right before I left Catawba. This concerned a ( 25 welder named Buck Henry.
-24/4 12,233 1
Is that you? 2 A (Witness Henry) Yes. 3 Q To the best of my knowledge, he is on 4 Mr. Rudasill' crew now. His name is D. A. Henry, 5 Everybody calis him Buck, He,was a helper and he worked 6 real hard to get his stencil. He was loaned over to a
?
welder foreman on No. 1 side by the name of Tim Hollingsworth . 8 This is the story that Buck gave me. 9 It is Friday afternoon. The grid that Buck 10 is using or the welding machine that he is using is n defective. He didn't have enough power to push a one-eighth 12 rod. To push a one-eighth rod on the Mos up there, you 13 have got to -- you have to get to 170, 175 amps even though 14 you will really only be running about 150. 15 The fine-tuning valve was broken on this. 16 He had 100 lever and he had a 50 lever, and that was it. 17 He had a welding job there on the table, a paperwork hanger 18 and it called for a partial penetration weld. And this 19 would be like a plate like so, and then another piece of 20 metal that was beveled like this. And you had to get the 21 metal down there as far as you possibly can, 22 About 3:00 o' clock he is out of 332 rods, the 23 smaller rods, You could easily push the rods with a 145, 24 and he tells Tim Hollingsworth that he is going out to the p mi i rod shack to pick out another pound of 332 rods. And
12,234 j 1 Hollingsworth tells him no,' that that job has to be done, 2 to go ahead and use the one-eighth. And he said, well, 3 Tim, this machine won't push a one-eighth. And he said, 4 I am the foreman and I am telling you what to do. And you ' 5 go ahead and use one-eighth. 6 And Buck did the best he could and he made a 7 mess out of it. Somebody over the weekend -- QC, QA man, 8 I don't know who saw it, but somebody saw it and Monday 9 morning Buck was called on the carpet. He tried to 10 explain his side of the story, but nobo'dy wanted to listen.
.11 They pulled his stencil, took his qualification 12 away from him, nade him go back out to the test shack 13 and retest. Had he not passed his test, he would have 14 been demoted back to a helper and all the while, in my 15 opinion, Mr. Hollingsworth was the one to blame.
16 We have been told before, quality, not 17 quantity. We have been told safety first, but that is not 18 always the case. In this case this man wanted to get this 19 weld done, and then when it fouled up and Buck said, I 20 told him that the one-eighth one was too big of a diameter, 21 that it lacked a quarter of an inch, if I push it all the 22 way down of even getting to the bottom of the groove, but 23 4 still he was made to go ahead and to do this because the 24 foreman told him to do so, and I don't think that is right. ( 25 That was the s4,atement made on November 9 by 4
12,235 24/6 1 Mr. Nunn. And I would like you to focus on particularly ( 2 the question of your running out of 332 rods and the 3 availability of the one-eighth rod. And could you tell 4 me whether there was anything inappropriate with using 5 the one-eighth rod in that situation as opposed to 332 rod? 6 A (Witness Henry) I believe either rod could 7 have been used in a situation vith the weld. 8 Q So you don't'believe it was improper for your 9 foreman to tell you to use one-eighth rod? 10 A No. 11 Q So as best you could explain it, what was 12 the source of the problem as it developed? Apparently 13 the weld was a bad weld; is that correct? 14 A Henry. Yes. But I couldn't get my heat rod 15 I was using, I couldn't get it to run right. 16 Q I didn't understand the answer. 17 A I couldn't get the metal to flow out of the 18 rod I was using. I couldn't get the metal to flow out 19 the root path, the stuff I was using, the material I was 20 using. 21 Q So what was wrong? Was something wrong with the n rod or was something wrong with the -- 23 A It was more or less the machine. 24 Q The machine. And did you inform Mr. Hollingsworth 25 that that was the prob em?
, , . . - , + - . , - , .,--
12,236 24/7 1 A' I did later on.
.( 2 Q But at the time of the incident, when he said, 3 Finish the weld, did you inform him at that time that 4 you were having trouble with the machine?
5 A No, sir. 6 Q Mr. Young, on page 195, same testimony by 7 Mr. Nunn, November 9. Mr. Nunn states the following: 8 A similar thing happened to a man on 9 Mr. Rudasill's crew when I first went to Catawba, 10 a man named Malcolm Young, You remember me talking about 11 Mr. Pride wanted to cut into a line to put a valve in 12 and finding a weld that supposedly x-rayed good. They 13 cut into the line that Malcolm welded on two years 14 previously, and this was just a class G weld. We were told 15 that class G like class A, and Malcolm said, Well -- 16 said he well remembered that weld. He was on a night 17 shift -- on night shift at the time and the fitters made 18 a sloppy fit on it. They didn't put the proper bevel or 19 proper land. 20 I am not sure that that makes too much sense, 21 but that is what it says.
- 22 They slopped.it together. He went to his foreman l 23 and he told him. I don't know who he was, but told him it 24 was ridiculous. They had it gapped open one place and I
g slammed together at another. It didn't have the proper [.
24/8 12,237 1 gap or proper land.
.: 2 Do you have some idea, Mr. Young, could you
-3 explain what that means,' proper land?
4 A (Witness Young) Well, when they cut the metal 5' down to -- put the bevel on the pipe, 37 and a half 6 degree bevel, they you have got a land indicating either a
, 7 sharp or blunt edge is what he is referring to.
8 Q That is a part of the pipe or part of the weld? 9 A That in part of the pipe, 1-END TAKE 2410 0 Okay. REE 11 .
- '12 13 .,
- 14 15 16 17 18 19
! 20 21 22 23 24 L (~ , i l
NON REG HOURS 12,238 Sim 25-1 I
-Q I Am going to continue reading. "I have already
( mentione,d that, that he was told that it was Class G. Go 3 ahead and weld it and weld it out. He, too, lost his stencil 4 and Malcolm is. good welder. Malcolm has about the same 5 number of years that I do. He had to retest. He came that
-close to quitting, that it was all over, the job."
7 I would like to know if this was a Class G weld, 8 does that mean that it didn't have a fit-up inspection? 9 A (Witness Young) It had a final visual on the 10 paperwork. 11 Q It had a final visual on the paperwork? 12 A (Witness Young) Yes, sir. ( 13 14 Q So that it was more or less up to you to determine whether to go ahead and do the weld? 15 A (Witness Young) The fit was made in code on 16 the paperwork. 17 Q You are saying the fit was made in code. Does 18 that mean that the fit was acceptable to you? 19 A (Witness Young) Yes, and I did not have my 20 stencil pulled from it, or I did not -- well, my stencil 21 was not taken out of service due to the fact that the weld 22 was not good. 23 Q So you are saying that the statement that you
^-
24 didn't make intermediate in that logical flow is that the 25 e weld came out bad; is thdt correct?
12,239 Sim 25-2 1 A JNitness Young) Ye's , 2 Q And you are saying that your stencil was not 3 ) pulled as a result of doing that bad weld? 4 A (Witness Young) Right. It was not pulled. 5 Q Okay. Well, what happened in this particular 6 case? If you could just spell it out, what actually happened? 7 A (Witness Young) I did go back to the test shack 8 just as a means to run a test, but I lost no certification 8 of it. The weld was bad. It had 1/8th of an inch excessive 10 penetration. 11 Q Okay. Thank you. 12 Mr. Ray. Which is Mr. Ray? 13 ( A (Witness Ray) Right here. 14 Q Hi, Mr. Ray. We are going to do the same exercise 15 with respect to the reference to you in Mr. Nunn's testimony 16 of November 9th. 17 On page 257 he starts out in answer to a question 18 having-to do with examples, he says, "I have that one. I
- 19 don't know the details of this case, but Marion Danny Ray."
20 The question is "I am sorry?" 21 And the answer is "Marion Danny Ray." 22 The question is "Can you share with us why 23 you would use him as an examp? i?" 24 The answer is "Just basically Danny tested about 2. thesametimethatBuckpid. They were helpers at about
12,240 Sim 25-3 1 the same time and I understand Danny was having problems ( 2 with his, not tig wire, but with his stick rods when we 3 were all having problems with porosity. He was afraid somebod:( 4 would see it and he'kept welding on top of it and welding 5 on top of it and he ended up with a weld that was way too 6 large. It was an error in judgment that a lot of young welder s 7 will make and Danny is a good kid, but he also had to get 8 retested." 9 This is a question. "Do you know if the welds 10 he was working on would have been inspected by the quality 11 assurance department?" 12 The answer is "I don't think they would have
.- 13 been unless they had been brought to the attention of 14 quality assurance. I think they were Class G and didn't 15 require any final visuals on them."
16 Question. "Now Marion Danny Ray, I take it, 17 is a separate concern. I don't see how that relates to 18 foreman overrides, which was the topic." I8
~ Answer: "It had to do with foreman pressure."
Question: "To do good work?" 21 Answer: "Yes." 22 Question: "Who was this foreman?" 23 Answer: "Rudasill." 24 Was this a Class G weld that you were doing?
- 25 A (Witness Ray), Yes, sir.
I
12,241
- Sira 25-4 1 Q And is it correct that you were having problems 2 with porosity and the stick rods?
3 A (Witness Ray) No, sir. 4 Q Okay. Does what Mr. Nunn was describing here 5 ring a bell with you? 6 A (Witness Ray) Yes, sir. 7 0 Could you describe the incident as it occurred? 8 A (Witness Ray) Yes, sir. I was working on g the structural hanger and I was not through with it yet. 10 The foreman that I was loaned out to seen my work and he 11 wasn't happy with my work. So I had to go up the hill to 12 run a practice coupon. When I returned to the hanger, and 13 without welding on it, I cleaned it up by grinding and 14 } got it inspected. 15 0 So is your position or statement that the weld 16 was not improper based on any pressure that was put on you 17 by your foreman? 18 A (Witness Ray) There was no pressure. 19 MR. JOENSON: Thank you very much. That is all 20 I have. 21 JUDGE KELLEY: Mr. Guild? 22 MR. GUILD: May I have a minute, please. 23 (Pause.) 24 MR. GUILD: Mr. Chairman, I want to ask that j' 25 Mr. Nunn, who is sitting with me at counsel table , be permitted e , 4 m. y-. , , - - - , , - - - . --s e.-,-, ~ - - ve =
12,242 Sim 25-5 g. to examine members of this panel as an expert pursuant to ( 2 10 CFR 2.733. Mr. Nunn not only of course is familiar with 3 the facts of these individual cases of foreman override, 4 but is demonstrably expert based on his experience and 5 qualifications as a welder over some considerably period 6 of years at McGuire and Catawba. 7 I think it would expedite the questicning and 8 would get to the core of some of the issues and use our g time, which is very limited, in the most expeditious fashion. 10 What I would propose is if we have 10 minutes 11 which my fraction experts tell me is i/10th of a minute 12 per member of the panel for our cross-examination. The only way I can even begin to treat this suoject is if
~
13 14 Mr. Nunn can take half of that time and I can take the 15 other, and I may in fact cede the rest of my time to him. 16 But we would ask that he be accepted as an expert examiner 17 for this purpose. 18 MR. McGARRY: Your Honor, very briefly. We don't 19 think that Mr. Nunn should be permitted to serve as an 20 expert and cross-examine this panel. This is basically 21 a fact panel and expertise isn't involved except in limited 22 areas and certainly not in the area that I would imagine 23 Mr. Nunn would pursue. 24 However, given the time and our interest to (- 25 be completed with this panel, because they have been here
12,243 Sim 25-6 three days now, and to speed it along, we will not oppose ~ 2- Mr. Nunn cross-examining these gentlemen. 3 JUDGE KELLEY: Mr.oJohnson. 4 MR. JOHNSON: I agree that Mr. Nunn is not 5 an expert. In any case, this.is not basically an expert 6 panel, but I have no objection to him asking any questions. 7 JUDGE KELLEY: In the circumstances and in the 8 interest of moving things along, why don't we grant the g motion. 10 CROSS-EXAMINATION INDEX 31 BY MR. NUNN: 12 Q Mr. Young, Malcolm, when you related the 13 story to me about being overridden in your decision about 14 making a weld when you were on the night shift, who was 15 your foreman then? 16 A (Witness Young) I was working for Arlan Moore 17 on the second shift, but the situation at hand didn't occur 18 on the second shift. 19 Q When you made this statement to me, had Mr. 20 Rudasill possibly come by right prior to then perhaps 21 criticizing your work and maybe got you down and dejected 22 to where-you would talk to me about a personal problem, 23 specifically a cold bell weld that you had made? 24 A (Witness Young) No. 25 Q Do you still work for Duke Power? A (Witness Your$g) Yes.
l 12,244
.Sim 25-7 Q i
Mr. Henry, you said that the machine was defective ( 2 and wouldn't carry enough heat to run a 1/8th rod, but you 3 went on ahead anyway and you brought this up to 4 Mr. Hollingsworth later; is that correct? 5 A (Witness Henry) That is right. 6 O And you did have to go and take a test of some 7 type or other; is that correct? 8 A (Witness Henry) I recertified. 9 Q You recertified meaning that you did lose your 10 stencil? You lost your stencil to run stick welds. 11 A ' Witness Henry) I didn't lose all my certifica-12 tions. 13 Q But you did lose your stick rod stencil and you 14 had to retest? 15 A (Witness Henry) Right, and I retested and got 16 it back. 17 Q Okay. Mr. Young, you didn't lose your stencil, or 18 may I call you Malcolmn, but you didn't have to go and retest; 19 is that right? 20 A (Witness Young) I did retest, yes. 21 Q And what was the purpose of the retesting? 22 A (Witness Young) The NRC was interested in my 23 ability to prove that I could still weld, which I did pass 24
... the certification with no trouble. -s_ 4j A (Witness Roge,rs) I may have something I could a
+ 1
12,245 Sim 25 1 add there if you would like. ( 2 Q No, sir, I don't like. 3 JUDGE KELLEY: Gentlemen, if this gentleman wants 4 to add he can add. I will give you a little more time if 5 you need it. 6 WITNESS ROGERS: The situation we are talking 7 about was Malcolm and Buck and Danny. What has been alleged 8 is that we pressured for production above quality. In all 9 three of the situations which we have here we prove and we 10 show that it is to the contrary. 11 In Malcolm's situation, he did make a weld that 12 wasn't quite up to par. It wasn't that the QA department 13 or the NRC or anybody required him to retest. His management 14 and other welding superintendent, we discussed it ar.d we 15 felt like we should take Malcolm back to the test shop, 16 give him some training and retest him to see if he did indeed 17 have the ability. 18 The same situation applies to_the other two 19 welders, too. That is basically the approach we took to
" it.
21 BY MR. NUNN: 22 Q Mr. Ray, Danny, is it true that you and worked together from the time I came to Catawba until I started transferring around to other crews? (-
' 25 A (Witness Ray 1 Yes, it is.
t
12.246 Sbn 25-9 1 Q And you were a helper most of the time? 2 A (Nitness Ray) Right. 3 Q Once you got your stencil -- let me go back a 4 little bit before then when you and Mr. Henry were practice 5 welding to get your stencils, did Mr. Rudasill ever use 6 kind of a challenge to you that Buck is getting slicker 7 than you cre, and, Danny, you will probably not pass the 8 test? Did he ever make any inference of that type to you? 8 A (Witness Ray) In a way he did, but that was to 10 encourage me to improve. 11 Q Did you feel encouragedAmr discouraged from that? 12 A (Witness Ray) Well, naturally it is a task that 13 I would want to improve because I did-want to be --- 14 Q No, you are not answering my question. Did you 15 feel --- (The reporter at this point interrupted because 17 she did not get the complete answer of the witness due 18 to Mr. Nunn and the witness speaking at the same time.) JUDGE KELLEY: Gentlemen, you are going to have 20 to wait until each side finishes what they have got to say, 21 whether it is the question or the answer. The reporter 22 just can stay up with you otherwise. 23 Why don't you restate the question. BY MR. NUNN: s c Q Did you feel tsomewhat dejected by Mr. Rudasill's
12,247 1 opinion that even though Buck had not welded as long as you ( 2
~
had, he was getting slicker, so to speak, or becoming a 3 better welder than you were? 4 A (Witness Ray) No. 5
, 0 You did not feel dejected?
6 A (Witness Ray) No. 7-Q Okay. Thank you. 8 Mr. McKinzie, you stated that Mr. Rudasill's e 9 crew had never worked for you before. Which welding crews 10 did your welding for you? 11 A (Witness McKinzie) Henry Best. 12 Q Mr. Henry Best's crew. Was it ever a practice 13 at the Catawba site that if Mr. Best's crew, if all his 14 men were tied up that you would borrow someone from another 15 crew to weld for you? 16 A (Witness McKinzie) Mr. Best might have done that. 17 O Was it ever to your knowledge, was that practice 18 ~ ever followed? 19 A (Witness McKinzie) Yes. 20 Q You have had welders from other crews? 21 A (Witness.McKinzie) Yes. 22 Q Could Mr. Rudasill's welders possibly have been 23 loaned out to you at one time or another? 24 A (Witness McKinzie)
,- I do not know that.
25 Q You stated a yhile ago that Mr. Rudasill's welders t
2 12,248 Sim 25-11 1 had never weldad for you. Now which one do you want? 2 A (Witness McKinzie) I said Mr. Rudasill had 3 never welded.for me is what I said. 4 Q That Mr. Rudasill had not welded for you? 5 A (Witness McKinzie) His crew, right. 6 His crew. Okay. Well, I have kind of a contra-Q
,7 dition right there.
8-Let's just assume on a hypothesis that maybe 9 I had been loaned out to you and maybe I had been asked to 10 do something without paperwork and maybe I refused to do 11 so and maybe I called Rudasill up there and maybe I said 12 I am damned well not going to do it and maybe Rudasill said 13 well., I am going to put you on another job. Would this 14 have been documented? 15 A (Witness McKinzie) I don't know anything about 16 what you are talking about. 17 0 Would this have been documented, sir? 18 A (Witness McKinzie) Between you and Rudasill? 19 Q This is a hypothetical situation. If this l did or could have happened, would you have documented this? 21 Is there any particular form that you would have written 22 my comments down and Rudasill's comments down on and my 23 refusal to do the weld? 24 A (Witness McKinzie) If you come to me and 26 refused to do work, I wohld document it on your personal
12,249
-Sim 25-12 1: record that you refused to do certain work and list why.
-( 2 I don't see anything wrong with that.
3 0 very good. i 4 Mr. Rudasill, do you have any recollection 5 whatsoever of me coming to you and telling you that 6 Mr. McKinzie wanted me to tack up some stainless steel pipe,
- 7. and I believe it was two-inch Schedule 80, without tha 8 proper paperwork just to expedite having them already tacked g when the paperwork did get there?
l- 10 .A (Witness Rudasill) No, Sam, I sure don't. From 11 all we can determine from the information in your testimony 12 describing a two-inch Schedule 160 socket weld --- 13 (Witnesses conferring.) 14 JUDGE KELLEY: Gentlemen, excuse me. You can 15 confer, but we have to catch that, too. If you are going 16 to confer, just speak in a normal voice so we can catch
- 17 ' hat, too.
18 WITNESS RUDASILL: I was describing the socket 19 welds that you were describing that you were actually working 20 on, the only thing that we can find out is apparently this 21 was temporary pipe and there would have been no paperwork 22 whatsoever. 23 BY MR. NUNN: 24 Q I want to ask you about Mr. Young again Do 26 you remember coming through the annulus and criticizing 1 i
12,250 i Mr. Young's work and telling him that this was not exactly what we were looking for and that he was to grind it slick and make it look nico and that the annulus was a show place? Do you remember making any statements to that effect? 5 A (Witness Rudasill) I don't know that I remember making that exact statement. Yes, I might have asked Mr. Young to grind a weld if it was deemed necessary in my decision. O Mr. Barker, I wuld like to address you for just a moment. I was loaned out to you one particular Saturday to work in the No. 1 pipe chase when we were boxing beams in. You and I did not hit it off very well 13 that morning about the control filler material on the floor. Did you later that day ask me to put my stencil on approxi-g mately six feet of boxed in beams so that you could get 16 it signed off because some welder had forgotten to put his 17 stencil on there? 18 MR. McGARRY: Objection. That incident is not 39 -part of the incidents that Mr. Nunn has raised to support g the foreman override issue. 21 MR. NUNN: Sir, I am just trying to show the 22 f reman override. This is a foreman saying I am foreman 23 and you are a worker. Will you do this for me. 24 MR. GUILD: I think it is a proper question, 25 Mr. Chairman, and the witness can answer yes or no. It is 1 a s
- . - y..
12,251 Sim 25-14 g a simple question. 2 JUDGE KELLEY: I gather that the particular 3 incidehce, however, is not an incident that you had previous 1:7 4 raised, Mr. Nunn? 5 MR. NUNN: That is right, sir. 6 JUDGE KELLEY: Let me just note that the better 7 part of the ten is gone. Do you want to cede? If you are 8 going to ask for a few more minutes, we will gi*te it to you. p How do you want to work this? 10 MR. GUILD: I would like to have Mr. Nunn 11 complete any questions that he has. 12 MR. NUNN: I have got just maybe two more
'13 minutes.
14 JUDGE KELLEY: All right. Go ahead. end 25 Fine. 15 and Sim Sun'fols 16 17 18 19 N 21 22 24
. r
- 26 s
a
12,252 at 26/1 1 Q Once again, Mr. Barker, I came to Catawba about ( 2 November '80, and do you remember Mr. Dry talking to you 3 about employee relations, about you denying him some sick 4 leave? 5 MR. McGARRY: Objection. Same basis. This is 6 a new incident, not relative to the allegations made by 7 Mr. Nunn. 8 MR. NUNN: I'm just trying to show Mr. Barker's 9 credibility as a person, as a person who would tell the 10 truth, Your Honor, that's all. 11 MR. GUILD: I think he should answer the first 12 question. I guess we were hoping he would. 13 MR. NUNN: Right. 14 JUDGE KELLEY: The first one sounded to me to 15 be a little bit closer to our concerns than the second one, 16 frankly. And I guess I didn't get a ruling done on that. 17 We just heard the points. 18 Could you restate the prior one, and I am going 19 to sustain the objection to the second one. 20 MR. NUNN: Okay, sir. 21 CROSS EXAMINATION 22 BY MR. NUNM: (Continuing) 23 Q Mr. Barker, I worked for you one particular 24 Saturday, and towards the end of the day -- let's #arget 25 about what happened prior to the end, but there was o
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12,253 ct 26/2 1 approximately six feet of horizontal weld, about my chin ( 2 level, and you were trying to get a certain amount of 3 work signed off for that particular day, which I suppose 4 you had a quota that you had to make. And some welder had 5 forgotten to stencil this. 6 Do you remember asking me to put my stencil 7 number on there, even though I had not worked it, this 8 particular six feet of weld? 8 A (Witness Barker) First of all, we had no quota; 10 and, second of all, I do not recollect ever asking anyone 11 to stencil anything that they did not do. 12 Q For Mr. Wilson. Mr. Wilson, did you ever go 13 to the top of any of the buildings and sort of spy on the I4 welders to make sure they weren't going to break early? 15 A (Witness Wilson) No, sir. 16 Q Beg your pardon? 17 A You mean spy? No, sir. 18 Q Okay. Observe. I will use that term. 19 C
. A I have observed.
20 Q You have observed? With the purpose in mind 21 that any welder who went to the break area early, or even 22 went to the bathroom early, prior to the break time, if he 23 did it consistently, that you were going to reprimand him? 24 Is that correct, sir? 26 MR. McGARRY: ,jObjection. Clearly beyond the s
12,254 ct 26/3 1 scope. ( 2 JUDGE KELLEY: Sustained. 3 CROSS EXAMINATION 4 DY MR. NUNN: (Continuing) 5 Q Mr. Wilson, do you' remember a meeting that you, 6 Hershel Brewer and myself had towards the latter part of 7 May of 1983? 8 A I remember meeting with you several times. 9 Q Do you remember this particular meeting in Mr. 10 Brewer's shack? 11 A I remember meeting with you in Mr. Brewer's 12 shack a couple of times, but I don't remember any certain 13 da tes . 14 Q Do you remember me becoming quite infuriated and 15 saying I was going to the newspaper with a lot of things 16 l that I knew, talking about Christmas parties and dope and 17 first one thing and then the other? 18 MR. McGARRY: Objection. Irrelevant, beyond the 18 scope of the contention. JUDGE KELLEY: Now, Mr. Nunn, what we are looking 21 7 at, I think the record will show, when you came in the first 22 time what we asked you for were your concerns and all of 23 your concerns. And I assume we got them. We are not here today to talk about dope. You didn't have anything to say about dope. Let's just -- that's i
12,255 et 26/4 1 just not before the house. ( 2 MR. GUILD: Mr. Chairman, that really -- I think 3 the objection was premature, or shall I say this. I think 4 Mr. Nunn is trying to lay a bit of a foundation. 5 I would direct the ' Board's attention to Page 37 6 of his affidavit. I think his -- the meeting is set out 7 at that point, the meeting that ostensibly happened betwean s 8 Mr. Brewer and Mr. Wilson. That's Page 37, about the 9 middle of the page. 10 And he relates that meeting at the time. Now, 11 he probably doesn' t say everything that was said in that 12 meeting at that point. I think that he wasn't pursuing 13 the allegation of drugs on the job. It is, did he remember J 14 the meeting and putting it in the context where he will 15 remember it. 16 MR. McGARRY: Your Honor, that has been ruled 17 out of the case. 18 JUDGE KELLEY: My next question, is that age 37 19 in the case? 20 MR. McGARRY: No, sir. This Board has already
- 21 thrown it out.
22 JUDGE KELLEY: My recollection is there is a 23 large segment of the affidavit that was thrown out entirely.
- 24 Does anyone --
26 p MR. NUNN: Ijm sorry, Your Honor. That issue has e
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l 12,256 ct 26/5 1 been struck. And I was improper to ask that question. My 2 apologies. I have just one final question to the collective 3 group. 4 CROSS EXAMINATION 5 BY MR. NUNN: (Continuing) 6 Q Fellow welders, do all three -- and I believe Mr. 7 Young has already answered me. Danny, Buck, do you still 8 work for Duke Power? 9 A (The witnesses answered in the affirmative.) 10 Q Can you tell me, Buck, you didn't answer? 11 A (Witness Henry) Yeah, I work for Duke Power. 12 Q You are still a welder? ( 13 A Yes. 14 Q Danny? 15 A (Witness Ray) Yeah. 16 Q Do you know what CFR means? 17 MR. McGARRY: Your Honor, I'm going to object. 18 If CFR is supposed to mean Code of Federal Register regula-19 tions -- 20 MR. NUNN: Sir, I was asking the witnesses if 21 they knew what CFR meant. 22 MR. McGARRY: I will let them answer the question. I 1 23 COURT REPORTER: Excuse me. I don't know the 24 names here.
# JUDGE KELLE%: Gentlemen, could you state -- the i
w
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[ 12,257 et 26/6 1 question is, do you know what CFR means. Could the three 2 of you say yes or no. 3 WITNESS YOUNG: Pertaining to what? 4 4 CROSS EXAMINATION 5 BY MR. NUNN: (Continuing)
, 6- Q Pertaining to your rights as a worker on the 7 nuclear power site, r
8 MR. McGARRY: Now, I will object, Your Honor. 8 It's clear CFR means Code of Federal Regulations, and that's i 10 irrelevant to the contention. 11 MR. GUILD: Mr. Chairman, that's just not the 12 case. Now, let's put it this way. If these gentlemen are (. 13 the victims of a kind of pressure that we have talked about 14 here, and let's just say that they may be as conscientious 15 as Mr. Nunn is and may have interest in maybe bringing 16 these concerns to the attention of the NRC -- now, let's 17 just say that, because I think that the testimony reflects L -violations of quality assurance at Duke Power. It is I' completely irrelevant'to understand the context of the testimony today here, sponsored by the Company, to I 21 understand they have any idea they are protected or not 22 under Federal regulations. as And I think that's a rather significant way to (; '94 25 - end the inquiry, to. find out whether the three gentlemen c who are here ostensibly,tto say that none of the things
12,258 at 26/7 1 that Mr. Nunn said happened did happen, have any notion 2 shat their legal rights are, sir. 3 JUDGE KELLEY:- I'm going to sustain the objection. 4 We are here to talk about foremen override incidents. To 5 get into sort of an editorial' discussion of rights before a the NRC seems, to this Board, to be far afield. 7 Certainly, if Mr. Nunn or Palmetto wants to 8 speak to any of these gentlemen or write them a letter 6 9 about CFR, they are free to do so. 10 MR. NUNN: Your Honor, I certainly thank you. 11 MR. McGARRY: Your Honor, we just have one 12 question. 13 JUDGE KELLEY: Okay, then. That then concludes 14 Palmetto's questioning? 15 MR. GUILD: Has my time elapsed and all that?
-16 JUDGE KELLEY: Yes, I think it did.
17 MR. GUILD: All right. 18 JUDGE KELLEY: You said you were willing to 18 concede your time to Mr. Nunn so he could finish. That takes us then to Mr. McGarry. 21 MR. McGARRY: Yes, sir. XXXXXX CROSS EXAMINATION BY MR. McGARRY: Q Gentlemen, there was some question about accelera-tion of schedule. I believc one of the Board members asked
12,259 st 26/8 1
.the question in this regard, and what do you do if you are
(. 2 not meeting schedules. 3 The question I have for you is, when you find 4 yourself in a situation where the schedule is being accelerat-5 ed, do you sacrifice quality? 6 A (Witness Webber) No. 7 (Witness McKenzie) Absolutely not. 8 (Witness Rogers) No. 8 (Witness Rudasill) Never. 10 (Witness Barker) Never. 11 (Witness Wilson) Never. 12 (Witness Henry) Never. 13 (Witness Ray) Never. 14 (Witness Young) Never. 15 MR. McGARRY: That's it, Your-Honor. I JUDGE KELLEY: Thank you, Mr. McGarry. Well, 17 gentlemen, we are able to complete matters after all.
-18 Appreciate all of you coming. Kept you a long time. Sorry 19 you were in and out of here at various times, but we finally 20 got you on the stand.
21 Thank you very much. You are excused. 22 (The panel of witnesses are excused.) 23 Let's quit and resume at 8;30 in the morning. 24 (Whereupon, at 7:18 p.m., the hearing was reces-sed, to reconvene kt 8:30 a.m., Tuesday, January 31, 1984.)
i CERTITICATE OT CCFF.07::33 l
\ 2
( 3 This is to certify that the attached procee:'.ings before the 4 ::RC CO.*4M:33 ION t-3 In the matter of: DUKE POWER COMPANY, et al (Catawba Nuclear Station, Units 1 & 2)
, Date of Proceeding: Monday, January 30, 1984 7
Place of Proceeding: Charlotte, North Carolina
, were held as herein appears, and that this is the original
, transcript for the file of the Commission.
10 James Burns is Official Reporter - Typed 12 C NW lbf
'[ ff"t p Reporter - Signature Rebecca Eyster is Offic'al Reporter - Typed to Official Reporter # Signdture 17 Mary Simons t- ,a Official Reporter - Typed 44%f W Official @eporter - Signsture 2o Myrtle Traylor l Official Reporter - Typed AZb' & Oc._ '
22 'Offid 1 Reporter Signature [. 23 l 2A l
.(
t 23 .
- l. 4 TA YLCE ASSOCIATES nacisir.oro pncressioNAL REPontens NonroLx, VIRGINim
, . , _ _ . _ _ .. _ _ _ _ _ _ _}}