ML20093K075
| ML20093K075 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/03/1984 |
| From: | Brandt C TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| References | |
| CON-#484-525 OL-2, NUDOCS 8410170157 | |
| Download: ML20093K075 (124) | |
Text
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4535C 6%S .
1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 2 BEFORE THE ATOMIC SAFETY f. LICENSING BOh7,. JD 3 IN THE NATTER oft )
) N 4 TEXAS UTILITIES CLECTRIC ) DOCKET NOS. 07 fg P2:53 COMPANY, ET AL ) 50-445'6 0 5 ) 50-446 O L -1 (COMANCIIE PEAK STEAM )
6 ELECTRIC STATION, UNITS )
1 AND 2) )
7 l
9 10 PREFILED TESTIMONY OF 11 C. T ii O M A S DRANDT OCTOBER 3, 1984 12 13 14 15 3 16 17 PREFILED TESTIMONY OF C. T i! O M A S PRANDT, taken on 18 the 3rd day of October 1984, in the above-stylod and 19 numbered cause, at Ramada Inn located at Beach 20 Stroot and Interstate 30, in the city of Port Worth, 21 County of Tarrant and State of Texas, before Janet 22 E. Schaffer, a Certified Shorthand Reporter in and 23 for the State of Texas.
24 8410170157 841003 ,
25 PDR ADOCK 05000445 T PDR g 4
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' 2 -. DISHOP, L I B E R M A N ',.. C 0 0 K', PURCELL )'REYNOLDS-
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' - LAtt_orneys at!Lawi .
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'120C: Seventeenth Street,.'N.W.
,- T. JWash.ington',-Dic. -20036 '
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=l+ :, BY: Bruce L._Downey, Esq. .
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APPEARINC FOR APPLICANTS '
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.C. THOMAS TRANDT, sag - .
f7-the witness 3hereinbefore named,.being-first~ duly i 1 2
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3- cautioned andjsworn.to testify: tho truth:'the whole
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- 4 truth'and-nothing but.the truth', testified.on his
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cath"as: followss' ,
EXAMINATION ~
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.5YI MR. :' DOWN EY's .
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8
-Q. Mr. Brandt, do the-travelers that you have 9 l produced in this proceeding 1 represent the travelers '
10 'that correspond to the fabrication and installation
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11' of the' liner plate for the refuelin'g cavity for
- 11 2 reactor Unit 2 at Comanche Peak?
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13 .A. Yes, they-do.
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< ws 14 Q. And does each' traveler correspond to a r'
15 raingic weld made in the-process'of fabricating and
' 16 installing that liner plate?
17 A. Yes.
18 i Q. And do the' travelers as a group correspond
-19 to.different t y p e s . .o f weldsLeado.In the process of 20 fabricating and installing that ' liner plate?'
21 A. Y e s .- LThere are several different types!of A
22- welds irfolved.
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x 23 Q. 'Mr. , arandt, would you give'some examples of
. 24 the types.of welds made in the fabrication and 1 ") r A )
, 25- installation of'this liner plate?
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- Esamplos4would include _plateito plate,
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'qf ' - 2 . p'i n t e to ~ angle,--angle'tocangle, plate,toipipe, embed
< -t 3 s to plate. 'Those are some esamples.
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- 4 0.: JMr. Brandt, when.you say'the traveler 1
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5 representsfa plate-to-plate weld, would you describe that weld?
6
. '_7 A.. Yes. This wouldLbe a weld adj oining:.two- of-c: ; 8 Tthe large stainless steelLplates, essentially
. -9, Lforming a seam.
101 ' ,0 . -And'when.you referenced a plate-to-angle 11 weld,' what>kindrof weld is that?
12 A. This would'be one of these large stainicas n 13 ' steel plates.to an angle, either at the side, the
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14 ' corner, ~the top (or the bottom of the pool. -
15 Q. And whenEyou mentioned an angle-to-angle 16 weld,-what type of weld is that?
17,. A. This would be a splice between two
'18 different angles.
19 Again,.would those occur at the cornara or 10 .
a 20 at the --
21' A. .The top or the bottom.
22 0. Mr.1Brandt, when you mentioned a 23 plate-to-pipe weld,.what kind of weld -in that?
'24 '
A. This..would be a pipe weldedfon to the plate'
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'J 25 .using,a_ fillet-weld.
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[ 1- 0. . -And.whenJyou~ identified an embed-to-plate.
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LJ m L2 weld, what kindLof weld is'that?
'3 A. There were1 embeds which were'to be1placed K.. . y, ..
.4 in the concrete. There were cutouts made~in the 5;- 4 plates,themselves toiweld these.cmbeds-into and-6 ' that's' parti of therpressure boundary. In some cases 17 ' these embeds are? welded to the_ plate utilizing a-8 ' full penetration weld and some cases they're welded:
to'the' plate'using.a full penetration weld and a 9'
10 filiet weld.' ,
7 11'- O. And Mr. Brandt, did the-number and type of 12 Inspections. performed by OC depend on the type of y :-
I' 13 vold that's being inspected?
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14 A. Yes, it1does.
15 O. Mr. Brandt, you've testified-that in many 16 casos the wrong traveler form was used to document 17 the construction;and inspection activity with-18 respect, to these welds. Is that'a correct 19 characterization of your prior testimony?
20 A. Yes,'it is.
21' O. And when this matter was brought to your
- 22. attention, what were your principal concerns as a OC 23 supervisor.'at Comanche Peak?
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'24 'A. I-wanted to ensure that the procedurally
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25- required inspections could be verified as having
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p 5- 11 xbeen, performed through objective' evidence of the
.R v 21 performance oflthe inspections.- InJcases where such
,3' Javidence co'uld not be found, I wante'd to_ ensure that
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- 4' appropria te Jde f'iciency, paper -was -initia ted- to
, 5- describe.the ~ missing-documentation.-
- 6 Q. To the best of your knowledge, has that
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. objective _beenisecomplished?'
8' A. Yes, it'has.
l9 Q.: Mr. Brandt, fare you awaro'that the
'10 intervenor in this. proceeding has made-numerous 11' allegations concerning' alleged deficlenctus in the 12 travelors that you have produced for the board?
13 'A. Yes,~1 am.
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14 0. Mr. Brandt, I'd like to take you through )
15 each of the traveler packages where cuch allegations 16 have been made and ask you some questions about 17 these allegations. And for orderliness, we'll start 18f .and do these in numerical order.
19 Do you have before you now traveler package
, 20 2-A7
'21 A. Yes, I do.
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r 22 0.. Mr. Brandt, are you aware t h'a t in a
- 23 memorandum filed sin this1 proceeding on September 27,
- 24. _1 9 8 4~, the intervenor alleged that traveler package
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^', J25 '2-A is' deficient because certain documentation is 7
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@_' s ..1- : missingifrom thel' package and-because the wrong 4 %C p-i {2:
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traveler--form was used?
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-3; A .' _Yes, I ~am.
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~0 -Mr. Brandt, what kind of. traveler-form was M.'
5- u s ed : ff o r weld 2-A?
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A. ' I t was the._eight-line form. ,
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O. Was this the proper form to use~.at the time 4
'8- this packagejwas initlated?
9 A.- Yes,'it-is.
10' Q. And so.when CASE alleges that the s
- 11 eight-line-traveler. form was improperly'used in 1978 a
12' and ' 7 9, . -tha t 's ' a n orror; is that correct?
-13 .That's true.
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I1'4 O '. Which procedure required the use of this
'15 particular traveler form in the period during which 16 this traveler package was issued?
.17 A. This eight-line form-was required by c: 18 interim change notice number 3 to CCP-38, which is
- 19' dated April 18th, 1979, and is referenced in the QC 20; inspection procedure QI-QAP 10.1-4 Rev. O, dated j 21; January 5th, 1979.
22 Q. So your testimony is'that this traveler }I 1
2,3 package was initiated using the correct form?
% 24 A. "Yes, it is.
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25 Q. And when CASE alleged in its memorandum b
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' dated september- 27,.1984,- tha't the wrong traveler
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-m. v i f- ! 2. package,.the wrong' form, was used i n - t h i s --.t r a v e l e r u -
. J3 package, that's incorrect? 2
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A '. .- -Yes.
- y. .5, - Qi- snow, Mr. Brandt, returning-to the 6 ,allega tion 4 tha t there'is documentation missing from
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f7 this traveler package, what-is your understanding of 8 'that allegation?
9 A. . .It's my understand'ing from intervenor's 10 -memorandum that intervenor-contends that the VT', PT
, s 11; an'd VB test reports are missing.
12 Q. Mr. . B r a nd t ,- with respect to Step 1cof the
! -L 13 traveler,-has.that. inspection been performed?
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14- A. Yes, it has.
15 Q. Is any, documentation-required other than i
16 the~ signature of the inspector to document that 17: ' inspection?
18 ,
A. No, it's not.
19, Q. ,
Mr. Brandt, I observe that for Steps 2 20 through 6 on the eight'-line' traveler 2-A the lines 21I are marked ,
"NA". Does that stand for Not Applicable?
.22 A. Yes, it does. As the traveler is marked on 2 3. _ the top, embed to plate Oumber,824,-the embed to n,
24 l plate. welds do,not have a leak chase channel, so bb i
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- Stepsj2 through 6 are not applicable. ..
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wj :11 Q.: And has there.been a' final; inspection of y%. ::q '
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1 (2 this weld? .
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_3 ; A. No, there has not.
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4 t,. .' ~4 ~Q. And willlthis'. traveler _. package be complete y J
, 5s prior to the 7 pe rf ormance.' of ~ tha t ~ final--inspection? 9
'6 .A.- No, 'ltfwi11 not..
., 7 [ 'Q . : .- Is this: weld 7st111 in. process? ,
q 3 1A. fYes, it i s .' ,
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- 9- Q. (Based 1on'your revlew'of this. package, is 10 there anyl' documentation missing?
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A., No. All documentation required for the
.12 ' current ~ status of the process i s ' l' n the package.
13 Q. . Mr. Brandt, are youl aware thatJin the 14 memorandum ~ filed Se p tiembe r 27th, 1984, CASE alleged 15 a deficiency in'this traveler package, that is 16 package 2-A, because an inspection was performed 17 before weld rod.had been i ssued?
18 A. Yes.
And'in fact, was an inspection performed
~ 19 Q.
20 be' fore weld rod was issued?
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21 .A. No. There's--nothing to indicate to me that
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22 'there was an inspection performed. I might explain 23 'the front page of the traveler' clearly indicates 24 that WNR was used to issue rod for the initial f %. ,
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~25 fit-up.and cleanliness.- WHR's were the' predecessor g L
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f.,te theiWFMLilchangeover-~from WMR's to.the;WFML took
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- >.y dc :# 2' place.;sometlie,in 1979. There's no reason'to:
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- 3 believe , ' f o r ime to;believe, that this WMR was-.not
- M '_ 4 _ issued:pri'or to1May 7th, 1979, which was the date o f-
. 5' the-first-inspection'on'this weld.
- 6 10 . Mr..'Brandt, would you please refer to ,
7 ," traveler package number 47
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x 8 :A.3 Okay., ,
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9' O. Mr.~Brandt,.are you awaro that in the e v 10 handwritten list of allegations served on the 11- applicant.during-the hearings in this proceeding and
'12 : in the transcript'of the'hearins for September 18
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13 the intorvenor-slieges that this traveler package is 9
14 deficient,because line 5 of the traveler was' marked 15 " Sat", but there is no inspector signature or date?
16 A. Yes, I am.
- 17~ 0. Mr. nrandt, is that in any way a deficiency 1
18- 'in the package:7 29 A. -No, it's not.
~20 Q. Why not?
.f 12 1 A. I have no idea who' wrote the " Sat" on line t
22 5 of the: traveler.- '
However, the " Sat" serves
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' absolutely no' purpose there without an inspector
.. 24 signature. The current status of this weld is still n
A )~ 25, ' i'n process; that-is, it has not received fina1 4
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45366 1 visual inspection of the inside weld; it has not
- 2 received a liquid penetrant examination and it has 3 not been vacuum boxed; the weld is still in process.
L 4 The final visual inspection of the inside weld is 5 yet to_ occur.
6 0. And it's only when that inspection occura 7 and.an inspector _ signs and dates the traveler that 8 the line 5 of this traveler package takes on any 9 . significance?
10 A. That's true.
11 0. Mr. Drandt, would you please refer to 12 travolor package number 6. Are you awaro that in 13 the handwritten list served on applicant in this 14 proceeding and in the transcript in the hearing for 15 September 10, 1924, the intervenor has alleged that 16 thero's a deficiency in this package because line 5 17 of the package was naa r k ed " Sat" and there's no 18 inspector's signature or d ,s t e on that line?
19 A. Yes, I am.
20 0.- Mr. Brandt, is that a deficiency in this 21 package? ,
22 A. No. For the samo reasons that I described 23 in weld 4, it's not of concern.
24 0 Mr. Brandt, are you aware that in the
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25 handwritten list served on applicant in this FEDERAL COURT REPORTERS
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(_Je 2 _,= September:18,and in the memorandum served on
~3 applicank on September.27th, 1984,.the intervenor-4 -alleged a deficiYncy'in this package because of the
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w 5 ~way.in which line 1 of' traveler, package 6 is signed?
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6 A. Yes, 1 am.
7 4 Mr. Brandt,'what inspection or inspections
- e; 8 does line i represent in this1 weld package?
9' -A. The signature on line 1-by Mr. Cole dated
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10- Marchi24th, 1980, indicates the fit-up and 111 cleanliness of thi inside weld. The fit-up and
. 12 cleanliness of the outside weld is' substantiated by r3 13' the existence of a chit which is attached to the
.LJ 14 ps,ckage signed by Larry Wilkerson, dated September
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15' 12th, 1978, which roads first fit-up and cleanliness "16 -of plate to plate.
17 0. ' Based on_your review of traveler package 6, 18 is it your judgment that cleanliness and fit-up 19 inspuctions wcro conducted for both the insido and 20 outside weld?.
21' A. Yes, it is.
22 Q. Based on your review of this package, are s
.23 there any deficiencies as a result of the way in 24 which line 1 was signed?
25- A. No. The package contains objective
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- 1 ' evidence substantiating that both cleanliness and
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'h$ . M r . - B r'a n d t', ~ ~v o u l'd you p1 ease _ refer _to
( u E4- .t'raveler package; number 7. . Are-you aware that in
- ~5- the handwritten list served-on. applicant in this T
6' proceeding,'thel transcript'of-the hearing for.
so i SeptemberL18 and 'the memorandum served on applicant 7.
8 'on September 27, 1984,:intervenor alleges that this I
9 package is deficient because of the way l'n which i
10- line 1 of the traveler is signed?
11 A. Yes, I am.
12 0. Mr. Brandt, would you please review the 13 package and state whether~there's any impropriety in
,[ 14. the way in which line number 1 is signed in this L
l 15 . package 7 h' 16 A. No, there is not. But to understand this
- 17) weld, you have to look at the weld description, 18; which indicatos that it's a plato to a. pipe wold, 19 which'is the fillet weld. It's not a two-sided weld
.,s ll 20 as the seam welds are, in that the fit-up and'
. 21 cleanliness only occurs once. Here the fit-up'and 22 cleanliness inspection was signed off on line 1 by A
23 Mr. McCoy on.rebruary 1, 1979. This inspection is
'24 for the fit-up of the fillet weld that attaches.the
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- 25 pipe to the plate.
$ $ 5 b
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45369 1 Q. Mr. Brandt, are you aware that in I 2 handwritten list of allegations and the transcript 3 of the hearing of September 18 and in the memorandum 4 -dated September-27th, the intervenor han alleged
- 5. that there's' documentation missing from traveler 6 package number 77 7 A. Yes, I am.
8 Q. Mr. Brandt, for traveler package number 7 9 what inspections'have been performed?
10 A. The fit-up and cleanliness for the fillet 11 wold and the final visual inspection of that fillet 12 weld.
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13 Q. And'would you pleano review the package to 14 see if any documentation with respect to those 15 inspections la missing from the package?
16 A. Per proceduro chits were required for the 17 fit-up and final VT innpoctions; these are not in 18 the traveler package, but both inspections are 19 documented on the face of the traveler.
20 Q. Mr. Brandt, would you please refer to 21 traveler package number 8 What kind of wold is 22 reprocented by traveler package number 87 23 A. It's a fillet wcld between a flange and a 24 . pipe.
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25 Q. Mr. Brandt, are you aware that in the 4
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45370 1 handwritten list of allegations and the transcript I) 2 of the hearing September 18, 1984, and in the 3 memorandum served on the applicant on September 27th, 4 the intervenor= alleges that there was a deficiency 5 in this package because of the way in which line 1 6 of the traveler is signed?
7 A. Yes, I am.
8 0 Mr. Brandt, in your judgment, is there a 9 deficiency in the way in which line 1 in signed?
10 A. No, there's not, for the same reasons as I 11 described on weld number 7. This is a fillet weld.
12 There's only one fit-up required. It'r clear that 13 the signature of Mr. Hilkerson is for that fit-up.
[])
14 0. ti r . Brandt, would you please refer to 15 traveler package number ton?
16 A. Yes.
17 0 Are you aware that in the handwritten list la of allegations and in the memorandum filed on 19 September 27 intervenor has alleged that this 20 package is deficient because line 5 of the traveler 21 is marked " Sat" without an inspector's signature and 22 date?
23 A. Yes, I am.
24 0. Mr. nrandt, is that a deficiency in this O 25 package?
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[ 45371 V
1 A. No,.it's not.
2 0. Why not?
! 3 A. For the same reasons I described on welds 4 4 and 6 previously.
5 O. ,Mr. Brandt, would you pleace refer to 6- traveler packago number 14.
7 A. Yes.
0 0. Mr. Brandt, are you aware that in the 9 handwritten list of allegations and in the 10 transcript of the hearing for September 18 11 intervonor alleged that this package is deficient 12 because line 5 is marked " Sat" without an 13 inspector's signature and date?
14 A. Yes, I am.
15 O. Mr. Brandt, in that a deficiency in this 16 package?
17 A. No, it's not.
18 0 Why not?
19 A. Por the same reasons previously stated for
-20 welds 4, '6 and 10.
21 0. Hr. Brandt, would you please refer to 22 traveler package 157 23 A. Okay.
24 0. Aro you aware that in the memorandum dated
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25 September 27th, 1984, the intervonor alleged that l
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11 traveler package 15 is deficient because of the way'
[ I i n w h'i c h ' l i n'e il is signed?
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2 T' 3' A .' Yes, I am.
4 :Q. Mr. Brandt, is: traveler package 15, r!L deficient for that reason?
6= .A. .No,.it's ~ not deficient.-
' ,7 O. What kind of weld is represented by 8~ traveler: package 15?
9- ~A. It's a plate-to-plate weld.
i 10 'O . In this the-kind of weld that has inside I 11 and outside weld? '
l 12 A. Yes, it is.
(N 13 0 Is there evidence that both the cican11 ness 1 L) 14 and fit-up of the inside and outside portion to this 15 weld was performed?
16 A. Yes,'there is.
- 17- O. Would you please, by reference to the 18 traveler package, indicate what evidence exista to 19 substantiato these two inspections?
20 A. There's a chit in the package dated August 21 31st, 1978, which atates that it's for the first '
t 22- fit-up'and cleanliness of plate to plate signed by 23 Phil Davis as acceptebic and the first page of the 24 traveler clearly indicates that the inside fit-up
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25 -and cleanliness of above is Gat, signed by Don R.
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1 ~vogt, dated December 5th, '79.
em "
-2 .0. :Hr. nrandt, are youJaware that the
?3 ~ intervenorfallegedfin its memorandum' filed on
- r 4 September 27 that traveler package 15 is' deficient 5 'because the cleanliness of the inside.part of this 6- wel was not reverified?
E 7- A .' I believe their clain was that welding ,
a started in 1979 and resumed in~1983 without 9 roverification of cleanliness. There's no 10 procedural requirement for QC to reverify it. Tho
- 11. cleanliness of the surface to'be welded must be 12- reverified by the wolder prior to starting. It's 13L part1of the welder's training to see that the 14 surface is properly cleaned prior to additional 15 welding.
16 Q. Is there any deficiency,in this. package 17 because the cleanliness was not reverified by a QC
- 1,8 inspector prior to resumption of welding?
19 A. No, there was not.
'20~ 0. Mr. Brandt, are you aware that with respect 21 to traveler package number 15 lntervenor alleged in 22 its memorandum dated September 27 that this package 23* is deficient ~because an inspection was performed 24 before weld rod-wan issued?
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25 A. Yes, I am.
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1 Q. Mr. Brandt, would you review the package N
2 and determine, if you can, the correctness of thin 3 allegation?
4 A. As I described earlier for one of the
'S previous welds, I believe it was wold number 2-A, 6 the HMR was the predecessor of the WFML. The 7 traveler clearly indicates that ten HMR's were j l
8 issued.in connection with hold points 1 through 4. 1 I
9 There's no reason to believe, for me to believe, 10 that these WMR's were not issued prior to the 11 initial outside fit-up.
12 Q. Mr. Brandt, are you aware that the r~'; 13 intervonor in its memorandum dated September 27th j
14 and in the transcript of the hearing for September 15 18th has alleged that this package is deficient 16 because line 5 is marked " Sat", but there'n no 17 inspector's sigt.ature and dato?
10 A. Yes, I am.
19 c. In your judgment, is that a deficiency in 20 this package?
21 A. No, it's not.
22 Q. Why not?
23 A. For reasons I've described previously on 24 welds 10 and 14, for example. The " Sat" without an
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25 inspector's signature does not indicate the FEDERAL COURT REPORTERS
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,'- c '45375-p s ,#
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1 ;E ' , , .
> ; v ;.
-p ' . ~ 'l- . performance ofEany. inspection., The wel'd w i.ll'not be ,
L yz . <
i.) ; 12. ' finally. accepted until the;inspectioniis performed
- 1 3' ,
and.: the;' tra veler: ,is signed .
~
41 0 . Mr. Brandt, are,you' aware'that the
- 57 intervenor cin'its. memorandum dated September 27th-
, [ , 6' has alleged : th'a t' _ t raveler ' package 15 is' deficient because"It ~ includes ' an_ eight-line .' traveler . f or 'a 7 -
f 8 weld initiated in the.1978-1979 time frame 7 i
L :9 A.- Yes,.I: am.
3 -
10 '0 M:. Brandtv is there such a= traveler i n-l > .
. ~ package 7-
~ 11' .that .
x 12 A. There is.such a traveler in tho package.
~
13 It's a copy of.the stainless steel inspection 14 traveler that was referenced by OA-OP-11.14-6, which D15 ~I believe~was issued in Harch '82. So that's 16 evidence'to me that that traveler was added in '82 i
! 17 or more recently. But in the event;that- they had i.
18 used an'-eight-line traveler in the '70 to '79 timo 19 frame, which this package does not indicate, it l
!' 20 woul'd have been proper, as it was prescribed by 21 + CCP-38 Rev. 2 ICNf3 I believe. We discussed it 22 . earlier.
23 .0 Mr. .Brandt, are you aware that the !
.'24 . Intervenor h'a s alleged that traveler package 15 is
'tW 25 ' deficient'because'it's missing certain documentation
.1 5
. li e
. _ _ _ 1 _'__=_._ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
FEDERAL COURT: REPORTERS _.
45376 i
1 that:it's required to substantiate inspections 2 performed?
3 A. Yes, I am.
J 4 -Q. Mr. Brandt, does traveler package 15
-5 contain all the documentation necessary to 6- substantiate the inspections that have been 7 performed?
8 A. It contains sufficient documentation to 9 substantiate the fact that all required inopoetions 10 were performed. There was a note in'CP-QCI-2.11-1 11 which required the chits to be forwarded to the QA 12 vault. The chit for the VT of the backing strip, ,
(~'3 13 which is hold point number 2, and the chit for the LJ 14 cleanliness of the channel, liner and backing strip, 15 which is hold point number 3, are not included in 16 the package;- however, the traveler in signed as l l
17 required by procedure by the inapcctor, 10 substantiating that these two inspections were 19 performed.
20 Q. Hr. Brandt, would you please refer to 21 traveler package number 17.
22 A. Okay.
23 Q. Are you aware that in the handwritten list 24 of allegations served on applicant in thin 25 proceeding the intervenor alleged the traveler FEDERAI, COURT RMPORTERS
45377:
1 package ~17 is deficient because line 5 of the
~2 traveler was marked " Sat", but there's no inspector 3 signature or dato?
4 A. Yes, I am.
5 O. Nr. Drandt, in your judgment is that a 6 deficiency in this package?
7 A. No, it's.not. Por reasons I've previously B stated on welds 10 and 14, for example.
9 Q. Mr. Brandt, would you please refer to 10 traveler package 19.
11 A. Yes.
12 0. Are you aware that in the handwritten list 13 of allegations in the transcript of the hearing for
\
")
14 September le and the memorandum served on the 15 applicant on September 27th, the intervenor alleges 10 that thin package in deficient because it is missing 17 documentation required to substantiatu the 10 inapections that have been signed off?
19 A. Yes, I am.
20 Q. Hr. Brandt, would you please review 21 traveler packago 19 and determine whether any 22 document --
required documentation in missing from 23 that packago?
^,
24 A. My understanding of the allegation in the
\
25 intervenors are concerned about the lack of chits to PEDERAL COURT REPORTERS ))
"l'
. 45378 r
1 substantiate certain inspections. The chit for the
() 2 original cleanliness inspection in present. The 3 chit for the VT of the backing strip tack welds is 4 not present. However, this inspection is signed off f
5 on the face of the traveler. Additionally, tho E
,6 backing strip was later removed and replaced for 7 which all required innpections are documented on an
- 8 cight-point traveler, and this traveler did not 9 require the use of chits.
1,0 Q. Mr. Brandt, would you please refer to 11 traveler packages 20, 21, 22, 25, 27 and 39.
L 12 A. Okay.
13 0. Mr. Brandt, are you aware that in the
[])
=
I 14 handwritten list of allegations and in the 15 transcript for the hearing of September la the r s 16 intervonor alleges that these packages are deficient i 17 because line 5 of the traveler is marked " Sat", but 18 there's no inspector's signature or date on that 1 #> line?
20 A. Yes, I am.
21 0 Mr. Brandt, are thcae traveler packagen or i ,
y 22 any of those traveler packages deficient becanoe of F
23 this itom?
u 24 A. No, they're not.
% A
! 25 O. Why not?
?
FEDERAI. COURT REPORTERS
~ '
.~
(l ,
4 45379_
lC f ,' ,
[<
- A., -
"a g" r.y.f j g, - For reasons I;previously described on welds
' a-
- m. <
gf s-
- .2-10 and'14, for esampic.'
~ ,' .
=3' -
O. -And fo'riclarity ofs theI transcript, Mr.
. .- 0 .
.p. , Brandt,.would(you please. state again.the feasons why.
- a. #
' W- 5- :you don't bE11 eve this is?a" deficiency. 3
- t
' ~'
6 'A.- - The' "Sa t"i on;:line 5 means nothing'without
- 7
'corrdsponding inspector's signature.
5 '
l8-
- 0; 'And:areIthese.weldsTs'till in process?
~
', . ., .3 .. .
9 '
.A. They. are'stillein process.
~
K10 i Q. Prior toffinal. acceptance of'these welds,
(..
.10 is an ' inspector ' required: to sign l.line 5 and.' indicate " -
12J that his or her inspection ha s' found the weld to be .
~
, ;13 isatisfactor'? y
,14 - A .- Yes, it~does require that.
k l~ 15 O. Mr. Brandt, directing your attention
~
l , Ll6- .specifically tortraveler package- 25 and traveler
$0 ~I '17 package':32, are'you' aware with~ respect to'these'two.
.~ >.
y . .
^
l18 packages that the intervenor in the handwritten list.
- v ,
19- offallegations and in the. transcript of theJhearing' '
.s >
2 0:- ,for September 18thwhas alleged that the packages.are-121
.'d e f i c i e n t -- b'e c a u s el. w r i t i n g . o n !theftraveler, and- 2 sj, 22; .sp_ec i f i cally' wri ti ng ' on single lines'of the ~ traveler, 1
-u:
o.
[2 31 appears.to[be,madeiby two.ditforent; persons? ,
. , r;~ .
2: . ,- 24- A. ~Yes,lI'am.
' C'j i K AW '
1Q . . ' M r . :7 B r a n d t , . is that a deficiency -- first s
( 2 5 '(
, p ,
W '
.g i
, , f, s ,
% .g .__. L M. A L. . .
,-y .--.
% s
.) T e e. ,
e r , .r ,
t,ilfC_. aW
,' $ , i < FEDERAL ]
_, , C00RT{ REPORTERS
45380!
V i
.. - I 1 l' is that*true?
em__-
2 'A. It would appear to me that it's different 3 .h ndwritings.
p '4 0. In that La ' deficiency in.these traveler 5 packages?
~
6' A. No, it's'not.
.7 -
O. Why not?
8 A. In my review-of all these travelers I'have
'9 not noted a single occasion where an inspector 10 indicated Unsat in the results column. The form 11 could have been designed without the results column 12 even there and it could have just had an inspector's 7^)v., 13 signature indicating satisfactory completion of the 14 hold point.
15- Additionally, these'two travelers have
~ 16 corresponding NDE chits attached, which substantiate
- 1.7 the fact that for weld 25 Mr. Stinson performed the 18- fit-up inspection, fit-up and cleanliness inspection,
. . . 19 on the 15th of January, and it was acceptable. And
'2 0. for weld. number 32, that he performed the fit-up.and 21' cicanliness inspection on the 20th of January, 1982, 22 and'it was acceptable. The chits substantiate the
. 23 ~ ' signature on line'1 of.the traveler in'both cases.
- 24 However, I~might note that absence of the t _; .
\J 25 chits would not- in my opinion make the travoler.any W 1
4 45381-LV s
~
il ' less. acceptable.
, x.f ,. 2
,' O. So it's your testimony;that it's the 3' ' signature.of a certified inspector that 4
4 substantiates the acceptability of the hold points?
Y 5 'A. Yes, sir. No certified inspector would 6 have' signed something wi.th " Sat" written in for him 7 if the-results of,'his inspection were not Sat.
.8 Q. So whoever writes the word " Set" on line 1, 9 t"h a t ' s really an irrelevant. consideration?
10, A. 'It's'somewhat' irrelevant, yes, sir.
11 Q. Could it have been' typed for example?
12 A. It could have easily been typed.
- 13 Q. It could7have been-typed by a secretary or 14 someone unrelated to.the inspection?
-15 'A. , Yes, it could.
16 Q. ;Hr. Brandt, would you please refer to 17 traveler package 34.
18 Are you aware with respect to traveler 19 package 34 the intervenor'in his memorandum dated 20 September -27 th, 1984, alleg'en that an inspection was il performed relative to this weld prior to. weld cod 22 ! being issued? ~'
23 A. Yes, I' am.
/%.
24 'Q. Mr. Brandt, i s ' t h'a t true?
. (#L
~
25 'A..- 'There's nothing to indicate _to me that it's n -
g , ,
FEDERAL COURT REPORTERS
g- ~:
-- ~ ' ~
3,
.45382 K
l ,
9 o f_ a
- ~
1 -[true.
I 2 ' ,c Q. Mr.,Brandt, would'you please refer to
-3 l. traveler ~ packages.36 and.59. -
"4 <
.H r . Brandt,;are you aware that at various 5 placesJin the handwritten list of~ allegations,'the
. ~6 hearing transcript of September 18th and'its 47 memorandum l dated. September 27th,-the intervenor
's alleges that these packages are deficient because of 9- ;the way ~in"which line 1 of the; traveler is signed?
10 A.- Yes, I. am.
11 Q. First, Mr. Brandt,.what kind of weld is 12 represented by these packages?
{}
13- A. In both cases they're an embed to a plato. '
14 Q. Mr. Brandt, based on your review of these 15 packages, is there any deficiency based on-the way' 16 1n which line 1 of the. traveler'is signed?'
17 A. No. Wold number 36 was signed originally 18 in 1980 by James Cole. Excuse,m'e. It was signed 19 originally byrLarry Wilkerson on September 26, 1978.
20 The chit states'first. fit-up and cleanliness of 21~ embed to plate. The traveler is signed " Sat" by 22 James Cole in April 1980, indicating the inside-weld 23 was inspected for.. cleanliness and fit-up. And it 2.4 was. reverified in~ December '81'by Dave Stinson.
i i
'O 'Apparently, welding
,. 257 --
- ~
b FEDERAL" COURT REPORTERS
e
- _ 7 - - _ _ _ _ _ ,..
t , . , -45383
- . g ,
r, 4
.;p-[1, l0 Let' m e..,j u s t g o back to that reverification.
t)$ 2: point,.Mr.'Brandt..
~
Wasn't-it.your prior testimony I
31 that~the; reverification is not required?-
Yes, it was. >
~4 A.
~
5 0.- .And so-in this case the reverification by
~6 an inspector is'something above.and beyond the, 7 requirements:-of the program?
8 A. Yes, it.was. 'd 9' 0 '. Now, is there any deficiency, in your 10 judgment, in the way line 1 of traveler package 36 11 'is ' signed? .
12 A. No,.there's not.
f] 13 c. .In' fact, doesn't'the'way in which line 1 is v.
'14 signed in'dicate that the inspection effort was above 15 and beyond the requirements of'the program?
.16 ' A. Yes, it does.
17 Q. Hoferring to package 59, Mr. Brandt, is-18
~
there a deficiency in'the way line 1 is signed?
19 A. No, there's not.
20 0 'Why'not?
' 21 - 'A . -There's a chit dated September 27th, 1978, 22 entitled first fit-up and cleanliness of embed to 23 plate. signed by Larry:Wilkerson. 'And the inside ,
~
~
,24 : fit-up and;. cleanliness is signed by Dave Stinson 3
25 dated September 29th,.1901, on1the face of the
+
ti . / =. , . . . . . I, .
FEDERAL COURT REPORTERS
45384' 1 traveler and also on a chit, which is attached to
, 2 the traveler.
3 'O. Mr. nrandt, would you pleaso-cefer to 4 traveler package number 52.
5 First, ;M r . Brandt, what kind of wold is 6 represented by traveler package 52?
7 A. It's angle to a plate.
L' 8 Q. Mr. Brandt, would you-refer to traveler 9 package 52. Are you aware that in its memorandum 10 dated September 27th the intervenor has alleged that 11 this' package is deficient because the' chits
-12 - associated with the package are written by two r
) 13 different people?
14 A. Yes, I am.
15 O. Mr. Brandt, is that a deficiency in this L 16 package?
17 A. No, it's not.
18 Q. Why not?
-19 A. Chits are filled out by the craft, as I 20 think I've testified ir this proceeding, in order to 21 obtain~an inspection. The craft fills out part of 22 it and QC arrives and performs the inspection. QC 23 signs and dates it.
24 Q. So in fact, per procedure necess.srily at 25 least two people would write on a chit; isn't that PEDERAL COURT REPORTERS
45385 1 right?
2 A. That's true.
3 0. Mr. Brandt,' are you aware with respect to 4 traveler package 52 intervenor allegos in its 5 memorandum dated September 27th that this package is 6 deficient because an inspection uns performed before 7 wcld rod was issued?
U A. Yes, I am.
9 O. Is that true?
10 A. There's nothing to indicate to me that 11 that's true.
12 Q. Why is not a deficiency, Mr. Brandt?
13 A. As I've stated before, the WMR's are not 14 required to be attached to the packago and the 15 traveler indicates that at least four WMR's were 16 used.
17 Q. Is there a requirement to attach the WMR's 18 to the package?
19 A. No, there is not.
20 0. Mr. Brandt, are you aware with respect to 21 traveler package-52 CASE has alleged in memorandum i
22 filed September 27th that the package is deficient 23 because line 7 of the traveler is marked " Sat" but 24 there's no inspectors' signatures or date on that F
'S line?
FEDERAL COURT REPORTERS
_- - ~ ~ ~ ~
~ -"
7_
r .u ; .
45386
~
l' c A.; Yes, sir.
- v. . .
I k_) -2 Q. Is'that a deficiency?
y 3' .A; No, it.'s not. .
J
-4 0., Why not?
=5 A.- As'I've; stated before, the " Sat" without an 6 ; inspector's signature means absolutely nothing. The
'7 weld-is.stilltin process.until that inspection is
. performed and'aigned'by
~
8 a certified inspector.
r- - .
~_
9 Q. Mr..Brandt, are you aware that CASE in its 10 memorandum dated September 27th has alleged that
- 11 this' package -ic deficient because it consists of an-12 cight-line traveler ~that was initiated.in the period 13 1978-797 M)
(.
14' A. Yes, I am.
15: 0. Is that a'deficlency?
16 A.' No,zi t_' s not. In fact, it's proper.. As I 17 discussed earlier,-ICNf3 to CCP-38 introduced the 18 eight-line traveler in April '79. This traveler 19 appears-to h'a v e been initiated in July 1979.
20 Q. Mr. Drandt', are you aware that in the 4
21 "va r, iou s - repr e se n ta t i o n s made at the hearing and in
- 2 27 papers' served on' applicant that the intervenor in
- 23 this proceeding alleges that traveler package 52 is
,m 24 deficient because it- is missing certain
(
e'~).
25 i documentation.which they believe should be included Y
m 1 v .. . . .
FEDERAL COURT REPORTERS
~ ~
7 .,
45387 7- ,
4 1 - 'inLthe' package?
' J -
7 ,l - 2 A.- Yes, 1 am.-
13 Q.: Mr. Brandt, what's your understanding of
~
-4 that allegation?;
L
_ 5~ LA. -Apparently, CASE was referring to the lack 1
L 6' of the inclusion of WFML's'in the package. ]
- 7 Q. _And is there a requirement to include 8 WFML's in-the. package?
_ 9- A. No,'there's not.
10 Q. .And is all required documentation, to the
.11 best of'your knowledge, i n c l u d o'd ..i n this package?
12 4._ Yes,;it'is.
(?T 13 'Q,c Mr. Brandt, would you please review (J. '
14 traveler' package for weld number 60.
15 A. Okay.
16 Q.- Are you aware that'in the handwritten. list 17 of allegations and in the transcript.of_the hearing 1
0 18 of September 18 the intervonor alleged that traveler 19 package 60 is deficient because the last lino'of the
.20 traveler is marked " Sat", but there's no signature 21 :f or an inspector and no date for the inspection?
22 'A. Y e s ,- 'I' am.
g 23 O. Mr. Brandt, is that a deficiency. in :the
. 24) packa~ge?
i 1 25 A. No', it's not.
. i -
._=-x_. .
~
45388 i
1 Q. Why not?
2 A. Without the inspector's signature,'the word 3' " Gat" serves no purpose. The weld is still in n' 4 process until the final inspection is performed and 5 signed by a certified inspector.
6 Q. Mr. Brandt, would you please refer to 7 traveler packages 61 and 62. With respect to those 8 . packages are you aware that the intervenor-in i't s 9 memorandum dated September 27, 1984, alleges that l
' '10 these packages are deficient because inspections 11 were performed before weld rod was issued?
12 A. Yes, I am.-
13 Q. Is there any evidence that this allegation v
14 is tree?
15 A. No, there's not.
16 0.- Based on your review of the package, can 17 you ascertain any deficiencies in the packago that 18 correspond to this allegation? _
19 A. No, I cannot.
20 Q. What's your. understanding of this 21 allegation?
22 A. They're.apparently alleging due to ~ the fact 23 thnt there's a WFML attached that's dated after.the 24_ first fit-up aas signed off, drawing the conclusion LS that the weld was made before -- excuse me -- the
+
FEDERAL COURT REPORTERS
.[
g;7.v r "i 1. f ,-
q 45389' me c , c-s 1 ' .. '.. .
, l' , fit-up wa's. signed off'before any. rod-had been drawn.
/s) ~ '2 ~In}realit'y,..the,ro'd was drawn.onfWMR's, which are 3 not attachedEto the package.
- 4 ,
Q.. -Is.there any requirement to attach the R :a
~
5 ~WMR's to the package?.
6 A. No, there's'not.-
o .
7- Q. Mr. Brandt,~3re you sware that at various 8 points in:the handwritten list-of allegations, the 9 , transcript of the hearing of' September 18 and'the 10' memorandum prepared and filed on~ September-27th, the
's) 11 ' int _ervenor alleges that traveler packages Gl.and '2 12 are deficient because the last line of the traveler L
4 is marked " Sat", b u't there's no corresponding q .13 A );
~ 14 ' signature of an inspector or date for the inspection?
15 A. Yes, I am.
'16 Q. In tnis a deficiency in these documents?
17 A. No, it's not~for reasons that I stated-in 18 describing the allegation for weld numberf60.
19 Q. And like weld 60-are wolds 61 and 62 still 120: in process?
l
' 21 -- A. Yes, they are. l 1
22 Q. Mr. Brandt, would you please 'efer'to r
23 traveler' packages 68, '6 9 , 7 1 , :'7 4 and 80. Lot me. add 24 a few more travelers to that list, Mr. Brandt.
r
- q. /
-( '
25 . Would you add to your list of travelers ~to review S
.~..
._~
FEDERAL. COURT REPORTERS j
~
w ,
~
t -
.,. _45390; x ' c
^
+
, 3 s
.1 " traveler packages 81, 84, 88, 89, 91, 9 8,, 99.
(. .
2 -
A .: Okay.
~
L -3 Q. Mr. .Dr and t , are you aware that-at varioun s 4 points-in the handwritten list of allegations, the.
~
J' -
5 1 transcript ~ o'f the hearing September 18 and in the
< <6 memoiandum flied on September 27th tho'-intervenor ,
~
7 has al'leged that this group of travelers is
.8 deficient because the last lineyof.each tra'veler is 9 marked " Sat", but there's no' signature present or 10 date.present on that lino ,of the traveler?
11- ,
A. Yes, I am, Mr. Downey.
12 0 And-in your judgment,'is the absence of a r~N 13 signature and date on the'last lines of these A ,/
14 travelers a deficiency _in the packages?
'15 A. .No,.it's not.
16 0 Why.not?
17 cA. As I've stated numerous times earlier, 18 without an. inspector's signature, the word " Sat"
-19 serves no purpose. Without1the ' inspector's 20 signature,-the welds are still in process and still 21' require final visual inspection.
22 0 Mr. Brandt,_would you please review
~
23 traveler-package numoer 80.
L :2 4 " A. Okay.,
7 s- ,-
[' 25 0.. .A r e -- y o u' a w a r e that in the handwritten list:
e ,,
4
. FEDER AL-- COURT ' REPORTERS _ - = ,.
,_- - - = -- , _ _ _ - .- -
[' (
- :/ > :; . .
45391-i
' ~
[ l' .of allegations'a,nd in the transcript of the hearing
,, i-s
) -2 of'SoptemberL18'the intervenor has alleged that
-3 ' pac'kage --
trav,eler-package 80 is deficient'because
<4 package _contains-an eight-line traveler-and it.was
. !E initiat d in 1976-79 time period?
6 -A. Yes, I'am.
t
.. 7 10 .' Are you aware of that allegation?
m
, 8 -
A. Yes, I am.
9 Q.- Mr. Brandt, is the use of the eight-line 10 travoler for this-package-a deficiency?-
11 J
-A. ti o , ' i t ' s n o't .
12 Q. Why not?
r~ 13 A. It~was-the correct traveler at:the time.
- ()'
14 Q.- DoLyou. recall the procedure that required 15 the use of this traveler during this time. period?
16 A. Yes. The procedure was CCP-38 Revision 2, 17 ICNf3, dated-April 1979.
18 .Q. Mr. Brandt, are you aware that in the
~19 transcript of'the hearing of September 18, 1984, the 20 intervenor alleged that-traveler pacnago.80 is 21 ' deficient because certain documentation is missing 22 from,that packago?
23 A. Yes, I.am.
-24 Q.. What's_your understanding of that
-t 'p-
l' 25 allegation?
p FEDERAL COURT" REPORTERS _ _ _ _ _ _ _ _ _ _ _ _
% _ % c- ,
45392
~1 A. They're;apparently referring-to the fact s'
_q;
(_f. 2 '. .that' some of the WFML's are not attached.
-3 Q. Is'that a' deficiency?
-- 4 -
A. No, it's not. ,
f5 . Q. Why not?
~
6 A.. They're not required by~ procedure to b'e
-7f attached..
Is all other documentation necessary to
~
8 Q.
9- substantiate the inspections that.have'been 10~ performed with respect to traveler package 80 11 present in that; package?
12 A. Yes, it-is.
-(yl' 13 'Q. Mr. Brandt, would you please refer :to
~14
- traveler package 817 15 A. Okay.
16 Q. Are you awaro that the intervenor alleged
~
17 during the hearing on September 18 t h a't that package 18 was deficient because'an inspection was performed 19- ~ before weld rod.was issued?
20 A. .Y e s , I am.
21 -0 Is that allegation'true? ,
22 .A. There's"nothing'to indicate to me that it's 23- - true. OnceLagain, they're'probably' referring to the-J24 fact-that-there are.no WMR's> attached to tiho package.
'~#
25 The WMR's were wha [t were.used-in.the'1978 time frame,
[ .
FEDERAL COURT' REPORTERS
45393 1 which is when the first inspection occurrod.
2 d. And was'there a requirpment to attach the 3 WHR's to this package?
4 A. No. Additionally, the procedure at the 5
time required that all the chits be forwarded to the 6 vault. There's no indication, at least in this 7 package, that chits exist for the VT of the backing 8 strip, tack and fillet welds or the VT of the embed 9 fillet weld. There is, however, a chit attached to 10 substantiate the fit-up, the outside fit-up, dated 11 September 26th, 1978.
12 Q. Does that package contain objective e-). 13 evidence to substantiate that every required L..:
14 inspection was performed with respect to this weld?
15 A. Given the fact that the weld is still in 16 process, there's evidence that all required 17 inspections previous to that point were performed 18 and documented. <
19 0. Mr. Brandt, would you please refer to 20 traveler package 84.
21 A. Okay.
22 O. Mr. Brandt, are you aware that the 1
23 intervenor has alleged that traveler package 84 is l l
24 deficient because of the way in which lino 1 of tho 25 traveler was signed?
PEDERAL COURT REPORTERS
.m .
p?.-. ;
'1 .
~ - +
_- 45394:
~
- 7 - -
. .:,:. 4 Y, e I 3 4 ic #
_f
~
R? .. l' 51' Yes, I Lam.. .
{4 x .
2' :
j /Q . - Is the packag'e deficient because of the way 31 [in which line 1.of'the traveler was_ signed?
~
4 _A. No,-it's not.
5 Q. Why not?. <
There's;an HD5 chit. attached dated August 6 A' . .
'L7 21,~1978, signed by'LarryJW11kerson,'which states
- 8 - that'it's for,the first fit-up and' cleanliness of
'~
S : plate to plate. The traveler on line 1-indicates 10 that'it's the: inside fit-u'p and cleanliness of above, )
11? -wh'ich was signed by Don Vogt on December 4, '79, and 21 2 then reverified sat for the inside fit-up..by Dave 13- Stinson on February 8th, 1982.
14 0.- Mr. Brandt, is this reverification part of 15 the procedure?
16 A. No, it was not.
17 Q. So that's an inspection that was done above 18 -and beyond the requirements of the program?
19 A. The verification by'QC inspector was not 20 required. In that sense it was above and beyond the; 21 requirements of the program.
J22 Q. And it's your testimony that reverification 23 is normally performed by the craftsman; is that 24 right?.
(~3
-V ~25 A. That's true.
FEDERAL COURT REPORTERS
P* -
45395 g,
s - m 1;- 0.1 Mr.-Brandt, would you p, lease review
.4
(~ j -
, , '2 .c-traveleE package 887
-3 A. Okay.
4 'O. 'Are you aware-the -intervenor alleged in its
~
S. handwr3.tten list of allegations that traveler 6 package 188 is:. deficient: because certain-
,7 documentation..is missing.from the. package?
8 A. Yes, I a m .--
9 Q. Mr. Brandt, what's your understanding of
. ~
10 'that allegatio'n?
11' Apparently,.they're" referring once again to
_A.
12 the lack of : WFML 's _ a nd WHR 's .
77 13 O. And is:the package deficient because WMR's
- x.> -
14 and WFML's are missing?_
15' A. No, it's not.
- 16 Q. Why not?
17 A. They're not required to be attached.
18 Q. Mr. Brandt, would you please review 19 . traveler package _110?
" -20 .A. Okay.
21 0. Mr. Brandt, are you aware that the 22 intervenorJin'this' proceeding has alleged'that
' ~
23 traveler-package 110 ~ is -deficient because of the way 24 in'which-l'ine'l.ofitho' traveler-is~ signed?
' . r%
( )
- V - 25 -A., Yes, I.am.
l's
'(,' #.-
. FEDERAL COURT REPORTERS
.w_., m m ,-
- -- ~ ~
45396l
. , m-o
~
1 Q. Is' traveler' package 110 deficient-because d~ ~2 --of the way 'in which line 1 is signed?
3L .A. No, it's not.
b J4l 0. Why.not?
'5 ,
A'. There'a'a chit attached dated October 4th,-
6 1978,Jsigned by Larry.Wilkerson, indicating that the
' ~
7 first fit'-up and1 cleanliness of angle to plate is
~
8 satisfactory. .Line 1 of.the traveler is marked, 9 quote, inside fit-up and cleanliness of above, close 10 , quote, noted as satisfactory a n'd signed by Don Vogt _
~ ~
11 '.on December 7th, 1979.
12 0. . So does the , package: contain verification
(~T . 13 that both the inside and outside fit-up and
\_/
f- -14 : cleanliness inspections were performed 7 15 A. Yes, it does.
16 O. Mr. Brandt, are you aware that the
' 17. Intervenor has alleged in its-memorandum dated 18 September 27th that traveler' package 110 is 19- deficient because the wold was inspected before rod
~20 was issued?
21 A. Yes, I am.
22 .0 Mr. Brandt, is there any evidence that that 23 allegation was true?
24, A. No, there's not. Apparently,-they're i t, 't l
[1 25: _'r e f e r r i n g to the lack of the inclusion of the early 1
ei w .- ._". - -
FEDERAL ~ COURT REPORTERS
n= -a. - - - ~ - - - -
~-- - -
.. 3 p. . , -
L 45397
~'
n't #
s . . . ~
}
'{
- e. , y . c _
% :l' , 'WMR's[in the' package, which as.I've statedJbefore,
. y I
f, ~.( ,
(A ,2- f.. w a's' n o t'.f r e q u i r e d .- ,
a L'... .
- 3i 2
, s, Q. M r . ~ B r a r.d t , are younaware.that the 4' j ..intervenor: hasjallegedLin~the ha'ndwritten list o f:
s
<a l'l e g'a t i o'^n s l a~n d fi n .the trans'cript.of-this~ proceeding
, ~
- . Y
+
6 4
. f o r Se p tembe r .'18,1- 19 8 4,. tha t. traveler ~ package 110-la
~7 dhficient because: the~last l i n e, o'f . t h e package 'was 8 marked " Sat",
g theSlast91'ine of the ~ traveler was ..
-marked " Sat", dhere's no inspector's signature or-9 10 , date on that line? 2 11 A. Yes, ILam. <
And ~ Ii's t h'a t a deficlency in thi_s. package?
- 12 Q.
13 A. No, 'i t 's: no t. As>I've stated before, the d- [ -
- 14. . indication of Sat without the inspector's signature-4 2 15 ' serves absolutely no-purpose. -
16- .Q . , And is.this weld still in process?--
~
' '17 - .
' A . -- The weld"is con'sidered in processuntil the
..j l 8 f i n a l '. , i n s pe c t i o n is-performed'and signed by-
- 7 19, certified QC inspector.
'20 Q. Mr. Brant, would you please refer'to.
y w 21~ - traveler package lil?
.o
3 .
- 2 2. -
A. Yes, Ifwould.
y ;
23' O. Are youfawaro that the intervenor has -l p
I' 24~
. alleged'that traveleripackageLill'is. deficient ,
.Q-t d
r ,
25 4 !because-[the last line o'f the1 traveler isimarked 1 1
~
_)
3 Y - _ x x
.FEDERALLCOURT REPORTERS. oi a
45398:
q' j %i <
t-1: " Sat", but-there's no inspector's. signature for that 3
\ ~
.. > 7 2r line or no date for the-inspection of._that line?
X ,
3 'A. .Yes, I a.m .
O 4 0 Is thatfa deficiency'inL this package?
5- -
A. 'No,.it's not.
6J 0. And - . i s it not.a deficiency: for the reasons l 7 you've testified to5several ' times before that this 8 is an in-process ~ weld _and the satisfactory 9 i n d 'i c a t i o n' i s meaningless until inspector's 10 signature is attached to the line?
11- A. It's meaningless in'the fact ~that t h e r e ' -s
-12 not an inspector's s i'g n a't u r e , but it's not an f'l 13 in-process weld in .that sense. If you'll note on V '
14 the second package of the traveler-in 1981 they had 15 switched to the eight-line travelec. And Mr.. Cole 16 had signed off, albeit in the wrong place, _and that 17 he signed off line-11instead of line 5, but he had 18 signed off the fit-up and cleanliness. The outside 19 fit-up and cleanlinese is substantiated by a chit 20 dated August 31,'1978, signed by Phil Davis. It's-
"21 my conclusion that Mr. Cole's signature indicates
~22- the inside fit-up is based on the date that~the' weld
- 23 of the leak chase channel to the liner plate was 24 inspected -- October 26, 1978. Once this channel l
' ('~l# was welded on the' backside of the liner plate, the
- 2 5 FEDERAL COURT REPORTERS
!- ' 45399;
+ .
1 .backsido of the; weld was completely inaccessible.-
(_[ 2 The..~only weld to which Mr. Cole could have been 3 ' referring was the inside, or' waterside, weld.
- 4. :Q. 'Mr. Brandt,.would you please refer to 5 _ ts aveler ' package -118 7-6; A. Ok'ay.
~
7- Q. Mr. Brandt, are you nware.that the 5
8 intervenor in this~ proceeding alleged in its 9 monorandum datedLSeptember~27th that travelor 10 package 118 is deficient because of the way: in which 11 line.1'of the traveler is signed?
12 A. Yes, I am.
13 . Q. Mr. Brandt, is_that. package deficient
[u~S -
14' because of the way in which line 1 is signed?-
15 A. ti o , 'it's not.
16- _
Q. Why not?
17 A. There's a chit attached dated August 10, 18 1978, signed by S. M. McCoy, which is entitled 19 fit-up and cleanliness. There is alsd'a chit
-20 . attached signed by Dave Stinson dated January 22nd, i
21 1982, for the inside fit-up and he reverified it j 1
, 2: 2 again on the 3rd of February, 1982, and= signed the -
23 traveler on thatrdate.
124' O. So does the package contain verification D.
'25 -that-all required-cleanifness and fit-up inspection FEDERAL COURTLREPORTERS
~ . =. _ ..
7 -.
L ,
45400
- V
1- . were performed?
f ,
,.2' A.. -Yes, 1t'does.
3 -Q. RMr.-Brandt, a'r e - y o u aware that i n 'i.t s
%~ 4 memorandum dated-September 27th, 1984,'the
~
5 intervenor" alleges that traveler package 118'is 6 deficient because cica,nliness was not reverified ,
~
~
7 prior tofthe'rcsumption.of welding?
~
8 A. Y e s , ' I' . a m .
, . , .9 ' O.' Is the package deficient for Uhat reason?' t
, 10 A. No. As-I've stated earlier, there is no 11 requirement for QC to. reverify cleanliness due to 12 starting and stopping of welding operation.
r~i 13' O. Mr. nrandt, are you aware that with: respect U-14 to traveler package 118 the'intervenor in its memorandum dated-September 27, 1984, alleges that
. 15 16 the-package is= deficient because certain
-17 'documentat' ion is missing from that package?
18 A. Yes, I am.
19 Q. What's your understanding of that 20 allegation?
21, A. The-only thing to'which they could be 22 referring would be the missing.WFML's and HMR's. ,
'23- Q '. And is the package' deficient because 24 :certain WFML's and WMR's are not included in the (G,
'-'/ '
~25 package?
M 4
g -
- FEDERAL. COURT ~ REPORTERS- '
W '
' ' ~
> 45401
(; * ,
. ~ +. . ,
a
^
. NF- ,
M1 '
- A. ,
-No, it's not. -As I've stated-earlier,:
- -5 , .
, ,,) '2l they're.not. required to .be : included -in the : package.
13 Q '. - 'And Hr.'Brandt, does the package contain
'." 4 all'documentat5on require'd~ to,vorify that all' i g.. .
' ^ ~
5 required'2 inspections-to this point in [the process 3 6' 'w e r e ' p e r f o'r m e d ?J L t
[
~
.7 A .. ,Yes, it does.
8 ' Q. LMr.,Brandt, are you' aware that in the-
~
9 . handwritten. list:of. allegations and .the=transcr1pt ,
10 of.the': hearing of September 18, 1984, and in
, 11' memorandum dated September 27,-1984, the intervenor 12 alleged that' traveler page 118 is deficient because r' ~13 t h e .- l a s t line'of.the traveler has been. marked " Sat",
d b
14- . b'u t there's nc inspector's signature or date on that' 15 line?' '
. 16 " A. Y e s ,' I am.
~
-17 Q. Mr. Brandt, is the package deficient for-18 that reason? _, ,
~
19 - A . s. No, it's not.
20' Q., And is it not deficient for the reasons -
'21 you've'given;several times.in: your testimony today 91 22 of'similarepackages and other' occasions? -
r 23; A. s Yes. .The indication " Bat" without i
24 inspector's signature serves no purpose. 1
.'(^T 1
N ;2 56
~
Q. And is-thl's weld still in process? '
1
],
M- . "
, s._z,,- ,
- 7 'l a -
Y ' FEDERAL COURT REPORTERS
F = ].
~ '
, "?
45402 a' ,, .
<. i : ,
~
+
1 . .< : . ; .;. A .
Yes,-it~is._
~ q ;. .,
d Q.
2 .And prior:.to final a c c'e p t a n c e , is it:
3J required that an inspector sign and date line - 5 of
- 4. _the~ traveler?
g.
'5: -
- A. Yes, it'is.
6 =0 Mr..Brandt, are you aware'that the..
+
7~ intervenor in.its memorandum dated: September 27th,
~
8 ' alleges that traveler-package-118 is' deficient -
9- because it-contains!an eight-line: traveler that was
- 10 ' issued in-the 1978-1979 time frame?
11 A.
Yes, I am.
12 : 0 ~. Mr. Brandt,.doos-the package contain such a
~ '
9'S 13 . traveler?
(.4 14 A. Po, it does not.
15 O. Hr. Brandt, is there any eight-line 16 traveler 'in thetipackage?
17 A. -Yes, thero' is.- The traveler that's 18 included in the package first appeared in QI-QP 19 11-14-6 in September 1982, so it's not possible-that 20 this traveler was~used in 1979. Additionally, 21 there's not-a single signature on-this traveler 22 . included,in the package.
- 23. O. Mr. Brandt, are you aware that the
'24 intervenor in this : proceeding has alleged that k'~
25 traveler p a c k a s ,e.-1 1 8 is deficient because certain.
. ~
f FEDERAL-COURT REPORTERS __. ..
--m--- - . ~ . _ _
~
, ' 45403-u ,
. ~
, l1 required, documentation is missing 'from that' package?
^
d ~2 ' A' . Yes, I am.
'* ^
,3 ~
Q .' Mr. Brandt, what's your understanding of the al' legation?
+
.5' lA. .From'my: review of the package, the'only J 6 th'ing to which.they could be referring would be a 7 chit for'the VT of the backing strip, which is hold
('8 point ~ number 2; a1 chit for=the cleanliness and liner 9 of.the backing strip, which is-number 3; a chit for 10- the final VT.of the channel fillet. weld, which11s 11 hold point number 4; and the-WMR's and WFML's.
^
12 As I've stated previously, the WMR's and (mp 13 WFML's are not required to be attached, and the y.
~14 chits-for hold points 2, 3 and 4' , although 15 procedurally required, the lack of such is not-
- 16 significant in the fact that the traveler was 17 updated as required and signed by the inspector on 18 the faco of the traveler.
19 0. - So your testimony is that there-is no-20 missing documentation from this-package?
21 A. There is documentation missing in the fact 22 that the chits for hold points 2, 3 and 4 are not 23 included. However, it's without significance as the
-24 inspector has~ signed the-traveler for those three
(,_;l . ..
'~d u25 . inspections. Had they-been included, it would have
- c j.
- ei ,
FEDERAL COURT REPORTERS
w- - -
- 45404l
^
' \
k- > 1~ been~a redundant piece.of. documentation to 1
s._[ 2, substantiate'jthe1 performance.of'that inspection. ,
b I :3. 0.- Mr. B,ra nd e , . would y.ou1please. refer to
-4 traveler package 126.- Is 'it yourJunderstanding that.
- 5~ ~ 'the'intetvenor'in this~ proceeding has alleged that 6- traveler ' package
- 126fis'dedicientsbecause '
~
, 7 ' documentation required'to;he in.the~ package is 8 ' missing?
.s :9 A. 'Yes, it is.
-10' O. What's your. understanding-of.that
- 11, allegation,7 12 ~ A.- -They'reapparently referring.to the WFML's 13- and WMR's, which I've previouslyfstated are not
14 required to be attached. 15 0.-. Dased on1your review of that package, is 16 all documentation required to be in the package
-17 there?'
- 18 ' A. Yes,'it:is.
19 0 Mr. Brandt, would'you please refer to 20 traveler package 130. L21 ~A. Okay. -
.0
" 2 2. Mr. Brandt, is: it.your understanding that 1
i 2 3.. the11ntervenor allegos in its memorandum of
~24 ~ 5 September.27th, transcript of September 18 and in O
~
._, 2 5 _'the handwritten list of allegations that this
+
+
, y - V p '+r -- _ - . FEDERAL-COURT REPORTERS
F g
.E a? .
~ I 5i.0 5) c.
L . x.
;+ -
~
- a. ,
1 ' package is deficient'becauselof~the way . in~'which i
,1 I ,;2. Eline 1-of~~ths-. traveler is' signed?_
'3- A. Yes,-it i s ~.
c , 4- Q. Mr.Harand t , 'is s the package _ deficient 5 because.of the way in which line-1 is signed? s
;6
- A.. .
No,-it's'not.
;7 7 Q. _W hy not?
*u . p ,
~8 A. The outside' fit-up was accepted by S. 'M.
9 -McCoy-on August _18th, 1978, on an HDE chit, which- < 10 ' states first fit-up and cleanliness offplate to i
- 11 plate. -The inside fit-up was accepted by Robert.
12 Kanney on March'27th,.1980, and the inside.was S_ 13 reverified-as satisfactory-by Dave Stinson on (Q ' 14 February 8, 1982.
~ 1,5 Q. .So .-i s your testimo'ny that:all' required 16 inspections, all required cleanliness ~ and fit-up
~
17 inspections can be substantiated by~ documents in'the g
'18 package? .
. .t
" . 19 A .- Yes.
20 Q. And that line 1 is properly signed? 21 A. Yes, it is. 22 Q.- Mr. Brandt, would youcplease' refer to 23 t r'a v e l e r package.1337-24
~
A. Okay.' (~T
'/
n Q. Mr. Brandt,.is it your underst9nding}that-
~
- 25 . 7 H '
.a L. .
, 'FEDERALLCOURT REPORTERS _
- -- - w-- , . _ - , , - . . , _
g v
' : ,. ~' ,
- s. ,
..- 45406 ;4 .m ; w .
Jgf~- ; _. 1: ' [,.;> r , 1-
}the'inte'rvenor has" alleged'in its' handwritten list- .
j ~ ,' - 2' of allehations?-and on;the transcript ~ of the hearing!
.a of thi,s. proceeding fo$ Schtember'.18'that traveler yz 3
, c_
; .y: > .' .
. 4- (package 13T.is'deficAent because'that package ,
- n. -
- .e ~ . .
^&b[s-
;0 5' 'contains'an eight-l'ine' traveler issued'in the' s
..p #,
;p ,
, . f-
!S o - M. c. 6 l'978-1979 time-frame?' ,
g y A
-- 7 A.~ Yes, it'is.
- ~
4 3 .,3 Mr. ' Brand t, -is- the' packinge. deficien t for
~
0~ 'Q . 9 that r e a s o n ?:- 7 10 :A. No, it's.not. " 11-' , Q '. why not?
, (12 -A. The eight-line traveler was required by s
13 procedure at that time. It'had been' introduced-into 14 .CCP-38 Revihlon~2 by ICNf3 dated April.10, '79', and x vl5 the first inspection per f ormed -.on ' this traveler is i 16- dated May 1979. ' Consequently, it was the correct 17 traveler. N 18- Q. Mr. Brandt, are.'you aware th'a t on the
~19 transcript of this proceeding for September 18, 1984, 20- the intervenor alleged that traveler package 133 is 21- deficient because'certain required documentation.-is 22 . missing lfrom the package?'
e y -23 , A. .Yes,.I'am. j ? 24 -Q. Mr..Brandt, what's your. understanding of . p! W
/
25 that. allegation?
- c; ,
~
l u J
' 'c
, $ FEDERAL' COURT REPORTERS
Q %-
, 45407i
-~ 1
+
m !
'~.V ,
(W j 'If 'A.- 4 Apparently, what they're' referring to is- ; 2' lthe lack of'the WMR's.and WFML's or this package 3 rwhich I've'previouslyJstated were not required to be 4 attached and. consequently'no deficiency. exists. If 5' they're- eferring-touchits, chits were notirequired 6 to'beEused'with the eight-l'ine traveler. e
,7_ -Q. So:it's.your testimony.that there-is no 8- . documentation' missing from-this package?
9 A. That's true. 10 Q. :Mr. Brandt, would you;please refer to 11 traveler 1 packages 134 and 1357 -
-12 A. Okay.
j--) -13 Q. Are you aware t h'a t in the handwritten list x-14 of' allegations and on the transcripe.of the hearing 15 i n .'thi s proceeding'for September 18, 1984, the
- 16. intervenor alleged that these packages are deficient 17 because inspections'were performed before wold rod
-18 was issued?
-+=
-19 A._ Yes, l'am. Once again, apparently, they're s
'20' drawing the conclusion, this conclusion based on the 121 lack of'WMR's and WFML's being attached to the 22 package, which'I've stated previously was not and is 23- not a requirement.- There is nothing olso to 24- indicate toLme - excuse.me. There's nothing at all
? }
'7- 25' in-these packages to indicate inspections were
- g. -- FEDERAL COURT REPORTERS
= r .
s o> 8 3 ,
- 7 9 1, .
?x
~ '
, r _ ,.
;- k f
's ,
. v1 -performed priorSto'the: issuance ofsweld rods.
m Sq; , t.) j $- I2 Q. . -Mr. B r a nd t", would you'please. refer to
,.r... traveler' package 137. ~
74 A.. 'Okay. 1 5 Q '.. jMr . Brandt, 'areJ;you aware that on the 6 transcript':of th'e : hea r ing; ~ 1 n this proceeding:for' . . September ~18, 1984,U the intervenor" alleged-that
~
e - 7 - !( .{ 3 package 137 was' deficient because it contains.an' - 9 :- jeight-line traveler;that was issued in the period i . '. .. .. 10 -1978-797 > 11: :A.. Yes, I am. , 12 .- 'Q.- ' Does Jthe package contain such a traveler? D, 13' ~ A.: ,Y e s'. tv , ,
~
'.14 Q.. .Is i t' deficient because of that?
15 A. .No, it.isn't. The eight-line traveler
,16 - co n t a i n e'd in the package was procedura'11y prescr'ibed 17 and proper at the time it was used. The first 18; inspection date on this travoler;is May 1979'and -
- 19. this traveler had been incorporated into CCP-30 in
- ~ '20- April-1979. Consequently, it was the proper ' form 2'l l .for'use.
~
'22' O.. 'M r . Brandt, would you please refer to
? 23 1. traveler package 138. i l
. 2.4 A. Okay. ' \ }) K .
Mr. .Brandt, are you aware-that in the
=25- . Q.
A f .
+
- FEDERAL' COURT-' REPORTERS ~
,'45409; k- ,k -
y dLL ~ handwritten list of, allegations and on the m.
) 2 : transcript 'of the'-hea r ing in t h i s . p'r o c e e d i n g for
,x_
"" September'18, 1984, the intervonor alleges that'this
. - 3.
4$ package is.-deficient because-certain lines on the 5's traveler are written.in two different handwritings?
, _ J 6: , ~ A. :Yes, I . am .
7 Q. .And does it appear to you that. lines.on 8 that"travelermare written in two different 9- handwritings? ,
- 10 A. It's;possible. I'm n o t- sure I'm willing to 11 ' draw that: conclusion. In either case it's 12 -insignificant. As_I've-stated before, what truly is y 3' -13 significant on that_line is the inspector's-
'sj 14 signature and date.
15 O. And as long as the inspector signe the 16 inspection hold point, is that .the critical issue 17 'from-the OC perspective? 18 A. Yes, it is. 19 Q. Mr. Brandt, would you please refer to
. 20 traveler package 142.
21 A. Okay. 22 .O.. Art-you aware.that' in the handwritten' list 23 of allegations,Jon the transcript of the hearing for
- 24 September.18, 1984, the memorandum filed on-I L 25' ,
September 27, 1984, the intervenor alleges that this p
. . FEDERAL. COURT [ REPORTERS
~
j
1 package is deficient.because of the way in which
,-2 l'i n e 1 of the pack' age was signed?
3 A. Yes,'I am. f: 4 Q. In your judgment, is the package deficient 5- because'of the way in which.line 1 is signed? 5 A. No, it's not. 7 Q. Why not? 8 'A. A chit dated August 16, '78, by S. M. ticcoy, 9 indicates that the first fit-up and cleanliness of 10 plate-to plate was acceptable. The first line of 11 the traveler indicates that the inside fit-up was 12 acceptable on January 3rd, 1980, and reverified on ,(
)
13 January 27th, 1982, by Dave Stinson for which a chit 14 is additionally attached. It's my understanding 15 from the fabrication sequence that took place and 16 from reading the chit that this is 6 inches of weld 17 on the west end of 142. It was a reverification of 18 cleanliness by tir. Stinson prior to manual welding 19 of that portion of the seam weld whero the automatic 20 wolder would not reach. 21- Q. Based on your review of the package, is all 22 documentation required to substantiate the 23 cleanliness and fit-up inspections present in that 24 package? 25 A. Yes, it is. FEDERAL COURT REPORTERS
.u W <*
, ; - +
4541,1 g -
~
a 3- ' 3..- u l 0.. And-is'.line 1 of that traveler properly:
;~. *
), -2 .s ig'ned?
3' A. Yes, it is. 4 !O. Mr. Brandt, I'd now 1-ike you to review ~a
;5 _ whole series.of. travelers ~ for-one specific point.
- ) 6 And:would you please , get before;you' traveler numbers 7~ ;104, 105, 114, 115,.116,fil7, ~ 119,- 120, 122, 124,^125i
'8 1 2'6 , _ 1 2 7 , 129, 131,.132,'134, 135, 136 and 137. .
1 9 -A. Okay. 10 - O. Mr. nran'dt,-do you~now have all those 11 travelers before you? 12f A. -Yes, I do.
'13 .< Q. Mr.'Brandt, are~ you aware that in various
_ 14 places in the handwritten allegations of the 15 transcript of the hearing of September 18 and in the 16 memorandum filed on September 27th the intervenor 17 allegen that these packages-are deficient because 18 the last line of each traveler is marked " Sat", but 29 there's no' inspector's signature and no date on 12 0 .those lines?-
~21. A. Yes, I am.
22 Q. Mr. Brandt, are any of these packages 23 def'icient because of that fact? 24 A. No, they're not. As I've stated previously, Q. 25 t h'e . w o r d " Sat" written on the line for the final F f FEDERAL COURT REPORTERS ~j
l
- 3 _45412
~
?-
y vn ~ " . : .6-
'l . visual inspection of1the-inside' weld without the
- -3
' )-
i 22' corresponding. signature o f ~a certified.QC inspector r -n. 3- s e r v'e s no purpose. These welds are still considered
~
4' in-process'and1will require complationLof this 15 visual inspection and signature of.the~ traveler by-6 QC inspector" prior ~to the. weld.being. considered 7 . complete.- , 8 0., Mr. Brandt','would you.please referito , 9 traveler packages 205, 207, 227, 240, 241,L243, 245 10' and 249. 11 A. Okay. 12 Q. .Hr. Brandt, are ycu aware that the 13 1.n te r v e n o r has alleged in various places in the {} - 14 handwritten list of allegations, the memorandum j 15 filed September >27th and in the hearing transcript 16 for September-18th that these packages ara ~ deficient 17 because they all use'an eight-line traveler that was 18 issued in.the ~ 1978-1979 time frame?
= 19 A. Yes, I am.
4 20 'O. .Mr. .Brandt, do these packages use suchJa 21 travel,er? 22 A. Yes,.they do. 23 Q. Nas1that impropor?
~
. - 24 ;A. No,-it's.not.
A ' 25 0 Why not?~ 6
~
^
(( _ PEDERAL' COURT REPORTERS
~
~
Sr 7 , 4'5 4 1 3 Q :., ? g
+
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~
~
i l1D A '. In Aprill.1979 anreight-line: traveler was t , N 'f '-,,
. 2i +
introduced in CCP-38. 'Its use.wasDrequired'by the 13 30C ~ p r'o c e d u r e .- And',on every one~ of theptravelers-14 r
~
we're-talking about, the : da te : ofl'the; f i r st i !~
- l
- ~~5 . inspection'is-aftercApril 1979. ' Consequently, the n - - _
> 6: ;cight-line ' traveler' was proper: for;use in-the time 4- <7 period itLwas used.
8 0. Mr. Brandt, are:you. aware that with: respect 9 .to these same' travelers,:this-same1 package-of
=10 'ravelers, t the intervenor'hos alleged tlin t various 11 places these. travelers'are-deficient because ,
12 required-documentati'on is missing from the packages?
'13 A. Yes, ILam..
l 14 Q. .Mr. Brandt, what's your understanding of
'15 the allegation?
16 A. If the intervenor was referring to the lack 17 c of chits being attached to these packages, chits 18 were not required ~ with the une of the-eight-line 19 traveler. 'If-the intervenor is reforring to'the 20 lack of"WMR's or WFML's, as I've stated earlier, 21 neither of:-theso f two documents were required to be j- 22 attached to the procedure and consequently, no 23 deficiency exis'tn. 3 24' O., Mr. Brandt, you' testified they weren't 25' required to-bo' attached to the procedure. Did you w , k 4 4 -
. FEDERAL' COURT REPORTERS
F ) 1 misspeak when you said that? i . 2 A. I intended to say they were not required to-3 be attached by the procedure.
- f. 4 Q. Thank you. And based on your review of 5 these travelers, do you find any evidence that c 6 required-documentation is missing from these p 7 packages 7.
[.
-8 A. No, I do not.
9^ 0. So it's your testimony that all 10 documentation required to substantiate the welds up 11 to this ' point in the processing of them is included 12 in the package?
~
' ') '13 A. All the documentation required to vj 14 substantiate that required inspections were 15 performed is in the package, yes, sir.
16 Q. Mr. Brandt, while you have that package of 17 travelers in front of you, would you plcase refer la specifically to travelers numbers 205 and 225.
- 19 A. Okay.
20 Q. Mr. Brandt, are you aware that with respect 21 to these two packages, these two traveler packages, 22 the intervenor has alleged in various points of the 23 record of-this proceeding that these travelers are 24 deficient because the last line of the travelera is 25 marked " Sat" but there's no QC inspector's signature FEDERAL COURT REPORTERS
- v. p#
. , iff ;
'
- 4541'5
, , 'v gw
- y 11 and no~:date.forL-the inspection? '
.+ ,
l, [ p2 LA.- ;Yes, 1: a m '. -
- 11. O. Mr. Brandt, would you please-comment again
- 4. fon whether this constitutes a deficiency in these 5 packages?'_
'6 A. sThe presence of:the word " Sat" without an 7- inspec to rs 's ig na tur es is.not objective evidence that 8 the inspection.was performed. In fact, these welds 4
9 .-are still in~procoss and will' require.a final v,isual 10- ' inspection to be performed and the' travelers signed 11- prior to the wold being considered completed. , 12 0. So your testimony is there was no-rm 13 .'d e f i c i e n c y in the; package because of the fac'tn cited 14 by the-intervenor? 15 A. Yes, sir. 16 Q. Mr. Brandt, again while you havo.this set 17 of travelera from the 200 series in front of you, 18 would you please refer to traveler.2357 19 A. okay. 20 0 Mr. Brandt, are you aware that the 21 .intervonor in this proceeding'has alleged'that 22 traveler package 235'is deficient because a chit 23- attached to the package appears _to-be written in two 24 different handwritings or written by two different H
/'l t '\'~/ 1 25' . people? i j
l r 1 i FEDERAL COURT' REPORTERS j
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* - '45416 9; 7A ,
[ 7. - -
!'i~ .1- . L A. . Yes, I am . -
'y -
) _
-2 -Q. Mr.'Brandt,:.is there anything improper
', 3.< about'-- f i r~ s t , based.on your review, do you believe
~'. . .
't ' '
4.. ; th a t' i t. wa s" w'r i t t e n 'by two different people? l 5- A. .One of'them clearly so. T,he other one I'm1 6 'not'quite sure.'of. iL Q., 'M r . Brandt, assuming both of them were c :8 writton by two'different' people, 'does that indicate 9 any ~ kind of' deficiency.;in t h e n t r a v e l e r' pack' age? L10' -A. No, it does not.
, ik Q. . W h'y' n o t ?
~
-12 -A. The NDE chit was filled out by the foreman.
13: Q. The foreman-being the craft foreman? (~] xn 14 A. . Y e s ', sir. And forwarded.to QC to perform
-15 an-inspection. QC signed the chit.and' indicated 16 results when they performed-the inspection..
17 Q.. So'in the, normal course of business, one la would expect them to be written in two different 19 handwritings; is that right? 20 A. Yes. 21 0._ Hr.1Brandt, would you please refer to 22 traveler package 221?
'23 A.- Okay.
24 .Q. Is'it-your' understanding that the ( ')
~
' 2 5: intervenor'in this proceeding has alleged'that a- ,
- Lc _o FEDERAL. COURT REPORTERS-
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, i'n. . c,f il itravelerDpackageD221wis' deficient..because required m.; v m - c; ~ /N _ : , .
r-4.J , 4_ . .. . m 'J2 . ' documentationais1 missing;_f rom ~ tha t' traveler package?
, -: . ~i: - w -
-Yes,?lt; is..
?3 ,
A ' ' ? A'.
;, , , i' '- '
' (30. , Mr.;Brandt,Mwhat's'yo'ur unde rs tand i ng. ~of:
..:-l' - l4c . ,
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t h e < a l l e g a'tti'on~,Ithe.., specific nature of the p g . .
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' ~
> '6; . allegation con;cerning1travo1erl package 2217 m
- 7, A.. They>'.re referringLto'aissing-chits,]the: ,
- ch i t's ..- a r e 1 m i s s i ng ' t o substantiate: ' hold points
~
? 3 '. 8 ' ' 2, 3
, lJ ,-
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' ~
.andl4L-how'ever, these: hold-points'.are properly 1 .
.10L signed..offLon the faceof the traveler itself. If.
111 , they're reterrihg to missing'WMR's.and WFML's,las
^ 12 L I've-statedLpreviously,-neither 'ofDthese two-
' l'3 ' documents are required to he' attached to'the package. ,
J(X f + '
<14 .Q.- And Mr. Brandt, _ is i t your. testimony that r'
15 there is'in'that package all the documentation. . 16 necessary.to' substantiate'the inspections that have 17 so-_far been pe r f o r:s ed ? :
-18 A ~. = .'Y e s , it is. .
19' Q.- 'Mr. Brandt,. would you please refer to 20 traveler packsgo 356. t 21 .A. Okay. 22- 'Q. Mr. Brandt, is it your understanding.that u ,
'23 ;the intervenor in this proceeding has. alleged that
. .. -24 -traveler package 356 is deticient because there is p)"
L . 25 . documentation missing from.that. package, which 'is
, .i -
4 7 ,
'; FEDERAL. COURT REPORTERS: ,
- -. _ . _ ._.-.,--,- ~~. ,_. -._
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, 45418i f 3 -
.1- required to' be there?
J 2? 'A. Yes, ^1t is.
.3' O. .Mr. Brandt, what's.'your' understanding of
~ 4. that' allegation?
5' .A. (They.could.be referring to a number of-6 thingsLhere. If they're referring to missing ~ chits,
- 7- chits were. clearly notLrequired,
" i S Q. Why not?
s I 9 A. .The time frame of those travelers is 1981. 10 The-requirement that chits be retained'was ~deleted 11 from. procedures in 1979.
< 12 They could be referring to missing WFML's.
13- As I've stated a nurabe r of times,.the WFML's are not 1(')-
- w. ,
~
34 requ i r ed ._to be attached to the package. 15 They could be referring to a missing PT 16 report. The PT was done by Mr. Cole on February 17 16th, 1981. During this time frame PT reports were 18 not included in the package. They were kept in a 19 separate file. The purpose of including this 20 information on the traveler was simply to indicate 21 't o the craft that the PT had been performed as 22 required.and that QC could file their tlD E report 4 23.. : independently. The results of the penetrant 3 24' inspection are clearly indicated by Mr. Cole on page 25 '2 of 2 in Section 5.B of the traveler. 3 L [i . - . . . . . FEDERAL COURT REPORTERS
< ~
,e. - _s .j ,
'45419; mp .k n. . oc ,
J ? gl- O. And Mr. Brandt, based on your review of the
. , ~
draveler, is there any documentation missing that lL)' 2
^
J 3- i should-be there?
~
~L 4 A. No, there islnot.
5 Q. Mr. B r a nd t', I'd.like'to ask you to collect Ind'get-before ~ you
-6 a whole series of. travelers from s- 7: thel400's, and those travelers are traveler numbers 8 400, 401, 402, 403, 404, 405, 406, 417, 418, 420 9' through 439 except for 424.
10 A. . Okay. 7 11- 0.- Mr. Brandt, is it your understanding that 12 with respect to these travelers the intervenor 13 alleges in their handwritten list of-allegations
.Lf-)g 14 that these travelers are' deficient because they 15 indicate that rod was burned prior to the fit-up and 16 cicanliness inspection?
17 A.~ I understand that that's their allegation, 18 yes, sir. 19 0. Mr. Brandt, it's my recollection that there 20 is another allegation that appears in many of these
- 21 sources that alleges that there's a deficiency-in 22 'other travelers because inspections were performed 23 prior to weld rod being issued., Have you testified 24 about such allegations?
O~. 25 A. Yes, I have.
' FEDERAL COURT REPonTERS.
p-- - . _ . - - g,
- 45420)
, s j
11 Q.-I Are those two allegations inconsistent with 3
.l . 12- ,one another? ,
'3- A.. Seem'to be.
# Q. Mr. ~ Brandt, what's your ovaluation of the.
.n41
>4 T51 allegation thatLweld~ rod.was. burned.prich to..the l
'6[ fit-up and:clea'nliness inspection?
7 A.. It's an indicati'on to me that the. person-8 making the allegation has s'-lack of understanding ., y 9 about-the welding process itself. Prior to 10 -performing ~a fit-up inspection the two pieces-to be 11: joined:by the weldingoprocess' are fitted.up, in that'
~
12 'they're drawn closeienough together to make'the weld, a specified gap.is maintained, and in this case, a r}- s-
- 13 '
14 backing strip-la tack welded to each of these piecen, 15 bridging the gap' formed by1the two -p i ec.o s 'to be 1"6 welded. In order to make these tacks, weld rod must
- 17- be issued to qualified welders and the backing strip 18 tacked on to the two plates being joined.
19 .Q.. When you say " tacked on", Mr. Brandt, does 20 that mean they're actually welded together? > 21 A. They are welded together by what-is termed 22 a " tack weld", which is'a small weld.
- 23 Q. Like a spot weld?
24 A.- Precisely. b)
'~'
25 Q. So is it necessary, in fact, to issue and J (FEDERAL COURT REPORTERS
, - . , , ,~ 45421-1 -
- ju
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, 11 ' burn. welding ~ rod prior.to~the time of fit-up and _
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~
2 c 1 h a n i'i n e s s. .-i n s pe c t i o n ., i s performed?
- 3 >
Al ' Y e s , J i t:: i s.- .In all olf these cases-that I' 4 ;have.in' front of,me,rI.believe-the only rod burned.
- 5. priorito the1first inspection'was-either:one or'two
'4 -
4 I6 rods,!which'is a clear-indication to-me-that the rod
+ ,
L-7 was.used only to make the-tacks,-as1one weld rod
'4 a will'.not. deposit a significant m.aount of filler 9 : material., ,
10 0.- . M r . B r a n d t', wi11 you-please review 1 each of 11 these trave.lers that you have before you to confirm 12 that only one or two weld rods were-bbrned. prior to 13 f fit-up inspection ~.in each. case? - 14 A.- Yes, sir. All of thess' cases. involved the 15 burning of' only one or two weld rods prior to the 16 inspection. 17 0. In your review of the travelers did you 18 find any.= indication of a deficiency in them because 19 weld rod was burned prior to fit-up ~ and cicanliness . t 20 inspection? 21 A. No, I did not. L22 Q. Mr. Brandt, I'd-like for you to get before
.2 3 - you another.scries of travelers in the 400 series.
24 Those are travelers 408, 411, 463 through 484. h- .
'25 ,
'A.. Okay.
, e -
{, , ,. FEDERAL., COURT-REPORTERS _ i
45422 ,? - l' O. Mr. arandt, directing your attention _first
,m .
(_, ' , r2- to travelers 408 and 411, is it your understanding
- 3, that the intervenor alleges that theseJtwo-travelers
-4 are' examples of travelers whore's Mr.'Hawford,
' ~
5 'H-a-w-f-o-r-d - Ewhich I believeiwas incorrectly 6 spelled a s . H a l f o r d ', H-a-1-f-o-r-d, in"their papers. 7' In;any' event, is'it your understanding that these 8 are examples'of'which the intervonor sites of l 9 travelers wherefMr. Itawford issued an inordinately 10 large number of weld rods on particular days?
'll- A. No, Mr. Downey. It's my understanding' tha t 12 the intervenor's contention for welds 408 and 411 is
('} v 13 that M r ~. Hauford signed the WFML, and next to it the 14 line is blank.- This is an example of Mr. Itawford . 15 apparently intending to issue weld rod to one of his l 16 wolders for these two welds and either the welder 17 did not come in that day or Mr. Hawford reassigned 18 the welder prior to the time of issuanco. In either 19 case, no weld rod was issued as a result of his 20 blank signature. 21 To. understand what the signature means, you 22 must understand the process tur which a welder 23 obtains rod. To obtain weld rod, a welder obtains 24 the WFML. signed by his foreman ~ authorizing issuance
'O' 25 and takes the WFML to the rod issue shack to receive t
4 t ......;............ . FEDERAL COURT REPORTERS
z-. . . _. . . . _ , ,_ y, :- . _ . - -_ 45423 y-; . . ,. !! _ . ~ n ' ' s i 1 .weldirod. iAlthough th e se..- two 'sFM L 's have been ,
>z m A _) /2 signed-by Mr. Hawford,'they.were never taken-to the '
' ~
3 issue = shack'to receive filler material,'and-no ,,
- 4 filler material- as issued as a. result..of those-
*~
5, signatures.. t6: Q. 'So is ~there any deficiency in theso' papers as a.renuit of.the' signature of Mr..,Hawford? { . 8 A._ Mr.,Hawford'should.have lined 'through~his
- z. N 9' signature, initialedLit and dated it so that the 10- next entry!on the WFML could be used. As these 11 copies are t'wo to three weeks, possibly even a month 12 old at this point,. it's . possible that it's been 13 corrected by this time.; I do not know.
4 14 0. Mr. Brandt, is it your'u'derstanding n that 15 the intervenor has. alleged in the-transcript of the 16 hearing of September 18th theres some improprioty 17 in a. number of. travelers because Mr. Hawford signed 18 a large number of travelers authorizing issuance of 19- weld rod on a single ~ day?
'20 A. It is my understanding, yes, sir.
21' , O. Is there anything' wrong with Mr. Hawford j22 signing a.large' number of travolers on a single day 23 lo r a large number of WFML's on a single day?
. 24- A. th) , sir.
Somelof these welds are not very ' I)
,C" long; they'can be completed in a relatively short 25 !
4 4 FEDERAL COURT REPORTERS
=
- = ~'; - x >
45424 W e .,
. '4
. .i
, 41t period $of t ime . - Mr.'Hawford is a. foreman over a r~y .
._J > -2
- crew .of millwrights.- He's responsible'for that' s
3 ' crew's. activities, and as I've; described, he must
.4 Nign'a WFML each' time.a welder is to receive, weld
~
'5- _ rod. In the course.of.a day he could sign quite a 6 number of these depending on the length of welds his
^
7 welders were workingLon, the number of welders 8 ' working and how many rods they were withdrawing at a 9 ~ time. lThere's=no reason _to believe'that due.to the 10 number of WFML's which have been signed by Mr. 11' Hawford that any improprieties took place. 12 This is another example of the person
~
13 making the allegation not fully' understanding either q} , 14 the welding process or the process by which a welder 15 receives his weld r o d 's . 16 Q.- Mr. Brandt, I'd like to ask you to now 17 refer to' traveler: packages 463 through 484. 18 .A. Okay. 19 O. Mr. Brandt, ,is it your understanding that 20 with respect to these-packages the intervonor has-21' alleged in the handwritten list of allegations that
.22 the packages are deficient-because of the . 'la r ge -
23 number of inspections and, signatures entered.on 24 those travelers by Mr. Jimmy Duncan on a. single day?- ,
) 25 A. Yes. I d
)
FEDERAL COURT' REPORTERS l
,_ , ~ L t. 45425 t
- l. -Q. .Mr. B r a nd t', have',you bad a chance to review 4.
j \ numbers 463'through 484-to . determine the ( )- 2' traveler 3 ' number'of' inspections that Mr. Duncan conducted--on 4: May 3, 19837
~
5 A. Yes, I'have. 6 Q. First,"let_me ask'you what kind of , 7 inspections was Mr..Duncan performing on that day:if 8 you ~ can generalize. 9 A. First I'd'like to clarify that welds number' 10 477 through 481 were not inspected by Jimmy Duncan. 11 Jimmy Duncan merely marked some hold points on the' 12 traveler "Not Applicable". r3 13 0. . How long does it take'to mark hold points L) 14 as not applicable, Mr. Brandt? 15 A. Maybe three seconds a line. It could have 16 conceivably taken 15 to 20 seconds a traveler. 17 For the remaining wolds it was essentially 18 a fit-up and cleanliness inspection and a visual 19 inspection of the tacks on the backing strip. It's 20 a.very simple inspection.
'21 Q. Do you find any evidence from reviewing 22 those travelers that Mr. Duncan made an inordinatoly 23 large number of inspections on that date?
24 A. Absolutely not. 25 Q. In fact, could he have performed a good FEDERAL COURT REf0RTERS ,
- . _ = _ - - - - - -
45426 deal'more work beyond what's verified in these
~
1 2 travelers? 3 A. Dopending upon how much the millwrights had 4 ready for him'to-inspect when they called him, Mr. 5 Duncan could have dono considerably more than what's 6 found on these travelers. 7 Q. Do you find any cause for alarm by the 8 amount of work done? 9 A. Absolutely not. Once again this appears to 10 be a result of a general lack of understanding of 11 the welding and welding inspection procesa. These 12 inspections, as I said, are extremely simple 13 inspections. If tt r . Duncan had performed even two 14 to three times that number, it would not be any 15 reason for concern. 16 Q. Mr. Brandt, would you please review 17 traveler 599. 18 A. Okay. 19 Q. Are you aware that intervenor in this 20 proceeding allegod in the memorandum filed on 21 September 27th, 1984, that this traveler package was 22 deficient because it fails to contain cortain 23 documentation that the intervenor contends should be 24 in that package?
.25 A. Yes, I am.
PEDERAL COURT HEPORTERS
T .;. n IE . .g ' ' " ~~ e~
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{45427-c n *
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'I Q.' -Mr. Brandt, what's.your~'understan. ding of
(;q ,s
-(f
- o-
~
'2 s that' allegation?/ . _
't y
?- _
- 3; JA. The allegation could be c re f e r r i.ng ; to' the
(;, ,'
<, ~1 4 -lack.of[wrMLs, which Ive previously : stated are.not
~
55 neequired to-be: attached. It'could be referring to 4 '. ltheJlack of.; chits,/which for.this. time ~' period wero
~
~7: not required orLI guess.'could be: conceivably .
8
. referring-to the'. lack ofLa liquid penetrant- ~ test-
, -9. report, which has not yet'.been performed..f
- 10. Q.' Based on your review of the~ traveler. "
11 package.339, do you find'-a'ny, indication that 12 documentation that.. shou 1d'be there at'this stage.in p 13 the process is missing? Q+ h,4 A. No,'I-_do not.
'15' O. Mr. Brandt,.would you please refer to 16 traveler packages 859, 867, 868, 871, 877,_078-and 17 8797 184 A., Okay. -
19 -Q. Mr. Brandt, are you aware'that<with' respect I20 to t'hese' traveler packages the intervenor in'the 21 , handwritten list of allegations and in the
, a
" ' 22 . transcript of the hearing of Geptember 18, 1984, 23 alleged:that these packages were deficient-because
. 24 <they all use an oight-line traveler which was
.O, -
? '? 25, originate'd in~the'1978-1979 time frame?
Re
' FEDERAL COURT REPORYERS
(" 45428 1 A. Yes, I am. i 2- O. Mr. Brandt, do all these packagen use an 3 eight-line traveler that was initiated in the f 4 1978-1979 time frame? 5 A. Yes, t, hey do.
~6 Q. Is that improper?
7 A. No, it's not. They're all datad after the 8 inclusion of the eight-line traveler in CCP-38 Rev. 9 2 in April 1979. 10 Q. Is there any deficiency, any problem in the 11 use of the eight-line traveler included in these 12 packages for thin time period?
) 13 A. No, there is not. It's in compliance with 14 procedural requirements at the time.
15 Q. Mr. Brandt, are you aware with respect to 16 the same group of travelers, that is traveler 17 numbers 859, 077, 879 and 878 that the intervenor in 10 this proceeding has alleged these travelers are 19 deficient because they're missing certain 20 documentation which the intervonor contends should 21 be included in the package? 22 A. Yes, I am. 23 Q. What's your understanding of that 24 allegation, Mr. Brandt? I 25 A. I'm not sure to which they're referring. FEDERAL COURT REPORTERS
I' t 4 45429 1 If they're referring to the missing HMR's and/or 2 WFML's, as I've stated numerous times previously, ' they're not required to be attached. If they're 3 4 referring to the lack of NDE chits, chits were not 5 required in this time frame. Other than that, all 6 documentation that's required to be pres 6nt;to' 7' substantiate the inspection process for each of the 8 welds is present in the package. The PT reports for 9 welds 877, '78 and '79, as I stated earlier, were 10 filed separately lduring this time frame. The 11 purpose of the cignature line on page 2 of the 12 traveler is to indicate to the craft that the PT had (m 13 been performed and was satisfactory. And in all V 14 three of these cases the inspector did sign-on page 15 2 indicating that the PT had bcon performed and was 16 satisfactory. 17 Q. Based on your review of these traveler 18 packages, do you find any indication that 19 documentation that should be there in this stage of 20 processing of the welds is missing? ! 21 A. No, I don't. 22 Q. Mr. Brandt, I'd like to ask you another 23 question about your testimony in-which you indicated 24 that WFML's were not required to be attached to 25 theoc travelers and similar testimony that the WHR's a _ _ _ - - - FEpERAE_ COURT REPORTERS
- _ x-- m --
m- - __ - 45430 l .l
+
~
- 11 re no t = regul' red _ to be attached to>these travelers.
75 , _) , '2' Are there some kinds offwelds at the site 3 which do' require the inclusion of these documents in 4^ ' traveler packages? . 5' ,A. Yes, there: are. 2-
'6 Q. Donyou know why'some welds require the.
7 inclusion of Jthose documents in traveler packages 8 and'those stainless steel liner travelers do'not? 9 A. s .Some wolds require _ traceability for the 10 weld filler material'. These welds do not. Where 11 applicable, traceability is mandated by either.a 12 . code, a specification or.both. For example, an ASME 13 class 3 pipe weld requires that weld filler material (^}e s_. 14 be traceable to the wold. That is a requirement of 15 the code itself. Consequently, the program for 16 inspection of pipe welds requires the inclusion of f 17 the WFML as'part of the package. These particular 18 welds are governed by no code and there's no 19 requirement in tho-specification for' filler material 20 traceability. Consequently, there's no requirement 21 that either the-WHR or WFML be attached and made s 22 part of the package. 23 .Q. Mr. Brandt, would you now refer to traveler 24 packages 867 and 8687 O' 25- A. Okay. w PEDERAL COURT REPORTERS _ - - - _ _ - - - - _ - -
[9: 7 ,
. 45431 1 1 ,
j
~ '
1^ _'O. Mr..Brandt,, is -it your understanding'that-c,- O
- j y() ,}
, ;2?
~
'intervenor in this proceeding allegesiin the 7
3' handwritten list of al'logations'and the transcript, J 14, - o f 't he - hea r i ng ' o f .- Se ptember _18 t'h . tha t ' t he s e -
.5~ particular packages are deficient-because'certain 6 lines on the traveler have been written.by two
- 7 different people?
~
8- A. .Yes,'it.is. 9 'O . Mr. Brandt, based on your review lof these 10 two-travelers, do you agree that_certain lines on 11 ~ those travelers are written in handwriting placed on
-12 the travelers by'two different people?
j3 13 A. I don't-claim to be a. handwriting: export,
%)
14 Mr. Downey, and some of them'are close enough that i 15 . I'm_not willing to s 't a t e one way or,the other what IL 16 feel-is different handwriting.
-17
- 0. Hr. Brandt, for purposes.of'my question, 18 would you please a s s u m e .. t h a t in fact the intervenor 19 is correct and that certain lines on that traveler 20 have been prepared by two diff'erent people. With
. 21' that assumption in mind, with making that assumption, 22 do you find anything improper about that?
23 .A. No. As I stated earlier,.the significant 24 feature of line 1 is.the inspector's signature. The t 25 word " Sat"'could have been written by_anyone. In s u- . YEDERAL COURT REPORTERS
45432 1 fact, it could have been typed in, as I think we've 2 previously discuaned. The inspector's signature 3 indicating satisfactory completion of the P 4 cramination and inspection is the critical portion 5 of that. 6 0. Mr. Brandt,.will you please refer to 7 traveler package 10917 8 A. Okay. 9 0 Mr. Brandt, is it your understanding that 10 the intervonor in this proceeding alleges that 11 traveler package 1091 is deficient because of the 12 way in which line 1 of the traveler was signed off? 13 Yes, it in. A. 14 O. Mr. Brandt, first what's your understanding 15 of the allegation, intervonor's allegation, with 16 respect to this traveler? 17 A. I don't understand it. Typically the 18 concern over line number 1 han been where the 19 fivo-lino traveler was used, what the signature on 20 line 1 stood for. In this case, the five-line 21 traveler was not used. It was the eight-line 22 traveler, and I don't underntand the allegation. 23 0. Mr. Brandt, in line with your observation 24 that the eight-line traveler was used, is it your ( l 25 understanding that the intervenor has alleged that FEDERAL COURT RCPORTERS
45433
~
1 traveler package 1091 is deficient because it in 2 fact does use an eight-line traveler that'was 3 initiated in the 1978-1979 time frame? 4 A. Yes, it is.
.5 Q. Is there anything .urong with the use of the 6 traveler, the eight-line traveler, in the-1978-1979
- 7. time frame? .
8 A. To clarify, Mr. Downey, it's clear that the M 9 traveler was used in the-1981 time frame, not in the; 10 1978-1979 time frame.- In either case it would have 11 been acceptable provided that it was used after 12 April 1979 as that was the date the eight-line en 13 traveler was introduced in CCP-38. 14 0. Do you find any evidence that' an improper 15 traveler package form was used in traveler package 16 10917 17 A. No, i do not. 18 0. Mr. Brandt, you've naw reviewed in the 19 course of the past several hours and testified about 20 what may be several hundred specific allegations 21 made by the intervenor with respect to these 22 travelers. Based on your review of the travelers 23 and these allegations, have you found any reason to 24 believe that the required inspections were not 25 performed or that deficiency paper does not exist FEDERAL COURT REPORTERS
~
. (
;45434' s: 1l 'where;such inspectlons can not ~ be documented?
_-m ' t ,
- vc ,
2 A. 'N o , I have not. , ;i: .3 , Q. .Mr. Brakdt, I perhaps prematurely saked you
. \-
. 4 tha t -la s t-~'que s tion . Before we move-on to.another
.5 ~ subject,'I wou'Id now-ask you to review travelers 6 number.23 and'151.
7 A-
. Okay.
) -
-i r ,
~8 sq O '. Mr. Brandt, 1s- it your understanding that
'. [ ;9 with respect to traveler number 23 the-intervenor
)A=
j.I.
'10 haO 511oged that there's some impropriety because p
11 the chit associated with that traveler states that 12 the inspection was for a partial cleanliness {) 13 , inspection? 14 A. Yes, it is. 15 O. Mr. Drandt, does that conform with what the ! 16 chit actually says? 17 A. Yes, it does. 18 g Q. Is there any kind of problem associated 19;' with that ' notation on the chit? 20 A. 'None that I see, Mr. Downey. The chit is 21 . dated February 25th, 1980. The chit clea'rly states 22 that it's for the partial cleanlinean of the seam. 23 This would be the inside cleanliness and fit-up u, 24 ; inspection. The entire seam was signed off
;7 25 satisfactory by James Cole on March 3rd, 1980, after t
c., FEDERAL COURT REPORTERS
- ~ , ,
q ;,. . c, ,
" 45435
(. . [:M , , , V' '
- 4. m: '
. ~
4' J '1' -the partial sign-off which;is, perfectly acceptable. u , ,
? .c J' ; j :2 Q. Do you? find-any; deficiency in traveler
~
'; 3 . package.23 as a result of;that n'otation on. ' the -NDE '
4- chit? 15j .A. No,^1 do not.
. ~.
6 Q. Mr.Jarandt, with respect.to traveler 7 :packagec151, la it:your understanding that the. i _ 8 .intervenor has alleged that there's a. deficiency in O'" 9- that package.because the chit attached to the
~
10 : package indicates.that the cleanliness inspection
~
11 was-for one half of the seam? 12 , A. 'Yes, it)is. . That's my unders'tand'ing.
~
fr's 13. Q. And in fact does the chit indicate-that? g
- 14. 4.- Yes,fitLdoes.
~
- 15 ;. Q.. Is.that a: deficiency in traveler -package 16- 151' in your judgment?
. 17 'A. No, it is not. . 18' ;Q. (Why not? 1. 19' A. Here the chit, once again, is dated March 3:20; 31,,1980, for.a'pproximately one half of the seam. 21 The final inside fit-up and cleanliness inspection 22 'f o r1 the entire' seam was'not noted as satisfactcry
' 23 until April.: 2nd, which is after the partial, which 3 24 <once again,: is perfectlyz proper.
fy Lu '2 5 : 0. . .And'do you find'any deficiency in traveler e , FEDERAL COURT REPORTERS ,
45436l 1 package 151 as a result of the allegation made by l l 2 the intervonor? 3 A. No, I do not. I 4 Q. Mr. Brant, in your prior testimony in a ; 1 5 hearing in this case you indicated that as far as E you're aware, the principal problem.with this set of 7 travelers was that for some of the travelers the 8 inspections were recorded on the wrong form. Do you 9 recall that testimony? 10 A. Yes, I do. 11 Q. Do you find in your review of travelers-12 that you testified today and other travelers you (3 13 reviewed over the past fow weeks, do you find any
~J 14 ovidence that your prior testimony was incorrect?
15 A. -No, I do not. 16 Q. Mr. Brandt, in addition to the allegations 17 about these specific travelers you have been 19 reviewing this morning and this afternoon, is it 19 your understanding that the memorandum filed by the 20 intervonor on September 27th contains another series 21 of allegations about improprieties with respect to 22 these travelers? 23 A. Yes, it is. 24 Q. Mr. Brandt, I'd like to refer you to page 2
) ~'
25 of that memorandum. In particular I'd like to FEDERAL COURT REPORTERE
45437-1 direct your attention to the sentence that says: 2 After the production of the travelers for Unit 2 l
'3 Refueling Dullding there is no question that Ms.
4 Heumeyer had overy reason to be apprehensive about 5 the condition of the liner plates and the specific 1 6 assignment she'was given'-by her supervisor. 7 Do you see that? 8 A. Yes, I do. 9 Q. Do you agree with that sentence? 10 A. I assume by the term " Unit 2 Refueling 11 Du11 ding" the intervenor's referring to the reactor 12 building as the're is no Unit 2 Refueling Building j 13 and the travelers produced were for the Unit 2 14 Reactor Building. 15 As I stated previously, I think what Ms. 16 Neumeyer was acked to do and what she did was 17 correct, that her signature clearly indicatos .which 18 . inspection it stands for as it refers to an attached 19 NDE chit. I see nothing wrong with that practico, 20 I am unable to address what Ms. Neumeyer was feeling 21 'a t the timo; however, I don't believe that it's 22 reaconable to assume'or it would not have been 22 reasonabic for her to deol apprehensivo about 24 signing off these travelers as she signed thns off. J ' ' ~ ' 25- O. Mr. Brandt, again directing your attention FEDERAL COURT REPORTERS
= ---- -
45438
- 1- to page 2 of the memorandum filed by the intervenor,
_j 2 I'd'like to direct your. attention specifically to 3 the sentence in' the: second f ull . paragraph that rea'ds, 4' ' quote OI investigators apparently.never reviewed
'5- the stainless steel liner plate travelers: which were
'6 the subject ~iof her -.. and I note parenthetically 7 t h'a t "her" refers to'Ms.'Neumeyer -- concern, 8' neither.did the Technical Review Team, paren, TRT, '
~
9 close.paren, close quote.
> 10 ( Do you see that sentonce?
11' A.. Yes, I do.
; 12' O. Do you' agree with that scatence or is that 13 sentence correct to your knowl9dge? .%, / ~)x 14 A. If the Technical Review-Team'that they're 15 referring to in this sentence is the. Technical 16 Review Team headed by Mr. Ippolitto which is 17 currently on site and has been,-the sentonce is not 18 correct.'
19 0 Why do you say it's incorrect if that's the
. 20 reference in the intervenor's memorandum?
21 A. I know f'or a fact =that the T,echnical Review 22 Team has looked at - these travelers. , 23 0. Mr. arandt, I'd now like,to direct-your 24 attention t o': t h e next paragraph on page 2 of the O- "'
'25 -memorandum, which reads, q'uote During the: September o
g YEDERAL COURT REPORTERS
~
r~=
. g. o
- ~ ~ '
,. tiJ-7 .
45439' 4-1 1: 1984Lhearings on th'is issue applicant produced f~1 s,
=2 approximately 1300 travelers,. including some of
.3 those. signed-nff by Hs. Neumeyer and another Quality
.4- . Control' inspector, Fred Evans, on Harch 3, 1983.
5' Do you see that paragraph? 6 A. Yes, sir. i
;7 Q. .I s that paragraph accurate?
8 A. It appears that.the point that the~ s 91 paragraph's trying to-make 'is Ms. Neumeyer and Fred 10 Evans signed off travolers other than those produced 11 by the appl'icants as a part of this proceeding. To 12 my knowledge, that i s - Lno t the-case. I have not 13' reviewed all the travelers for the Unit 1 Refueling (~)T. 14 Cavity, nor have I. reviewed the travelers for-the 15' Fuel Building. .flo w e v e r r. as 1 previously stated in 16 this proceeding,.the ~ review effort that occurred the 17 first week in March 1983 was for the Unit 2
~
18 Refueling-Cavity and not the Fuel,Dullding or.the 19 Unit 1 Reactor Building. 20' The only travelers for Unit 2 which have 21 .no t been produced that were signed by Mr. EvansLor 22 Ms. Neumeyer are for. welds number 285, 344, 345, 346 23 and 347, which were part of"those i n a d v e r t o .'. r l y not
~
24 copied aszpart of the original box full of travelers (m.> s 25 presented in the September hearings by the applicant. f 4 FEDERAL COURT REPORTERS
- i. 45440 1 Q. Mr. Brandt, on again page 2 of the 2 memorandum filed September 27th, the intervenor 3 asserts, quote: A review of the travelern 7 4 ~demonstratos that at least as to the fabrication and 5 installation of the stainicas steel liner pintes G there has been a complete quality control breakdown, t
7 close quote. 8 See that assertion? 9 A. Yes, I do. 10 Q. Do you agree with that assertion? 11 A. No, I do not. 12 Q. Why not? i
~a ) 13 A. The overwhelming majority of weld. numbers I 14 indicates that all inspections were performed as i
15 required. There are scattered instances where the 16 documented ~ evidence of performance of these 17 inspectious could not be located and thero'n 18 deficiency paper initiated for these specific wcld 19 numbers. As I stated initially in this hearing 20 process, the QC inspectors failed to use the cor cet 21 form in some cases. In this regard, it was a lack 22 of procedural compliance by.QC, But to categorize 23 such as a, quote, complete quality control breakdown, 24 end quote, is an outrageous statement. ( ) 25 Q. Mr. Drandt, I'd like to dicect your L - . ____qDJRAL . OURT REPORTERS
-- -- ~
?~ 45441 1 attention to pago 3 of the memorandum filed by the 2 intervenor on September 27th. In particular, I'd 3 like to direct your attention to the second full 4 paragraph, the first sentence of that paragraph, 5 which reads in part, quote Our -- referring tw the 6 intervenor -- preliminary research into the 7 technical merits reveals that the vacuum box test 8 and penetrant test are unacceptable substitutes for 9 insuring that the wold was clean, that is, free from 10 -foreign materials. 11 And it continues: These welds must last 12 the lifetime of the reactor and the damage caused by
~. 13 impurities in a weld cannot be detected by vacuum j
14 box, hydrostatic or penetrant test. The impurities 15 may not manifest thomselvos for months or years, but
~
16 when the impuritios eat their way out of unclean 17 wolds, it is likely that the impurity will extend to 18 the liner plate also. 19 Do you see that text that I just quoted? 20 A. Yos, 1 do. 21 0. Do you agree with that text?
'22 A. I agree with portions of it and disagree 23 with portions of it.
24 Q. What portions do you agrce with? ! 12 5 A. They seem to imply the vacuum box test and FEDERAL COURT REPORTERS
~ m. _
p , 3 , 45442:
~ '
4 l penetrant test were designed to insure that1the weld
~ t -
- 2. ,
was freeTof'foreignLmaterials. That's simply not
- 3. theLease. Their; assertion that: these two-tests will 4 ~not detect all foreign materials that will be
'5 prosent within the~ weld itself is a valid assumption.
6 .llowever,;the purpose of the' liquid penetrant test,
; 7~ _and the vacuum' box l tost was to insure a
-8 watertight. barrier exists between the waterside'of
, 9 the fue. pool and.the concrete. These tests are 10; ~ capable of determining that.
-11 They also imply that these impurities may 12 .not manifest themselves for months or years, but -
13 when impurities, quote, eat their way out, end quote,
}-
14 of unclean welds, it is likely that the impurity 15 will extend to the. liner plate also. I don't 16 understand that statement. The mechanism by"which., 17 the hypothetical impurities could, quote, eat their 18 way out, and quote, of unclean welds is beyond me,. 19- _ whatever.these impurities may be. 20 Q. Mr. Brandt, I'd.now like to direct >your 21 attention to page 4 of intervenor's menorandum and 22 particularly the paragraph in the middle o f_ the page 23 which roads, quote: The liner ~ plates are _also 24 susceptible to being hit or. jostled by the fuel as j f~)
#~~
25' it moves through the canal and-refueling cavity and 1
- x. FEDERAL COURT' REPORTERS
45443 f i l ,
'l into the spent fuel pool. Because of this, it is j 2 important that the structural integrity of the wolds 3 be adequato. Further, the llRC requires that the 4 fuel pool and other cavities be seismically 5 qualified, and therefore dictate that all quality 6 assurance requirements of Appendir.
- to 10 C.F.R.
7 Part-50 be applied to these structures and 8 components, close quote. 9 Mr. Brandt, do you agree with the text of 10 that paragraph? 11 A. No, I do not. 12 0 In what ways do you dicagree with the Text (~) 13 of that paragraph? LJ 14 A. They're implying as spent fuel is removed 15 .from the reactor, that it is moved by some manual 16 process and could bump up against these fuel pool 17 liners, thereby causing a breach of the fuel pool 18 linor itself. There are several things that make 19 that virtually impossible. Number one, as fuel is 20 removed, it's removed in bundlos. Each bundle is 21 approximately one' foot square, the length of which 22 is probably 12 to 13 feet. But they're moved 23 through the canal by the fueling machine -- excuse p 24_ me. They're.placed in a spent fuel cask and moved 1 3 25 through the refueling cavity by the refueling FEDERAL COURT REPORTERS ;
,- 45444; 4
- t. .
- d
't ; . , _ .
-. . . ; 1- ' machine and-it's" carried down the conter of the m) ^ ,
=2- canal. 'Thi's is dono: to; maximize shielding that the provkdes.
; .3 ~ water As it's moved down the middle --
.s.
4L and I' don't.have;andrawing in front of me, but I 5 would-guess the refueling cavity to be at-least 25~ 6' ifeet wide', and given that these-fuel bundles are a v ' l- [' 7~ f oo t - wid o , 'the r e 's :'a t least 12 feet of space on 8 'either side of the' fuel bundio as itJ moves down the 9 refueling cavity. For that reason, it's virtually 10 impossible for a bundle to' hit the fuel pool liner: 11 itself, iAdditionally, thesc _ welds forming.the seems 12 between' the liner plates are not structural welds. t
/m v ,; 13 This tends to-imply --
14 0. ay "this", do you mean the paragraph.that I 15 quoted you?. 16 A.' Right. This paragraph seems to imply that 17 in'the -event th'at these liner plate was bumped by
-18 something, it would cause plate ficxure, and 19- therefore, could cause a breach of the linor plato 2 0 l, titself., This' is not-the case. The welds are
- 21~ non-structural. The liner plate'is p1' aced solidly
- 22 ~up~against concreto and is one: quarter.or 23 three-eighths-of an inch thick, and it would simply-24 -not cause,enough plate flexure to cause breach of d '
25 the weld ' 'i n the event that something-did hit it.
-gN-
~
mm. _ = .. = __ - FEDERAL COURTLREPORTERS ._
45445 l' , As far as_the 14 RC requiring.that the fuel.
<m ..
( )- 2 pool and~other1 cavities bo_ seismically qualified, (; , , 3 the-_ Comanche Peak PSARfhas s t a t e d i t h e' requirements J < =4 for;these pools.' Appendix.D requirements are
'5 applicable to the i n s t a l l a t'i o n , - ' a n d the inspection 6 of'these and the program' designed and implemented 7 did satisfy.the. requirements'of Appendix B.
!8 0. -Hr. Brandt, I'd like to direct your-9 . attention to page 5 of the memorandum f i l e d -: b y the' 10 intervenors on September 27th,.and particularly that 11- sentence.that appears as Subparagraph A
-12 approximately halfway down the page. And for
(] , - 13 clarity of the transcript, I'll quo te. ' tha t sentence us 14 which reads: The failure to use~ the correct S/S
'15
~
Liner traveler testified to-by Drandt was a 16 , violation of Criteria V, VI a n d;' V I I -V, /I and
~ 17- VIII --
excuse me. 18 And I will note that those references are
, 19- references to criteria contained in 10 CFR Appendix.B.
20 Mr. Brandt, in your judgment, was the 2 1- failuro to use the correct form with respect to some
^ '
22 of the travelers about'which you've been testifying
'23 a' violation-of Criteria V, VI or VIII-of 10 CPR 50e p 24- Appendix D?
I "s h
. 2 '5 ,- -A. No, they're_not.
V i FEDERAL COURT REPORTERS
7 - , 45446 1 Q. With respect to Criterion V, why is the use 2 of the wrong form in some cases not a violation of 3 that criterion? !~ 4 A. Criterion V requires that instructions, 5 procedures or drawings include appropriate 6 acceptance critoria for determining that important 7 activitics have buon satisfactorily accomplished. 8 As I've stated previously in this proceeding, these 9 procedures did include appropriate acceptance 10 criteria and did provido inspection forms for 11 documenting inspections to substantiate 12 acceptability of installed items. 13 0 Do you find any evidence that the j 14 acceptance criteria developed for these welds, for 15 the inspection of thear, welds, were inadequate in 16 any way? 17 A. No, I do not. 1B Q. Do you find any evidence that those 19 criteria were not applied in the inspections? 20 A. !!o , I do not. 21 Q. Mr. nrandt, with respect to Critcrion VI, 22 do you find the use of the wrong form in some cases 23 to violate that critorion? 24 A4 No, I do not. O 25 Q. Why not? FEDERAL COURT REPORTERS
.x 3 .. ; -m '
-45447
~
, .1"" 'A.-
Criterion VI is 'normally associated with-1 ._ ,) 2s procedures,. drawings, specifications and
~
'3 instrucElons, of'which this; form.wan none. There's
'4 no ~ evidence:to me t h a't . t h e procedure-was iaproperly 5 prepared, that it was improperly -- there's no
.6. ' evidence to' substantiate'that it was not reviewed 7- for adequacy. There's no evidence that it wasn't
~
-3 approved.for'use.. 4The only evidence there could i 9 possibly be applied to criterion VI as the criterion' 10 also' requires that ~ the procedure be used a t. t h~e -
l '1 location where the prescribed activity is performed. f12 There's no indication tla s t the procedure was-not r~3 13 used at the location being performed'to the extent U 14 that all required inspections were performed. It's 15-not evident, however,;that the proper travelor was 16 used, so I guess by inference you could speculate 17 t h'a t the lack of use of the correct traveler was.in 18 some-respects the lack of use of the procedure.
-19 0 Mr. Brandt, with respect to Criterion VIII, 20 do you find any evidence in these tra/elers that 21 Ct.terion VIII was violated?
22 A. No. Criterion VIII requires identification
.23 and controlling of materials, parts and components.
., 24 These meterials were identified by part number; ,
)" 25 records traceable to that'part number are' maintained.
.-r . . . . . . . . . .. . , , . . _ . FEDERAL COURT REPORTERSV
, , . . . . . . _ . _ _ _ . _ _ . _ _ _ _ _ _)
45446 4 , 1 And I feel that that meets the requirements' of K A 2 'Criter' ion VIII. 3 If the intervenor is attempting to imply I that. weld rod traceability was not maintained, as 4 5 I've stated earlier, there was no requirement for
~6 such.
7 Q. Mr. Drandt, I'd like to direct your l 8 . attention to Subparagraph B at the bottom of page 5, 9 about two -t hi rd s of the way down the page, which 10 reads, quote: The lack of sufficient documentation 11 violates criterion VI. 12 Do you find any evidence of'that sort?
-(-)
~J 13 A. I'm not sure what the intervonor means by 14 lack of uufficient documentation. As I stated 15 carlier, the failure of QC inspectors to use the 16 appropriate form in some cases is an indication that 17 the procedure'was not properly used even though all 18 inspectiono required by that procedure were 19- pe formed. If they'rc attempting to state that the 20 'Inck of sufficient documentation is the fact that 21 some of the chits are lost, I don't feel that's a
- 22 violation of criterion VI. !! o w e v e r , Appendix B doos
- 23 not assume' perfection. It merely requires that when 24 you-do have a' violation of requirements, you note 25 such on deficiency paper, which in this case did FEDERAL COURT REPORTERS
l Occur. 2- O. Mr. Brandt, directing your attention to 3 subparagraph C of_page 5 of the intervenors 4 memorandum which reads, quote: The lack of OC 5 verification in supporting documentation violates 6 Criteria V, VI 'a n d VIII and includes all the 7 categories, close quote. 8 Do you agreo ~ with that statement?
~9 A. ~No, I do not.
10 0. Why not? 11 A. I feel that the statement implies that 12' there was a lack of Oc verification and supporting (7 13 documentation, which from my review I cannot draw t/ 14 the same conclusion. To the contrary, in the 15 overwholming~ majority of cases there was evidence 16 that the inspections were performed and documented, 17 albeit in some casos on the wrong form. That being 18 so, there's no violation of the cited cr,teria. 13 0. Mr. Drandt, I'd like now to address your 20 attention to Subparagraph D, the last subparagraph 21 on page 5 of intervenor's memorandum, which states, 22 quote: The failure to include all supporting 23 documentation, WMR's and WFML's in the we_1 ding 24 package is, a. violation of Criterion VIII that
-' 25- requires identification of traceability of materials FEDERAL COURT REPORTERS
-mm . . 3 '45450: b- :
- p. .
4 m- ,
'l ,
'used and to' prevent.the uselof incorrect ~or
'--( ' i. x_/ 2~ ' defective; parts, materials and components,- close
~S .Lq u o t e .
~
F" , U - -Do'you see-that sentence?! r. 5 A. Yes, I=do. 6 O. Do you. agree.with'it?; 7i A. No, I don't. j 8 Q.. Why not?
'9 A. As I've' stated on numerous occasions . j 10 alreadyrtoday, there was no requirement that' WMR's ,
11 .and WFML's be attached to the package. In fact, i
's
= 12 - ther no requirement in~ Appendix B that'even l
13 requires compilation o f- t h'e documents associated. {} 14 with a given weld into a package. ~ Appendix,B.merely 15 requires that all in~spections, examinations and 16 tests be documented.and. retained where ap'plicable. 17 ; Q. So I take it you disagree totally with that 18 statement? 19 A. Yes, I' d o . >
^
20 . O. Mr. Drandt, directing your attention to 21' page'6 of the intervenor's memorandu , the noxt 22 allegation which is Subparagraph E, states, quote: 23 There-is no adequate traceability for any of the 24' welding ~ packages reviewed, close~ quote.'
.O '
25 Now, with respect to the welding packages k A FEDERAL COURT REPORTERS [ .
_- 7 _ ;m
--.p ,,
(45451
, a m . .
4_~.-
~
m a ,n f 3p [ . 9... ~1'- "you.-have reviewedJtoday in your tes timony,> is: that
- y. , ~ _
m .r.. d j k- c 2". ;ttue?: .
.c s
,3 ,
A.' J'm not Lsure what: the' allegation refers t o , .. 4- but it.' appears-to refer.to.the.. lack of'the: WFML's
' iSI y ,, and WMR 's . 'in ItNe~ package Jand the wold. rod- -
.c : .
c 6 ' traceability. If;this is the' case, it'_s:not
, ' O [7 requi red- by procedure , 'speci f ica tion : or- code.-
8 _ Q. 100 youLdisagree with-that.. statement? .
;9 ~ A. .-l disagree fully--with the statement.: I
-10 disagrse w i t h' < i t to the. extent khat, number;onc, I
~11 believe the statement's false; and secondly, even if w .
12- -true, there's no requirement--for weld ' rod 13 traceability to exist.
. ' s14 'Q.- Mr'. Brandt, under. Subheading 2-on page 6 of.
15 t h's intervenor's memorandum there appears , 16 Subparagraph A which s t a t e s , -. q u o t e s - From at least
~
17 11-29-77 through l-4-79 applicant used the-wrong 18 traveler f o r m , p a r e n , , a d m i t t e d ' b'y -! B r a n d t , close 19l paren, failed to enter NDE chits on the traveler: z20 each day when used, and failed to put:the chi ts- in: 21 - the QA. vault: daily as--required'by CP-QCI-2.ll-1
- 22 R e v'. O ', - a n d 2, -
Section 3.1.1, paren,_ note, close
, -23 paren ,- a nd - tised a: chit for fit-up'and cleanliness
' 72 4- when no chit;for that~ inspection was: authorized for- -
O. L -
, 25: . procedures'in'effect.for:_that pe r i od ,-- c i ti ng two .
s
< s
[
~
, FEDERAL: COURT REPORTERS:
45452 D _
.y. .
e-
~1' ~ procedures.
A I .2 Mr. Brandt,-do you ~ agree with that 3 statement,- that Par'agraph A? 4' A. I; agree with : portions of.it and disagree w 5' with portions of it.. 6 Q. Mr. Brandt, would you go through the 7 paragraph point'by' point and state.those parts you 8 - disagree with and state-why and identify the parts 9 of that paragraph with which you do agree. 10 A. The statement under subheading A from at 11 leastcil-29-77 until 1-4-79 applicant used the wrong 12 travelor' form, paren, admitted by Brandt, close 13 paren,.I-agree with as it ' refers to the Unit 2
]}
14 Hefueling Cavity. 15 The statement failed to enter HDE chits on 16- the traveler each day when used, I agree with, but 17 only sometimes did they fail to update this. In 16 some cases the travelers were properly updated. As 19 a matter of fact, in the majority of cases for hold 20 points 2 and 3 the traveler was :proporly updated. 21- ~The~ statement failed to put the chits in 22 the QA vault daily as required by CP-QCI-2.ll-1 Rev. 23 0, I and 2, Section 3.1.1, paren, note,'close~paren, 24 I agree w'ith as.there are a few chits that'are not b'
~ 25 . available. !!owever, there are a large number of Y
e FEDERAL COURT. REPORTERS _ __ _
o45453-
~
L. w- -c + - o ce ,
~
1- - c h i t s. t h a t ,'a r e available,.so I'can only agree'with
~y a c (j' '2 this on a-partial basis.
~
3' And thelstatement used':a chit for fit-up
;4 and. cleanliness when no- ch'i t -f or tha t inspection was 5 authorized lfor.t.he. procedure'in offect for that 6 period, paren, CP-QCI-2.ll-1 and~35-1195-CCP-38,
~
7 .close paren, I disagree with. The; procedure stated 8 Section 3.1.1 of CP-QCI-2.11-1 that the QC inspector
~
9 tshould inspect th'e' items and' document the'results on t . l
.10 attachment 4-A, which is 'he c traveler that was not-11 'used for the Unit 2 liner. However, it mentions the 12 u s e' of'those chits', so I would maintain that the r3 13 chit's use was procedurally described and it'was- '
\./
14 proper to use the chit to document the inspection of
~
~
15 fit-up and cleanliness requirements. 16 I might add that in the earlier statement 17 in this very same paragraph the-intervenor notes 18 that applicant failed to put the chits in the QA'
-19 vault daily as r'equired by CP-QCI-2.ll Revision O ',
20 1 and 2, Section73.1.1, which was the procedure in 21 cffect from November 29th, '77, to January 4th, 1979, 22 'and yet, later claims that a -chi t was used for
-23 fit-up'and cleanliness when no c h'i t for that-
, :24 inspection was authorized by procedures in-effect 25- for that per.iod seems to beninconsistentito me. I b
A., . m.. . . . . . . .. .
, , , . . . FEDERAL'. COURT REPORTERS-
F- '= - - 45454 I t 1 'do'n't tnderstand the point they're trying to make, 2 and in fact, the two portions'of the.same' sentence f 3 seem to contradict each other. I 4 Q. Mr. Brandt, directing your attention to the 5 next subparagraph o r. page 6, which is labolod ; 6 Subparagraph B and reads, quote: No QC procedure 1 1 7 published nince 1-4-79 authorizes the use of NDE 8 chits to record fit-up and cleanliness inspections 9 having been performed. Procedures require that 10 sign-off for all inspections included on the 11 eight-line traveler be on the authorized eight-line 12 traveler, paren, nec e.g. 01-QP-11.14-6, paron, Rev. ( , 13 1, close paren, Section 3.S, close paren. Although 1.J 14 this was not followed in many instances and even 15 today unauthorized and uncontrolled chits are being 16 used to record inspections, close quote. 17 Mr. Brandt, do you agree with the 18 statements made in the paragraph I've just quotea to 19 you? 20 A. Some I agree with; some I disagree with. 21 O. Mr. Brandt, would you please go through 22 Subparagraph D on page 6 of the intervenor's 23 memorandum filed September 27th, 1984, and identify 24 the portions of that subparagraph with which you 25 agree and those portions with which you disagree and
~
g FEDERAL COURT REPORTERS _ _ _ _ ____ __
= -
~
45455 A a s - z 1 ~ stateJthe. reasons for your disagreement.
. ,h 2': A.. The statement-that no'QCLprocedure- .
F .. . .
-3_ published.since.1-4-79 auth~orizes the'une'of NDE t_ li ' chits to record fit-upland cleanliness inspection ~ .l S 'having.been performed is true. I agree with'that H
'6' statement..
7 The statement that procedurcs' require that
- -8 sign-off for all inspection included on t h e .:
9 eigh t-line :tr aveler ' be on the authorized cight-line 10 , traveler, see'e.g. QI-QP-11'.14-6, p a r e n', R e v .' 1, 11 close paren, Section 3.8, paren, although this was 12 not followed in many instances, I' don't agree with.' r3 13 As' I believe I've stated earlior in this proceeding, X./
- 14 the. procedure was corrected in 1979 in-April, and-15 for any new work initiated past that point, an
, 16 eight-line traveler was used. For new work 17 - initiated after April '79 the inspections were 18 signed off on the eight-line traveler as.porformed.
19 The error that occurred was for travelors existing 20 in April '79 for which work was in process. The 21- inspectors did not ~ ;ncorporate the use of'the 22 eight-line traveler.in all of these cases, and-in 23 some cases chits were used to substantiate
, . -l 24 inspections performed after January.4, 1979.
n. x25. The statement, quote, even today 7 FEDERAL COURT-REPORTERS J
~ ~ , 45456 i unauthorized and uncontrolled chits are bel'ng used
_ 2 to record inspections, end quote, is false. Chits 3 are being used today as a means for construction to 4 request QC inspection and for QC to notify [- 5' construction that that inspection has beer, performed.- 6 The required documentation as a result of the QC
'7 inspection is the traveler itself'that's 8 procedurally described and from both the evidence in-
, 9 front of me and from my personal knowledge, I 10 believe this to be true.
11 Q. And when you say the.ovidence in front of 12 you, Mr. B r.s n d t , you have reference to the many
/- )
13 hundreds of. travelers produced in this proceeding? a 14 A. Yes, I do. 15 Q. Mr. Brandt, I'd like to direct your 16 attention to the allegation on the bottom of page 6 17 of the intervenor's memorandum filed September 27, 13 1984, which is listed under subparagraph C and i 19 continues on to.page 7 of that memorandum. And-for 20 clarity of the transcript, I'll quote-that section 21 which reads: With the adoptio:, of QI-QAP-ll.1-4 in 22 12-26-79 applicant had no QC authorized traveler 23 form for stainless steel liner inspections and no 24 chit forms for any inspection since this procedure 25 deleted any reference to 35-1195-CCP-38 and does not FEDERAL COURT REPORTERS
. ,. g . - - - - - - , m y ., _
me- -g .. , 7 m',p - s . ,. m45457)
.~ . ..
^.. ~" "
w: : ;F- ' J a; }. '
~4f , A l' 'j'-
~t _l ,,
3 e '!',
~ % _' L ~ 1- Sinclude;any traveler or'chitiforms.. ' >
i x-. .v qq (, . 1Mr. .Brandt,'d6iyou'seeEthat--allegation on; U? -
,'2: ,
.' -g. . . . ..
" 3 pagesl6and,77 -
1 1 j
.4 i
'A.-
.q; '4-Yes , . Ic;do. -
.- o
__3
- h" 1 .
'5 -
, - Q '. - Do' you agree.with'.it?- .
. e - L -
'f6' Ah' Ho', I~ don't.'" -
e,~ , 7. -
- Q.~ 'Would you= plea'se' s ta te ' why Lyou don't agree 8 with it? ' '
t . ,'
- v. .
9- , A.- All construction procedures are.revlewed by
*y
'10 Ou'ality-Assurance. They-,are now and-always have t- i I 11 J be e n .: There's no regulatory;or' code requirement 12: that process records or process documentation be
- 113 71ncluded inSquality control" procedures. It?s 14 perfectly. acceptable for inspection'documentationsto ,
15- appear in construct 4oncprocedures. The procedure
~ 16 .. Q I -- Q A P - 11. l'- 4 dated-12-26-79' states in Paragraph
' 3 . 1 . 1 : a n'd I'11' quote: The QC inspector"shall -inspect
~17=
2 18~ Nthe;following items during: fit-up.and= welding-of 19 liner material upon receipt of~the stainlessisteel~
, 20- 111r.crDinspection traveler., The stainless.steci -
21 liner . traveler :shall remain at' the work area or
- 22' millwright office 'until it has been completed,.and
< 23 upon: completion, it aballebe forwarded to.the.
-- 2 4 , permanent plant records, vault by the Millwright "O'. . 25 . Department. "
x- , 2 >
- 4 . FEDERALT COURT REPORTERS
- - - ~ '
' 7 45458 4 4; s
~
12 This.: traveler a' t that' time was the e'i g h t point
>me ~
)
~
m 2' ! traveler - - ?
'When you say "at that time", Mr. Brandt, do
~
j- . 3 .- :Q. r . 4; you mean at the. time'after the adoption of 5' QI-QAP-ll.1-4 oniDecember 26, 19797
- 6 A. Yes, I do. I'm referring to the travele'r
~
7' 'that was referenced by the QI-QAP-ll.1-4 on December 1 8 26, 1979. .And that was the traveler which was
- 9. containedfin the. construction procedure CCP-38 Rev- 3
. 10 dated.May-23rd, 1979,-which was entitled stainioss
, 11' steel liner inspection traveler.
- 12 ' - Q. And does your review of the documents, the.
rN 13 traveler packages,.. indicate that tisat form'was used' LJ , 14 on'many occasions? - 15- A.' 'Yes, it w a s .-
"16 'Q '. . So Mr. Brandt, it's your testimony that you ;
- 17' disagree totally with subparagraph -- the thrust of
- 18. subparagraph C--on pages 6 and 7 of the intervenor's e 19 memorandum? ,
20- A. -1 totally _ disagree with therfirst part'of-21 It. .The second part-states no chit forms for any 12 2.- linspection since this proceduro deleted.any, 23 reference to 35-1195-CCP-38 and'does not include any 24 traveler.or-chit. forms. . I disagree with the-portion i h, '
" 25 of. that3 that refers to traveler because the-QC t
EEDERALICOURT REPORTERS
45459;
^
o ^ l . F
;11 procedurefdoes reference the traveler by ..t i t l e .
r^r
- ()L H2 However, no chit forms are require'd by either ; x 3 procedure at~that time.
4 0.- Mr. Brandt, I'd like to direct your 5 ' attention to Subparagraph.D on page 7 of.tho 6 intervenor's memorandum filed September 27th, 1984. 7 For clar'ity,of.the transcript, I'll q u o t e . t.h a t 8 subparagraph, which reads: As of March 26, 1982, in 9 .per QI-QP-11.14-6, paren, Rev. 0 - 6 ',- c l o s e paren,
~
10 Section 3.5, paren, in Rev. O, close paren, 'the-11: . issuance and distribution of inspection travelers 12 were to be governed by 35-1195-CCP-38,' 'which 13 contains no instructions on issuance or distribution
)
14 of. travelers, paren see section 3.4.2, paren,-page 5 15 of.18, doubic close paren. In,additien, the. March 16 26, 1982, instruction for inspections is-woefully-17 inadequate compared to the level of detail and 18 guidance on the conduct of inspection contained in 19 its. predecessors and successors, closo quote. 20 Mr. Brandt, do.you agree or disagree with that 21 allegatiod in the intervenor's memorandum? 22 A. I disagree. 23 ' O.s Would you state why you disagree with that 24 ' subparagraph? (T
'* 25 A. This subparagraph seems to imply the ggp_ FEDERAL COURT REPORTERS
p 45460 1 issuance and distribution of travelera was some x, 2 major operation. The format and content of the 3 traveler was procedurally described in a procedure 4 which had been reviewed and approved by Quality 5 Assurance. In' order to issue the traveler, it was a 6 matter of writing a weld number on the traveler and 7 starting to work with it and there was no 8 distribution of the traveler. So that part of the 9 subparagraph I neither understand nor find 10 significant. 11 The statement that the March 26, 1982, 12 instruction for inspections is woefully inadequate (i
~
13 compared to detail and guidance on the conduct of LJ 14 inspection contained in its predecessors and 15 successors, I disagree with. The fact that it 16 referenced other procedures rather than 17 incorporating all the inspoetion criteria 18 into one procedure does not make the procedure 19 inadequate, and I feel that the procedure -- that 20 procedure, namely Rev. O procedure, was adequate to 21 perform inspections to assure compliance with 22 specification. 23 c. Mr. Brand t, directing. your attention-to the p_ 24 allegation contained in Subparagraph E on page 7 of i 25 the memorandum filed on September 27, 1984, which g_ FEDERAL COURT REPORTERS
454G1 1 reads, quote: QI-OP-11.14-6, paren, Rev. 4 and 5, () 2 close paren, does not contain any traveler form at 3 all, although it is allegedly included as an 4 attachment. 5 And it cites to the proceduto and then 6 continues: This condition continued from June 17, 7 1983, until January 10, 1984, paron, Rev. 6, close 8 paren. 9 Do you.soe that allegation, Mr. Brandt? 10 A. Yes, I do. 11 Q. Do you agree with it? 12 A. Yes, I do. 13 0. What is the significance of the allegation? 14 A. It was a clorical mistake. The page -- 15 that happens to be page 5 of the procedure states, 16 quote, Attachment one continued, Brown & Root 17 Stainless steel Traveler Wold Inspection Sheet, end 18 quota. Page 1 of the traveler was inadvertently 19 cmittod when the procedure was issued. However, the 20 same traveler existed in Rev. 3 and although 21 slightly different in f o r n a't , exactly the same in
\
22 content in Revision 6 of_this proceduro. The same 23 travelor existed for this entire period as Figure 24 Three in CCP-38 Revision 3. O 25 O. Is that the construction procedure?
! \
l s FEDERAL COURT REPORTERS
'. 45462 1 A. Yes, it is. I see no significance to-the
() 2 clerical error of the admission -- omission -- 3 excuse me -- of the first page of the traveler in 4 the QC proceeding. 5 Q. Mr. Brandt, do you see any evidence in your 6 review of [he travelers that the wrong traveler form
\
7 was used during the period June 17, 1983, through 8 January 10, 1984? 9 A. No, I don't. 10 Q. Mr. Brandt, directing your attention to 11 subparagraph 8 or Subparagraph Y on page 7 of the 12 intervenor's memorandum filed September 27, 1984, {} 13 -which reads, quote: All forms authorized and/or 14 used for inspection of stainicos steel liners and 15 all instructions required a fit-up and cleanliness 16 inspection for all welds. The NCR dispositioned the 17 innpection defici'ency only as to cleanliness and not 16 as to fit-up. Thus the NCR does not fully address 19 the problom, close quote. 20 Do you see that? 21 A. Yes, I do. 22 Q. Hr. Brandt, do you agree with that 23 allegation? f 24 A. Ho, I don't. g5 Q. Why not? s PEDERAL COURT REPORTERS
y , 7 .
.45463
* .j-
{ ,# $ N. 'Y, l' -A. As I tried to explain last week.or the. week h' 2L before'in this proceeding, the inside inspection.is
~
' 31 -really a cleanliness inspection to. verify that the L
4_ weld joint is cleaned:after'the' spacer ~ bars..are 5 removed _. As t'h e gap.is maint'ained by the Espacer bar pre' venting the gap [from getting narrower than
~
, 6-7 permitted and the two plates are prevented from 8 noving.further away by backing bar welded;on the ,
9 cack side ofstheigroove and a leak chase' channel 4
-10 tillet welded for -the length offthe' channel on the 11- back side-of;the two plates, the-gap could not 12- " increase.. .The only situation which could, occur 13 between the outside inspection and inside inspection 14 that in any way could'be termed a fit-up inspection 15 of any significance is the back!"ng bar could have 16 been dislodged.by the tack welds cracking in transit 17 between the fabrication area and its final ~ installed 18 nosition. In this case,.the' backing bar would havo 19 'come off the back side of the weld and you would be 20 able-to detect the lack of the backing bar when you 21 . perform the cleanliness inspection andLit would have
- 22. been reported to that point. So essentially, 23 .hether w you call 'the' inside inspection a fit-up and 24 cleanliness' inspection or merely a cleanliness f'T
. i /
25 inspection'is to a large degree a matter of h, - g 7 FEDERAL COURT REPORfERS
7-,-_ g . y:.=u .. . .
. . x y 3 y- ;-- ,
~ ' ~
, 1 r 45464 m -
,bc .
'Y' A_s_.
' 1*
i ! semantics.and.not;one of substance. - f)ek f
.q ,.
21
- 10. - s o _ i n i y o u r.:: j u d g m e n t ,1. t h'c N C R does address,
'.1.-
, ; $3.
. f u l l y . a d d r e s s ,' the problem'of lack'of documentation-4 iforithose-few welds,to which it applied? -
~
5' -A. Yes,-sir. 6 10 . - Mr. Brandt, 'I'd~ likes to askTyou a.few
~
27~ . ques tions . abou t{ thel allega t io'ns. con ta ined in ,
'8- Category'4,,pagesM11.'and^12'in'intervenor's. '
'9- memorandum-filed Sep'tember?27, 1984.- . I n - t h a t.-
10 : portion of;^ the memorandum intervenors a l l es e g. t h a t - I i ,
- 11 t h e' chits attached to travelers 1 through 175 appear
^
12 to'bei written in'two -- one i'o f two different.
- 13. handwritings. . .Is that true?
79) 14 A. - From a quick review of the travelers
.15- referenced it-appears t'o me that the observation-16 made_by the[intervenor in this case'is probably.
17 correct.- The wrifting describing the comments 18 appears to.be.in one of two different handwritings. 19 I might note, however, that'these fit-ups = were 20 performed all 'in the time frame of August, September 21 1978, and I don't find it ~ unusual-'to'-have only one or 22 two. foremen responsible for this-activ.ity on a two-mon th 23 time f rame. 24 However,. it appears that the intervenor is 7p/-* s 25. inferring .that these comments were: entered on these tr - ,
, O _ _
g g. _ j7 ] EDERAL_ COURT _ _ REPOR(ERS.
45465 1 chits after the inspection was performed, and h! 2
~
further, it seems hhat they're inferring that it 3 occurred after March 3rd, 1983. I find no evidence 4 that this is the case. My quick review of the 5 handwritings -- and as I stated earlier, I don't 6 cinim to be a handwriting expert -- appears that for 7 each Of the two types of handwriting, the 8 handwriting describing the dato, the uelder, the 9 drawing number and the comments appear to be in the 10 same handwriting on each chit, which 10 exactly what 11 one would expect if the foreman filled out the chit 12 at the time the inspection was requested. In all 13 cases the inspector's signature in different than 14 the handwriting that describes the date, the welder, 15 the drawing and the comment section, which is also 16 exactly what one would expect. 17 0 Mr. Brandt, you testified at great length 18 about the documentation that exists to subatantiate 19 the various inspections required by the QC 20 procedures on these liner plates. For pucposes of 21 this question, I'd like you to assume that in fact 22 nono of the,outside or concrete side fit-up or 23 cleanliness inspections were performed. With that 24 assumption in nind, I'd like you to state what 25 significance that would have for the correct l l l
'y PEDERAL COURT REPORTERS
g: ; - 45466 -k: 1 fabrication and-installation of the fuel pool liner?
\
.2 A. Assuming that none of them were performed --
3 and we're talking at this point only about hold 4 point number 1. Hold point number 2,'the VT of the 5- backing strip was performed!for the welds which are 6 seam welds and have a concrete side and a water side. 7 -Step numbers 3 and 4 were performed. All that would
+
8 have been missed by missing Step 1 was that the gap 9 betwcon the two adjoinging platos would not.havo 10 been verified by Oc to be correct and the
~ 11 cleanliness of -the backside of the-liner plate where 12 the backing strip is eventually attached, would not r~} 13 have been verified. ;/_
14 'And as the intervonor has pointed out, the 15 procedure required a reverification of that gap as 16 'part of the waterside fit-up, which did occur in all 17 cases and is documented on the traveler, not on a 18 chit, which would substantiate that the fit-up gap 19 was proper. Onco the inside weld is made, the 20- eleanliness inspection performed on the outside weld 21 prior to hold point 2 is totally without 22 significance.
' 23 Earlier in my testimony I stated that it 24 was a matter of semantics on whether you called the
[- ) ' 2:5 inside inspectirn a fit-up and cleanliness i l FEDERAL COURT REPORTERS l
45467 1 inspec' tion or merely a cleanliness ~ inspection. 'And ( 2 I stated that the fit-up gap'was maintained by the
-3 welds attaching the leak chase channel to the liner 4 plate-itself, they could not move. I based that 5 answer, in part, on the fact that the outsido fit-up 6 inspection had been performed, as I believe the 7 records show, but in this hypothetical example that S you've included in your question that these outside 9 fit-ups did not occur, I believe the inside fit-up 10 and cleanliness inspection would have detected any 11 .anomalics.
12 Q. Mr. Brandt, I'd like to direct your
,m 13 attention to paga 15 of the intervenor's memorandum
)
s 14 filed September 27th, 1984. Particularly, I'd like 15 to direct your attention to the last full paragraph 16 on the page, which reads, quote: The NCR does not 17 identify the discrepancy as a generic problem, which 18 it was. The reference here -- and I add 19 parenthetically is to NCR M83-00795. The paragraph 20 continues: Nor does the disposition require that 21 the review of welds be expanded to determine the 22 root cause of the problem or include engineering 23 evaluation of the requirements for the potential for 24 rust-through during the lifetime of the wcld if the 25- weld could not have passed cleanliness, close quote.
+
f FEDERAL COURT REPORTERS
1, .
~
~1 Do_you agree with,that?
' ^x 4
_f , 22: _' A. .No, I do.no.t. - a 3L Q. . Would you please go through that paragraph,
- l\ Mr. Brandt,:nnd. point by point 1 state _what-parts you
$' disagree _with and why.
6 A.- The'NCR d'oes not identify the. discrepancy ' s L7 as a generic. problem, which it was. I guess whether
-8 , I agree or disagree with.:that statement-depends-on
- 9 the.definiti~on"of, quote, problemi end quote. In my , _
10 view it's not a problem even-today. If you're-11 .t a l k i n'g about a. safety _ problem or a technical 12 problemi there is none. There was s' problem with-b 13' paper. . The paper did not exist ~ to substantiate that h . '14 some of'the inspections were performed. 15 Their statement, quote, nor does the
~
16 disposition require-that the review of the wolds be
- 17. expanded to determine the root cause of the problem, 18 cnd quote, to determine the root cause of the l -
19 problem years after the cause has been resolved 20 seems absolutely meaningless to me. As I have
~
21- previously stated, the problem was the. fact that 22 there weren't enough lines on the traveler being 23- Jused in the field for Oc to. document each i n s p e c t i o r, . g , 24 The-construction traveler was revised in April 1979, I) ~ ' 25 so I'have-;a hard time imagining what we could have ki, -
! FEDERAL COURT (REPORTERS
.p_ ,
.~ . - . . .. . . . , .
DS x _
^ '"
. 45469, 6 ~
's
}; n .
donegin the;way of correctiveVaction in March
'1; '03.
^2" 1The.cause of the problem.was clearly eliminated by o
, 23. ,that
- point.
" ~
'4 .
I do not agree with the statement to,
,s- - _
- !L - 1 quote, include engineering evaluation,of the 6 r e q u i r e me n t s - :'f o r theJpotential: for rust-through.
-g.
~
- 7. during~the lifetime of the weld.if the weld could 8- not h a v e -- p a s s e d cicanliness, end quote. The
~
.9 s'ituation was-c'learly described,on the 10 Non-Conformance Retort, in.that-the NCR s t a t e's _
ll. that there:was no: documented evidence that the 12 -cleanliness inspection had taken place. The (3, 13 Pon-Conformance Report was dispositioned b'y n, 14 +ngineering in-light of the fact that cleanliness 15 may not have been-verified. The intervenor's 16 assumption that rust-through could occur on 17 stainless steel is a hypothesis I am not willing to l 18 _ accept. Austenitic. stainless steel does not rus t .- l 19 Q.. Mr. Brandt, directing your attention to 20 Subparagraph B on Page 16 of tne intervenor',s
- 21. . memorandum, they reference an NCR number M83-0079 22 dated 3-17-84.and cite to attachment 4. Are you 23 ' aware: of-such an NCR?.
24 A. .I'm . unable to find such an NCR'as part of f~~) ; -
'~'
attachment 4. Further, checking the~NCR log at the s 4t ' * - 4
% FEDERAL COURT REPORTERS
m- -- - _- , 45470' 1 , site, I'm unabic to find any NCR numbered M83-0079 2 dated 3-17-84. [ 3 Q. Mr. Brandt, intorvenor's subparagraph C on (f 4- Pago 16 allegos_that NCR M83-01000 was improperly l- 5 dispositioned. Do you agree with that allegation? G Can you identify that NCR7 1 7 A. I don't find it included in attachment 4. 8 However, I do-have the NCR. 9 0 Do you agroo with the allegation that the 10 disposition-is improper? 11 A. No. The disposition states that the two 12 welds in question may be used as is, based on ( , 13 satisfactoryEcompletion of the vacuum box test. The 14 rationale for this disposition is exactly the same 15 as I discussed earlier in this proceeding when 16 discussing the disposition of HCR MS3-00795, which 1 17 believe was Brandt Exhibit' 18 or 19. The function 18 of the liner is to provide a barrier to preclude 19 water from leaking from the pool. The vacuum box 20 test assures that the liner performs this function. 21 Q. Hr. Brandt, directing your attention to 22 Subparagraph D on Page 16 of the intervenor's 23 - momorandum they assert in that subparagraph that NCR 24 M84-00669 Rev. l'was improperly dispositioned. Do 25 you agree with thot allegation? I note that l l p_ __ PEDERAL COURT REPORTERS
g '
-y.- ~
"2 n s , . 45471 Y f
- p. =,f .
Leontinues Jo'n.to page 17 . -
~
~ 'l
^ '
l2 -A. This allegation' appears to be another case 3 to where the intervenor doesn't' understand exactly 4 what-occurred. Wold-number 1091-is a sp l i c e ~f r,om 5 . angle 'to: anglu, and as they assert on page 17, c . .
, 6 signatures on form'did'make it appear as if'the
- 7. inspect' ions were:per" formed in the: proper 8 . chronological order. .This is true. They were
,9 _ : performed in the proper chronological order, execpt
. 10 that Mr. Cole who signed out stop 8 of'the traveler,-
11 which is entitled completion of weld inspection, 12 -erred when he deemed on page 2 of the traveler that 13 . vacuum box was not required. 14 Intervonor draws the conclusion-that if r 15- those signatures were in the proper order, there was l E 16 no basis;for the'HCR. This 'is not the case. A l 17 traveler which is signed by Mr. Cole is a complete 18 traveler. It's signed off on page 1, step 8, as 19 being complete and on page 2, step 5-C vacuum box is 20 marked "NA". And as the NCR properly describes, 21 stop 7 has not been performed as required. Stop 8 22 was signed as complete. These welds are pressure 23 boundaries and require vacuum box testing. The 24 disposition of the NCR was to reestablish the hold ( ) ' 25 point'for performing vacuum box test and the vacuum k L _
, FEDERAL COURT REPORTERS
~~
45472 1 box test performed by CC. The second traveler to 2 whichithey're referring on the top of page 17, which t
- 3. states, quote, this traveler originated to satisfy 9 4' t h'e requirements of NCR M84-00669, end quote, was
'S originated in August 1984 to comply with ~ the 6 disposition of'the Non-Conformance Report in that a 7 traveler had to be established or had to be created
- 8. for QC to perform a vacuum box test and properly 9 sign the traveler as being compinte.. The only 10 purpose of the traveler to which CASE refers to as 11 Porm C, quote, with no signatures or dates, close 12 quoto, is this traveler. The only purpose of this 13 traveler is for Oc to sign-off after satisfactorily
(} 14 comp? o t ing the vacuum box test and will be part of 15 the closure documents for NCR M84-00669. 16 0. At the time this travel package was copied 17 had the vacuum box test been performed? 18 A. At the time that the NCR was written in 19 June '84 the vacuum box test had not been performed; 20 in fact, it wasn't until August that the NCR was
. 21 dispositioned stating perform the vacuum box test as 22 required.
23 0 And my point is at the time this traveler 24 package was copied for presentation in this case had
'l 25 the vacuum box test been performed?
L FEDERAL COURT REPORTERS
i g[=m . , 45473' E' _ -
' .,y - .y 1 A. No, itihad not.
[j 2 0 ~. - And.must'that test be; performed _ prior to
+ '
3 the final l acceptance of this weld?
, . 4 A.- ,It must be perfctmed ~ prior 'to ' acceptance of c5 'the, weld and prior to. closure of the NCR.
o
.6 0. When.such test is p e r f o r m e d ,;. - w i l l it be
_7 enfered.on the traveler that was generated as"a a c 8 result ofLthe.NCR7s . 3When they do complete the test, the 9 A. ~Yes. 10 t r a v e l. o r whic'hiCASE refers to:as Form C, will be
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11 signed stating'that the vacuum box has been 12 satisfactorily performe'd and the Non-Conformance i 13 Report-will be closed.
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Mr. Brandt, under Subparagraph E on page 17 15 of CASE's-mamorandum, the intervenor asserts that 16 NCR's number 200087 through.200088 and NCR 84-200018. 17 -are improperly dispositioned. Do you see that 18 portion.of the memorandum? 19 A. Yes, I do.
. 20 Q. Do you' agree with those assertions?'
21 A. NCR M84-200018 was written and subsequently 22 volded; as the inspector who wrote the NCR admitted a 23 he was in error. Tho concrete that h2 thought was-24 exposed as a result'of the backing strip slipping
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25' was on the surface of the backing atrip itself and
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tL 1 was not in structural concrete. l } 2 Q. Was that a proper disposition of that NCR7 F k 3 A. Yes, it is. 4 NCR 200087, which is actually NCR 5 M84-200007, was dispositioned -- excuse me -- was 6 written due to the fact of cleanliness not being 7 reverified by OC after a discontinuance of welding 8 for a long period of time. In my opinion, this NCR 9 was improperly dispositioned in that the NCR 10 disposition implico that there was a subsequent hold 11 point to be signed off by QC every time welding 12 started and stopped. As I've stated earlier today, (^; 13 thht is not the case. In this case, although the 14 NCR was improperly dispositioned in my opinion, it 15 was on the side of consetvatism and had it been my 16 decision, I would have voided the NCR and stated 17 that no procedural requirement existed. 18 NCR referred to as number C10088, which is 19 actually NCR number M84 200080, reports that the 20 backing strip has a gap in it an eighth of an inch 21 wide by three-sixteenths of an inch long and a union 22 of backing strips. NCR's dispositioned. There's no 23 requirement that the intersecting backing strips be 24 continuous; therefore, if there is no evidence of 25 discontinuitics, the wold may be used as is. I u _. PEDERAL COURT REPORTERS
45475 E l- Jagiee 'wi t h .- tha t- d i spos i t i on and can state that the
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(f , 2 .MCR-:wasLyroperly dispositioned.
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~ ~3' 0. .Why did you' agree with that NCR disposition?
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4 A. There is no requirement for backing, strips 1 5 to be cont'inuous. , 6 -Q. .Mr. Brandt, at the' top of page 18, the
.7 intervenor's memorandum dated Ser: ember 27,'1984, 8 t h'e r e are a number of allegations-concerning field.
- 9 weld number'52. Would you please review tbone-10 allegations, determine whether you. agree or disagree j 11' with them and for each that you disagree with, 12 please state the reason?
I. g 13 A. . Might be more meaningful for me to just 14 discuss the allegations, Mr. Downey. L 15 The statement Form A reveals no signaturo. 16 on line 1, although ~ the WHR log indicctos that the 17 first fit-up was done during this time period and 18 the chit, indicates first fit-up and-cicanliness donc 19 September 13, 1970. That is the case for this weld. 20 The back side fit-up was done on September 13th, 21 1978. The tack welds on the backing strip were a 22 inspected on September 15,,1970. The results of 23 that inspection are indicated on line 2 of what CASE
. .24 refers to as Form A. The backing strip was p)'
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. 25 subsequently removed from this weld in order to trim -#- PEDERAL COURT REPORTERS
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454761 1 .the plates to achieve the required elevation 2 tolerance, unich is indicated on an inspection 3 report included in the package and signed by Don
.4 Vogt. The backing strip was reinspected and 5 cleanlines was reverified as indicated on the 6 inspection report.
7 CASE also states that comments made on the 8 traveler, quote, cleanliness verified where 9 accessible, end quote, and indicates that it's 10 without signature or date. That I cannot agree with. 11 The initials M.N., which were an inspector named 12 Mike tiorton who was working in this area at this 13 time and it is dated 8-17-79. This is an angle to 14 plate wold at the top of the Refueling Cavity. The 15 backing strip was removed and reinstalled, as I 16 stated, and cleanliness was reverified. The notation 17 by Mr. Norton was made for a portion of the weld and 18 was made before the final cleanliness inspection was 19 made by Mr. Vogt. 20 Cleanliness for the inside weld was 21 reverified by Dave Stinson on 12-30-01. I have 22 connfirmed that this is for the inside weid, 23 although signed in the wrong place, by confirming 24 that the backside of the weld was embedded in 25 . concrete on 9-21-79. [_ _ FEDERAL COURT REPORTERS _
n 3 =i,@ :,. n;- f-3i 3v,
' 45477 r - : , .
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... 'l 'O. Is: Lit your testimony,.-Mr. Brandt, that al'1 l.
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.f 2i required, inspections have occurred for weld 527'
",7-l3 A.. .j Ye s .. As I stated,' Mr. Stinson signed the <
<- '4 . traveler'in the wrong place; however, myJreview
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. . v.-- 5 i nd ica tie s . tha t : all required inspections have been'
,6 performed.
7 - O. Assuming that:Mr. Stinso'n's signature is 8- not f or: the inside-weld, do you feel t h a t ' t h e r e .' i s -
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9' r e a s o n -~ t o question the' adequacy-of.the.. weld?' ,. n k 10 A.. No. Pn analogous situation is described la 11 ~NCR M83-01000, t h a t -- w e discussed earlier. Weld 2.73' l' t 12L is exactly the:same type-of weld as weld 52. -
'It is 13' ! a weld of the top. angle to a plate. No
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! 14- documentation exists to substantiate performance of 15 the inside cleanliness inspection for weld _273. This l 16 is exac'tly the:same situation ~is-would exist for !' 17 weld 52 lf you assumed that Mr. Stinson's signature l 18 , dated 12-30-81 is not for'the inside weld. NCR 19 M83-01000 is dispositionedluse as is based on the
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20 satisfactory results of a vacuum box t'e s t and if the l 21 hypothetical situation you'have posed for weld 52 ~
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l: 22 'were. described on.an NCR, it would'be dispositioned 12 3. 'the samelway. 24 ' lp j
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25 REPORTERS; i_1 - _ _ , _ lE? ERA { COURT _ . _
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CORRECTIONS: ~AND SIGNATURE
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M.;; ~ k./ _ _ l2T* .PAGE/LINE CORRECTION ' REASON-FOR-CHANCE
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= 17-I,.C. THOMAS BRANDT, have read the 18- forego!ng deposition, and hereby affix 1my signature that same is true'tand correct, except as noted 19 herein.
20 C. THOMAS BRANDT - L. 21 . SUBSCRIBED and svorn to before me this the day of , 1984. 22
. 23. NOTARL'PUBLIC:for.the Jtate20f Texac
,= 24 My Commission Empires
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'l~. zi S T J. T E OF TEXAS )
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^23 I, Janet E '. Schaffer, RPR, Certified Shorthan'd
^4 Reporter,in and.for the; State of Texa's, do hereby ,
L5 ' ce r ti'f yf tha t there came before mefon t'h e 3rd day'of
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61 'o c t o b'o r ,- A . D., 1984,.at the Ramada Inn Central, c7 . Fort Worth Texas, the following named person, 8- C. Thomas Brandt, who was previously duly
..to-wits 9 sworn to testify the truth'and nothing but the~ truth 10 of his knowledge touching and concerning the m4 tters
.1 11 in controversy in this causo; 'and that lue was
-12 ;theroupon examined upon'his oath and his examinrtion s
/N- 13 reduced to writing; same to be sworn and subscribed I Q.]
o 14 to by said witness before any notary public. 15 16 -I further certify that I am.neither attorney or 17 < counsel for, nor related to or employed by, any of 18 the parties to the action in which this deposition 19 is'taken, and further that 1 am not.a relative 1or 20 employee of any attorney or counsel employed by the 21' parties hereto, or financially interested in the 22 action. 23 I: l 24 In witness whereof,'I have hereunto set my hand , .,m , k i 1-b# 25 and affixed my seal t hi s /hE6d d ay o f October, A . D .', I + [' s j _ FEDERAL COURT REPORTERS
~45480
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Dnt fY' n . NET E. SCHAFFER, 154/
.WRPR, CSR
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d,- '- c 4 . , N AND FOR-THE STATC-O[ EXAS.
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1226 Commerce,~Sulte;411 Dallas', Texas. 75202 (214) 742-3035. 6 , s . 7, My commission-expires December 31, 1985 s
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