ML20082C139
| ML20082C139 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 07/08/1983 |
| From: | Bradley W DUKE POWER CO. |
| To: | |
| Shared Package | |
| ML20082C119 | List: |
| References | |
| FOIA-83-434 NUDOCS 8311210476 | |
| Download: ML20082C139 (51) | |
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I UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD IN THE MATTER OF: ) Docket Nos. . e DUKE POWER COMPANY, et al. ) 50-413 (Catawba Nuclear Station Units 1 & 2) ) 50-414 COPY I, Barbara V. Haas, Commissioner and Notary Public, pro-coeded to take the deposition of William Harold Bradley on the eighth day of July, 1983, beginning at 8:15 o' clock A.M.
[ in the offices of Duke Power Company, South Church Street, Charlotte, North Carolina.
DEPOSITION OF WILLIAM HAROLD BRADLEY a
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( l WILLIAM HAROLD BRADLEY, being first duly sworn, testified as 2 follown:
3 EXA'INATION:
M (By Mr. Guild) d MR. GIBSON: Mr. Guild, at the conclusion of yester-5 day's session with Mr. Bradley, we were discussing a memo that 6 Mr. Bradley had written to Mr. Van Doorn. I now have the 7 July 6, 1983, memo from Mr. Bradley to Mr. Van Doorn which a reads subject documentation of action taken on Welding 9 Inspector Task Force recommendations. Paragraph. The attached to package parenthesis "s" reflects the contents of my files 11 regarding the subject documentation. A. V. Carr of our Legal 12 Department requested that I provide you copies of this material
( 13 pursuant to a request from George Johnson.
l' Mr. Bradley, you can identify this document as the O.
15 transmittal of files you described yesterday to Mr. Van Doorn?
16 A. Yes.
17 Q. Let's mark that as the next Exhibit Number 3 to Mr. Bradley 's 18 deposition. Mr. Bradley, yesterday you related that one of I' your present duties was chairing a committee that was respon-20 sible for reviewing, Nonconforming Item Reports.
21 A. Yes.
22 Can you describe the responsibilities of that group, that Q.
23 committee?
2d The group is basically responsible for reviewing each A.
25 Catawba NCI Nonconforming Item Report'to assure that the 2
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i responsible parties who developed took action on the NCI, have 2 expressed it clearly, and answered the questions raised by 3 the NCI completely.
4 Q. Describe for me, Mr. Bradley, how the process works from 5 the point at which your committee or you are involved in 6 receiving the NCI.
7 A. The document control clerk at Catawba Nuclear Station 8 provides sufficient copies for my team to review. We review 9 it,and I basically described a moment ago, if we have any 10 problems with it, we return it to the responsible department 11 to resolve our question.
12 Q. When in the procedure for originating or processing the Nonconforming Item Report does your team receive the
( 13 14 documents?
15 A. When it's complete.
16 Q. When the document is complete?
17 A. When all action has been taken.
18 Q. When the NCI has been resolved?
19 A. Yes.
20 Q. And closed?
J I can't say it's been closed. It's in the process of 21 A.
22 being closed might be a better expression.
23 Q. Is it your committee's responsibility to close the NCI?
24 A. No.
25 Q. Who would close the NCI?
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( Each NCI is final reviewed by member of the QA Department 1 A.
2 at Catawba prior to filing for record purposes.
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3 Q. Who would that person be?
4 A. I don't know. It would be various individuals.
5 Q. Are there specific authorized individuals?
6 A. I would assume so. I don't know.
7 Q. What procedure governs the work of your nonconformance 8 evaluation team?
9 A. There's no procedure as such in the context of the QA 10 procedure. We drew up various guidelines to use at the time 11 of the formation of the team.
12 Q. What are the form of those guidelines?
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13 A. Excuse me?
14 Q. What form are those guidelines in?
15 A. They are what, I believe, we called a plan for the Task 16 Force or evaluation team, and it was approved by the applicable- --
17 all three department vice-presidents who established it.
18 Q. Is that the written plan?
19 A. Yes.
20 Q. Approved by which vice-presidents?
21 A. Vice-president construction, vice-president design 22 engineering, and my superior, Mr. Grier.
23 Q. How does this team's responsibilities relate to procedure 24 R-6?
25 A. It does not relate to R-6.
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( 1 Q. Is this team's responsibility at all referenced in 2 procedure R-6?
3 A. No.
4 Q. How about procedure Q-l?
5 A. No.
6 Q. It doesn't relate to procedure Q-l?
7 A. If you mean relate, if it was mentioned in either of those 8 procedures, no, it does not relate.
9 Q. Is it the work of your team to be referenced or specified 10 in opposed revision to either procedure Q-1 or R-6?
11 A. No.
12 Q. How about any other contemplated written procedure of the 13 Quality Assurance Department?
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14 A. No.
15 Q. Why is that, Mr. Bradley? Why is there a team which 16 reviews the review function in nonconforming items that's not 17 referenced in any written procedure?
18 A. I don't know. There's no necessity for it basically.
19 Q. What is the authority of your team?
20 A. The authority of the team is that authority vested in.
21 the team by the department vice-presidents who approve the 22 guidelines we work under, and that is the authority that the Omissions, things of 23 people we correspond with point out.
24 NCI's will respond to us. So in that. sense, we that nature.
25 have the authority and direction of the departmental heads.
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( Do you have the authority to direct persons who are speci-1 Q.
2 fied in the Q-1 or R-6 procedure on the manner of origination
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3 of honconforming items?
4 A. No.
5 Q. Do you have the authority with respect to that person 6 identified in procedures Q-1 or R-6 with respect to corrective 7 action to be taken with regard to a nonconforming item?
8 A. Only in the sense I earlier described to you.
9 Q. How about specifying what sense it is.
10 A. If we are not satisfied with the corrective action, we 11 will inform the individual who assigned the corrective action 12 or his supervisor ve feel additional action needs to be taken,
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13 and he is responsible to-- either take that action or explain 14 why it should not be taken.
15 Q. Does your team have the authority to determine that 16 proposed corrective actions are inappropriate?
1:7 A. Repeat the question. Mr. Guild, I'm not sure I understand la what you mean by authority.
Well, does your team have the authority, as you understand
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19 Q.
20 it, to tell the person responsible for corrective action 21 that their proposed corrective action is inappropriate? ,
22 A. No, not really.
23 Q. How about the proposed corrective action is unnecessary?
l l 24 A. No.
25 Q. Why not?
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( 1 A. If the proposed corrective action was unnecessary, in !
2 most cases the corrective action documented on the NCI will 3 be taken by the time my team reviews. It would be academic 4 to tell them it's unnecessary.
5 Q. Let me put a hypothetical to you. Let's say a Nonconforming 6 Item Report identifies a F.eficiency that calls for generic 7 corrective action; generic corrective action requires a con-8 siderable investment of time and resources. Your team reviews 9 that proposed corrective action and reaches the conclusion 10 that the corrective action is in excess of that required in 11 your judgment. Does your team have the authority to instruct 12 the persons responsible for that corrective action to reduce
(~ 13 the level of corrective action?
14 A. In the hypothetical case you described, Mr. Guild, we have 15 no respansibility to do that. However, as a good Duke employee ,
16 if I thought we were expending unnecessary funds, I would feel 17 it my obligation to take some action.
18 Q. Would that action include under my hypothetical, Mr. Bradle:r, 19 under the hypothetical facts I set out, Mr. Bradley, would 20 that obligation as ,a Duke employee in your judgment include 21 communicating to those persons that their corrective action 22 was unnecessary?
23 A. Not directly in the hypothetical case you postulated. I 24 would probably go to my supervisor and relate my side of the 25 story to him for whatever action he deemed appropriate.
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( 1 G. Who was responsible for establishing this team?
2 A. Actual responsibility for establishing the team was, I 3 sup' pose, a joint effort of the appropriate department heads.
4 Q. Those would be the vice-presidents and Mr. Grier you 5 identified?
6 A. Yes.
7 Q. When did they do this? When was this team established?
8 A. Mr. Guild, I'm not clear on the date. Early Fall last year ,
9 Q. You have been in business performing those functions since 10 then?
11 A. Yes, sir.
12 Q. Why do you understand that the team was formed, Mr. Bradley?
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13 A. I don't mean to be trite, Mr. Guild, but the team was 14 formed because the departmental vice-presidents saw it neces-15 sary for it.
16 Q. What is your understanding of their perceived necessity?
1:7 A. They saw a need for further clarification in some cases is that the NCI's perhaps were not complete'and were not as clear 19 as they could be.
20 Q. In what ways? ,Give me an example.
21 A. Let me think. Well, an example might be that something 22 had occurred and the corrective action perhaps did not go to 23 the root. of 'the problem.
2d Q. Give me an example of a kind of NCI that would represent th at 25 set of facts?
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1 A. Well, perhaps damaged equipment, and the equipment was 2 repaired which, of course, is the technical problem with
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3 perhaps no corrective action to determine how or why it got d damaged.
5 Q. Then what would your team do if it were confronted with an 6 NCI that stated that affair?
7 A. We recommend that someone investigate why this incident 8 occurred, attempt to get to the root cause, correct that root 9 cause, so that it was not repeated.
10 Q. How would the work of your team be documented, Mr. Bradley?
11 Let's take on the Q-1A Form. Would the work of your team be 12 documented on that form?
13 A. No, sir.
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Id O. How else would it be documented in the instance where the 15 team saw further action needed to be taken on an NCI?
16 A. I, as chairman, write to the appropriate individuals.
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- 9. So it would be documented in correspondence from you to the 18 appropriate official responsible for the further action?
19 A. That's correct.
20 And any other manner, Mr. Bradley?
Q.
21 We might' discuss it with the responsible individuals A. No.
l 22 to clarify our position.
23 Is there a central-- does your procedure call for a central Q.
24 form of documentation of actions taken by your team?
l 25 Just in a' response to my correspondence or in corrected or l A.
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( 1 updated NCI's.
2 Q. But not on the Q-1A Form?
3 A. ~ No.
4 Q. Are you familiar with procedure R-67 5 A. Yes.
6 Q. Significant corrective action?
7 A. Yes.
8 Q. I will show you a copy of that procedure. I believe that 9 to be a current revision. Mr. Bradley, if under the example 10 you used, you determined that that nonconforming item had 11 failed to determine the root cause of the problem, and your 12 team directed that that root cause be determined and effective 13 corrective action be noted for that nonconforming item, and
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1d that corrective action was significant within the term 15 significant in procedure R-6, how would your team's role in 16 that determination be documented, u ider that procedure, sir, 17 if it would?
18 A. As yet, Mr. Guild, we have not-- the team has not reviewed 19 any NCI's processed under the new revision or R-6. I think to 20 answer your questio,n more completely, there would be no change.
21 If we saw that something was wrong or inadequate on R-6, we 22 wculd operate as before.
23 Q. Would your team's work be' documented on the form specified 24 in procedure R-6?
25 A. No, sir, as before.
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( 1 Q. R-6 has just been implemented?
2 A. Something close to a month ago I understand.
3 Q. -Y6u ' haven't seen any NCI's?
4 A. I have seen some, but I haven't reviewed them.
5 Q. There have been some coming from Catawba?
6 A. I haven't seen any complete ones.
7 Q. Are any NCI's coming from Catawba that are being processed 8 pursuant to R-6?
9 A. Yes.
10 0. What are those, do you know?
11 A. I have absolutely no idea.
12 Q. No idea what the subject is?
( 13 A. No.
14 Q. How do you know there are some?
15 A. They are on my desk.
16 Q. Waiting for you to take some action?
17 A. Right.
18 Q. We'll send you back to your desk soon.
19 MR. GIBSON: Can we take that as a promise?
20 Q. How many Nonconforming Item Q-1A's have you seen from 21 Catawba since your team began its work?-
22' A. I happen to have that number, Mr. Guild, fourt'en _
e hundred 23 and one.
24 Q. Since the Fall of-last year?
25 A. Yes.
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( Of those, give me an estimate or a figure, if you know it, 1
Q.
2 Mr. Bradley, of the number which your team has required further 3 act' ion as a result of your review.
4 A. We have returned seventy-three NCI's. Not all of them as 5 such required further corrective action. Some of them we 6 merely pointed out a circumstance or situation and recommended 7 that it be used for training purposes.
a Q. Help me understand what you mean by that reference.
9 A. Training?
10 Q. Yes.
11 A. The team as a body felt that for some items being handled 12 on nonconformances which could best be handled by other means.
13 Q. For example?
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14 A. For example, if we received defective equipment from the 15 manufacturer, the team took to view, that was the manufacturer's 16 problem. It should be returned to the manufacturer for cor-17 rection, documented on some other form, and not used the 18 NCI as that vehicle.
19 Was there vendor defects?
Q.
20 A. Right or shippi,ng damage.
21 Q. How about construction deficiencies that were identified 22 in the course of an inspection that were handled as a non-23 conforming item and could have been handled through an R-2A?
24 A. We don't get into that._ We do not necessarily attempt to 25 direct or tell them what they should write on an NCI, so if it
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1 was an R-2A upgraded to an R-6A to an NCI, we wouldn't take 2 umbrage with that.
3 Q. In your example here of some of these items that were 4 returned not for further action but for potential training 5 as you explained should have been handled differently, were 6 any situations or NCI's in your judgment that should have been 7 handled as R-2A's or through process control?
8 A. In my personal judgment, yes. A number of them could 9 have been handled as R-2A's in my personal judgment.
10 Q. Did the team express that view when they returned it?
11 A. No, we have not returned it for that cause.
12 Q. Does your team meet as a body to discuss the treatment of 13 an NCI?
14 A. Yes.
15 Q. How frequently does it meet?
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!v 16 A. Generally once a week.
17 Q. Do you take up NCI's that have been generated since the 8
18 previous meeting at that point?
19 A. It doesn't work that way, Mr. Guild. There are many a
j 20 NCI's in the process. There are many completed rather rapidly.
I 21 There are many that take a lot longer period of time; the ones 2
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22 that I see can range over a span of many weeks.
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23 Q. So what form is your agenda then from one week to the R
24 next?
25 A. The agenda is very simple.- We have a stack of NCI's to
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1 review. I collect them, collate them, separate them with the 2 eldest received to be the first reviewed, and we just labor 3 away at them.
4 Q. How do you document the results of your work as you review 5 an NCI?
o A. I keep a running tally of the count that is the numerical 7 assigned number of what we have reviewed and as I stated earlier, 8 any we have problems with are documented on correspondence.
9 Q. From you?
10 A. Yes.
11 Q. Do you keep minutes of every meeting?
12 A. Only as reflected-- No, only as reflected by log or what I 13 we review on that particular day.
14 Q. Does your team ever--review documents beyond those, beyond 15 some of the NCI's, the Q-1A Forms?
$ 16 A. Beyond the NCI's?
0 17 Q. Take the Q-1A Form, do you review anything-besides the 8
4 18 Q-1A Form?
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{ 19 A. No. Occasionally we have to call in reference material E
g 20 it might reference another procedure or something, and we want U
2 21 to go look at that procedure to clarify in our mind what we're 22 talking about.
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I 23 Q. How about attachments to the 0-1A?
! 24 A. Oh, yes, attachments.
25 Q. Whatever attachments are generated in the process you 14
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l I review also?
2 A. I take your question to mean we take the 0-1A as the total 3 package consisting of one or many sheets?
4 Q. Then you have-- may have reference to procedures that 5 would answer questions about how to handle--
6 A. Yes.
7 Q. How about other technical resources?
8 A. Well, the technical resources are vested in the body of 9 the team that represents a cross section of disciplines, and
! 10 we have at our disposal the entire expertise of the Duke 11 Power Company if we need it.
12 Q. You have reference to that if you need it?
I 13 A. We call on it when we need it.
14 Q. Well what I don't understand, Mr. Bradley, is let's say 15 you've turned to someone, it's a technical question and you n
v 16 turn to someone that has technical expertise in the company g
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- 17 to express a view about a particular hardware question or 8
18 corrective action question. How would their conclusion be 3
e How would it be reflected in your work?
g 39 documented?
e j 20 A. It would not be.
E g 21 Q. Does your team or representatives of your team ever look I
l 22 at the hardware in question, if it's a hardware issue?
8 23 A. Yes.
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- s 24 At the facility?
Q.
25 A. Yes.
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l 0. Let's say hypothetically we are talking about a weld, 2 and the corrective action involved in resolving a nonconformanc e 3 in welding. Your team makes a review. Looks at the hardware.
d A. Not necessarily. Not in the hypothetical situation you're 5 stating unless it was something that made us very curious 6 or we were just interested in looking at it. It sounds-- the 7 situation you described sounds fairly straightforward, and we 8 wouldn't look at it in those circumstances.
9 Q. Tell me if it's not accurate, an accurate hypothetical 10 but might there be circumstances where a weld is involved in 11 a nonconforming item, and you might take a look at it?
12 A. It's possible.
l 13 Q. Let's say you did, and your team reviewed, looked, at the ld weld in question. How would your team's review of that weld 15 on site be reflected in the documentation involving that weld?
Q 16 It would not.
A.
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- 17 Q. Would that be consistent with any other hardware, for 8
e 18 example, if you looked at it, your team's examination of the 3
" hardware wouldn't be reflected in the documentation?
} 20 A. It hasn't to date. There could be circumstances where i 21 The-team has looked at it, We might want to reference it.
f 22 and it has not occurred in which case it would be reflected in 23 the correspondence probably.
24 Q. Is it clear, though, let's take this hypothetical of a 25 weld, you're familiar with the procedure M-4?
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l A. Not really, sir.
2 0 ., You're aware that it's a procedure that governs visual 3 inspection of welds, code welds?
4 A. Yes.
5 Q. And that it specifies various process control documentation?
6 A, yes, 7 Q. Including documentation of inspection by quality control?'
s A. Yes.
9 Q. I just want to clarify with reference to the weld process 10 control sheet M-4A, that's the documentation of process con-11 trol for welding, is it not?
12 A. I'm not that familiar with the document. I believe it is.
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13 Q. Take a look at it, and look at the procedure if you would Id like, and what I want to understand is it clear that the team's 15 review of that weld, if in the hypothetical you are reviewing 3
Q 16 a weld, your team's review would not be documented as an 8
- 17 inspection point on that process control form?
8 g 18 A. No, sir.
3 19 Mr. Bradley, are you familiar with the trend analysis g Q.
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20 performed on nonco'nforming items?
E 21 A. I know the ones performed. I'm not familiar with the l
22 methodology. I occasionally see reports. I have no involve-8 23 ment in the trend analysis.
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2 24 g.. Does you'r team ever review those trend analysis?
25 No, sir.
A.
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1 Q. Counsel has the procedure, the written procedure, 2 reflecting the formation and operations of the team, the 3 nonconformance item team, that Mr. Bradley has been describing.
4 Has it been produced in discovery?
5 MR. GIBSON: Mr. Bradley said there were no procedures 6 written which identified to form that team in response to the 7 question.
8 I just heard him tell me there was a written description Q.
9 of the team responsibility in authority that was signed by 10 Mr. Grier and by two vice-presidents.
11 MR. GIBSON: You described it as a procedure. He 12 indicated there was some written guidelines established.
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13 Q. Yes, the guidelines.
Id It's my understanding that information MR. GIBSON:
15 has not been made available because it.was not in any way O'
16 associated with the Task Force, the concerns,the Task Force 8
- 17 recommendations, or any dispute or disagreement between an 8
18 inspector, his supervisor, and/or management and, therefore, e
- 19 has not been within the scope of the discovery or relative E ,
20 to the proceeding.
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l 21 Q. We take the view that if it has to do with review of 22 quality assurance in welding, that it's within the scope of E
8 23 discovery. If it's a procedure that is written that, in 3
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24 fact, governs the way Duke Power Company resolves construction i
25 deficiencies at Catawba Nuclear Station, that it should have 5
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l been identified long ago and produced. Nonetheless, we ask 2 that it be produced at this time.
3 MR. GIBSON: As we said previously, we think this is d beyond the scope and decline to make it available; but as we 5 have done in the past, we will consider that request and if our 6 position on that changes, we'll make it available.
7 I would desire to question Mr. Bradley further about these Q.
8 specifics contained in any document reflecting the work of
' this team that I have only learned about in his deposition; 10 and in order to do so, I would ask that that be made available I
11 at this time. Of course, if your position counsel is you won't 12 produce it, then the only course I have available is to get it
(. 13 produced and bring Mr. Bradley back to talk about it, which, Id of course, I will do.
15 MR. GIBSON: Which, of course, you will attempt to do 16 with the Board, I take it you're saying.
t* I7 Q. Yes.
O 18 h MR. GIBSON: Mr. Guild, if you seriously want 3
" Mr. Bradley to locate those guidelines at this time, we'll do 20 that and upon revidw of them upon getting them, if we're f
21 inclined to make them available if you desire to do that.at 22
$ this time.
8 23 g 0 Absolutely.
24 We'll stand in recess or adjournment MR. GIBSON:
l 25 till Mr. Bradley can go to his office and will locate those
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2 SHORT RECESS (9 :00 a.m. )
3 CONTINUING EXAMINATION: (By Mr. Guild) (9:30 a.m.)
d MR. GIBSON: Mr. Guild, during this recess, we went 5 to Mr. Bradley's office in the other building to find the 6 document which I have handed to you entitled " Implementation 7 of a Nonconformance Evaluation Team". We take the position i
s that this document is beyond the scope of discovery and in j
i 9 the interest of moving the proceeding along and limiting the 10 number of items that have to be reviewed by the Board, we 11 have made this item available as well as a document entitlet 12 "NCI Evaluation Check List" which is attached. By making this
( 13 document available, we do not waive or change our position Id that the items requested during this deposition are beyond the 15 scope of discovery will therefore be produced. You have any 5
16 questions of Mr. Bradley about this, you may proceed.
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- 17 Q. I want to show you a document dated July 8,1982, and ask C
18 if you can identify that, sir?
h 2
e 19 5 A. Yes.
t 20 '
} Q. What is that?
2I A. It's a memo to file by myself relating to nonconforming 22 i items and training that I recall on the resolution or handling 8
, 23 of nonconforming' items and also an attachment in this case-
! 24 to one of the implementation objectives.
25 What implementation objective is that?
Q.
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1 A. 93E.
2 Q. That's 9.3?
3 A. 9.3.E.
4 Q. Let's mark that as an Exhibit, Exhibit 4. Did you prepare 5 this memo?
6 A. Yes'.
7 Q. In quote, in parallel with,but not related to, the a resolution of inspector concerns, the company will initiate 9 an NCI evaluation team. This team will be charged with 10 improving the overall quality of NCI resolutions by various 11 means. End of quote. Is that the team to which we have had 12 reference in our earlier discussions this morning?
b 13 A. Yes.
14 Q. And the team that is reflected in the document you have 15 produced?
5 i 16 A. Yes.
v 8
- 1:7 Q. In what manner is this in parallel with but not related to O
{3 18 the resolution of the inspectors' concerns?
la 19 A. During the resolution of the recommendations of the j 20 Task Force, there were numerous items reflecting on or with ig 21 NCI's, and their resolution.
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22 Q. Yes. What is the term in parallel with mean?
8 - 23 A. Were going on at the same time.
24 Q. But not related to?
25 A. Yes, sir. I 21
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1 Q. Why is it attached to objective Number 9.3.E of the t
2 Wel, ding Inspector Task Force Recommendations?
3 A. 9.3.E called for certain actions. I don't recall but 4 one of them was any specific item or anything of that nature, l
5 it called for certain training, I think I recall. The Task i 6 Force efforts had nothing as such to do with that. They were 7 in addition to and the reason it's attached to demonstrate 4 a that we were moving forward in any problems we had with I 9 NCI's.
10 Q. Do I understand correctly that objective 9.3.E calls 11 for, as it says in the title, continued emphasis on training 4
1 12 of proper NCI resolutions?
( i 13 A. That's what it says, yes, sir, 14 Q. And the training aspect was to be performed in part on 15 the basis of the work of the NCI evaluation team?
9 g 16 A. No.
y 8
- 17 One of these will. include-- this is the text of the July 8th Q.
8 i g 18 memo you wrote to your file. Quote, one of these will. include.
3 19 the development of training materials to be used by the E
i 20 involved' departments. End quote. . And that memo was attached t
e
[ 21 to 9.3.E. Why'is it attached to it if it has nothing to do I
- v 22 with it?
8 '
23 A. A generic issue on'NCI's. Many files are puy together on l g 6
24 generic topics. I think it' represents our. effort in total to 25 resolve any NCI problems.
L .
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1 Q. But it has no relationship other than that to the Task 2 Force report? -
)
1 3 A. No, it deals with NCI's.
4 Q. I want to understand how you interpret the relationship 5 so I will be able to presume the relationship between this 6 Task Force or this team evaluating NCI's is consistent with 7 the relationship of things I don't know about yet that may be 8 in your terms not related to the Welding Task Force report.
9 A. Those are my terms. .
10 Q. I expect to be further surprised, Mr. Bradley. Let's 11 identify this document then, these two documents, the ,,
12 Implementation of Nonconformance Evaluation Team and thN~NCI 13 Evaluation Check List. Can you identify those documents?
^~ '
14 A. Yes, sir.
15 Q. Let's mark those as Exhibit 5. Do I understan'd that the 5
l i 16 check list is the check list that is used by the. team in this v
8 '
- 17 review of the NCI's?
8 .
e 18 A. In general, yes.
I -
e 19 How do you mean that?
g Q. -
t j
20 A. Well, it's a check list and not a procedure' to be followed
, i :
! g 21 step by step verbatim.
t 22 Q. Is that check list used in any o.ther part'of the process 3
l I 23 of originating, evaluating, or res$1ving NCI's?
- ,5 24 A. No. #
J' : -
25 Q. It's not used by anyone other than the team?.
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) A. No.
2 Q. Is it available to anyone other than the team?
3 A. I will provide copies to anybody that wants it.
4 Q. You gave one to me. I appreciate that.
5 A. You're welcome, sir.
6 Q. The people at the construction site have copies of the 7 evaluation check list?
8 A. Not to my knowledge.
4 Q. Do people in Quality Assurance have copies of the NCI 10 check list?
11 A. No, not to my knowledge.
12 Q. So you have no basis for believing this check list or the I y subst5nce of the check guides the origination of processing 14 of NCI's'by persons other than your team?
15 A. No, sir.
!v 16 Q. Team objectives, the second one. Identify specific trends 8
a 17 or problem areas. How have you addressed that area?
O 18 A. We have identified on occasions some trends, and we have
{2
{ 19 addressed those trends usually with a compilation of a number a
j 20 of similar problems as reflected on the NCI through correspondenc V
E 21 process to the appropriate individuals.
t l g 22 Q. What trends have you identified?
v .
l 5 g
23 A._ I don't recall the specific trend. I have to take a few i 8 24 mome n t's--
- 25 Q. Think about it and take whatever time you need.
- 24
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1 A. I simply cannot recall the topic of one piece of corres-2 pondence, -
3 Q. If you addressed objective two and you have identi fied 4 trends, tell me anything you can recall about the trends you 5 have identified.
6 A. I can only recall one trend which is, as I said, a 7 compilation of NCI's; but I don't recall the subject of the 8 NCI's.
9 Q. How would that trend you identified be documented, sir?
10 A. In correspondence.
11 Q. Did you bring that correspondence with you, Mr. Bradley? A.
4 12 A. I did not.
( 13 Q. Why not? '
s 14 MR. GIBSON: I will answer that, Mr. Guild, by saying 15 we brought to you what wa's related and wilat was requested, 4
4 g
16 although we have waived our objections, items related to the 8
welding inspection, the Welding Inspector Task Force, have been
- 17 8 =
18 made available. .
g
!4 19 Q. lir. Bradley, I want to show you a Notice of Taking j
20 Deposition, can yo6 identify that document, sir?
Ig 21 A. Yes, sir. )
r # 3 22 Q. Have you seenthat before? -
3 8
- 23 A. Yes.
[
i s
24 Q. Is that the document that was served on you requiring 25 'your attendance at thid deposition?
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1 A. I can't verify the dates. It looks similar.
2 Q. Would you read the second to the last paragraph, please?
~
3 A. You are required to attend and may be represented by 4 counsel and are required to bring with you any and all docu-5 ments in your possession or subject to your control reflecting 6 your knowledge of the above-described matters on which you 7 will be examined.
8 Q. You understood those matters as described above?
9 MR. GIBSON: Mr. Guild--
10 Q. Excuse me, counsel--
11 MR. GIBSON: Go ahead and finish your question.
12 Q. As stated above, the deposition will relate to Palmetto
( 13 Alliance's Contention Six, particularly your knowledge 14 relating to Quality Assurance in welding at Catawba.
15 A. Yes.
E 16 MR. GIBSON: Mr. Guild, we take the position, as has-
, v 8
- 17 been indicated in earlier depositions, that this Notice of O.
h 18 Taking of Deposition and the language included therein, 3
19 relating to production of documents, is limited by the two
{
fv 20 most recent Board orders as indicated earlier. The documents E 21 responsive to discovery and included within the scope of the r
22 notice have been made available.
n Q. Mr. Bradley, I want to show you some documents here', sir.
8 3 23
! 24 Can you identify those please? Tell me what they are if you 25 know.
k 26 l
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1 A. Insofar as I can ascertain without looking at each document 2 contained within these folders, it appears to be those folders 3 containing the action taken on the Welding Inspector Task 4 Force recommendations.
5 Q. Are they from your files, Mr. Bradley?
6 A. They are copied from my files, yes.
7 Q. Would you agree that's a stack six inches thick?
e A. Including the folders.
9 Q. Several hundred pages?
10 A. Probably.
11 Q. Do you know how many pages there are, sir?
12 A. No, sir.
(. 13 Several hundred pages, would you agree?
Q.
14 A. Probably.
15 Q. Those were made available to me last week, Mr. Bradley, 5
16 and your lawyer told me that they were identified on Saturday, 8 17 How did they come to be identified, the previous Saturday.
O 18 Mr. Bradley, if you know, sir?
{3 19 A. On the previous Friday when I was discussing with counsel E
g 20 what had been provided, what I had provided--
Ig 21 Q. You mean Mr. Gibson here?
r !
22 A. Yes.
e 8
23 Q. All right.
24 A. And I raised a question what about these particular docu-25 ments?
27' g___ _ ... _ . _ ._. . . . , _ . ._ _ ...
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1 Q. What did counsel say to you?
2 A. As I, recall, counsel said he would look into the matter 3 and let me know.
4 Q. Did you make available copies of those to him at that time?
5 A. Not specifically. I told him of their existence.
6 Q. Did he ask you--
7 A. I told him what they contained.
8 Q. Did he ask you for a copy of them?
9 A. Not at that time.
10 Q. When did he ask you for a copy, if he did?
11 A. Correction. I believe Saturday he did ask me for a copy, 12 and-- Monday we satisfactorily produced them on Monday.
I 13 Q. To Mr. Gibson?
14 A. I believe I gave those to Mr. Bell for transfer to 15 Mr. Gibson.
a iv 16 Q. Were you aware of the request by Palmetto Alliance for 8
- 17 production of documents related to the subject of quality O
18 assurance at Catawba?
I 19 A. Yes.
E p 20 Q. Prior to the Friday which you had these conversations i 5 g 21 with Mr. Gibson?
E
- n 22 A. I realized which documentation was being gathered, yes.
8 23 Q. Why.weren't these documents identified before then?
I 24 A. Mr. Guild, I was not in the chain of determining what 25 documentation you and Palmetto required. .I made no such b 28 m_ _ _ _
J
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1 determina tions . I provided what documentation I was requested 2 to. ,
3 Q. You were assistant to Mr. Grier, correct?
4 A. Yes.
5 Q. And Mr. Grier was a participant in identifying documents o responsive to Palmetto's request for documents concerning 7 Contention Six, you understood that?
8 A. I assumed so, yes.
9 Q. Did Mr. Grier ever say to you, Mr. Bradley, "Bradley, H) how about those files of yours, the six-inch stack regarding 11 the implementation of the Task Force recommendations; how 12 about producing those for legal"?
t
- 13 A. No, sir.
14 Q. He never asked you for them?
15 A. No, sir.
5 g to Q. Did you ever talk about your work and the documents that E* l'7 you are responsible for maintaining custody of as responsive 8
g 18 to those document requests?
3 19 A. We talked about Volume 1 and Volume 2.
E r 20 Q. But not the implementation documents?
Ig 21 No, sir.
A.
22 Q. Or the documents relating to the nonconformance evaluation 3
8 3 23 team?
! 24 A. Ik), sir.
25 Q. Did Mr. Grier ever ask you about producing these documents?
( 29
~ - . - . , . -_
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1 A. No, sir.
2 Q., Did you ever suggest to him that these documents might 3 be producable?
4 A. No, sir.
5 Q. Did Mr. Grier ever ask you to review your files for docu-6 ments reflecting matters requested by Palmetto Alliance?
7 A. Yes, sir.
8 Q. Did you?
9 A. Yes, sir.
10 Q. When did he ask you to do that?
11 A. I don't recall. Three or four weeks ago.
12 Q. Only very recently?
( 13 A. Three or four weeks ago.
14 Q. Was that after you were informed that your deposition would 15 be taken?
j9 to A. I don't think so.
8
- 17 Q. But you're clear that Mr. Grier didn't ask you to review 18 your files any earlier than three or four weeks ago?
19 A. I may be wrong on the date. He asked me to review my files, i
20 yes, he did; but the specific date and time, I don't recall.
r Ig 21 Q. Was it'a year ago?
r 22 yo,
] A, 8
23 Q. Was it, if it wasn't three or four weeks ago, was it more 3
g 24 than a month ago? Two months ago?
25 A. It wasn't two months ago.
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1 Q. When you performed the review, or did you perform the 2 review Mr,. Grier asked you?
3 A. Yes.
4 Q. What did you identify when you did that review, sir?
5 A. I identified certain letters in my letter file. They were o copied, given to, I believe, Mr. Bell, and I believe some of 7 the documentation you have shown me this morning were those e copies.
9 Q. The ones from these files here?
10 A. No, sir, not these.
11 Q. How many documents did you identify then and pass on to 12 Mr. Bell?
b 13 A. In what time period?
14 Q. Well, when you responded to this request by Mr. Grier?
15 A. Possibly twenty.
5 16 Q. They were in the nature of correspondence?
E 17 A. Yes.
o y 18 Q. They were not the files'that you have got in front of you, a
19 the six-inch stack of implement documents?
{
g 20 A. No, sir. >
E 21 Q. What did Mr. Grier ask you to look for in your review, r
y 22 Mr. Bradley?
8 23 A. Anything related to the Welding Inspector Task Force. I 24 Q. Why didn't you identify the implementation documents at 25 that time?
I 31
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1 A. Why didn't I identify the implementation documents at that 2 time? I believe the request was to go through my letter file 3 and identify anything to do with the Welding Inspector Task 4 Force,which I complied with.
5 Q. He aske:1 you to go through your correspondence file?
6 A. Yes.
7 Q. Mr. Grier familiar with the existence of the implementing 8 documentation?
9 A. Yes.
10 Q. How do you know?
11 A. He signed each and every one of them.
12 MR. GIBSON: Mr. Guild, I want to point out_one of
( 13 those folders is labeled correspondence in those documents 14 referred to, but the bulk of those folders are the implementing 15 documents broken down into specific areas. One of those Q
= 16 folders given to you is labeled correspondence or correspondence v
8
- 17 file or something similiar and has those documents if you want B
18 to be clear on that.
g 3
19 Q. Counsel, your position is that the correspondence that the
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20 witness identified,in response to Mr. Grier's request for r
Ig 21 reviewing of the correspondence file are contained in that I
22 correspondence folder?
g 8
s 23 MR.'GIBSON: Why don't you ask Mr. Bradley to be sure.
8 s
24 Q'. Is that correct, sir?
25 i A. Yes, there is a great deal of duplication.
( 32
__ .___ _ _. m ._ . _ _._ _ _.
(
1 Q. Let's talk about it the best we can, Mr. Bradley, of the 2 implemen,tation of a nonconformance evaluation team, written 3 guidelines that you have identified, Exhibit 5, authority of 4 the team, decisions of the team regarding NCI acceptability 5 or denial. Is there any other written procedure of the company 6 to your knowledge, Mr. Bradley, that vests in this team final 7 authority to decide on the acceptability of a nonconforming 8 item other than this guideline?
9 A. No.
10 Q. But it may be appealed to the appropriate department head?
11 What is intended by the appropriate department head?
12 A. Well the team is not vested with all knowledge. We attempt,
(
13 to reconcile any problems with the resolver of the NCI. As I i
14 said, we may not be right. We may get to a minor confrontation' 15 and have to resolve it at the departmental level.
4 g to O. Who would be the department-head?
v 8
- 17 A. It would be one of three.
O 18 The individuals who signed the guidelines?
h Q.
I 19 A. That's correct.
I 20 r Q. Mr. Dail, Mr. bick, or Mr. Grier?
Ig 21 A. Yes.
E 22 Q. Do you know of any other procedure of the company _that i 8
23 vests in the appropriate department head the authority to g
24
~
, consider on appeal the acceptability of a nonconforming item?
25 A. No, sir.
4
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33 i
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1 Q. Other than this guideline?
2 A. That,'s correct.
3 Q. Though work may normally proceed on NCI's being reviewed, 4 the team may stop work through the site quality assurance 5 organization. Is there any other procedure of the company 6 that you know of, Mr. Bradley, which vests in the team the 7 stop work authority?
8 A. No.
9 Q. Other than this guideline?
10 A. No.
11 Q. Is it your understanding that it's consistent with other 12 procedure at the company for work to proceed normally on
(
13 pending nonconforming items?
14 A. Under certain circumstances, work may proceed.
15 O. What circumstances?
G g 16 A. If the defect will not be-- I'm searching for a word. If U
t- 17 the defect will not be covered up, such as poured over with 0
{ 18 concrete, or something like that, work could proceed under 19 certain circumstances. It depended on the defect.
20 f Q. Is it reflective of general policy of the company that as r
ir 21 the guideline seems to suggest, work may normally proceed on g 22 NCI's being reviewed?
8 23 A. I can't speak to company policy.
24 Q. You don't know?
25 A. No, other than what's stated how it_may proceed. I 34 I
l p _. _ . . ~ .
, l
(
i Q. You don't know whether that's an exception to the rule 2 or whether that's the general rule?
3 A. I don't.
4 Q. Under the provisions basically operating rules of the team, 5 the team evaluates each NCI and associated Criteria 16 6 Evaluation. Does that Criteria 16 Evaluation refer to 7 Criteria 16 of Appendix B to LOC of Part 50?
8 A. It does.
9 Q. Nuclear Regulatory Commission's quality assurance lo criteria?
11 A. Yes. ,
12 Q. Against a prepared check list of considerations limiting
( 13 to their concern to those listed on the check list,'that 14 check list is the list attached, NCI Evaluation Check List?
15 A. Yes.
16 Q. Did you write these guidelines?
i= 17 A. I participated in the writing, and I put together the O
y 18 final draft, yes.
3
{ 19 Q. Who else participated in writing them?
a j
20 A. Mr. Tom Robins 6n.
21 Q. Who is Mr. Robinson?
I g
22 A. Mr. Robinson is a civil engineer Catawba Station, and 5
23 Mr. Bob Dobson of Design Engineering Department, who is also 24 an engineer, electrical, I think.
25 Q. At Catawba? l I
35
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1 A. No, he's general office.
2 Q. Thos,e gentlemen have any relationship to the evaluation 3 team?
4 A. No.
5 Q. Who wrote the NCI Evaluation Check List?
6 A. The same individuals.
7 Q. How is the check list employed when your team is reviewing 8 a nonconforming item?
9 A. It's available. We are all quite familiar with it. We 10 don't use it for constant referral.
11 Q. Do you document each of the criteria as set forth, almost 12 all of the criteria set forth are questions, are they not, on
( 13 the check list?
14 A. I don't understand.
15 Q. One, is the problem clearly stated and described?
5 4 16 A. We address that, yes.
0 8
- 17 Q. How do you address that?
C h 18 A. Well, as I said, we become familiar with the contents of 3
{ 19 the check list. We don't have it in front of us. We go I 20 through a mental process that answers that question.
g Ig Do you document the answer to that question?
21 Q.
I g 22 A. No.
n 8
23 Q. Do you document the answer to any of_the questions on the g
24 check list?
l l 25 A. No.
, +
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36 l
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1 Q. Do you document the answer if the answer is a negative?
2 A. I th, ink some of those require a positive answer.
3 Q. If the right answer is positive and the answer is negative, 4 do you document the negative answer, sir?
5 A. Only in case of the correspondence that would send the 6 NCI back in that sense.
7 Q. Do you maintain notes of the committee's deliberations on 8 an NCI issue that you could compose the appropriate corres-9 pondence later?
10 A. No.
11 Q. Who does?
12 A. No one.
( 13 Q. How do you compose the correspondence?
Id A. If we run across an NCI which we don't feel is satis-
~
15 factory, I document that in correspondence to the individual Q
16 responsible for satisfying our problem.
8
- 17 Do you do it from memory?
Q.
8 18 A. I beg your pardon.
e E
e 19 Do you do it from memory?
g Q.
a j 20 A. Yes.
5 2 21 Q. You have the NCI in front of you? You have your meeting I
22 and have gone through a stack of NCI's that day, and_you come 8
g 23 in the next day to write the correspondence, and you remember
\
s 24 without reference to the check list' or any notes what the deficiencies were and how the eighteen items on the check list;
'l 25 37 i 1 l
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i were answered affirmatively and negatively?
2 A. ,
That,'s not totally an accurate description. What occurs, 3 I possibly, if we consider an NCI deficient, I will probably 4 "X" it at the top with some notation and, as I told you 5 earlier, I maintain a log and make some note on that log to 6 remind me of the problem. I would probably write the letter 7 that same day.
8 Q. So the notes that would serve as the basis for your 9 correspondence were the notes on the face of the copy of the 10 NCI you had or related document and in a log you maintained?
11 A. Yes.
12 SHORT RECESS (10: 25 a.m.)
( (By Mr. Guild) (lO:50 a.m.)
13 CONTINUING EXAMINATION:
14 Q. Mr. Bradley, let me show you another document and ask is you to identify that.
~
3 I have seen the document before, yes.
g 16 A.
y 8
- 17 Q. Can you hand the book to me?
O j
3 is A. Yes, sir.
2 19 Q. Let's mark this as the next Exhibit, Exhibit 6.
E j 20 September 3, 1982,' document, memo to file, subject meeting n
E 21 between W. H. Owen, L. C. Dail, R. L. Dick, and G. W. Grier, r
22 and Kim Van Doorn, and Jack Bryant of the NRC. Have you got g
5 23 a copy-of this memo?
I 24 A. Yes.
25 Q. I want to understand how you understand this statement in I
i
(~ 38
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1 Mr. Grier's memo. W. H. Owen asks that we assure ourselves 2 that con,cerned inspectors have had an opportunity to agree 3 that their concern has been resolved. What do you understand 4 by that statement?
5 A. It means to me that Mr. Owen would like us to have devel-6 oped, perhaps, an interview system with the inspectors to 7 assure that their concerns have been addressed.
s Q. An opportunity to agree that their concerns have been 9 resolved? How about an opportunity to agree that their con-10 cern has not been resolved?
11 A. Yes, that would be part and parcel of it in my view.
12 Q. W. H. Bradley needs to take the lead here to recommend
(
13 a course of action. What course of action did you recommend, 14 if any?
15 A. I never documented a cour',e of action. We had a number of Q
g 16 discussions over what should be done in that particular case.
v I 17 I suggested at one time that I be permitted to interview each 8
g is concerned inspector as an outside party to answer the questions 3
lt 19 Mr. Owen asked.
j 20 Q. Who did you su'ggest that to?
Ig 21 A. I believe Mr. Grier and Mr. Davison.
r 22 Q. What was their response to that suggestion?
3 8
23 A. They were receptive, but they were trying to develop a g
24 final course of action, and they didn't need one immediately.
25 Did they ever leave upon it?
Q.
(,
39
(
1 A. Not my particular recommendation, no.
2 Q.,
Did .they explain why not?
3 A. No. We discussed it in context of how should you do it, 4 what should we do? How should we do it? And my suggestion was 5 that I be permitted to do it.
o Q. What did they decide instead?
7 A. I'm not sure.
8 Q. Ideas, this follows from the last statement, ideas:
9 construct a matrix showing general areas of concern, 10 recommendations, to answer those concerns, and actions taken 11 based on those recommendations. Was such a matrix con-12 structed?
13 A. We had such a matrix which was brought in yesterday, and 14 we discussed it yesterday, but the matrix I developed was 15 not in direct response to that. It happened to satisfy it,
~
3 16 but it was not in direct response to that.
3 0
8 17 Q. You developed a matrix showing the general areas of concern',
I 8
e 18 correct, the programatic recommendations?
2 e
g 19 A. You have the one on the programatic recommendations that a
20 I developed, yes.'
}
e E 21 Q. You also developed one on specific recommendations?
- I 22 A. Yes, sir. -
l 8 23 Q. That's the one your lawyer has declined to produce?
l 24 A. I believe that's correct.
- 25 Q. What else did you do, or do you know about the response to k,
40
.m...._._ . ._
7 - - . - _.
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1 Mr. Owen's request?
2 A.
I wo,uld have to lock at it to refresh my memory.
3 Q. Please.
4 A. Other than what's stated there, I don't believe I had any--
5 I had no other involvement if that is what your question is.
6 Q. Yes, sir, it was. Do you know of any other action that 7 was taken if you weren't involved?
8 A. I can't speak specifically to any other action taken. As 9 I say, I wasn't involved. I'm sure some of it was carried out.
10 Q. Page 2, paragraph 4, of the same Grier memo. There may 11 be a need to make a presentation of our Welding Inspector Task 12 Force material to the Office of Investigation of the NRC.
t 13 Jack Bryant will determine whether this is necessary. . Warren 14 Owen indicated that we could make a presentation or that 15 office would be free to talk with Lew Zuissler. Kim Van a
j 16 Doorn made a comment that he has sent some material to Jack s*
17 Bryant in this area. W. H. Bradley needs to take the lead to 8
g 18 determine what material has been sent to Atlanta. G. W. Grier 3
! 19 will' follow-up with Jack Bryant on this item. What did you do I 20 with regard to tha't matter?
i g
I 21 I believe I communicated with Mr. Van Doorn, and we 2 A.
r 22 reviewed what information I had supplied him, which was in 3
8 23 the nature of Volume 1, Volume 2, any revisions to those docu-g 6
24 ments, and he then ascertained what had been sent to Atlanta.
j 25 Q. What did you understand had been sent to Atlanta?
( 41 I,.___.._...__.
e .
(
1 A. I had no understanding.
2 Q. Mr. Van Doorn didn't tell you?
3 A. No.
4 Q. Page 3 this same memo, W. H. Owen made a brief statement 5 in regards to the INPO Self Initiated Evaluation to be con-6 ducted at Catawba in September. He assured Kim Van Doorn 7 that we would keep him informed of the progress of this 8 evaluation and would share results with him. G. W. Grier 9 informed Howard Huggett of this requirement on September 2nd.
10 Who is Mr. Huggett?
11 A. Mr. Howard Huggett I have lost track of his exact 12 responsibility now, but I believe he is in the Project
(. 13 Control Group.
14 Q. Do you know whether Mr. Van Doorn has been provided with
~
15 the results of the INPO Self Initiated Evaluation?
Q z 16 A. I have no understanding of that.
y 8
- 17 Q. Do you have any knowledge that he has?
8
. 18 A. No.
B Would you know if he had?
l4 19 Q.
20 A. No.
E 21 Q. Do you know whether or not Mr. Van Doorn or anyone else r
g 22 with the Nuclear Regulatory Commission is aware of the existence 8
g 23 of the-nonconformance evaluation team?
s 24 A. Yes, sir, they are. Mr. Van Doorn.
25 Q. How do you know?
42 l
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i A. Because I have told him.
2 Q. ,
When, did you do that?
3 4. . At about the time of the initiation of the team or 4 perhaps prior to the initiation of the team's efforts.
5 Q. How did you tell him?
6 A. Verbally, casual discuscions.
7 Q. Did he have any response to your information?
8 A. Yes, he had a response. In normal conversations, I think 9 Mr. Van Doorn was pleased that Duke had taken a lead to develop 10 such a team.
11 Q. Did he say you're doing a good job or words to that effect?
12 A. Not that I recall.
(. 13 Q. But he expressed pleasure at the existence of such a 14 team?
15 A. Yes.
E 16 Q. Did he ask you any questions about it?
v 8
- A.
17 Yes.
t O
y 18 Q. What did he ask?
2 l4 19 A. Who was going to be on it, what are you going to do, and l 20 I described it to him.
r l g 21 Q. Did you provide him a copy of the implementation memo,
! l
! g 22 Exhibit 57 e
1 5
l y 23 A. I don't recall, Mr. Guild, I probably did.
2 24 Q. How about the NCI Evaluation Check List?
25 A. Same answer.
[.
43
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( 1 1 Q. Probably had?
2 A. Yes.
3 Q. Have you had any subsequent conversation with Mr. Van Doorn 4 or other NRC about the teamwork?
5 A. Only with Mr. Van Doorn. I kept him apprised of how we 6 were doing, what we were seeing, generalities, and Communi-7 cated with him on probably a weekly basis for some weeks.
a verbal communication.
9 Q. Nothing in writing?
10 A. No.
11 Q. Do you know whether or not Mr. Van Doorn has ever ref1 cted 12 information regarding the team in any of his written reports,
( 13 inspection reports to others?
14 A. No , sir. -
15 Q. You just don't know?
{
y 16 A. No.
8
- 1:7 Q. Do you normally review those inspection reports?
O y 18 A. His inspection reports?
3 19 Q. Yes.
{~
E g 20 A. No. -
n ir 21 Q. Mr. Van Doorn ever review any of the results of your g 22 team's work?
n 5
23 A. Not to my knowledge.
24 Q. Did you ever provide him copies of correspondence reflect -
25 ing identification of deficiencies NCI resolutions?
( ' 44 1
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1 A. No.
2 Q. Did he ever review your correspondence on the teamwork?
3 A. Excuse me?
4 Q. Did he ever review your correspondence on the team's work?
5 A. No.
o O. Ever express any interest in reviewing them?
7 A. No.
8 Q. How about your log of the team's work?
9 A. No.
10 Q. Would Mr. Van Doorn have known of it, I believe you stated 11 about seventy-five NCI's which your teum sent back for one 12 reason or another?
i 13 A. No, sir, he would not know the numerical count.
14 Q. Would he have seen those specific NCI's?
15 A. He would have seen them but not as a result of my activi-lv 16 ties.
17 Q. Mr. Van Doorn sees all the NCI's, doesn't he?
O
{3 18 A. That's my understanding.
19 Q. He gets a copy of the NCI's?
E g 20 A. Yes. '
21 Q. Would he have gotten-- would there'be anything on the I
g 22 NCI that would have indicated to him that the NCI had been 8
23 processed b'y your team and the team had reached a certain g
24 conclusion about that?
25 A. Not likely, no.
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1 Q. When, if you know, does Mr. Van Doorn get sent a copy of 2 an NCI? ,
3 A. I believe, and this is conjecture or. my part, he gets a 4 copy at initiation of the NCI and he gets a copy of the 5 resolved NCI. That is the same piece of paper except in 6 different stages.
7 Q. So, is it fair to understand, as you understand anyway, 8 that Mr. Van Doorn would see a copy before your team reviews 9 and after your team has completed its review?
10 A. He would certainly see it before. I'm not sure after.
11 Q. Would he see it af ter if your team sent it back for 12 further action?
' Yes because it's my understanding he sees all final 13 A. ]
14 NCI's.
15 Q. But there would be nothing about the final NCI's that he 16 saw that would indicate to him any action by your team on 5
0 17 that NCI?
O
{3 18 A. There is a situation that has developed that he could
{ 19 derive that we had sent it because on some time, when an NCI E
g 20 is sent back, they'might-- they, meaning the site, might i 21 attach a copy of the correspondence to the NCI file; and in 2
r g
22 that manner, Mr. Van Doorn could ascertain that yes, I had 8
23 seen it and taken some action with the site or engineer.
g 24 Q. Is that consistent policy or practice to attach the 25 correspondence to the resolved NCI?-
46 l
f 4
(
1 A. I can't speak whether it's consistent or not, but I have 2 seen some where they have done it.
3 Q. So where it's not done that way--
4 A. I don't know.
5 Q. Is that required by procedure?
6 A. No.
7 Q. At this time, counsel, I would like to adjourn i Mr. Bradley's deposition and have Mr. Bradley available to 9 resume next week as we discussed off the record. I would 10 ask that Mr. Bradley identify and make available at a time 11 later next week when we get him back-- the documents referred 12 to reflecting the work of his team, the NCI Evaluation Team.
( 13 I understand from his testimony that consists of his log 14 and of Correspondence reflecting the action taken by the team 15 on those NCI's. .
3 g 16 MR. GIBSON: Mr. Guild, we will not agree to adjourning v
8
- l'7 Mr. Bradley's deposition to be continued at some other time.
O y la I indicated to you off the record we will consider your 3
19 request for these other documents and at this time will not 3
y 20 agree-to make Mr. Bradley or any of the other persons available
( I 21 for continuing depositions absent an order from the Board. Jus l 2 i E g
22 I have indicated to you generally, we will consider and i
23 reconsider sach of these positions as we discuss matters with g
24 you further. With respect to the documents identified by l
25 Mr. Bradley, we, as I have stated earlier,-contend they are l
b 47 3_ _. _ _ . _ ._._ _ _ _
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1 not discoverable, but have made some of them available. I 2 suggest we both note our positions as we have done; and if you 3 will, as we requested, when you get a moment, make a complete 4 listing of the items that are in controversy you think should 5 be produced, and we haven't produced, we'll review those and 6 make a determination as to which ones we will make available.
7 I understand your position is that you want to continue with 8 Mr. Bradley at some point. We are declining to agree to do 9 that subject to reconsideration. I would note that 10 Mr. Bradley is not going to be available next week as indicated 11 to you earlier in correspondence.
12 Q. Counsel, of course I would ask that the record reflect.that i
13 upon identification and production.of the six-inch stack of 14 documents reflecting implementation, Mr. McGarry and other 15 counsel for the applicants, informed me~that at my option, we 4
g 16 could postpone Mr. Bradley's deposition.to permit me to review 8
17 .those documents and, of course, I would rely in part on that O
18 position expressed by counsel with respect to documents made
{3 I 19 available to me only during the course of these series of-I j 20 ~ depositions we have been taking.
e E 21 MR. GIBSON: Mr. Guild, you never' indicated to us you E
22 wanted to postpone Mr. Bradley's deposition although it was nog
[ g i 23 taken when it was originally scheduled. I think we both 24 expressed our positions, and we have done before, and we l 25 will continue to try to work out matters between counsel to C2 48 l
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1 avoid burdening the Board with unnecessary disagreement, but 2 some items will have to be taken to the Board; and if you will l 3 identify all those and we will discuss them again and see 4 which ones can be resolved and which ones can't. At this time, 5 we are not agreeing to set another time for Mr. Bradley or 6 any other Duke employee absent our changing that position or 7 some further order from the Board. Have you any other questions 8 of Mr. Bradley at this time?
9 Q. I'm prepared to adjourn subject to calling Mr. Bradley as 10 I have indicated.
11 MR. GIBSON: I think the record is clear that you take 12 the position it's adjourned, but we take the position it's the
( 13 end of the deposition and that our positions will have to be 14 reconsidered or the Board will have to tell us the present 15 status. I have one question of Mr. Bradley.
16 EXAMINATION: (By Mr. Gibson) v 8
a l'7 Q. Are you aware of anything that would cause you to question 18 whether Catawba Nuclear Station is safely built?
E 19 A. No.
t 20 f ,
e g 21
- WILLIAM HAROLD BRADLEY g 22 a
23 e
24 25 i
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(
1 STATE OF NORTH CAROLINA )
) CERTIFICATE 2 COUNTY OF MECKLENBURG )
3 4
5 I, the undersigned Commissioner and Notary Public, in and 6 for the State of North Carolina, do hereby certify that 7 William Harold Bradley was duly sworn prior to the taking of 8 his deposition.
9 I do hereby certify that the foregoing forty-nine pages 10 constitute a true and accurate transcript of the evidence 11 given by the said witness as taken down by me and transcri'ed 12 under my supervision.
I 13 This the twenty-sixth day of July, 1983.
14 15
~
BARBARA V. HAAS k 16 Commissioner and j
= 17 Notary Public o My Commission Expiresi g
18 April 23, 1987 3
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