ML20093L395
| ML20093L395 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 03/15/1984 |
| From: | Boyer V, Clohecy D PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | |
| References | |
| CON-#484-557 OL, NUDOCS 8410180550 | |
| Download: ML20093L395 (110) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY & LICENSING BARD . 32 In The Matter Of: PHILADELPHIA ELECTRIC COMPANY Limerick Generating Station Units 1 and 2 Docket Nos. 50-352 and 50-353 0' Philadelphia, Pa., Thursday, March 15, 1984 Depositions in tandem of DAVID T. CLOHECY and VINCENT S. BOYER held in the offices of Philadelphia Electric Co., 2300 Market Street, at 9:10 a.m. on the above date before Neith D. Ecker, Registered Professional Reporter.
APPEARANCES:
AIR & WATER POLLUTION PATROL by: FRANK ROMANO Chairman CONNER & WETTERHAN, P.C.
by: Mark J. Wetterhan, Esq.
Counsel for Applicant e
ALSO PRESENT:
JAY M. GUTIERREZ, ESQ.
Regional Counsel NRC Staff 8410180550 840315 PDR ADOCK 05000352 T PDR
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DAVID T. CLOHECY and VINCENT S. BOYER, sworn.
MR. WETTERHAN: This is a deposition as ordered by the Atomic Safety & Licensing Board provided in the captioned proceeding as ordered in l Transcript 8306 et seq.
The deposition will be by pursuant to the rules of the Nuclear Regulatory Commission, 10 CFR Part 2, in particular 10 CFR 2.74a.
Before we start, I just want to bring the procedure to your court reporter's attention that when the court testimony is fully transcribed, the deposition shall be submitted to the deponents for examination and signature.
Let me be clear that we do not waive this.
Once you receive the signature, the deposition shall promptly be forwarded by registered mail to the Nuclear Regulatory Commission Office of the Secretary, Washington, D.C., 20555.
MR. ROMANO: I wish to say that I stipulate h
that I don't want to waive any of my rights here, too; and that I will first have to see the copy before I sign it. That's...
MR. WETTERHAN: Off the record.
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(A discussion off the record.)
MR. GUTIERREZ: I want to make one clarification. It's the NRC staff's understanding that this is a deposition ordered by the Board as a result of a discovery dispute between the licensee and the Air & Water Pollution Patrol. I am not l
making -- entering an appearance in this case and l
have been asked by the case attorneys to sit in and monitor the deposition.
MR. ROMANO: I would like to ask the representative of the'NRC why wasn't it possible for the inspector for the NRC to be here?
MR. GUTIERREZ: You want an on-the-record response to that?
MR. ROMANO: Yes.
MR. GUTIERREZ: It's my understanding based on the Board's order that what the Board ordered was t that PECo produce certain witnesses to clarify l
certain answers they've already given you in response to interrogatories; and that there's no pending l
discovery before the staff that needs clarification.
MR. WETTERIIAN: Applicant's understanding
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l is the same.
MR. ROMANO: However, I would like to add
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that the order of the Board'also indicated that I may have followup questions depending upon what statements are made; and that I feel that inasmuch as the NRC inspector is very important to the clarification of answers received from the applicant to AWPP interrogatories, that I feel that without him it jeopardizes our effort to clarify a number of points. And I really feel that the NRC being part of this entire operation at least should have the inspector involved with the 76-06-01 incident.
MR. GUTIERREZ: I only reiterate our understanding that this is a discovery dispute between PECo and the Air & Water Pollution Patrol; th,at at no time did the Board direct deposit' ions be taken of NRC staff personnel.
MR. ROMANO: Well, I just have to add again that the Board did say I would have followup questions; and without knowing what my followup questions would be, I think it's unfair to have limited, limited -- the people I might want to depose or ask questions of.
MR. WETTERHAN: Well, we'can't settle anything. Your statement is on the record. You can do with it what you want. I suggest that you now
o-5 question the witnesses who have been made available.
MR. GUTIERREZ: Just one further clarification.
- ~
I have read.the transcript in pertinent parts; and it is the staff's understanding that the followup questions which the Boara referenced were followup questions you may have directed toward the PECo employees that provided answers to your interrogatories.
MR. ROMANO: Well, there we have a matter of a misunderstanding in that the Judge specifically .
stated that when he -- when I asked for everybody involved with the 76-06-01, he designated -- he
, stated that there probably would not be all of them there but that the applicant must understand that my followup questions might require something like that.
So that we have it on the record that the only two witnesses for the applicant is Mr. Boyer and Mr. Clohecy.
MR. WETTERHAN: That's on the record.
MR. ROMANO: I will ask a question as we go.
And at this time I would like to say if we get an answer, I expect that it indicates that you
+' 6 are answering what"I ask and not again having what I feel might be not quite the answer to the question.
I would like to see - .let's see. I'm a little at a loss here because I had expected that the NRC inspector would be here to sort of corroborate or say -- be a sort of umpire in some of these-questions.
And so I'll start off with the plan to perform welding with electrodes fastened to a broomstick was revealed.to the NRC inspector by, according to the answer to Interrogatory No. 4, my first set, was answered by Jay Windsor, Bechtel structural steel and rigging superintendent; R.
Johnson, Bechtel general foreman ironwork; R. Seisle, Bechtel foreman ironwork; G. P. Auclair, Bechtel welder.
Is that so? Is Mr. Corcoran not here?
MR. WETTERHAN: Mr. Corcoran is not here.
These are the two witnesses.
MR. ROMANO: The inspector who was involved for the applicant and the inspector who was involved for the NRC are not here. I don't see how i
it's possible to clarify a dispute between applicant and AWPP without principal people being present.
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MR. ROMANO: I am going to continue.
MR. WETTERHAN: Thank you.
MR. ROMANO: Well, then, I would have to say, Mr. Clohecy, is that not so?
MR. CLOHECY: Let me see what we said.
You said the fourth set of interrogatories?
MR. ROMANO: No. I said Interrogatory No. 4, first set.
MR. CLOHECY: Oh, first set, okay. Let me take.a look at that.
Okay. Yes, I agree with our previous statement.
MR. ROMANO: Well, I see here as licensee's inspector I was going to ask a question; but now I have to say as the licensee's representative, which is not the person I really wanted to be speaking to, Mr. Clohecy, should you have known that the weld procedure had not been qualified using extensions?
MR. CLOHECY. I don't agree with your
- characterization.
MR. ROMANO: I said should you have known --
MR. WETTERHAN: Let the witness finish, please.
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l 1 MR. ROMANO: Well --
2 MR. WETTERHAN: Let the witness finish.
3 You asked a question. He's going to answer it, j l
4 Then you can follow up, but let him finish.
5 MR. CLOHECY: I don't agree with your 6 characterization there of the weld procedure not 7 qualified. That's not correct.
. 8 MR. ROMANO: I didn't ask you.that 9 question.
10 MR. CLOHECY: Would you repeat the
[f 11 question?
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p 15 MR. CLOHECY: There's no requirement to 16 qualify the weld procedure using extensions.
17 MR. ROMANO: Well, then will you turn to 18 the Attachment 1 from letter of R. T. Carlson to 19 V. S. Boyer dated 11/10/76 transmitting NRC i.e.
l 20 Inspection Report No. 50-353, 76-06?
i l 21 MR. CLOHECY: Okay. Are you referring to 22 Appendix A, Mr. Romano?
23 MR. ROMANO: I am referring to Page 5 --
24 well, Attachment 1. Attachment 1 subsequent to ARl!A. WIDE Fl.DI R AL REPORTING, INC.
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1 Summary of Findings, Page 5.
2 MR. CLOHECY: Okay. I have Page 5 and 3 Summary of Findings.
4 MR. ROMANO: Page.5.
5 MR. WETTERHAN: Yes.
6 MR. CLOHECY: Yes.
7 MR. ROMANO: Would you read the second 8 paragraph starting with "The inspector," which I 9 note to be the NRC inspector. Would you read that?
10 MR. WETTERHAN:. Read.it.
11 MR. CLOHECY: Okay. "The inspector determined
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12 that the weld procedure PI-A-Lh (Structural) Rev. 0 N' 13 'hadnotbIen}qualifiedusingelectrodeholder 14 extensions, nor had the welder been qualified using
, 15 such extensions. Although the applicable Code AWS 16 Dl-1-72 does not specifically address the use of 17 electrode holder extensions with respect to I
18 procedure / welder qualifications, it does in Part 19 3.1.2 require that equipment be designed and 20 manufactured so as to enable qualified welders to 21 attain the results prescribed in the AWS Code."
22 MR. ROMANO: Then they do have a specified 9
23 Procedure there. You said that the welder did not l 24 have to be qualified; is that what you said?
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20 qualified, but there it that the welder was states the welder specifically that 21 nor had the welder been quali 22 That means that as he w fied.
not qualified 23 extensions; doesn't tha t to use the mean that?
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was making an .-
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" , You have to
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read on where he also says that "the applicable code does not specifically address the use of electrode holder extensions with respect to procedure / welder qualfications."
MR. ROMANO: That's right. It says that.
But that's talking about the extensions.
MR. CLOHECY: Uh-huh.
MR. ROMANO: Here it specifically states that the welder had not been qualified.
MR. CLOHECY: No, it doesn ' t say that.
MR. ROMANO: Well, I would like then to have this page -- I think the procedure is that you .
will read this, is it, and that we can put this in as an exhibit.
THE COURT REPORTER: Okay.
MR. WETTERHAN: You can do it that way or identify it, since we all know what page we're talking about, to save you a couple of cents.
MR. ROMANO: Okay. I then will have that become Exhibit 1, the Attachment 1, letter from i l
R. T. Carlson to V. S. Boyer dated 11/10/76 transmitting NRC i.e. Inspection Report No. 50-353, )
76-06, specifically Page 5 and specifically the first sentence of the second paragraph where it states i
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1 the welder had not been qualified using extensions.
2 (The above-described document was marked )
3 as Exhibit No. 1 for identification.) .
I 4 MR. ROMANO: Isn't it true, Mr. Clohecy_,
5 that -- see, I could say this to the inspector who 6 was there; but it makes it difficult now for me to 7 be asking somebody .else a question which I had 8 specifically written for the NR -- for the licensee's 9 inspector.
10 So I have to say isn't it true, Mr.
11 Clohecy, in place of Mr. Corcoran, isn't it true
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- S h 14 we just. mentioned before, Mr. Windsor, Mr. Johnson, 15 Mr. Seisle and Mr. Auclair?
't ?" 16 MR. CLOHECY: What paragraph are you 17 referring to?
18 MR. BOYER: Yes. That question is not 19 clear.
20 MR. ROMANO: Well, I'm not taking it out 21 of a paragraph. I'm taking it out of --
22 MR. WETTERHAN: Could you rephrase it, Mr.
23 Romano? The witnesses do not understand the question.
24 MR. ROMANO: Well, I'll try to rephrase it.
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13 1 Isn't it true that you, Mr. Clohecy, for.
2 Mr. Corcoran, stated such non-qualified weld 3 procedure had been used after it was revealed by the 4 craft and supervision people?
5 MR. CLOHECY: Where?
6 MR. ROMANO: Well, then we go back again 7 to Page 5.
8 MR. WETTERHAN: Let me state something, 9 an objection for the record.
T 10 I was willing to let one or two questions
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14 So I will object for the record, and I 15 will allow my witnesses to answer.
16 MR. ROMANO: Yes. But I want to ask these 17 questions because I feel they're very important to 18 the clarification which I didn't get previoasly and 19 which is not just perhaps specifically to one 20 interrogatory, but it comes in somewhere in the 21 various interrogatories that I didn't feel I got a 22 Proper answer to.
23 It states in the second -- third sentence 24 on that " Interviews" -- and that's NRC inspectors -- !
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14 1 "with craft and supervision personnel revealed a 2 plan to perform welding with the electrode holder 3 fastened to the end of a broomstick; and the personne]
4 stated, and licensee" -- and licensee, that's the 5 one we're talking about -- "and contractor QA and 6 QC personnel later confirmed" after the interviews 7 with the craft and supervision personnel, "that,"
8 as you read it there, "this approach had been used 9 on similar limited access weld joints at Elevation 10 253, Columns F and H at Wall 23."
11 Now, then I asked the question, isn't it 12 true that you -- as you read there -- know that 13 non-qualified weld procedure had been used -- have 14 been used previous -- before, before the personnel 1
15 revealed this broomstick affair was going to take 16 place at weld -- at Elevation 253, Columns F and H at 17 Wall 237 18 MR. CLOHECY: No, it's not true that the 19 weld procedure was not qualified.
20 As it says there, the inspector made an 21 observation that the procedure had not been 22 qualified using electrode holder extensions.
23 MR. ROMANO: That doesn't answer the 24 question I'm asking.
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15 1 MR. CLOHECY: But the procedure was 2 qualified.
3 .MR. WETTERHAN: One at :s time.
4 MR. ROMANO: How is he going to finish --
5 MR. WETTERHAN: One at a timo.
6 MR. ROMANO: -- when he stops? I feel 7 that's it.
8 No, you'ro not answering the question.
9 It is indicated right there in that 10 paragraph that once the craf t and supervision 11 personnel or through their interview found out that 12 this situation was going to take place, then, after 13 that that the licensco and contractor QA and OC 14 personnel, it says, stated that this approach had 15 boon used before at olovations -- at Elevation 253, 16 Columns F and !! at Wall 23.
17 MR. BOYER: That's what it says.
l 18 MR. ROMANO: That's what it says.
19 May I ask you, Mr. Boyer, what do you mean 20 by "That's what it saya"?
21 MR. BOYER: Well, you road a statomont 22 and asked whether that's what it said. I said yes, 23 I agroo with you that that's what -- that you road 2.i it correctly.
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16 l 1 MR. ROMANO: But you don't agree that the 2 licensee inspector knew of a similar case describad 3 there previous to the interview of the NRC inspector?
4 MR. BOYER: That question isn't clear.
5 MR. GUTIERREZ: Can I have a clarification 6 of that question? I didn't understand the question.
7 MR. WETTERHAN: What do you mean by 8 "similar case"?
9 MR. ROMANO: The craft and supervision 10 personnel as a result of an interview with the NRC i
11 inspector found -- brought out the fact that a 12 wold was going to be dono using broomstick 13 extensions.
14 And it says then that the licensee and 15 contractor QA and QC personnel later confirmed --
16 that's after they learned about this -- later 17 confirmed that this use of broomstick extensions, 18 which is a non-qualified uso, had already boon used to beforo.
20 MR. WETTERHAN: Wo will stipulate to the 21 fact that broomsticks had boon used beforo, in the 22 interest of saving timo. Wo do not stipulate that -- i l
23 MR. ROMANO: All I want is the answor to i l
21 the questions. I maan your interpretation is not ARIA.WIDI II !)1 B AL Rt l'ORTING, INC
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5 MR. GUTIERREZ: Mr. Romano, just.so'I'm -- 1 6 7 ,MR. ROMANO: 1 don' t believe you're 7 qualified -- I don't believe your effert is to 8 qualifyitfortherecohd, to clarify it for the 9 record.
10 MR. GUTIERREZ: Are you asking the witnesse3 11 whether th'ey' agree ~ with the " facts a.s stated on Page A.
5?
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14 a'nd in some cases I Want to find out, for instance,
.15 why the licensee hadn't brought this improper use l'
16 of extensions to the notice of whoever had to know 17 it there before. it was found out by the NRC 18 inspector.
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Would you state -- I have to say now,
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l 20 ' Mr. Clohecy, for Mr. Corcoran, who I expected to 21 question, woulds you state who the NRC QC inspector j
- 22 was and who the Bechtel QC inspector was?
23 MR..CLOHECY: Let me make sure I understand t 24 You want to know who the NRC inspector was?
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MR. ROMANO: You know, that's a pretty 9
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'3 MR. CLOHECY: Okay. Would you --
4 MR. WETTERHAN: Let the witness complete --
5 MR. ROMANO: Yes, but I can't --
6 MR. CLOHECY: Would you repeat it?
Y MR. ROMANO: Would you state who the NRC 8
QC inspector and Bechtel QC inspector was?
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MR. WETTERHAN: Why don't you ask one at 10 a time.
MR. ROMANO: Well, that's one question.
19 ~
MR. WETTERHAN: Do you know the names?
13 MR. BOYER: He's asking who the NRC 14 inspector was who made the observation.
15 MR. CLOHECY: The NRC inspector was Al 16 Toth.
I MR. ROMANO: Who the Bechtel QC inspector 18 was?
19 MR. CLOHECY: Okay. We answered that in 20 one of our interrogatories, in one of -- in response 21
, to one of your interrogatories.
l 22 MR. WETTERHAN: It's 17, I think.
23
! MR. CLOHECY: There were two individuals l
24 l involved, as stated in our previous answer to ;rour l
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first discovery request, Interrogatory 5. Ken 9
Bishop and Bill Driver.
I 3
(Witnesses conferring off the record.)
4 MR. BISHOP: We were -- Mr. Clohecy was 5
reading the names that were listed in Interrogatory 6
No. 5 of applicant's answers to the first set of 7
interrogatories, Discovery No. 15 dated December 5th, 8
1983, which was a list of names in response to a 9 general question.
10 On Discovery No. 17 dated December 19th, 11 1983, the answer to Interrogatory No. 1 under the
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12 76-06 case re5Nrence number, which is the one you 13
- 24 -1
-are referring:to, there are a list of names given 14 there wh'ich includes Mr. Bishop's --
15 MR. ROMANO: Yes, okay. It has been --
16 MR. BOYER: -- but does not include Mr.
17 Driver's.
18 MR. ROMANO: All right.
19 MR. BOYER: So we would say it was Mr.
20 Bishop.
21 (Witnesses conferring off the record.)
22 MR. ROMANO: Was Mr. Bishop one of the 23 inspectors or Mr. Driver one of the inspectors or 24 not?
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MR. CLOHECY: He was also a QC inspector 2 at that time.
3 MR. ROMANO: Is there any reason why he l l
4 hadn't been indicated as one of the inspectors?
5 MR. CLOHECY: On the NRC Inspection Report?
6 Is that what your question is?
7 MR. ROMANO: My question is: You are )
8 bringing up the fact there was a Bill Driver also l i
9 inspector at this -- in this situation. Why wasn't 10 he listed?
11 MR. CLOHECY: Where?
12 MR. ROMANO: In with the answers.
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13 MR. CLOHECY: Okay. In the Answers to 14 Interrogatory.17?
15 MR. BOYER: Wait a minute. Hold on.
16 (Witnesses conferring of f the record.)
17 MR. BOYER: Well, to simplify the matter, 18 we can see Mr. Bishop's name is listed in both 19 places. Mr. Driver's may or may not -- he may or 20 may not have been involved in this particular 21 incident.
22 MR. ROMANO: He may or may not have been?
23 MR. BOYER: Well, his name is not listed 24 on Discovery No. 17.
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21 1 Can you clarify it?
2 MR. CLOHECY: Yes. Discovery 17 are the 3 names as listed in the NRC Inspection haports as 4 personnel contacted by the NRC. And you would have 5 to ask the NRC why they didn't list Mr. Driver.
6 MR. ROMANO: But are you saying then that 7 you had sent in his name and that the NRC did not 8 list it?
9 MR. CLOHECY: That's correct. The NRC did
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10 not list his name in their Inspection Report.
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11 MR. ROMANO: Okay. We'll go on. WE'll t 12 go on here to the Interrogatory No. 5.
, ,, - 13 ,. ,f,UI.'GUTIERREZ: Point of, clarification.-
14 Your question to Mr. Clohecy.was "Are you saying i
15 you did not send in his name and the NRC did not 16 list it?"
17 He answered yes.
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18 This is the first reference that's been 19 made to the fact that PECo is sending in names.
( 20 Can I have a clarification of either -- of the 21 answer?
22 MR. WETTERHAN: Can you clarify your
't 23 answer?
21 MR. CLOHECY: Okay. Yes.
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22 1 In one of Mr. Romano's Interrogatories, 2 Discovery 17, Item 1, he asked us to provide the 3 names of licensee contractor and NRC inspectors and 4 welders who are indicated in all safety-related 5 welding deficiency.or infraction reports or notices 6 so that applicant can provide depositions and/or 7 affidavits.
8 So in complying with that request we 9 listed the names for Mr. Romano as listed in the d
10 NRC Inspection Reports under " Personnel Contacted."
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' ~5' ' ' ' 11 MR._GUTIERREZ:
I understand. Thank you.
~ 12 MR.-ROMANO: Mr. Clohecy, I want to again
] T i13 go b'acik to thel fact that you said that there was
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14 somethin'g wrong'in the manner in which the welding
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16 And it states here, the same Page 5, "The 17 inspector considered that an electrode holder 18 attached to a stick did not meet the requirements 19 of the code unless proven satisfactory by
, 20 qualification test for the six different weld 21 configurations to be welded at the limited access 22 joints." i 1
23 Wouldn't you say there that the NRC l l
24 inspector is saying that the manner in which they
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weld or had done were going to do the in 1 not proper?
welds was answer to your quest o ,
In 2 MR. CLOHECY:
said about my previous - . ,
3 items you didn' t say all the first I ,
4 were not correct.
statements 5
was those things. Well, you said there .
6 ion.
MR. ROMANO:
by that welding situat 7
nothing unqualified didn' t say that.
I say?
8 MR. CLOHECY: did you Well, what 9 MR. ROMANO: the welding I said that 10 MR. CLOHECY:
d was j 11 Procedur,e..was [fi, qualifiewelding . procedure
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. 12 MR. ROMANO:
13 1 .: , -
qualified. ,
any action taken there was Well, then 14 Was he welder?
15 - how about the regarding ,
16 qualified? Yes, he was.
17 MR. CLOHECY: again I ask you Well, then 18 MR. ROMANO: considered The NRC inspector 19 this statement. a stick did not about attached to that an electrode holder Part 3.1.2 unless 20 21 requirement of the AWS for the meet this lification test 22 satisfactory by qua necessary in the Proven i ue that was 23 kind of welding techn q l 24 ORTING. INC.
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- A WIDF FI DI:RAL REP
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24 1 limited access joint.
2 Isn' t that specifically stating that the 3 welder was not qualified?
4 MR. BOYER: No. That is not that the 5 inspector's view was as you stated it there. It was 6 his opinion. And the next sentence indicates that 7 .the licensee disagreed with his opinion.
8 MR. ROMANO: Wel.' , I don' t see it that way.
9 Let -- it specifically states that the 10 manner in which the weld was to be done did not meet 11 the requirement. If it was to be -- to meet the 12 requirement, this welder had to take a quaiification 13 test for the six- different weld techniques that 14 would be needed in order to do that.
15 So that the statement is clear as it is 16 written here unless we want to challenge -- I say, 17 Mr. Boyer, are you challenging the NRC inspector's 18 statement at that point?
10 MR. BOYER: I am not challenging it. I'm 20 just trying to clarify what you read and to interpret 21 for you what it said. And it says, "The inspector 22 considered," et cetera.
23 MR. ROMANO: Yes.
24 MR. BOYER: That was the inspector's view.
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The next sentence says, "The licensee disagreed."
2 So there was a difference of interpretation 3
or difference of opinion as to the interpretaion of 4
the code requirements relating to the qualification 5 procedures necessary'tx) use an extension.
6 MR. ROMANO: Would you say that good 7 quality assurance by.the licensee would have them 8 oppose or disagree with a view of the inspector who 9 had quality assurance in mind?
10 MR. BOYER: That was a rather long sentence 11 and I lost it.
12 MR. ROMANO: I've heard them longer than 13 this morning.
14 MR.fBOYER: Well, maybe you can repeat it 15 again and I might be able to answer it again.
16 MR. ROMANO: I said that the licensee 17 quality assurance inspector, wouldn't you feel that 18 the licensee QC inspector would instead of disagreein< ,
19 you know, go along with the idea of the NRC 20 inspector who had determined or felt that use of the 21 broomstick and by the specific person did not 22 qualify him to make this type of weld?
23 MR. BOYER: The NRC is free to make its 24 interpretation of' requirements; and we, the applicant,
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the licensee, make our determination of. requirements.
2 Generally, there is agreement between the 3 interpretation.
4 However, in this particular case there 5 was a difference of opinion as to the interpretation 6 of the requirements. The inspector felt that the 7 particular. extension that was used should have been 8 qualified. We felt that the requirements were 9 covered'by our procedures which consisted of the 10 qualific5tions of the weld procedure and the welder.
11
.MR. ROMANO: What do you mean by "qualifi-T 12 cation of'the weld. procedure"?
T-13 . L. MR
.;YBOYER:
. This relates to the weld rod 14 that would be used and to temperature, pre-heat, 15 post-heat requirements and other aspects with regard 16 to the placement of the weld.
17 MR. ROMANO: Bat use of a broomstick'as 18 the extension was not considered proper procedure, 19 was it?
20 MR. WETTERHAN: Objection. I don't' 21 understand that question.
22 MR. ROMANO: Well, you don't have to 23 understand it. I'm asking --
24 MR. WETTERHAN: I have to understand it in AREA WIDE FEDI:RAL REI'ORTING, INC.
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27 1 order to state whether I have an objection to it.
2 So you're wrong, Mr. Romano.
3 MR. ROMANO: But I am being asked to 4 repeat questions all the time here. And, again, you 5 know, it doesn't seem proper.
6 MR. WETTERHAN: Did the witness understand 7 the question?
8 MR. BOYER: I understood it when he stated 9 it; but there's been so much conversation since then, 10 he'll have to repeat it.
11 MR. ROMANO: See, same thing happens to 12 me now. That's .what I think is not fair about it.
~
13
"[i' _lDo you,.Mr. Boyer, feel that'the use of 14 the - -of a broomstick as an extension is proper in 15 line with what'you-just said was proper technique?
16 MR..BOYER: I know that extensions are 17 allowed. As to whether a broomstick is appropriate 18 or not, I would have to defer to someone who was a 19 little more knowledgeable in welding technique 20 areas to make that judgment.
21 MR. ROMANO: Do you have anyone here who 22 could make that judgment?
23 MR. BOYER: Do you feel...
24 MR. CLOHECY: Ye~s.
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MR. SOYER: ... capable?
2 MR. CLOHECY: Use of a broomstick is 3
allowed when it is approved by engineering -- not 4
a broomstick; an electrode extension, an approved 5 electrode extension.
6 MR. ROMANO: But is a broomstick allowed?
7 MR. CLOHECY: Use of.an approved --
8 MR. ROMANO: You're not asking (sic) the 9 question ~--
10 MR. CLOHECY: -- approved electrode holder 11 extension --
12 MR. WETTERHAN: Fine.
13 EAsk'another question.
14 MR. ROMANO: Is a broomstick considered 15 to be a proper extension?
16 MR. CLOHECY: I can only answer with the --
17 MR. ROMANO: I'd like a yes or no answer.
18 MR. CLOHECY: -- requirement -- is it?
19 MR. WETTERHAN: Just continue your answer 20 and finish it.
21 MR. CLOHECY: Okay. It would have to be 22 approved by engineering. They would have to 23 evaluate it.
24 MR. ROMANO: You said that for the third AREA. WIDE FEDERAL REPORTING. INC.
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l 29 time, and I ask you.again: Is a broomstick which 1
can be picked up off the floor or anywhere around 1 o.
considered a proper technique and good procedure 3
for welding? Is that broomstick considered to be 4
5 proper -- a proper extension?
(Witnesses conferring off the record.)
6 MR. CLOHECY:
It could be'if. approved by
( 7!
3 engineering.
MR. ROMANO:
We came here today with the 9
I ask
(
idea of.. clarifying things and ask questions.
- 10 a question now that could be stated.
11
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Youjas an inspector should know that such *
'.12 %
a simple question as that,. and you refuse to answer 13 it yes or no..
And-it's obvious that the inspecto,r 14 has stated here that it's not proper. And I think
( l 15 r l
the applicant is here today.not to clarify but to, l 16 it seems to me, to hold the same position before 17
( irrespective of.whether an.NRC inspector has already 18 stated it as improper.
19 MR. CLOHECY: Mr. Romano --
( 20 MR. WETTERHAN:
There's no question 21 on pending.
MR. ROMANO:
I'm not asking a question.
( 23 In regard to this number -- Interrogatory 24
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No. 5 of my first set as to who confirmed the use n
~ l of broomstick extensions to performs welds, 3
applicant answered various -- Mr. Claus and Mr.
4 Bishop. And here Mr. Driver is mentioned; L.
5 McNamara and L. McNamara.
6 Who among those people stated to the NRC I
inspector that broomstick ' extensions were used before 8
at another location? I want to know who that 9
specific individual was.
10 (The witnesses conferring off the record.)
11 MR. BOYER: The exact person is not known.
12 It was one -- undoubtedly in our view one of_those
. 3 that were listed.
14 MR. CLOHECY: One or more.
15 MR. BOYER: You are trying to'go back and 16 make us recall from memory a statement -- the 17 individual who made a statement that reported in the 18 NRC Inspector Report. We cannot absolutely identify 19 the individual. So we listed'a group of individuals, 20 one of whom we believe made that statement.
21 Well, now here we have a MR. ROMANO:
22 situation where the NRC inspector isn't here who 23 could have clarified this thing. And if some of 24 these people who were involved also could have AREA WIDE FI DFRAL REPORTING. INC.
31 1 clarified things, that's why I state that not having 2 people who are absolutely necessary to the clarifi-3 cation of this thing is not here, again I say 4 jeopardizes my right to depose those people who 5 could have clarified some of these answers. And I 6 want that on the record. I want to ask --
7 MR. GUTIERREZ: Excuse me, Mr. Romano.
8 I just want to reiterate -- I don' t want 9 that remark to'go unanswered -- to suggest it was 10 ever the intent of this deposition to depose NRC 11 inspectors is totally contrary to my understanding 12 what the purpose of this deposition was ever
- sa ~-
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intended 'by;;the Board to be. .
13 .
14 It is my. understanding that the Board 15 required the licensee to provide witnesses to 16 answer clarifying questions on specific interrogatori es.
17 MR. WETTERHAN: Let me add two things --
18 MR. ROMANO: But, wait a minute --
19 MR. WETTERHAN: -- first of all, in a 20 telephor4e conversation we had with Mr. Romano, I 21 stated the same thing. I agree with the NRC counsel's 22 Position. And I believe as stated in the transcript 23 section which I quoted, that is clear.
24 MR. ROMANO: Well, now here we are again.
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MR. WETTERHAN: Mr. Romano, let's --
2 MR. GUTIERREZ: I think our positions are 3 clear on the record. And you probably should ask 4 the questions to the witness.
5 MR. ROMANO: But Judge Brenner did say.I 6 could have followup questions. Now we're finding up --
7 finding out that without the NRC inspector I can't 8 proceed with followup questions. And --
9 MR. WETTERHAN: Mr. Romano --
10 MR. ROMANO:' I cannot understand how we 11 can clarify.a; dispute without the principal people 12 being here. And I think it was an obligation of j '7l 13 the NRC. inspector to be here, I would feel, for the 14 purpose of ---
15 MR. CUTIERREZ: The dispute was --
16 MR. ROMANO: -- for the purpose of --
17 MR. GUTIERREZ: -- between your organi-18 zation and the utility.
19 MR. ROMANO: But the NRC is what I said 20 earlier -- in this case in particular could have 21 been an umpire here today.-
22 MR. WETTERHAN: Well, everybody's position 23 is on the record.
24 If you want to take any action before the AREA-WIDE FEDI RAL REPORTING, INC.
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33 1
Licensing Board once the deposition is transcribed, that's up to you. But I suggest again that you ask 3
questions of these witnesses who are provided.
4 MR. ROMANO: Isn't it true, I guess Mr.
5 Clohecy, for Mr. Corcoran, that the licensee and 6
contractor -- contractor's QC were negligent in 7
permitting broomstick extensions on previous welding?
8 MR. CLOHECY: I would not say.that's true.
9 MR. ROMANO: Well, did they. allow the use 10 of broomsticks on previous -- broomstick extensions 11 on previous welding?
- w -- 3, MR. CLOHECY: I do not believe they a'l lowed
.,;&ip-dli ,t "
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3
- w rify . - it with prior. knowledge.
14 MR. ROMANO: What do you mean "with prior 15 knowledge"?
16 MR. CLOHECY: What it says in the report II is that the licensee and contractor QA and QC 18 personnel later confirmed that this approach had been 19 used.
20 MR. ROMANO: Yes.
21 They later confirmed af ter it was brought 22 out by interviews with craft.
23 Why didn't they object to this use of 24 broomsticks for extension at the previous use that
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34 l 1 they knew about?
2 MF. BOYER: Who is "they"?
3 MR. ROMANO: The. inspectors, l
1 4 MR. CLOHECY: It's my understanding that 5 they.did not have prior. knowledge of it. ,
6 MR. ROMANO: Well, it states it right 7 there. ,,,,'
8 MR. CLOHECY: It says they. confirmed it.
9 MR. ROMANO: Yes, they. confirmed it 10 because th'ey had knowledge with which to confirm it.
11 MR. CLOHECY: Not necessarily prior 12 knowledge.
13 MR.. ROMANO: Well, all I get is "not 14 necessarily",; and that doesn't clarify anything.
15 I'd like.to ask: Isn't it true a Mr.
16 Ferretti was also an inspector involved with 76-06-01' 17 MR. CLOHECY: Yes.
18 MR. ROMANO: Where was he mentioned here 19 this morning in other questions asking who the 20 inspectors were?
21 MR. CLOHECY: Because it does not appear 22 that he was the one who confirmed or was questioned 23 about this approach with the electrode holder 24 extensions.
1
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MR. ROMANO: It doesn't say who was --
o who anybody was of.the QA and QC personnel 3
inspectors.
4 Fo why do you say he wasn't mentioned?
5 Dcesn't mention anyone at that point here on Page 5 6 that we are discussing. I'm limiting this to this d
question..
8 MR. CLOHECY: Okay. Mr. Romano, Mr'.
9 Ferretti was included as a name provided under 10 Discover 17,' Interrogatory 1.
11 MR. ROMANO: Well, the~n I had asked you
- ~ 12 earlier. ~ And you' mentioned Mr. Bishop and Mr.
. . '. & -i -I . &, . . . ,
. . t. -
13
-Driver, but you did not mention Mr. Ferretti. -
14 That's correct.,
.MR. CLOHECY:
15 MR. ROMANO: You~did not mention him.
16 MR. CLORECY: That's correct.
17 MR. ROMANO: Why did not you mention him?
18 MR. CLOHECY: Because, to the best of our 1
19 knowledge, he did not confirm the extension approach 20 with the NRC.
21 MR. ROMANO: I didn't ask you whether he 22 confirmed anything. I just asked you why did you 23 not state that he was involved in this 76-06-01.
24 MR. CLOHECY: That was not your earlier
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! 1 question.
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2 MR. ROMANO: Well, it was my earlier 3 question.
4 MR. WETTERHAN: Do you have a question 5 pending? Is there a question pending?
6 MR. GUTIERREZ: (Shaking head.)
7 MR. WETTERHAN: No?
8 MR. ROMANO: Now, I go to Interrogatory 9 No. 6, first set. This has to do with 76-06-01.
10 Is it your understanding, Mr. Clohecy, 11 that welder G. P. Auclair, who the applicant stated 12 was the welder involved in the broomstick affair, 13 was stated to be a qualified -- you stated him to be 14 a qualified welder, did you not?
15 MR. CLOHECY: That's correct.
16 MR. ROMANO: And also it was stated that 17 no unqualified welders were involved; isn't that 18 true?
19 MR. CLOHECY: That's true, i
l 20 MR. ROMANO: Well, then the NRC inspector 21 at this point, again on Page 5, makes the statement 22 that the welder was not qualified -- broomstick 23 extensions and that he was not qualified unless he 24 was -- had passed a certain qualification test in l
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I cess joints. l 1
order to weld such limited aci was qualified Do you say that Mr. Aucla r Do you have 2 - let me ask you this: ,
even though l ir was qualified to 3 ,
4 records to show that Mr. Auc aCo you have records do a limited access weld?
5 t
showing that?
6 We have records showing tha .v . ,
MR. CLOHECY:
e the welding -
7 Mr. Auclair was qualified to us 8
procedure assigned. - was he 9 Well, he was MR. ROMANO:
10 weld at this limited access ~
assigned to make this 11 .
joint? ,. ; ..
nr
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Yes.
MR. CLOHECY: -
ljl ,
And did he -- then the >
MR. ROMANO:
elder had not been 14 .
inspector first states that the which was part of t 15 qualified to use extensions w 16 was asked to do. ;
process that you saw he lt of the l 17 And then I asked you as a resu ation, I asked you 18 i inspector's questioning the situ was qualified !
19 whether you can show that Mr. Auclair ld techniques that would 20 l, to do these six different we weld joints.
21 be required at those 22 Let me first state that I i MR. CLOHECY: an extension, ll 23 was asked to use U1 did not say that he ,
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38 1 MR. ROMANO: I didn't say -- I didn't -- I 2
never said that.
3 MR. CLOHECY: You did.
4 MR. ROMANO: No, I didn't. I'll have to 5 ask you again.
6 The NRC inspector had stated that the 7 welder was not qualified to use those extensions.
8 Not only that, the NRC inspector questioned Mr.
9 Auclair's qualifications as to whether he had been 10 qualified to do these six different kinds of 11 limited access joint welds.
12 Are you saying that, again, you differ 1 13 with the NRC inspector as to whether he was 14 qualified or not?
15 MR. CLOHECY: Are you asking whether I 16 differ with the NRC inspector?
17 MR. ROMANO: I asked you that. You 18 question --
19 MR. CLOHECY: Whether he was qualified?
20 Yes, I do differ with him.
21 MR. ROMANO: Do you have proof that Mr.
22 Auclair did.in fact meet the requirements, qualifi-23 cation test for the six different weld configurations l
24 to be welded at the limited access joints?
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MR. WETTERHAN: Objection. That was asked 2
and answered.
3 MR. ROMANO: I -- wasn't answered.
4 (Witnesses conferring off the record.)
5 MR. CLOhECY: Yes, he was qualified.
6 MR. ROMANO: Would you give references to 7 where we can'get that proof, that at the time that 8 this happened and that at the time the NRC inspector 9 questioned his qualifications, that he was qualified 10 in these six different weld techniques?
11 MR.' WETTERHAN: Objection. This is beyond 12 the reasonable scope of what the Board asks for.
- 2. ,.-
13 This is not clarification of questions. This is 14 discovery -- a request for production of documents 15 which is well beyond the close of discovery.
16 MR. ROMANO: I feel that this is a very 17 important part.
18 Here we have a welder who the NRC has 19 stated was not gnalified to do this. The applicant 20 is stated that he was, and we would like to have 21 proof of that situation.
22 MR. WETTZRHAN: Could you state for the 23 record whether those qualifications are stored at 24 the Limerick Generating Station?
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MR. CLOHECY: Yes. Those qualification 2
records are at the Limerick Generating Station.
3 MR. ROMANO: Then will you make these 4
available?
5 MR. WETTERHAN: Objection. That's not 6 for him to provide. Discovery is open -- over. I 7
will state that we will not make them available.
8 MR. ROMANO: Well, this is to clarify
~
9 previously-improperly-answered questions that didn't 10 give full information. And here we are blocked 11
- p again from receiving very important information to r_ ~ . -. .
12 this controversey.
^
.- 13 77 I would like the court reporter to -- we
~
14 already have this page, but I want to refer to
' 1 15 Paragraph 2 wherein it states that this weld -- the 16 NRC inspector considered that the welder was not 17 qualified to do this welding and call that Exhibit 2, 18 Page 5 of the same previous attachment, letter from 19 R. T. Carlson to V. S. Boyer dated 11/10/76 20 transmitting NRC i.e. Inspection Report No. 50-353, 21 76-06.
22 MR. GUTIERREZ: Clarification. Mr.
23 Romano, don't you already have as Exhibit 1 that 24 entire document? That was my understanding of what
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o 41 1 you did.
2 MR. WETTERHAN: Applicant's understanding 3 is the same.
4 MR. ROMANO: But -- what is your name?
5 MR. GUTIERREZ: Jay Gutierrez.
6 MR. ROMANO: Mr. Gutierrez, I am not a 7 lawyer., And the limitations of even asking a 8 question are coming out here, so that I did not 9 know that I could just say "Here, put this whole 10 thing in."
11 So.that that's my clarification on that.
12 I'm sorry,'but I would rather have it that I did
.a..
c
- 13 undershh*dd and save'some time.
14
, LMR. GUTIERREZ: That was my intent, too.
15 I think you could save some time if you realize that 16 you've attached that whole document. So I don't 17 think you had to do it each separate page.
18 MR. ROMANO: Then we will have that whole 19 document put in as an exhibit.
20 We go to Interrogatory No. --
21 MR. WETTERHAN: Off the record.
22 (Discussion off the record.)
23 MR. ROMANO: I'm going to Interrogatory 24 No. 8. I miedthe question: "Did applicant design'
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and manufacture equipment as required by AWS Dl-1-72 l
i 2 under Part 3.1.2 so as to enable qualified welders l
3 to meet the AWS Code?"
4 The applicant answered that " Applicant has 5 not designed or manufactured equipment described 6 under that reference and that any such equipment 7 needed for use at Limerick would be procured from a 8 vendor of such equipment."
9 Then I ask: Isn't it true that proper 10 equipment was to be available to available qualified 11 ' welders to meet AWS Code?
12 MR. CLOHECY: Yes, the code says they 13 should use equipment designed and manufactured for 14 welding.
15 MR. ROMANO: That means that the use of 16 broomsticks were not considered to be proper then; 17 right?
18 MR. CLOHECY: That's not what the code 19 says.
20 MR. ROMANO: The code says that the 21 equipment has to be designed and manufactured so as 22 to meet the code, do:s it not?
23 MR. CLOHECY: It says it has to be designed 24 and manufactured for welding.
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MR. ROMANO: So as to meet the AWS Code; o
right?
3 MR. CLOHECY: Le't's take a look at the 4
code.
5 MR. ROMANO: Well, we're not going to go 6
through all that whole code. I'm just going to ask 7
you that question.
8 I want to rephrase the question. I don't 9
want to take time co go look though that whole thing.
10 MR. WETTE3HAN: Fine.
11 Listen to the' question. He does not want 12 you to look at the code.
I ~
MR. ROMANO:
Well, it's not necessary for-14 this case.,
15 MR. WETTERHAN: Are you directing them not 16 to lock through the c9de and just , to forget that II question?
1 MR. ROMANO: Not at til. If I feel it's 19 necessary as we go on, I will then perhaps look it 20 up.
21 Now, AWS Dl-1-72 under Part 3.1.2 does 22 state that the equipment must be designed and 23 manufactured so as to enable qualified welders to 24 meet the AWS Code?
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I MR. BOYER: I would like to read that o
paragraph.
3 All right. Go ahead.
MR. ROMANO:
4 MR. BOYER: It says, "All items of 5 equipment for welding and oxygen cutting shall be 6 so designed and manufactured and be in such condition 7 as to enable qualified welders, welding operators and 8 tackers to follow the procedures and attain the 9 results prescribed elsewhere in this code."
10 MR. ROMANO: Well, that's exactly what I 11 said. It has to be designed and manufactured so to 12 enable qualified welders to meet AWS Code for 13 welding.
14 Now, then I ask again: Isn't it true that 15 proper equipment was to be available, that equipment 16 that's been just described in that code, was to be 17 available to enable qualified welders to meet AWS 18 Code?
19 MR. CLOHECY: That is a requirement of the 20 code.
21 MR. ROMANO: But I ask you: Was it to be 22 available by the applicant, contractor, whatever, to 23 enable the welders to meet AWS Code?
24 MR. CLOHECY. Yes, it --
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l MR. ROMANO:
'It was to be available. l
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1 Had you finished your {
I MR. WETTERHAN: d" 2 ,
answer?
3 b .
Yes.
MR. CLOHECY: j 4 Thank you. ,
MR. WETTERHAN:
5 In other words, the use of !-
i MR. ROMANO: {:
6 h pplicant did ?
the broomstick may , indicate that t e a - Is
~e, -
7 to use.
not have proper equipment for a welder 8
that possible?
9 I'm sorry. I don't under-MR. CLOHECY:
'10 ._',.
stand your question.
11 ,,.,',.
Well, in view of the fact MR. ROMANO:
- - - /12 d;su ; x ;. ,g; . f or an extension, ,?.-
" 'm that the welder used;the broomstick 13 .
r was {
.._, is it possible that- the applicant or whoeve that the 14 in charge there or even the inspectors, l
15 1
proper equipment was not available?
16 No, I don' t believe it was.
MR. CLOHECY:
17 r. A ,
The equipment used for welding was prope 18 d as a i broomstick which was not approved was use 19 i
construction aid, But you have -
20 I know that. !
MR. ROMANO:
21 ,
ld use an do you/know any reason why a welder wou re present? i 22 !
improper extension if proper extensions we '
23 No, I don't. V
- MR. CLOHECY:
24 I .- - _ . . ,
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MR. ROMANO: Would you say that quality 2 assurance includes the use of specified equipment?
3 MR. CLOHECY: Yes.
4 MR. ROMANO: Therefore, isn't it true that 5 the use of. equipment which is not specified, which 6 was not the proper equipment, is contrary to good 7 practice, is contrary to good practice?
8 MR. BOYER: Well, if it -- if it is-9 specifically, stated that a piece of equipment is 10 not to be used,.then if that piece of equipment were
'," ~ 11
' to be used, 'it' would be a violation and would not 12 be~ good p'ractice.-
~ '
13~ . .1 MR.' ' ROMANO: Okay. Would not be good 14 practice.
15 MR..BOYER: Or acceptable.
16 MR. ROMANO: All right. Well, then I ask:
17 Do you know whether the applicant had proper equip-18 ment to meet that code that we are discussing here?
19 MR. CLOHECY: The equipment used was 20 designed and manufactured for welding. The 21 electrode holder extension used as an aid was not 22 approved by engineering.
l 23 MR. ROMANO: Well, did applicant have the pr >pe 1
24 equipmed; tnere to in this case rather than have a
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welder use a broomstick?
2 MR. CLOHECY: The welding equipment.was 3 proper.
1 4 '
MR. ROMANO: I'm not talking about welding 1
5 equipment. I'm talking specifically about -- did 6 the applicant have proper equipment --
7 MR. CLOHECY: Listen to the question, 8 please.
9 MR. ROMANO: -- proper extension to meet 10 this code so that the welder did not have to just 11 use a broomstick? >
"'i_.
12 (Witnesses conferring off the. record.)
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3 MR. ROMANO: -Well, Mr..Boyer, you can
[(. [ 14 , , answer.the question... . -.
s 15 Mht. WETTERHAN: No. They're discussing 16 it.
17 MR. ROMANO: Then call it off.there then.
18 MR. WETTERHAN: It's entirely proper.
19 MR. ROMANO: Are you taking the witnesses 20 conferring?
21 THE COURT REPORTER: No.
, 22 (Witnesses conferring off the record.)
23 MR. CLOHECY: No, there were no approved 24 extensions available. j AREA.\\'IDE Fl:DERAL REPORTING. INC.
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1 MR. ROMANO: Wouldn't you say that this is
! l 2 a violation of the code when the code specifically 3 states that there should be equipment properly l 4 designed and manufactured in order to enable 5 qualified welders to meet the code, AWS Code?
6 MR. CLOHECY: No, I wouldn't say.that.
7 MR. ROMANO: Are you saying that in spite 8 of the fact that. specific wordage is given as to the 9 manner, the type of. extension that should be had 10 when not present does not violate the code.?
11 ,
MR.'CLOHECY: The' code does not address 12 .. extensions..
v:
13 MR. ROMANO: But here we have just been 14 talking about that equipment must be -- extensions 15 must be properly designed and manufactured as the 16 NRC inspector specifically called attention to.
17 And now you're saying it's not required.
18 MR. CLOHECY: The code does not say that 19 extensions must be designed and manufactured.
20 MR. ROMANO: In view of the fact then that 21 the applicant did not have the proper extensions, 22 are you saying that it's okay for a welder then to 23 Pi ck up any stick or anything like that and use it 24 in the absence of.the applicant's not having the fl - - -m .__
s
- 49 1 proper equipment?
2 MR. CLOHECY: No, I'm not saying that.
3 MR. ROMANO: Well, then you said that he 4 could use this extension or you say that there's no 5 such specification for an extension.
6 You did say that, didn' t youI, that there's 7 no such specification?
8 MR. CLOHECY: No, I didn't say.that.
9 MR. ROMANO: All right. I'm glad we have 10 a tape recorder this morning.
11 MR. WETTERHAN: And a court reporter.
12 MR. ROMANO: And a court reporter, right.
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'14 the applicant did not have extensions designed and 15 manufactured so that a welder in this case where 16 this was needed would be able to meet the 17 qualifications for welding such things; isn' t that 18 so?
19 MR. CLOHECY: That's correct.
j 20 MR. BOYER: You say.you had -- we did not 21 have -- he said that we did not have on site other l 22 approved extensions, other extensions which had 23 been approved. We did not have a supply.of 24 extensions. My interpretation of.your question is
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s 50 1 related to that aspect, and that was the answer that
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2 he gave you.
I 3 MR. ROMANO: Well, isn't it almost an 4 indictment of the applicant to say that they don't l 5 have on the site equipment that is absolutely 6 necessary to do work properly.and then we find that 1
7 hecause of improper equipment, welding was done that 8 did not meet the standards of the AWS Code?
9 MR. WETTERHAN: Objection. That is so 10 argumentative that it's not worthy,of a response.
11 I will not.have these witnesses talking about 12 indictments or anything. Just ask questions as to 13 the fact's. ' You'can make any. inference you want 14 before the. Board or in your published findings.
15 MR. ROMANO: I'll ask the question: Why 16 didn't the applicant have approved extensions on the 17 site?
18 MR. BOYER: If they had been considered 1
19 to be required, they would have been made available.
20 MR. ROMANO: Well, isn't it so that this 21 code that we've discussed here states that they had 22 to be used in these kinds of welding?
23 MR. BOYER: Can you point that out to me?
24 MR. ROMANO: Yes. Where the inspector AREA WIDE FLDERAL REPORTING. INC.
51 l
1 states, again on Page 5 --
2 MR. BOYER: That's not reading from the 3 code.
4 MR. ROMANO: Well, he refers to the code.
5 And he refers to -- and the inspector states that 6 the use of electrode holder extensions -- the 7 inspector,. .the NRC inspector, considered that an 8 electrode holder attached to a stick did not meet 9 the requirements of the code we're talking about.
10 MR. BOYER: That's what that sentence says,
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11 yes, I; agree to that.
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12 " IMR. ROMANO: Well, it isn't -- it's not
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13 just 4that,ithat the sentence says that.- I t's .
14 detailing what the NRC. inspector stated.
15 Now,.you do know, Mr. Clohecy, that the 16 weld that was performed using the extension and 17 esing that welder did not comply with AWS Code 1
18 welding; do you know that?
19 MR. CLOHECY: Yes.
20 MR. ROMANO: Now, the applicant says that 21 if they need any.such equipment needed for use at 22 Limerick -- we're talking about the extensions --
23 it would be procured from a vendor of such equipment.
I 24 Didn't the applicant know the requirement AREA. WIDE Fl:DERAL REPORTING. INC. 1 l
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of the code relative did or did not -- did or did 2 not the applicant know that proper extensions were 3 required as per AWS Dl-1-72 under Part 3.1.2?
4 (Witnesses conferring off.the record.)
5 MR. BOYER: Well, the applicant was 6 familiar with that section of the code. The welder 7 involved in this particular weld felt that the 8 extension that he was using was appropriate.
9 As it turned out, there were some 10 deficiencies in the weld. So he had not made a 11 proper judgment. The deficiencies have not -- were s .
i
, 12 not analyzed to determine the total effect of the
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13 deficiencies on'the strength of the weld; that is, j
r- 14 the -- it was decided to re-do the weld and have it a:
15 fully comply with the code requirements.
16 MR. ROMANO: You say the welder took it 17 upon himself to decide to use the non-qualifying 18 extension?
19 MR. BOYER: Yes. Well, not a non-qualifyin J.
20 He felt it qualified for the work that he was to 21 Perform.
22 MR. ROMANO: Is it general that welders, 23 especially in a nuclear facility, can make the 24 decision as to whether they can modify a specificatica?
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1 (Witnesses conferring of f the record. )
MR. BOYER: No. That should be discussed 3
with the foreman if he has any question about the 4
adequacy of it.
5 In other words, this welder MR. ROMANO:
6 did not conduct himself properly in this case?
7 Well, he did not use -- in MR. BOYER:
8 retrospect'he did not use the best judgment.
0 And isn't it possible that he MR. ROMANO:
10 may have done this because there was improper or 11 not totally attentive inspection and supervision?
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MR. BOYER: No.
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- MR.~ ROMANO: In other words,'this -- you
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14 - feel.-- do'you. feel that this welder didithis'on 15 more bian one occasion but supervision had not seen him?
3 17 MR. BOYER: I can't answer that.
18 MR. ROMANO: Can't answer it.
19 You do know that this fault -- faulty type 20 of work was brought to the attention of the 21 applicant by the NRC inspector; is that correct?
22 MR. BOYER: Yes.
23 MR. ROMAMO: Yes.
24 Do you know whether it's possible that
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- s . s 54 1 this same welder could have, as he had, taken 2 liberty to modify procedures, could have on many 3 other occasions taken liberty and did improper 4 welding?
5 MR. BOYER: Your statement was that it 6 was an improper procedure. In the welder's view 7 it was appropriate and proper. There was no 8 specific procedure which said that he could not use 9 that type of access to the weld.
10 MR. ROMANO: Well, I thought we went 11 through this, did we not, that the extension had to 12 be designed and manufactured so as to enable him to e
' ^
_ 1 '13 do the weld properly?,
14 And then, you'know -- and then --
15 MR..BOYER: In his opinion, he was using 16 a suitable extension.
17 MR. ROMANO: We're back again to whether 18 an individual welder can determine through his own ;
l 19 OP i nion rather than specify procedure what he will f 20 do.
And I think again -- I say says something 21 about quality assurance -- is the big key situation 22 that we're discussing.
23 MR. BOYER: That's right. It was detected --
24
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l 55 1 MR. WETTERHAN: There's no -- there's no 2 question pending.
3 MR. ROMANO: When a welder on his own is 4 permitted to make a decision that's contrary to specified procedure, don't you feel that that is not
~
5 6 proper?
7 MR. BOYER: If.it's a specified procedure, 8 it would be improper.
9 MR. CLOHECY: If the welder is violating 10 a procedure, that's improper.
11 MR. ROMANO: The use of a broomstick 12 instead of a qualified extension is improper, isn't -
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14 MR. CLOHECY: The use of an unapproved 15 extension is improper.
16 MR. ROMANO: Right.
17 Okay.- Now I'm' going to Interrogatory No.
18 8.
19 MR. WETTERHAN: Okay. 8? You're there.
20 (Discussion off.the record.) ,
1 21 (A five-minute recess was taken at 22 approximately 10:40 a.m.)
23 MR. ROMANO: Now, we are on Interrogatory 24 No. 9 of the first set. And I aded the question:
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1 Under 76-06-01 has the name of the person who is 2 represented as the licensee who disagreed, the 3 inspector requested for visual inspection of.the l l
4 limited access welds performed at Elevation 253 on
.5 Steel Beam Piece No. 232B7?
6 And the applicant said it did not -- does 7 not agree with my. characterization of the inspection 8 report identified in this interrogatory.
9 Well, on that score I want to ask -- again 10 I was asking the licensee inspector, Mr. Corcoran,
' ~
11 who is not here, and,.therefore, tends to make my 12 questions look like they're hardly. applicable.
.' " 13 So I ask again. Isn't it true -- and I 14 have to ask this of Mr. Corcoran again --
15 MR. WETTERHAN: Clohecy.
16 MR. ROMANO: Clohecy for Mr. Corcoran --
17 well, now, let me see here. I have-to take a 18 second.
19 Well, I'm going to read again from Page 5 20 as to whether or not I did not -- I mischaracterized --
21 whether I mischaracterized that the licensee 22 disagreed.
23 Now, the NRC inspector states that in 24 l Part 3.1.2 it is required that equipment be designed
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a nd 3 man to ufa at ctur ed 4 tain so it resl as f co u ts to e 5 ntin u pr k
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a slu t disagr when fic eme nts e the of ed, " a next ation.
e his eld disagr nd se nte that the in spe nce was eeme the po done nt ctor sta tes, s ibili s wi that requ to tho ut they e do pr no sted ,
that ty .
that oper e w look
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MR. BOYER: I can just repeat my.former 2
answer.
3 MR. ROMANO: I've asked that question, 4
though. How do you say I mischaraterized it?
5 MR. WETTERHAN: I think he's explained --
MR. ROMANO: No. I'm asking Mr. Boyer.
7 MR. WETTERHAN: Can you give a fdrther 0
answer, or do you rest on that answer?
9 MR. BOYER: As stated in the last sentence 10 of the interrogatory, our interpretation of the II NRC report as you quote it on Page 5 --
19~
MR. ROMANO: May I interrupt --
13 MR. WETTERHAN: No, you may not.
14 MR. ROMANO: I don't know where he's r
15 reading, and I'd like to know.
MR. WETTERHAN: Could you just continue.
17 MR. ROMANO: Well, I will repeat. I said I
that the last sentence in the response to 19 Interrogatory No. 9 which says, "The licensee's 20 representative, Mr. Corcoran, disagreed with the 21 inspector's statements on the need for certain
- l 22 qualification tests"; and that is an cxplanation 23 of the statement "The licensee disagreed " comma.
24 MR. ROMANO: But the statements there of
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1 1 the NRC inspector calling attention to the non-2 qualification situations with the licensee disagreeir3, 3 he disagreed to the inspector's statement on a need 4 for certain qualifications; but he also disagreed 5 with the fact that the welder wasn't qualified --
6 you know, the welder himself.wasn't qualified. So 7 that that doesn't really. answer the whole situation 8 as far as I can see it.
9 MR. BOYER: I thought your question relatec 10 to the inspection of the -- what other welds which 11 had been identified.
12 MR. ROMANO: Well --
13 MR. BOYER: That's what Interrogatory,9 14 is referring to, and I thought you were discussing 15 Interrogatory No. 9.
16 MR. ROMANO: That's right.
17 And the inspection of the weld is 18 involved there because the NRC inspector had already 19 said that they had used improper procedure and there 20 was a dispute at that point.
21 And as a result of.the dispute, the NRC 22 inspector said, "Okay. Let's inspect that thing 23 then."
24 That infers that PE, the licensee, was
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not agreeing to a reinspecI would just come back MR. BOYER: No. 9 is 2 answer to Interrogatory I believ(
say that the 3 will stand by that answer.
correct, and we 4
ng.
your interpretation is Well, wro the statement of the 5
MR. ROMANO:
6 - what do yo u feel the licensee licensee,.the t?
7 disagreed with at that poin covered in the last 8 It's MR. BOYER: No. 9 9 answer to Interrogatory sentence of the Why doesn't the licensee 10 MR. ROMANO:
ability
- with whether 11 with the Why does agree or disagree weld?
12 welder.was qualified to r?
or not the t discussed in your answe 13 te 14 that - why .is that no The ' question did not rela {
MR. BOYER:
15 to that. Well, the question does '
16 MR. ROMANO:
17 e to be used on limited relate to improper procedur been 18 And that weld had already access welds.
19 inspected, had it not?
20 I can't answer that.
MR. CLOIIECY: record.)
21 conferring off the (Witnesses it has been inspected.
Yes, 22 MR. BOYER:
23 And it was found to be MR. ROMANO:
24 NG, INC.
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62 1
non-conforming; isn't that so?
~
(Witnesses conferring off the record.)
MR. BOYER: You may respond to that.
4 MR. CLOHECY: Okay.. Would you repeat the 5
question, please?
6 MR. ROMANO: That weld --
7 MR..BOYER: Which weld?
8 MR. ROMANO: The weld that -- 253, 9 Columns F, H at Wall 23.
10 MR.- CLOHECY: Okay.. Thafs two welds.
11 Go ahead.
12 MR. ROMANO: Those welds were found to
.m
. 1 13
be non-conforming; right?
I4 MR. CLOHECY: That's correct.
15 And that non-conformsnce, MR. ROMANO:
16 both in that weld and in the procedures used by 17 the inspector, the licensee had already.known that I8 that procedure using improper extensions had been 19 used before, did he not? We already discussed that?
20 MR. CLOHECY: No, that's not correct.
21 MR. ROMANO: Well, doesn't it state there 22 that he later confirmed that the approach had been 23 used before up at the end of the first paragraph?
24 MR. CLOHECY: That's not referring to the l
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63 1 procedure. That's referring to the --
2 MR. ROMANO: No. I'm referring to the 3 licensee.
4 MR. WETTERHAN: Let him answer, and then 5 you can change your question.
6 MR. CLORECY: That's not referring to the 7 procedure. That.'s. referring to the approach of 8 using an electrode holder extension.
9 MR. ROMANO: I.was discussing the 10 licensee inspector and not the procedure using 11 extensions.
I 12 MR. BOYER: Can'you point where you are 13 referring to or can you : read? None of that has to 14 do with Interrogatory No. 9, as far as I can see.
15 MR. ROMANO: Well, it has to do with the 16 weld involved-there and whether or not the licensee 17 disagree with another inspection. We are hung up 18 on the same thing we were hung up on before about 19 mischaracterization.
20 Again I have to say that I would -- my 21 questions were to be for Mr. Corcoran who I feel 22 might have been able to more precibely answer. Pnd i
23 I think Mr. Clohecy is trying to do a dood job, but 24 he isn't the one that was specifically involved here.
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And so we have it as an incomplete picture of the 2 situation, as I see it.
3 MR. WETTERIIAN: I'd like to make a 4 statement. Mr. Clohecy's name is written under 5 Answer to Interrogatory 9, which is in the set 6 designated Discovery 15. And as far as I have heard, 7 he has been able to answer any questions that you 8 have had of him.
9 MR. ROMANO: Well, so is Mr. Corcoran's 10 name under there, and he was the inspector. And I 11 think in order that I could fully question and 12 receive answers -- as I say again, the fact that the
"G. 13 ? inspector involved s.is not here adversely affects 14 what I try to do here this morning.
15 MR. WETTERHAN: I suggest you take that up 16 with the Licensing Board.
17 MR. ROMANO: Would you say, Mr. Clohecy, 18 that what did -- how do you interpret that sentence 19 starting with "The licensee," second paragraph, 20 "The licensee disagreed"?
21 Would you read the whole sentence and tell 22 me how you interpret that?
23 MR. CLO!!ECY : Well, I would have to say 24 that my interpretation is as stated in our response AREA WIDl! 171 DERAL REPORTING. INC.
65 1 to Interrogatory No. 9.
2 MR. ROMANO: Well, I'm going away from 3 that response now and asking you another question.
4 Would you read that question -- read that 5 statement and then tell me what your interpretation 6 of that...
7 MR. CLOHECY: Okay. "The licensee 8 disagreed, and the inspector requested that the 9 provisions" -- "that provisions be made to permit 10 his visual inspection of the limited access welds 11 performed at Elevation 253 on Steel Beam Piece No.
12 232B7."
13 MR. ROMANO: How do you interpret that?
14 MR. CLOHECY: Well, my interpretation is 15 as given in the Answer to Interrogatory No. 9.
16 And I would have to say that the -- you 17 have to read the sentence before that and the sentenc 3 18 after that in order to understand that sentence 19 fully.
20 The disagreement was with the need to 21 qualify the welder and procedure using the 22 electrode holder extension. There was no disagree-l 23 ment regarding the need to inspect.
l 24 MR. ROMANO: Well, wouldn't you think l
l l
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. 1 66 1 that there had to be a discussion on the quality 2 of that weld if the license -- the inspector l
3 immediately following the disagreement of the 4 licensee called to reinspect that weld? That's 5 immediately what he did after the disagreement, that 6 the NRC inspector immediately requested that we go 7 and look at that weld.
8 Doesn't that infer that there was 9 discussion on the possibility of whether that weld 10 was good or not?
11 MR. CLOHECY: No, it doesn't infer that.
12 MR. ROMANO: But why would you feel the 13 inspector immediately called -- requested that 14 Provisions be made to permit his visual inspection 15 of that weld?
16 MR. CLOHECY: I think because he wanted to 17 inspect it.
18 MR. ROMANO: But it had already been 19 inspected once, hadn't it?
20 MR. CLOllECY: Yes.
21 MR. ROMANO: Why would he want to 22 reinspect it?
23 MR. GUTIERREZ: Point of clarification. l 24 Are you asking these witnesses now questions as to
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.' 67 I the motivations of NRC inspectors?
2 MR. ROMANO: Well, I'm trying to -- I 3 don't know what you exactly mean by " motivation."
4 But I'm trying to clarify -- l 5 MR. GUTIERREZ: It's.my understanding 6 you're asking the utility witnesses to explain why 7 NRC inspectors took certain actions.
8 MR. ROMANO: Yes. And I'm doing that 9 because the NRC inspector is not here.
10 And again I say that that jeopardizes my 11 position, because I have to take time trying to get 12 around with many questions when I could ask it
^[ 13 directly and could possibly have the support of the
, 14 NRC inspector during this questioning.'
15 MR. WETTERIIAN: Why --
16 MR. GUTIERREZ: I would only stand on my 17 former explanation as to why there are no NRC 18 inspectors and only add that the report you're 19 reading from speaks for itself.
20 MR. WETTERIIAN: I would agree that my 21 interpretation is the same as Mr. Gutierrez'.
22 I have allowed this to continue because it 23 is your deposition, and I don' t personally think it 24 has any utility whatsoever. But I've allowed it to
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2 MR. ROMANO: You mean -- you mean to tell 3 me you're going to say I wouldn't be able to proceed 4 unless you agreed to it? Is that what you're saying?
5 MR. WETTERHAN: I am saying that if at all 6 useful, this is marginally useful.
7 _You're asking an applicant's witness to 8 look at an inspection report that was written by the 9 NRC and ask what was their motivation behind certain 10 actions. They can hypothesize. They can guess.
11 They can give you their feeling. That's what these 12 witnesses are doing.
' 13 My only answer to you is I don't see what 14 usefulness it plays, but it is your deposition and 15 I have not objected.
16 MR. ROMANO: Okay.
17 Do you know, Mr. Clohecy, whether or not 18 the licensee inspector was present when Bechtel's 19 quality control inspector checked off this weld as 20 being suitable?
21 MR. CLOHECY: I believe he was not.
23 MR. ROMANO: You don't know for sure, do 23 you?
21 MR. CLOHECY: There's no record that he
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2 MR. ROMANO: There's no record that he 3 wasn't, either, is there?
4 (Witnesses conferring df f the record. )
5 MR. CLOHECY: It would be documented if 6 he had been.
7 MR. ROMANO: In that specific situation 8 where there was this question,.why.wasn't --
9 MR. BOYER: Clarification. Question.
10 What question?
. 11 MR. ROMANO: About that whole situation,
.s.
12 the broomstick affair and the type of_ weld that was 7 13 made.' . [. ,
14 Why wasn't he there?
I 15 MR. CLOHECY: Why wasn't...
16 MR. BOYER: Mr. Romano, your question is 17 not clear. Why.wasn't he there at what particular 18 time? Are you referring to --
19 MR. ROMANO: Well, at the time that weld 20 was made and --
21 MR. BOYER: Which weld?
22 MR. ROMANO: -- reported as okay, the one 23 at 23, Column F and H at Wall 23.
24 MR. BOYER: At that time that that weld
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. 7) 1 was made there was no question raised about the 2 method of the adequacy or anything else relating to It was inspected by 3 that weld. The weld was made.
4 Ferretti, and the records were recorded and placed 5 in the file, I presume.
6 MR. ROMANO:
Well, I'm talking about Mr.
7 Corcoran.
MR. BOYER:
There was no question raised 8
9 by Mr. Corcoran or anyone else at that particular
(
10 time. It was on the next occasion that a weld was 11 going to be made that an NRC inspector observing 12 the preparation for the weld raised the question
('
13 about the methodology that was to be employed and 14 then raised a question as to whether others -- other i
15 welds of a similar nature had been made using the 16 same techniques that were going to be employed in 17 the placement of the weld that was being observed.
i I8 MR. ROMANO: But isn't it so that Mr.
19 Corcoran knew about the previous use of an improper
( 20 extension?
No, that's not so. He had 21 MR. CLOHECY:
22 not -- he did not have prior knowledge that that had t 23 been used, lie later confirmed that.
Just t@
MR. BOYER: Later confirmed what?
24 I
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clarify.
2 MR. CLOHECY: He later confirmed that the 3
electrode holder extension approach had been used at 4
Elevation 253 on those particular columns, F and H, 5 Wall 23.
6 MR. BOYER: He confirmed that it had been 7
used, but he did not confirm that he had prior 8 knowledge of it.
9 MR. CLOHECY: That's correct.
10 MR. BOYER: He did not have prior knowledge 11 of it at the time that the weld was conducted or at 12 the time that the --
13
. A ' i s<.
MR. ROMANO: Well, isn't it so by "later 14 confirmed," it means after'the NRC inspector obtained 15 this information from craft rnd supervision 10 personnel?
17 MR. CLOllECY: Yes, he confirmed it after 18 the NRC talked to craft and supervision personnel.
19 MR. ROMANO: But he had known it before,'he 20 had known it before it was brought up to the -- by 21 the NRC inspector, as it's stated there.
22 MR. CLOHECY: It does that state that there 23 MR. ROMANO: Well, it was not known by --
24 it was not brought out that impropor welding had been
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C inspector bro gh the NR until using extensions donc that so? correct. -
1 isn' t That's ey found it out; MR. CLOHECY: coran 2
So that after thit out, Nr. C 3 MR. ROMANO: So he did inspector broughtdone before.
4 been after the NRC this had thrs 5
admitted that it before. confirmed that -
about He 6 know No. s nto r exten ions context 7
MR. CLOHECY: the electrode whole holde approach using not giving i
8 same think you' re 9 actually I the crafts l
10 inspector talked tons to there, abour,their pla 11 When the NRC at sonne l, that was ot used them 12 nd other'per They had n a
13 extensions.
use these his questioning, in result of firmed 14 that elevat o . as a d QC personnel con And then wcld 15 c the similar i contra tor QA usedan on ll 23 16 the licensco had boon mns F and H, Wa the-that approach Co3u 17 that that say that Elevation 253, doesn' t i
18 joints at but this improper MR. ROMANO:
19 v us inc ident where they k 20 of a pre io kno w used? doost' t say that was It 21 cxtension 22 MR. CLOHECY:it occurr 23 it at the tilne that RIP 02 TING. INC 21 IT DI.R AL arf: A. WIDE w.-
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1 1 MR. ROMANO: Well, that's your 2 interpretation. I think I can read as well as you 1
3 can; and it seems to me that Mr. Corcoran did know 4 about this before, as he states that he -- was used 5 at another place.
6 So to me it does indicate that he did know 7 about this before, and that I feel that's improper --
8 that adds to the fact that the QC work was less than 9 what -- less than proper.
10 Well, I'm going to the third set. ,
11 'MR. WETTERHAN: What is it -- 17?
12
^
Nor the record, the third set of
. .e ,k ..
13 . interrogatories is also known as Discovery',17; and 14 it was dated December 19, 1983.
15 MR. ROMANO: I just want to go back to 16 No. 6 of the first set to be sure that I have this 17 in the record, that G. P. Auclair was stated to be 18 a qualified welder.
19 MR. BOYER: Yes, we -- I believe that it's 20 in this deposition already.
21 MR. ROMANO: Yes.
22 And that -- was he -- was he qualified in 23 every respect or in every technique which would be 23 involved in welding he performed?
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1 MR. BOYER: Yes.
~
2 MR. CLOHECY: Yes.
3 MR. ROMANO: You stated yes.
4 And that the NRC inspector's questioning 5 him about whether or not he was in fact qualified 6 for limited access welding was the inspector didn't 7 know his qualifications; is that so?
8 MR. CLOHECY: I don't understand your 9 question.
10 MR. ROMANO: Well, the NRC inspector i 11 questioned whether or not the welder was qualified
~~
12 to do the six techniques necessary.for that weld; '
'~
13 and'you_say he was qualified in all techniques.
14 Are you,.therefore, saying that the NRC 15 inspector was wrong in assuming that G. P. Auclair 16 did not have. qualifications to do that kind of 17 welding?
18 MR. BOYER: It's a matter of. interpretation.
19 MR. ROMANO: Well, the NRC inspector did 20 question the qualification of Mr. Auclair,.did he 21 not?
22 MR. BOYER: Yes.
23 MR. ROMANO: As it relates to quality 24 assurance on the-third set, Interrogatory No. 3
. . AREA WIDE FEDERAL REPORTING. INC.
75 I asked to indicate name of welders who more than 2 one time were involved in reported deficient welds 3 and who , nevertheless, were not discharged or 4 separated from work at Limerick.
5 Applicants state that "Not all welders 6 who performed deficient welds identified by.the 7 NRC as welding infractions have been identified."
8 Is that so?
9 MR..CLOHECY: Yes, that is so.
10 MR. ROMANO: They have not all been 11 identified.
And it further states that " Welders
~
12 13 : invblved with unacceptable welding performance or 74 non-adherence to specified welding procedures are 15 retrained. . ThEQ( are not Recessarily , discharged. "
16 Is that also your understanding?
17 MR. CLOHECY: I would agree with our 18 response there in Interrogatory No. 3.
I 19 MR. ROMANO: Well, I ask you, you know, 1 l
20 specifically en that statement.
21 MR. CLOHECY: Yes. When it is determined 22 that c. welder is experiencing difficulty, he is j l
23 retrained and/or requalified as appropriate and not 24 necessarily discharged or separated. l
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76 1 MR. ROMANO: You are saying that welders 2 who repeatedly or more than once performed bad l 3 welding are not necessarily discharged?
4 MR. CLOHECY: That's correct.
5 MR. BOYER: Wait a minute. Pardon me.
6 MR. ROMANO: Do you have --
7 MR. BOYER: Pardon me.
8 (Witnesses conferring off the record.)
9 MR. CLOHECY: I would like to clarify. We 10 have not identified any. welders who were involved 11 more than once in a safety-related welding
[
~
12 infraction reported in the NRC report; but were one
- ~ ~
13 involved more than once, he would not necessarily 14 be discharged.
15 MR..BOYER: But his case would certainly 16 be reviewed.
17 (Witnesses conferring off the record.)
18 MR. ROMANO: Well, how is it that you can 19 say that welders identified by NRC as having 20 performed improper welding, that the applicant, 21 however, doesn't -- hasn't identified them?
1 22 MR. BOYER: Wait a minute. I don ' t think - -
23 that's not clear.
24 MR. CLOHECY: Would you repeat that?
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77 1
MR. ROMANO: "Not all welders who performec 2
deficient welds identified by the NRC as welding 3
infractions have been identified." That means by 4 the applicant.
5 How is it that the NRC identified these 6 welders, these infractions and the applicant states 7 all those welders have not been identified?
~
8 MR. BOYER: Well, you see, in the sense 9 before it refers to welders -- it refers to AWS 10 Code which does not require traceability to the 11 welder's identity:to the particular weld.
12 So' in certain of the balance of plant
..m 13 non-safety-related systems,. .there are, according to 14 the code requirements, that the welder or a 15 particular weld does not have to be clearly 16 identified.
17 MR. ROMANO: Are'you saying that even 18 though the NRC identifies those welders, that the l
t 19 applicant does not clearly identify those welders?
20 MR. CLOHECY: Okay. The NRC did not say 1
21 that they identified those welders.
22 I'd like to clarify that the AWS Code does 23 not require traceability --
24 MR. WETTERHAN: Let him finish.
l
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M_ :;?.c .- .s _ - . a c.- - . : . - -. . . . . . - - . . - - - - .. - - --
78 1 MR. CLOHECY: -- of the welder's identity 2 to the particular weld; but it does require that the 3 inspector verify the qualification of. welders and 4 permit welding only by qualified welders.
5 MR. ROMANO: Well, I know. That repeats 6 a question that was answered before.
(
7 But it does say here that "Not all 8 welders who performed deficient welds identified by 4
~
9 NRC have been identified."
10 Can you say.that that can happen anywhere 11 else, where.NRC comes up with knowing who welders
(. . 12 are and where the infraction was, that records of
~
e.
13 the applicant do not parallel such disclosure?
~-
14 MR. WETTERHAN: What do you mean "anywhere t
15 else?
16 MR. ROMANO: Anywhere else in the plant.
17 MR. CLOHECY: I don't understand the 18 question.
19 MR. ROMANO: I'll skip the question because
( 20 we have repeated answers.
21 And you do agree that, as it states here, 22 that " welders involved with unacceptable welding
(
23 Performance or non-adherence to specified welding 24 procedures are retrained. They are not necessarily l -
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79 1
1 discharged."
2 MR. CLOHECY: I agree with our statements 3 in Interrogatory No. 3.
MR. ROMANO: Then the applicant does permit l 4 '
l 5 welders who have more than at one time performed 6 bad welds permit them to continue working, retraining 7 and working; right?
S MR. BOYER: That is not what this says.
9 MR. CLOHECY: We had not identified welders --i l
10 MR. ROMANO: No. I'm talking about the 11 last sentence.
12
'MR. CLOHECY: -- more than once in a weldiny l
[$2 13 infraction ' reported by the NRC.
14 .
MR. ROMANO: I'm not talking about that.
l 15 I said we have passed that one.
l 16 The last one about -- I asked whether it 17 is so -- is it so that welders at Limerick who have ,
1 1
18 been known to or found to be making improper welds 19 are, nevertheless, not necessarily discharged?
20 (Witnesses conferring off the record.)
21 MR. BOYER: This last sentence refers to 22 the continual monitoring that is done of the 23 quality of welds produced by welders by their 24 supervisors. And if it is detected that a welder l
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may be having difficulty in making a satisfactory 1
2 weld by dipenetrate test, something else, 3
intermediate checks found a deficiency which would 4
se taken care of at that time. And if it is 5 considered he is having more than an average amount 6 of difficulty in performing satisfactorily, he would l I
7 be retrained.
8 MR. ROMANO: How do you retrain a welder 9 that has been making poor welds?
10 (Witnesses conferring off the record.)
11 MR. CLOHECY: I can't answer that off the
' ~ '
' 12 top of my head.
- 'li, , .. .
- 4.. . .s
? 9; MR. .BOYER: But retraining is going on.
14 MR. CLOHECY: We do have retraining
- 15 occurring occasionally.
16 MR. ROMANO: On a welder such as that 17 that you know is having trouble making proper welds, 18 do you have a program of a more precise and more 19 inclusive inspection of what that welder does?
20 MR. CLOHECY: The inspection requirements 21 would remain the same. There is a -- all welds get 22 a final inspection, all safety-related welds.
23 MR. BOYER: And you must appreciate that 24 these welders, to be able to work there, have passed AREA WlDE FEDERAL REPORTING. INC.
81 1 stringent qualification tests.
l 2 MR. ROMANO: Well, how stringent is the 3 qualification test when a welder is found subsequent 1r 4 to be performing improper welds repeatedly?
5 MR. BOYER: We have not had improper 6 welds repeatedly.
7 MR. ROMANO: You had -- you do specify 8 that you've had welders who have more than once 9 been found to have unacceptable welding performance.
10 MR. BOYER: Where do you see that?
MR. ROMANO: Because you state here that 11
~ 12
~ *
"Weldars involved with unacceptable welding
' " * " 13 performancd'lh( non-adherence to specified welding [ -
t, .
14 Procedure are retrained. They are not necessarily 15 discharged." -
16 That same interrogatory I said -- I asked 17 to indicate name of welders who more than one time 18 were involved in reported deficient welds and who, l 19 nevertheless, were discharged or separated from l
l 20 work at Limerick.
l I 21 Then you say, applicant states that l
22 "Walders involved with unacceptable welding i
23 Performance or non-adherence to specified welding 1
24 Procedures are retrained. They are not necessarily l
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1 discharged." l 2 Doesn' t that indicate that's more than 3 one welder?
4 (Witnesses conferring off the record.)
( 5 MR. BOYER: It could be more than one i
6 welder. More than one welder certainly has had 7 some problems and been retrained.
8 -MR. ROMANO: Yes.
9 -Can I ask -- I do ask: Do you have any 10 welders there working who were found and records 11 show that'more than once they were performing 12 improper welds?
~
. .:. , 13 MR. BOYER: The first paragraph states that 14 we did not have.
15 MR. ROMANO: That is your answer --
16 (Witnesses conferring off the record.)
17 MR. BOYER: Oh, that relates to NRC 18 inspections.
19 MR. CLOHECY: Yes. Our answer relates to 20 welders involved with safety-related welding 21 infractions reporting to the -- reported by the 22 NRC. l 23 MR. ROMANO: Well, how about other than 24 reported to the NRC? Do you have -- can you state l
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- - 83 1 that there are no welders who more than once have 2
been reported to have made improper welds but still 3 retrain?
MR. CLOHECY: No, I don' t state that.
4 MR. ROMANO: I say do you have records of 5
6 such a thing?
MR. CLOHECY: Of what?
7 (Witnesses conferring off the record.)
8 g MR. CLOHECY: There have been some welders 10 who have been found to have some minor defects in..
11 their welds more than once.
MR. ROMANO: On safety-related matters? -
12 13 Safety-related welding, that is? -
MR.-CLOHECY: Yes.
14 MR. ROMANO: And they are, nevertheless, 15 retrained to continue welding; is that.so?
16 MR. CLOHECY: Their performance is 17 evaluated on an individual case-by-case basis; and 18 it is determined what action should be taken, whether 39 retraining, requalification or other appropriate 20 a tion.
21 MR. ROMANO: What do you mean by "other 22 appropriate action"?
23 MR. CLOHECY: That would be determined on 24
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a case-by-case basis.
2 MR. ROMANO: Do you have a record of the 3 number of welders which have been discharged from 4 Limerick as a result of poor welding?
(
5 MR. CLOHECY: Yes. We answered that 6 question in one of the earlier interrogatories.
1 7 MR. ROMANO: Where is that? _
8 (Discussion off the record.)
9 MR. CLOHECY: Yes. As we stated in 10 Interrogatory No. 4 to that same set of questions, 11 we'have identified one welder who was -- no, that 's - -
12 I'm sorry. That's not the answer I was referring to.'
13 There's another interrogatory.
14 MR. ROMANO: Could I hold this up a i
15 minute?
16 MR. WETTERHAN: Yes. '
17 (Discussion off the record.)
18 MR. CLOHECY: Yes. In Discovery 24, also 19 known as AWPP's twelfth set of interrogatories, l 20 Interrogatory 7K we have stated that "Bechtel Power 21 Corporation has separated, discharged or transferred 22 welders from work at Limerick for reasons such as 23 those listed above."
l l 24 MR. ROMANO: Would you read that again,
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85 1 please? I was thinking about something else.
2 MR. CLOHECY: Yes. "Bechtel Power 3 Corporation has separated, discharged or transferred 4
welders from work at Limerick for reasons such as 5 those listed above," which are the reasons you 6 listed in your interrogatory.
7 MR. ROMANO: How many were separated during 8 the working period?
9 MR. CLOHECY: I don't have that number 10 right now.-
11 MR. ROMANO:
You do have records of.such 12 a thing?
. a. d;eL A G i - . J: .aG -
" 13 MR."CLOHECY:' We have stated'that there are some welde'rs who were separated, discharged or
~
14 15 transferred for those reasons which you' listed.
16 MR. ROMANO: . Do you have records showing 17 all -- how many such welders and what the situation 18 was for their removal?
19 MR. CLOHECY: We have records on that.
20 MR. ROMANO: Okay. I'll go to the tenth 21 set of interrogatories.
22 MR. WETTERHAN: A particular one, Mr.
I
- 23 Romano?
24 MR. ROMANO: What's that?
i i
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86 1 MR. WETTERHAN: A particular interrogatory?
2 MR. ROMANO: It's tenth, tenth set under 3 2A.
4 MR. WETTERHAN: Okay. Thank you.
5 MR. ROMANO: What is the procedure, Mr.
6 Boyer, that you used to indicate that the number of 7 welds whigh now were involved with the 76-06-01
. . . . , 8 . inspector, Mr. Ferretti, went up from your original PCE ~ ^ 9 estimation of 350, roughly 350 to 709 on your second 10 approximation?
fi' 11 ~MR..BOYER: To answer that, I think you 12 have to have an appreciation of the filing system
.~
, $~ " ^
13 and how you determine the number of_ welds that a 14 welder -- that a quality. assurance inspector or 15 quality. control inspector has been involved with.
16 The weld records are not filed under each 17 inspector's names. They're filed by. groups of 18 welding records and the weld sheets, the drawings on 19 which the welds are indicated. And there is an 20 inspection sheet attached to those drawings.
21 At the time the initial question arose, 22 an inspection was made of.the files; and all of the 23 drawings were.gone over and examined to determine 24 welds which had Mr. Ferretti's initials on it and AREA WIDE FEDERAL REPORTING. INC.
l .
. 87 l I the number came up to be 350.
2 At -- the group who did that evaluation l
l 3 thought that they .had encompassed therein thereby 4 all of the welds that Mr. Ferretti was responsible 5
for.
6 It was -- right, they were the accessible 7 welds, right. _ .
8 -It was subsequently determined that'there 9 were a number of weld sheets, weld record sheets and 10 drawings that had other welds that had not yet been
~
11 inspected or were in the process' of .being inspected 12 'that were out on field engineers' desks, and they
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were sort-of. working.in an act of review. This
, .(.; ,
14 then brought the number up to the higher level.
15 MR. ROMANO: Yes.
16 Well, then you said, did you not, that you 17 don't customarily.have the name of-the inspector on 18 these --
19 MR. BOYER: No. We have the name of the 20 inspector.
21 I said we do not have a file by inspectors' 22 names for every weld that he inspected. We do not 23 file them under the inspectors' names. That would 24 mean duplicate files and just a massive increase in
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1 the amount of paperwork.
2 A drawing can have a number of welds on 3 it. What? --10 to -- 5 to 20?
4 MR. CLOHECY: Yes, that many or more.
5 MR. BOYER: It can have 5 to 20 welds on 6 it. And a number of inspectors could be involved 7 with the.various welds on the drawing.
8 There is an inspection sheet attached to 9 that drawing which has a place for each of the welds 10 and for the inspector to put his initials.
11 MR. ROMANO: Well, then that was the 12 second time. .
E':l. 13 'You'would think by.the second time that 14 you weren't sure you 'would at that point know what 15 the number of welds should be, shouldn't you, after 16 the second approach to it?
17 MR. WETTERHAN: Which second approach?
18 MR. ROMANO: Well, the recount.
19 MR. BOYER: The second approach included 20 the drawings that were out in the active working 21 arena, so to speak, on field engineers' desks and 22 whatnot --
23 (Witnesses conferring off the record.)
24 MR. ROMANO: We are talking about 1976.
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89 l And you -- these questions -- these answers came. up 2
recently. And -- l 3
MR. WETTERHAN: Sir, are you asking the 4
difference between 709 and 1235? Is that your 5
question?
6
- MR. ROMANO: No, not yet.
7 Why wouldn't these records in 1976 summed 8
up or otherwise, .especially when it was determined 9
in 1976 that this incident occurred, why wouldn't 10 it have immediately.been looked into so that you e ,
11 would absolutely.know where all these welds that
- 7. . 12 could have been improperly done, why.wasn't it looked i:.Jilb& - .
.'... a Q:w:R h?~ ~
13
- :'f0?" -
into duringitb$t 1976. period instead of having now
~
s 14 to go look}hgIthrough what you say.they're around
~
15 the plant's'omewhere?
16 MR..BOYER: I was referring to the 1976-1977 17 time frame.
18 MR. ROMANO: But then you should have had 19 the number of welds at the time you reported what 20 you thought was the number originally reported as 21 the number which he was involved with if you're 22 talking about the '76 - '77 time frame.
1 23 (Witnesses conferring off the record.)
24 MR. CLOHECY: The number reported in the
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l 1 response to the NRC's Item 9 compliance was given as i
2 an approximate number which had been reinspected; 3 and those were considered to be at that time all 4 accessible welds that this inspector has been l 5 involved with.
6 MR. ROMANO: Yes.
7 But,we're also concerned with inaccessible
-,- 8 welds, aren't-we?
9 MR. CLOHECY: Yes.
10 MR. ROMANO: And subsequent to the 709
. 11 we come up with 1235 welds.
12 Nowl -was that also known in the '76 - '77
.:- . r, :.---.
.,: . 13 time '. frame? 2. . {fL 14 MR. CLOHECY:' No.
15 MR..BOYER: No.
16 MR. ROMANO: I would say why wasn't it 17 known at that time when it involved not only bad 18 welding, but it involved bad quality assurance and 19 involved false documentation of records?
20 MR. WETTERHAN:. I can't let that go by.
21 I disagree with false characterization of falsi .. .
22 fication -- false characterization of false records.
23 MR. ROMANO: I disagree it is a false 24 characterization because we'll read again on Page 5 i
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\
I at the bottom.
2 "For the weld joints designated No. 3 3
in the record drawing of the in-process checklist, 4
all inspection items had been checked off by.the 5 Bechtel quality control inspector, including ' Final 6 quality verification.' The QC inspection 7 apparently did not comply with the requirements of 8 AWS Dl-1, Section 6 ' Inspection.'"
9 '
In other words, the inspector inspected, 10 supposedly inspected -- he possibly did not inspect
. ~.
11 bu't checked it off as a final quality. verification p- . ... . - .
even though the weld was subsequently found to be'
- T. "' " '
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improper._'Tha_t would' indicateit wasn't -- there.
.s 14 was falsification of . records of -- wouldn' t you '*1 -
15 say that if.an inspector inspected a weld or did'not 16 inspect -- just say that he inspected a weld and 17 checked it off, final quality _ verification; but the 18 weld then was found to be non-conforming, very badly 19 non-conforming, that wouldn't you agree that that's 20 indicating that those welds were okay is a 21 falsification by the inspector?
22 MR. BOYER: Mr. Romano, your statement 23 was rather rambling. It had some statements in it, 24 partial statements in it that I would take objection AREA-WIDE FEDERAL REPORTING, INC. l
1 92 1 to.
t 2 MR. ROMANO: Let me clarify it then.
l 3 MR. BOYER: And the question is not clear.
4 MR. WETTERHAN: He's going to clarify it 5 and withdraw it.
6 MR. ROMANO: Let me clarify..
7 ,
The QC inspector, Bechtel QC inspector 8 checked off. the weld and went beyond that and put it 9 down as having been given final quality verification.
10 then that same weld was reinspected and 11 found to be totally off,_isn't that a misstatement 1 "; 12 of fact'and isn't that falsification of. records?
- r. " ' ~
13 , MR. BOYER: At the time'Mr. Ferretti 14 fnspectedthewelds,hefeltthatthatweldwas--
15 would meet the code requirements.
16 MR. ROMANO: Well, I say.my interpretation 17 of reading this situation that he probably never 18 ever looked at the weld because -- he is qualified 19 as an inspcctor, is he not?
20 MR. BOYER: Yes, sir.
21 MR. ROMANO: Would you think that he would 22 know a good weld from a bad weld?
23 MR. BOYER: Yes.
24 MR. ROMANO: Would you think he would know
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that the welds when reinspected were of.an 2 unacceptable profile, contained excessive undercut !
3 and were incomplete at the upper and lower edge of 4 the angle clip? Would you say.that it would be 5 difficult for a qualified inspector to recognize l
6 that situation?
7 ,MR..BOYER: I-can't really.make a statement 8 relative to that because I did not see the weld.
9 We are going by the words that are there. And I 10 don't think.since the weld was repaired at the time l
' ~
'l 11 in 1976 rather than evaluated,"- none of us can really
- .+ . . . : ,
' 7 " 12 .
determine p'ersonally['from a personal observation ~'
- w. ,. n.5':;#d TN)M 7 or. evalua.525D Oll l' .on ta Ms to the. adequacy of .the., weld. 2:
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4 4' F 14 MR.. ROMANO: I understand that you can't -
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15 personally do it. .
16 But you agree that the inspector was a 17 qualified inspector --
18 MR. BOYER: Yes.
19 MR. ROMANO: -- do you not?
20 And you know that the NRC inspector made 21 the second inspection, do you not?
22 MR. BOYER: Yes.
23 MR. ROMANO: Would you say that the NRC 24 inspector incorrectly determined the condition of
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l l 1 that weld?
l MR. WETTERHAN: I object. I don't know 3
how he can testify as to the qualifications of_any 4
NRC inspector.
5 MR. GUTIERREZ: Well, I object for a 6
different reason.
7 He has already stated that he cannot 8 personally: talk about the adequacy of.that weld.
'~
9 He did not look at the paperwork or the radiographs 10 or whatever.
11 Now you follow up with a question
- 12 relative can he judge what an NRC inspector did
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- m. . .o 13 i relative to that same weld. He has no personal 14' knowledge.
- 15 MR. ROMANO: I think it's very important, 16 though, that we have to agree -- we have to -- the 17 NRC inspector is being questioned as to his 18 qualifications, too.
19 MR. GUTIERREZ: I haven't understood the 20 witness to question the qualifications of the NRC 21 inspector. l 22 MR. WETTERHAN: We don't even know even 23 if the NRC inspector's qualifications --
24 MR. ROMANO: Just a minute, Mr. Wetterhan.
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95 1 (Discussion off the record.)
2 MR. ROMANO: Mr. Boyer, you did say.that 3 you're not sure what the applicant -- what the 4 Nuclear Regulatory inspector saw there. You can't 5 vouch for what he saw?
6 MR. BOYER: No, I can't.
7 MR. ROMANO: Would you, therefore,.
8 question other inspections and reports made by.NRC 9 inspectors because they may also create a. doubt in
~
10 your mind?
11 MR.!BOYER: I'm not really questioning
~ '
12 this{.one'.^.
- G4i
";$7" . MR.y'ROMANO: 'Well,.I thought you said that
'.^:: :7 '13 .f
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14 because~you r weren't there,' you couldn't vouch for
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,, 15 what'the inspector.saw, the NRC inspector saw.
16 MR. BOYER: That's right.
t 17 MR. ROMANO: Then there's a little element 18 of doubt there since -- isn't there a little element 19 of doubt?
20 MR. BOYER: Well, what I'm basing my 21 statement on or - is that in this total reinspection 22 Program where we had a number of different inspectors 23 looking at a number of welds and in some cases we had 24 two or more inspectors looking at the same weld, we l
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1 would get a difference of views as to whether the 2 weld fully' met the qualifications or not. So that r
3 welding inspectors can have different opinions as c
4 to the, situation with regard to a particular weld.
y N 5 Now, .I don' t honestly think that that would 6 have been a -- that this weld would have been that
_ _ . _ 7 borderline _a case. But it could have been a case 8 wherein Mr. Ferretti felt that the weld was adequate
~
, 9 for the job that it had to do; and he did not comply 10 with the strict full requirements. He was using t
- e -
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' '12 part at that point in time; but that could have
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~~ ~
13 en #
14 at this point.
15 MR. ROMANO: You have no way either of 16 knowing whether Mr. Ferretti inspected that weld at 17 all, have you?
18 MR. BOYER: I'm sure he did.
19 MR. ROMANO: How can you be sure of that?
20 MR. BOYER: Well, just from the total l
21 program that we have and the records and the monitorirg 22 that is done and a review of other welds which he was 23 responsible for that generally show a reasonable l I
24 degree of_ adequacy..
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-97 I MR. ROMANO: A reasonable degree of 2
adequacy.
3 What do you consider a reasonable degree 4 of adequacy?
5 MR. CLOHECY: The -- there were no --
6 other than the -- these initial welds, which were
(
7 redone --Athere were no welds that he inspected that 8 had to be+ repaired t"o meet.the requirements for the 9 strength of the weld.
' ~~
10 l MR. ROMANO: Isn't it true that you were
. ' : _ ; Wa ; , .
11 still-looking for some of the welds that he did?.
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2 rmMR.-BOYER: No.
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15 of this interrogatory, 2B? You state that you~are --
16 MR. WETTERHAN: Would you care to examine 17 it?
i 18 MR. ROMANO: No.
19 You state, last sentence, I believe that 20 is ---
21 MR. BOYER: Yes.
22 MR. ROMANO: -- that there may be other 23 deficient welds.
24 MR. ROMANO: That was an interim report.
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1 That was a quotation from an interim report while l l
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3 MR. ROMANO: But isn't it possible that 4 there will be welds that you still might find off 5 and also many of the welds which are inaccessible 6 now, isn't it possible that they could be off?
I , . . . . 7 . . .. MR. BOYER: They have all been evaluated 8 and found to be acceptable; or where there was any
, 9 question, we have chipped out the concrete and made L
10 a physical reinspection.
-i ' *G.rc;; : . . .
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MR.:BOYER: .A lot of them were, yes.
, ).[ ,.' ' ,14 MR. ROMANO: I would say aren't most of
~
- 15 them that way?
1 16 MR. BOYER: Yes.
17 MR. ROMANO: Is it true, Mr. Clohecy, 18 quality control relative to audits on welding 19 activity were done with random sampling rather than 20 scientific statistical sampling?
21 MR. CLOHECY: Which audits of what welds 22 are you talking about?
23 MR. ROMANO: Well, in many of your audits --
24 well, let me ask you: You continue that question.
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Do you do or do the inspectors do random 2 sampling or do they do sampling based on utatistical 3 scientific procedure?
4 MR. WETTERHAN: I think that is confusing.
5 Are you talking about inspectors or auditors?
6 MR. ROMANO: Well, do inspectors make
. 7 , audits and in those audits take samples,,do they.
8 randomly.take samples or do they use scientific 9 statistical procedures to be sure that they have
~
10 proper representation of the welding population?
11
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15 MR. ROMANO: Where would you use ju~dgment 16 and on what basis do you use judgment?
17 MR. CLOHECY: I would appreciate it you 18 would be a little more specific in your question.
19 MR. ROMANO: You said you used judgment 20 at times in how many samples you take.
21 MR. CLOHECY: Yes, I answered this question 22 MR. ROMANO: And I asked you when do you 23 use -- on what basis do you use judg:nent?
24 MR. CLOHECY: Okay. We answered a similar
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100 1 and related question in one of your earlier 2 interrogatories.
3 MR. ROMANO: No. Just tell me now.
4 What basis do you use when you make a 5 decision you're going to use your judgment on this?
6 MR. CLOHECY: It's the judgment of the 7 , auditor and the auditor's field branch head as to 8 what sample size or what items-should be audited.
~
9 MR. ROMANO: What' basis do you use for
- 10 when you're going to do that?
m 11 MR. CLOHECY: It's the judgment of a 12' qualified auditor.
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14 thatLjudgment any time he wants without, you know,
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15 qualification, without checking it with anyone else?
16 MR. CLOHECY: It's approved by supervision.
17 MR. ROMANO: Why isn't a statistical 18 procedure used rather than random judgment by an 19 ' individual?
20 MR. CLOHECY: We have used statistical 21 procedures.
22 MR. ROMANO: Why isn't it always used?
23 MR. CLOHECY: It's not' felt necessary.
24 MR. ROMANO: That's your opinion, isn't iti
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1 MR. CLOHECY: It's also the opinion of my 2 supervision. l 3 MR. ROMANO: Can you tell how -- what the 4 biggest welding population would be in which you 5 would use your own judgment as to how you're going 6 to audit it?
_ 7 . : JiR. CLOHECY: I don't understand the .u . .
8 question 9 -
- 9 MR..GUTIERREZ
- Can I have a point of
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15 16 make up the sample?
k 17 MR. ROMANO: Both.
18 MR. GUTIERREZ: I don't think that's been 19 clear in the questions and answers.
20 MR. ROMANO: If you don't understand 21 random sampling versus scientific statistical l l
22 sampling, it would be covered. 1 l
23 MR. WETTERHAN: Well, the record will 24 speak for itself.
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MR.' ROMANO: Yes.
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would you say that in this sampling 3
situation, if one out of sixteen samples is found 4
to have a deficiency, is that okay, one out of 5
sixteen?-
6 MR. CLOHECY: Where are you reading from?
7
_ . . . . . . . . m -MR. ROMANO: Paragraph 13 of I think it's 8 Mr. Boyers October 4th, 1983, affidavit.
9 MR. BOYER: October 4th?
-10 MR. ROMANO: Yes.
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.2. ;MR. WETTERHAN: September 29th.
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. . I4 . MR.' ~ CLOHECY : Paragraph what?
15 MR. ROMANO: 13.
16 MR. BOYER: I don't have a 13.
17 Fr. ' LCHECY:
.- I don't, either.
18
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19 MR. ROMANO: In that summation ~it was l 20 found that there was one deficiency on welds 21 previously inspected. One cat of sixteen was now 22 found to be deficient.
23 And would you find that acceptable, Mr.
1 24 Clohecy, that one out of sixteen is acceptable?
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1 2 and it was evaluated by engineering to be acceptable.
3 MR. ROMANO: I'm asking you if you think 4 one out of sixteen welds should be considered 5 acceptable.
6 MR. BOYER: It was evaluated so that it
_ _. _7 .
was acceptable. It wasn't any question of.whether --
8 I mean if.one.out of sixteen was unacceptable, then
@/-E 9 you have--a different question.
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. . . .,, But there~again we have some -- either
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17 Now, then Paragraph 6, Page 4 of.the 18 September 29th affidavit. Well, that's... There 19 were 423 welds;-is that right? Do you have that?
20 MR. BOYER: Yes.
21 MR. ROMANO: But in answer at 7G of the
~
22 twelfth interrogatory it is stated that there are 23 439 welds.
24 Which is it? --423 or 439?
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r 2 You have to add the 16 and the 423 in order 3 to get 439.
- 4 MR. ROMANO: But it seems to me that the 5 16 were already -- weren't those 16 already in the 6 423?
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7 MR. CLOHECY: No.
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16 were not in the-423?
' l'[ 10 MR. CLOHECY: Yes.
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~ 1n v 15 - MR. WETTERHAN: He's saying it under oath, 16 Mr. Romano.
MR. BOYER: We will admit that following 17 18 through the numbers it's rather confusing.
19 MR. ROMANO: I just want to ask. You had 20 stated, Mr. Boyer, in your December 15th, '76, 21 letter to James O'Reilly that the inspector involved 22 in that broomstick affair is no longer employed by 23 the contractor.
24 MR. BOYER: Right.
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MR. WETTERHAN: True statement.
2 MR. BOYER: Right.
3 MR. ROMANO: I have then -- I have then i
4 later been told by Mr. Wetterhan that Mr. Ferretti !
5 was not fired.
6 Would you.tell me how that stacks up, how
_ . ;_. 7 the ,two answer.s stack:up? . , , ,_
-. - < - 8 -MR. BOYER: -
He left the employment of 9 Bechtel ---
10 (Witnesses conferring off the record.)
'J','" 11 .MR..BOYER: He left for other employment.
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Y. - 'MR.tWETTERHAN: ..Well, the previous answer 16 was that- he -lef t - for other employment.
17 MR.' ROMANO:~ I asked him if the applicant 18 had anything to do with it.
19 MR. BOYER: No.
20 MR. ROMANO: When did he leave; do you have
! 21 an idea?
l 22 MR. BOYER: It was --
23 MR. ROMANO: Do you know when?
24 MR. WETTERHAN: Do you have a date?
l
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MR. CLOHECY: It was 2
right after the inspection ended, the NRC inspection 3 ended, which was October 22, 1976.
4 MR. ROMANO: Did the NRC or the applicant 5 or Bechtel/statie'why.he was released?
6 MR. CLOHECY: I think Mr. Boyer --
.. .n. 7 . .,.MR..WETTERHAN: .
You mischaracterized the
-- - .8 answer. The answer stated he left the employment.
~
9
. He never stated he was released.
10 MR.'BOYER: I have no additional
. . . , , . . ~ . .~ '. . - % . -;;,
11 information.?-
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12 . MR. '. ROMANO : Then are you saying, -Mr.
- l. . : li. ,;;.u' :13 1 . . . . '.i :'
- . . s, : ,, Boyer, that.he.was not discharged; is that right?
-', '$ 14 MR. BOYER: No.
4; v ,
15 IMR. ROMANO: He had -- he did not leave 16 as a result of the quality of.his work?
17 MR. BOYER: Since he left the employment, 18 there was no need for further consic _ ion of that.
19 MR. ROMANO: Except to find out really 20 every weld he did in order to inspect it; is that 21 right?
22 MR. BOYER: That was not his function. ;
23 MR. ROMANO: I know; but it was important 1
24 when we consider Mr. Ferretti, isn't -- that he was l l
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a; 1 107 1 to be considered in light of whatever other welds 2 he inspected; isn't that so?
3 MR. BOYER: We located and inspected ~or 4 evaluated all the welds that he had had responsibilit ie@
5 for.
6 MR. ROMANO: You are sure that the last
,. 7 . ,_ number, the -last number of .1235 is absolutely .the...
,, 8 total amount.of. welds which he had something to do
~..
9 with?
l' 10 .MR..BOYER: As sure as I can'be.
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. . . 16 transcript for signature to Mr. E. J. Cullen, Jr.,
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l I 3 17 Legal Department, Philadelphia Electric Company, 18 2301 Mark't e Street, Philadelphia, Pennsylvania, 19101 19 (Witnesses excused.)
20 -
21 (The depositions were condluded at 12:10
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23 24
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EXHIBITS 3
NUMBER DESCRIPTION IDENTIFICATION I 4 1 Attachment 1, letter from R. T. Carlson 12 5 to V. S. Boye.r dated 11/10/76 transmitting NRC i.e. Inspection Report 6 No. 50-353, 76-06.
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i 1 l 2 We hereby certify that we have read 3 the foregoing transcript of testimony,given by 4 us in this matter, and it is true and correct
'5 to the best of.odr. knowledge and belief, s
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PATRICIA A. JONES '
21 Notary Public, Pnita Phila. CO.
My Commiselon Expires Oct.'t3,1999 .
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I, NEITH D. ECKER, a Certified Shorthand 6 '
Reporter and Registered Professional Reporter,
, do hereby certify.that the foregoing is a true 8
T and accurate transcript of my stenographic notes 9
taken ir the above-captioned matter to the best 10
{l' of my knowledge and belief.
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