ML20094P350
| ML20094P350 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 07/18/1984 |
| From: | Gardner R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19258A087 | List:
|
| References | |
| CON-BX19-012A, CON-BX19-12A, FOIA-84-96 NUDOCS 8408170166 | |
| Download: ML20094P350 (100) | |
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s, 8032 rPj4 Il Whereupon, RONALD N.
- GARDNER, 2i Regulatory Staff, called as a witness by Counsel for the t
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was having first been duly sworn by the Chairman, t
4 follows:
examined and testified as 5
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DIRECT EXAMINATION 0
BY MR. WILCOVE:
7 i c6uld you tell us your name and A
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for the record?
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position with the NRC
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5 9Y I am reactor Gardner.
is Ronald N.
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My name in the plant systems j
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5 II inspector in the electrical area l
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NRC.
I I2 section, Region III,
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4 Are you f amiliar with a meinorandum f rom an E=
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in which Mr.
b I4 investigator from the NRC, regarding the cua' '-
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employed by Comstock?
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Yes, I am.
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Could you please describe those allegations for 2
me?
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Yes.
An anonymous gentleman contacted Mr.
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Foster at the Region III NRC office expressing several I
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' items of concern.
One concern dealt with Comstock QC 3
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7l Mr. Poster,as stated, is an NRC inspector.
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Mr. Foster requested the gentleman to provide some examples l N
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The gentleman j
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was unable to provide specifics.
Mr. Foster asked t he i
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or could find out abcut and that Mr. Fcster would call
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him back a t a subsequent time to try to get that infor-z=
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2 Approximately a week later Mr. Foster contacted I
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the gentleman again and requested from that gentleman if l
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he had, in fact, identified or could identify any specifics.
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5 18 The gentleman indicated that he could not identify any C
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- specific locations or lines, et cetera, which contained i
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installaticas.
However, he did express a 21 !
concern with Cemstock QC personnel.
He identified two 3
i 22 j 'personne.1 by name, stating that he did not believe they
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Q And what actions had ycu taken to pursue thess i
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I have examined the certification records for
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2 I have noted that they are qualified in two cr more areas 3
4 of inspection.
One of the two gentlemen was not qualified in an elec rical area, although he was qualified in pipe 5l
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supports and concrete anchor -- e::pansion anchor installation.
The other gentleman was qualified in E
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9 supports.
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However, there were no specifications on which j
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Therefore, l
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12 in examining the records and observing that the two z
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A 14 certified, that is as far as we can pursue this at this i
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15 time, unless, of course, specific data is given in the x
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So at this time the NRC does not intend to l
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18 pursue these allegations further?
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A No.
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20 i MR. WILCOVE:
Mr. Chairman, that i's the end 21 !
of the Comstock matter, so at this point we are ready 2
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3 23 i CHAIRMAN BECHHOEFER:
Fine.
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21-irtl 8035 1:
3Y MR. WILCOVE:
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Q Mr. Gardner, do you have in your hands the 3
testimony, a copy of a document called "The Testimony of 4
Ronald N. Gardner Concerning the Qualifications of Bechtel I
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QC Personnel"?
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Yes.
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Do you have any additions, deletions or
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corrections to that testimony?
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A Yes, I do.
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Could you please tell us what those corrections z
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are.
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The corrections will occur on Page 4,
specific-i ally the corrections pertaining to the final answer on l
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That answer should be removed. In lieu of that g
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17 "As stated in my testimony, Consumers Pcwer l
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18 QA personnel had identified instances in which Bechtel
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QC inspectors had not identified non-conforming concitions.
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20 ' The QA personnel documented these non-conforming conditions.
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on non-conformance reports, NCRs.
The licensee determined 22 j.that 9 QC inspectors had NCRs written against them.
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23 The licensee also determined the number of inspections l'
24j which each of the nine inspectors had performed frca tha I
i 25 l time of initial certification to the point at which the i
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j, NCR was written and remedial training given.
I 2l "We requsted the licensee to perform over 3.
inspections of those QC inspections.
Subsequ'ently the l licensee reported that 100 percent over-inspections would 4
be performed on eight of the nine inspectors.
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1 6l theywould stop after performing over-inspections of
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a f7 250 of the 1147 inspections completed by the remaining E
inspector, Mr. U rb any..
They reported that at least one 8
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9j misrouted cable had been identified witnin the 250 over-l i
10 inspe tions pertaining to Mr. Urbany..
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13 f "The NRC requested the licensee to complete another
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250 over-inspections-of Mr. Urba=y's inspections.
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14 additional misrouted cables pertaining to Mr. Urbany..
5 15 Based on the increase in detected errors, that is from l
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5 16 3 to 29, NRC Region III has requested as of yesterday that t
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In addition, we have requasted
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that the licensee make a full report of the results of the X
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Q And had the licensee agreed to continue the 22 l
23. over-inspection of Mr. Urban y 's work?
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Not at this time.
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Is your prepared testimony with the changes ycu u
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I have just made true and complete?
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Yes.
MR. WILCOVE:
Mr. Chairman, I offer Mr. Gardner's prepared testimony into the record as if read, into I
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evidence.
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a CHAIRMAN BECHHOEFER:
Any objection?
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7' MR. ZAMARIN: No objection.
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CHAIRMAN BECHHOEFER:
The testimony will be i
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(Prepared test.tmeny anc supple-I
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mental statement of Ronald N.
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Gardner follows :)
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c 01/22/82 UNITED STATES OF A!! ERICA NUCLEAR REGULATORY CCH!!ISSION BEFORE THE ATOMIC SAFETY AND LICENS!NG BOARD In the Itatter of CONSUMERS POWER C0ftPANY.
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Docket fles. 50-329 Oli & OL (iiidland Plant, Units 1 and 2) 1 50-330 Ott & OL TEST!rictlY OF RONALD N. GARDNER CONCERNING
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Please state your nane and position with the NRC.
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A.
fty name is Ronald N. Gardner.
I am a Reactor Inspector (Electrical), Plant Systen Sections, Region III.
Q.
Is a statenent of your professional qualifications attached to your testirony?
A.
Yes.
Q.
What is the purpose of this testimony?
A.
This testimony discusses an item fron the !!ay 1981 inspection which still remains open. (Inspection Report No. 81-12--Staff ExhibitI). CPC QA engineers had been performing "overinspections" of itens which Bechtel QC personnel had been inspecting.
In the f4y 1981 inspection, the Region III inspectors observed that the QA engineers had been identifying nunerous occasions in which CC inspectors were accepting nonconforming conditions. The QA engineeers, documented these instances in nonconformance reports. (NCR's). The construction activities f
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prinarily responsible for generating NCR's were cable pulling and cable teminations.
The Region III inspectors at the fiay 1981 inspection observed two potential deficiencies with the experience and training of the OC inspectors.
First, they had little or no prior OC experience.
- Second, they were certified as cable pulling and cable termination inspectors within three weeks of their reporting date.
From October 6 to October 9,1981, the NRC Staff conducted another
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inspection of the !11dland site.
(Inspection Report No. 81-20). They detemined that the item still remained open.
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Please state your involvenent with the inspection of this
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As a renber of the Region III inspection team, I was personally involved in the liay 1981 inspection. I was also a co-author of Section IV of Inspection Report 81-12, which addressed this natter.
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As a result of the Region III inspectors' concerns with respect to the qualifications of QC personnel, what action did they take?
A.
We required CPC to (1) deter line if previous inspections perfomed by the aforementioned OC inspectors were acceptable and l'
(2) verify the adequacy of the training, qualifications and exa.ination j
of Bechtel QC personnel.
1 Q.
What action has CPC taken to neet the above requirements?
A.'
The licensee has conducted two audits of the Bechtel QC Departnent. Audit No. 11-01-24-1 was conducted fron June 2 to July 3, l.
1981 and Audit No. M-01-72-1 was c:nducted from November 2 to !!avember 6, s,w. em e
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1981. These audits evaluated the adequacy of the hechtel OC training and certification program. As a result of the audits, the following inprovements have been made in the area of OC training; (1) Rechtel is now documenting on the job training as part of its certification / training process for OC inspectors and (2) itp0AD site personnel are overviewing Bechtel's training / certification program to assure that the certification of inspectors meets flidland Project requirenents.
Q.
'elhat has the Staff done to assure itself that Bechtel's OC training and certification program is now acceptable?
A.
I selected three QC inspectors to be questioned concerning two cuality Control Instructions (CCI's) for which they had previcusly been certified. Both QCI's involved cable pulling and cable termination, the construction activities in which the greatest nunber of f;CP's occured.
The selected QC inspectors were each hired in 1981, had no prior DC exparience and were certified within approximately three nonths of their reporting date.
In answering ny questions, the QC inspectors deronstrated acceptable knowledge in the twc areas.
Q.
Do you believe that there is a need at the flidland site to recaire higher standards than are set forth in Regulatory cuide 1.58
-l which incorporates ANSI standard N45.2.67 A.
flo. Although problems have arisen due to the vagueness of the regulatory guise, I do not believe the licensee has abused these provisions. Since Bechtel is now documenting on-the-job training as part of its certification / training program and !!PQAD site personnel are overviewing the progran, prior problems should now be alleviated. These l
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I' changes should also enable the NRC to c nduct a better audit of CPC's use of these provisions.
Q.
Are you satisfied that certification of OC inspectors reets 111dland Project requirerents and NRC requirements?
A.
Ye s.
Q.
that is the status of CPC's cennitnent to "overinspect" the inspections performed by OC personnel against when NCR's had been initiated?
A.
We are waiting for the results of the overinspection so they may be evaluated.
I expect to make that evaluation prior to testifying in the first week of February 1982.
Dated at Bethesda, Maryland this 22nd day of January,1982 l
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q UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of CONSUMERS POWER COMPANY Docket Nos. 50-329 OM & OL 50-330 OM & OL (Midland Plant, Units 1 and 2)
CERTIFICATE OF SERVICE I hereby cartify that copies of " TESTIMONY OF RONALD N. GARDNER CONCERNING THE QUALIFICATIONS OF BECHTEL QC PERSONNEL" and " PROFESSIONAL QUALIFICATIONS CF RONALD N. GARDNER" in the above-captioned proceeding have been served on the following by deposit in the United States nail, first class or as indicated by an asterisk by deposit in the Nuclear Regulatory Commission internal mail systen, this 22nd day of January,1932:
- Charles Beenhoafer, Esq.
Frank J. Kelley Administrative Judge Attorney General of the State Atomic Safety and Licensing Board of Michigan U.S. Nuclear Regulatory Commission Steward H. Freeman Washington, D.C.
20555 Assistant Attorney General Environmental Protection Division Ralph S. Decker 525 W. Ottawa St., 720 Law Bldg.
Administrative Judge Lansing, Michigan 45913 Route #4, Box 1900 Cambridge, Maryland 21613 Ms. Mary Sinclair 5711 Summerset Street Dr. Frederick P. Cowan Midland, liichigan 48640 Administrative Judge 6152 N. Verde Trail Michael I. Miller, Esq.
Apt. 3-125 Ronald G. Zamarin, Esq.
Boca Raton, Florida 33433 Alan S. Farnell, Esq.
Isham, Lincoln & Beale
- Dr. Jerry Harbour One First National Pla:a Administrative Judge 42nd Floor Atomic Safety and Licensing Board Chicago, Illinois 60603 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 James E. Brunner, Esq.
Consumers Power Company Myron M. Cherry, Esq.
212 West Michigan Avenue 1 IBM Plaza Jackson, Michigan 49201 Chicago, Illinois 60611 e
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- Atomic Safety and Licensing Board 5795 N. River U.S. Nuclear Regulatory Coc:.ission t
Freeland, Michigan 48523 Washington, D.C.
20555 James R. Kates
- Atomic Safety and Licensing Appeal 203 5. Washington Avenue Panel Saginaw, Michigan 48505 U.S. Nuclear Regulatory Cc. mission Washington, D.C.
20555 Wendell H. liarshall, Vice President Midwest Environmental Protection
- 0ccketing and Service Section Associates Office of the Secretary RFD 10 U.S. Nuclear Regulatory Co,ission Midland, Michigan 48640 Washington, D.C.
20555 Jeann Linsley Steve J. Gadler, P.E.
Bay City Times 2120 Carter Avenue 311 Fifth Street St. Paul, MN 55108 Bay City, Michigan 48706 Paul C. Rau Midland Daily News 12a ric0cnald Street Midland, Michigan 48640
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'21-lrt4 8038 I
BY MR. WILCOVE:
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On Page 4'cf your prepared testimony, you were P
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"Are you satisfied that the certi-4 fication of QC inspectors meets Midland Project re q uire.-
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5; ments and NRC requirements?"
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Does any information which you have received 1
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A For those QC inspectors that will be certified j
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y under the program in which the changes have been made, l
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job training and the QA overview of the certification 13 E
process, I believe are satisfactory.
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For those that predate those changes, I cannot l
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Q Mr. Gardner, is there anything in the testi=cny C
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A No.
205 MR. WILCOVE:
I have no further questions.
1 21l CHAIRMAN BECHHOEFER:
Ms. Stamiris.
22 CROSS EXAMINATION I
23 ii 37 MS. STAMIRIS:
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Mr. Gardner, you were a member of the inspec tion i
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team that identified the need for these audits on Eechtel ALDERSON REPORTING COMPANY. INC.
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1i QC inspectors in May of 1981, weren't you?
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A Yes, that's true.
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Were you a member of the inspection team that i
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As a result of your inspection in May of 1981, d
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A The licensee, as I stated, has made two changes l
2' in regards to Bechtel QC.
One is that they a.e documenting 3
100 percent of the on-the-job training and the second is 4
that QA is over-viewing QC, inspector certifications.
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I need to back up and sort of as background e
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6 before I get to that ask you didn't Consumers commit to e
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Yes, they did.
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Q Okay.
They in October of 1981, were you a member i
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No, I was not.
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And do you know what the inspectors' report E
A 14 81-20 had in mind when they said in Item J essentially
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The word was inconclusive and, yes, I do have i
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~4ould you please tell me.
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A Yes, I can.
I don't know if you have a copy of t
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the audit in front of you or not.
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I do.
Is this the June 2nd through July 3, j
l 23 1981 audit by Consumers Power Company?
24 i A
Yes.
Unresolved Item No. 3 states in part:
4 25 "It i,s not clear that successf,ully completing 1
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Since our request was that the licensee establish, I
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such as this being unresolved, we could only determine R
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On Page 2 of your prepared testimony, in the z_
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" Region III inspectors at the May '91
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16 First they had little or no prior QC experience; second, A
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5 18 inspectors within three weeks cf their reporting date.
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Do you consider these to be potential deficiencies.
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20 or do you think it might be more correct to identify 21 ' them as deficiencies in the training and experience of j
22 ' QA inspectors?
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I think potential deficiencies was the best.
24 Q
Would vou exclain why?
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Yes.
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1 existed cotential deficiencias was the fact that the 2l licensee was not documenting on-the-job training. That 3{
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inspector was certified caused us to feel there were 5) potential deficiencies and that in fact resulted in our 3
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requesting the audit.
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Q I can understand how that could be a potential I
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deficiency.
In other words, if the training actually i
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But with regard l
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three weeks of their reporting date, does that in itself b
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connote to you an actual deficiency in their experience?
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Not if they could successfully demonstrate 1.
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Okay, just a minute.
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19 In respcase to the question, the next-te-the-last n
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question and answer on that page when it says, "As a result 2I of Region III inspectors' concern with respect to the I
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qualifications of CC personnel, what action did they take,"
23 1 and ycu made the answer that you did, did this response 24 f of the NRC take place after Report S1-12 or after Report I
25 81-20?
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That would be a part of 81-12.
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On Page 3 of your testimony, keeping in mind r
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the determination by the NRC that the results, that in L
4 October at the 81-20 inspection it was determined that g
5 the results of the July audit were inconclusive and you R
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7i last sentence in unresolved Item 3, were there other aj 8l bases for the determination that this July audit was
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inconclusive?
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Could you please rephrase that?
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Were there bases beyond the one that you mentioned 2ll 1
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regarding unresolved Item 3 for the determination that.
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I believe an unresolved Item 3 was substantially l
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Q Now, you said on Page 3 of your testimony that 1
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and, as a result, the following improvements had been made,j t
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ut.d to shorten them they were on-the-job training and the 1
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That's correct.
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Q When you came to this conclusion, am I correct 1
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14]in assuming that you had thoroughly acquainted yourself l
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B these commitments?
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A Yes.
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I would like to start with the second one first, 19 '
j that being that MPQAD site personnel are overviewing
' Bechtel's training certification program to assure that 21 i
- the certification of inspectors meets Midland Project 4
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23 You concluded in this paragraph that that ever-a 24 !j view of the training and certification program was adequate 25 :! didn't you?
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Would you please repeat that?
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Does this testimony conclude that MPQAD site l
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This indicates that that has been initiated.
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Okay, what I want to know is do you understand E
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19 which is Csnsumers' Exhibit 22 in this proceeding, did M
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you understand that audit to be a follow-up to the June 21 and July Audit report we have been discussing?
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I understand that this is the audit that they j
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additional audit.
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Do you think that Consumers' November aucit 5
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20 report adequately addressed the concern of unresolved 21 i Item 3, specifically regarding the fact that there was no 1
22
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23 ence or certification 24 -
When you turn te near the and of the July audit 25 ! report, and it would be I believe four pages from the end, i
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Would you explain to me by subjectivity?
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As stated, I agree.
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Yes, I do.
21 Q
Do you think that concern was addressed at 22 all in the process that was fellowed in the audit, tne 23 November audit by Consumers when they looked at the 24i certification process?
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Are you saying do I consider tne Scverber audit
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I am saying do you' consider that the November 4I audit recort even addressed that concern?
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Please go on.
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I believe the problem or the question Mr.
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Turnbull was getting to, does a QC inspector, when h'e 3
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That is not the concern that comes through to e;
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20 I want to ask you whether you'think that aside or in 21) addition to the concern that you expressed, which was 1
22 addressed in the second audit report, do you think that 23 there is a concern here.
And throughout a lo: of -- you 24 l knew, there are many letters and things : hat record i
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Do you think that this sentence on that subject I,
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in other words, that the criteria were not set down i
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I will try and rephrase it.
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Sure.
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5 10 BY MS. STAMIRIS:
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Do you believe that Mr. Turnbull was expecting l
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on which to base an evaluation of competency for evalua-l m
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Could vou read that back to me?
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(Question read.)
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Yes.
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Let me say first that Mr. Turnbull there I
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expressed that concern and subsequently I did interview 1
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had, in fact, been satisfied that that concern no longer l
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I cannot speculate as to why Mr. Turnbull 3
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So you don't know how that concern was resolved?
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If he passes that test, he is certified.
I dc 2I not have a problem with that method.
4 22 Q
Do you have a very clear idea, through dis-i 23l cussions with Mr. Turnbull or any other way, what his I
24 concern was with the lack of clear criteria?
25 A
I did not pursue it to that extent, no.
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I object to the form of that E
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Did the witness understand the 1
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2 THE WITNESS:
I can answer to what.I understood..
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If he can tell us.
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the person who has been trained, that that is a deficiency 39 2
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20 that you are concerned with.
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THE WITNESS:
I am not sure what you mean.
MS. STAMIRIS:
Let me try and get at the thing 22 i 23 a ecmpletely different way.
It's because when I asked 24 ; you in essence 25 I MR. ZAMARIN:
This is improper and I object, t
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5l MR. ZAMARIN: I object.
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Pardon?
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I object.
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Is there any way for you 8
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Perhaps you could have the question.
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My objection is I don't mind i
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MS. STAMIRIS:
I won't do that, I hope.
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When I asked you whether the subjectivity in 25 ! the criterion was a concern to you, then you answered I)
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in terms of on-the-j ob tz aining; and to me that answer 2l was not responsive to the question I had in mind.
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MS. STAMIRIS:
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BY MS. STAM!RIS:
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But doesn't there need to be a system by which I
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his own unique ability and, therefore, scme individuals 2l will, in fact, be more readily able to quickly pass an 3
examination and some may not.
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So there is some R
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You mean there are two set questions that 2l every examiner uses?
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A' No, what I mean is that he is required to L( 0.?
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Q Well, if you have a good examiner who is asking e
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But what assurance i s :1 T
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of questions that are being asked?
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I believe the overview that QA is performing 1
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Well, moving down to the bottom question aEd 19 O'
answer on page 3 of your testimony, when asked whether 21 I you believed that there was a need at Midland to i
22 require higher standards than those in Reg. Guide 1.58 23 I
which incorporates ANSI Standard'N.45,2.6,-your answer was 24 l "No."
25 l I wonder if you're familiar with some 1
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being met.
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Could you tell me exactly which page?
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I have on page 4 in the next to the last full h
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Are you familiar R
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with the discussion in that paragraph?
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Are you talking about the paragraph that begins l J
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Yes, I am.
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Would you like to tell me what your understand-l 5
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On May the 4th, 1981 the NRC t_
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and Reg. Guide 1.58, Revision 1, as does the audit you 21,
mentioned.
They required the licensee in that generic 22 letter to respond to their method of complying with the l
23 Reg. Guide 1.58, Reg. 1 requirements.
l 24 The licensee was either to commit to compliance 25 l with Reg. Guidt 1.58.1 or to submit an alternativa method t.
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of' compliance.
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What did Consumers -- I am - so rry, I thought you 3
were finished.
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to that generic letter.
In the generic letter they E
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Q Can you please explain.what that alternative s
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I can read from their response if you would I,
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like.
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Since our qualification
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should not be required to be a high school graduate 22 or have earned the G.E.D.
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reasons:
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andon-the-jobperformancedemonstrationsf."
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They sent this to liRR on November the 2nd.
2
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And is it NRR's rresponsibility to accept or
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A Yes.
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Did they accept it?
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I do not have full information -- sufficient i
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Do you have an opinion as to whether you find 3
18 that acceptable?
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A My opinion is that it depicts the present method 20 '
Bechtel quality control personnel are being certified that 21 i by, and I have already stated that I have no problem with L
22 the adjusted certification process.
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23l Q
The sentence that is a part of this answer en l
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b i the bottom of Page 3 i
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25 l MS. BLOOM:
What answer, please.
I am not sure a
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what you are referring to.
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It is the bottom answer that we 3l have been referring to before.
They are not numbered.
4l; MS.. BLOOM:
The testimony?
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MS. STAMIRIS:
Yes, Page 3.
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Oh, the testimony.
That is all I R
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BY MS. STAMIRIS:
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The sentence that indicates that Sechtel is'now Y
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5
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Yes.
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Q Are you aware of the circumstances that are 4
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July under which Bechtel agreed to do on-the-job training, cb 19, although their continued and final position throughett n
20 was that it wasn't really necessary cr that thev disacreed i
21 ; with it but they would do it anyway?
1 22 MS. BLOOM: I am going tc object to that character-23 iration of Bechtel's response only because the question was 24 ' not whether they were doing on-the-job training.
The 25 i question was whether they were documenting it adequately.
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MS. STAMIRIS:
Right.
2 MS. BLOOM:
And this is not what Ms. Stamiris 3
said.
4 BY MS. STAMIRIS:
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A Yes.
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Okay. Do you believe that this is a fair z
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I can't speculate on all the circumstances.
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I am aware that Bechtel had a different cpinion concerning x
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I am not aware of all the 3
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17 letters that went back and forth and I cannot cenclude C
18 anything from them other than tha end result that, in t
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Q Then are you saying te me that the fact that 21 !
they are now documenting on-the-job training is efficient i
L 22 to the point that it is of no concern to you that if --
23 ' I put this as a hypothetical:
24 If they were dcing it grudgingly, if th2y were 25 dcing it though they didn't believe it was necessary, the
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fact that they were doing it is enough to satisfy you?
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2l MS. BLOOM:
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MS STAMIRIS:
I am asking and I i
4l MS. BLOOf::
There is no evidence in the record l
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I can speculate M.
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7 fair for us to do so.
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But I don't i
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MS. STAMIRIS:
I think I attempted -- at least I
2' I had hoped to attempt to elicit such a characterization 3
from Mr. Gardner.
And I belive his response that he was 4
not familiar enough with all of the letters and all of the 5
g transmittals that I was referring to to make firm conclus-n
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ions about that.
But he had some awareness of the situation R
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MS. BLOOM:
Yes.
9 MS. STAMIRIS:
So in lieu of going through -- and
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4 II ; to get me to that point, I asked a hypothetical question i
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12 that if Bechtel was doing it, even though they didn't
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it was enough to satisfy Mr. Gardner as an investigator.
ej 15 MS. BLOOM: I still object to the form.
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16 MR. WILCOVE:
I think that without any evidence
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that Bechtel was documenting the training grudgingly, it can E
3 18 almost be characterized as irrelevant if they were doing C
19 so.
4 20 MS. STAMIRIS:
Well, Mr. Gardner expressed scme i
awareness of what I was talking about, so I was just trying!
2I i
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i 23 E
MS. BLOOM:
In addition, I disagree with her 24, characteri=ation.
i 25 !
CHAIRMAN BECHHOEFER:
Can you find any particular j
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examples that show: that?
You don't have to look for all 2 I of them but can you find any?
I 3l BY MS. STAMIRIS:
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Q In the first audit finding report under " Correct-
.a 5l ive action commitment" is a statement that "Bechtel U
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" constitute a finding, a formal N
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within 30 days of this report."
10 Then in the notas that are in the be:< labeled z
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Method of Verification" is the statement that "Sechtel 3
g 12 provides the commitment to document OJT, even though 5
g 13 Bechtel does not agree that this A:I SI code requires such
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j 15 I think really to show that what I have drawn is
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17 mittals that were sent back and forth between Consumers d
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Mr. Chairman, may I make a n
20 suggestion? !!aybe when she is going through it and our j
i 21 objection to characterization -- maybe we are talking about q
22 two different things.
f 23 1, What those records do demonstrate was sechtel i
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she.did.
She talked about whether it would be begrudging 2
to do it.
a-3 MS. STAMIRIS:
That is when I said "If," because 4
I kind of wanted to set an extreme hypothetical example.
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MR. ZAMARIN:
You did.
ef6 MS. STAMIRIS:
To elicit the process that he was U
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involved in.
I want to know the process the inspectors A
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Are they concerned only that they see on-the-job M
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the circumstances surroundina it?
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MR. WILCOVE:
I'might suggest that she just
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3 1 4 li MS. BLOOM:
That is a good question.
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THE WITNESS: Would you ask that question?
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(Question read.)
t THE WITMESS: I can only answer that in my opinien 7
there was a difference of opinion between Bechtel Quality 19
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QA won the argument or 20 ' the difference of opinion.
21 !
i The end result is that the documentation is 22 1
being performed.
I do not believe that Sechtel is doing 23,a lesser job of doing the documentation tnan they would 24 6{have if they agreed with the interpretation of AUSI.
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on what did you base that belief?
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A on~the lack of evidence that's -- to the contrary.
3 Q
Do you believe it would be accurate to say that 4
this resolution of the on-the-job training issue did not 5l, come about until after the NRC October 6 inspection?
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A I can't answer that.
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Well,I will ask you, do you think that the s
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I have to speculate.
I don't know if the facts E
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are enough te answer that.
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Q In Mr. Turnbull's October 29 letter, which is 4
g 13 I believe the second page from the end of this July audit
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report, I wanted to ask you some questions:
In the second i
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15 to tha last paragraph of this letter dated October 29, E
16 1981 frc= Mr. Turnbull, which I would like this letter g
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22 ; evaluation of the certification process of the candidatas 23 on an on-going basis as described in his letter rather 24 than depending on programmatic and documantary changes i
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I Do you believe that Mr. Turnbull was expressing 2i a fact that at the and of this exchange -- well, do you 3l believe that Mr. Turnbull's expressing a feeling that i
4' l Consumers -- or that -- well, I will just' withdraw that 5l e
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Mr. Urbany the only inspector whose records are being
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A No.
Let me correct-uhat you are
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involved with non-conformance reports written by MPQAO
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through 9.
100 percent of those inspections were over-
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At this time 500 19 j
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I was having trouble taking notes -and I am l
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A As I stated, we requested, as a result of this u
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10 the remainder of Mr. Urbany's inspections, and I did s
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Is it not a requirement?
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I will convey =y
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Well, did you have a discussion with some "g
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I did.
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Q Did you notice any reluctance on the part of
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As I've stated, they have not agreed to do it.
t 24 Q
Well, that is what I am trying -- I mean, de 25,
you know why?
Did this come up in your discussion?
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They are still'looking at the data and if in
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unless it involves evider.ce which I have not seen thus l
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MS. STAMIRIS:
I don't have anymore questions e
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Gardner at this time.
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CHAIRqAN BECHHOEFER:
Okay, Ms. Bloom?
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Can I have about a minute before I 3
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CHAIRMAN BECHHOEFER:,Yes.
We can take a five l
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14 MR. ZAMARIN:
I would like to add a little F
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Apparently I was a little' x=
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Apparently there is still some censideration i
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22 the dike and, rather than keeping water out, the water i
23 somehow came in.
There was a matter before this hearing.
I 24i I provided the transcript citaticas to the Board.
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I think it is pretty clear that no one, none l
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of the witnesses believe that it is related to the soils 2
fanndacion properties and that it is properly a matter 3
to be addressed at the OL stage once there is some resolu-4 tion of what the probable maximum flood is.
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MR. PATON:
Mr. Chairman, I' agree with that.
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My only request is I think the record would be a little R*y 7l cleaner -- if everybody is agreed with that, that's fine.
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in the record.
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I agree with the Applicant's position that that !
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MS. STAMIRIS:
Well, I have a concern.
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can find in the transcript pages where it was.
Let me 3
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If it is not here, I will come j
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Okay, here it is.
All right, when Mr. Paton i
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and Mr. Zamarin were discussing whether or not the prob-F
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in the OL proceeding, on page 3521 -- well, I found part 20 '
of it, but I didn't find the response here.
Why don't 4
21 'l I wait until I have the quotes.
22 But the concern is that Mr. Paton said some-23 that place that the Applicant at first had said that 24
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is the part I did find.
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MR. ZAMARIN:
Oh, I know what she is referring I
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That the dike wasn't in the 3
proceeding and now he is taking a complete change.
Oh, 4l here it was here.
It says, this is Mr. Paton talking, p
5 and he says:
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7 the dike wasn't in.this proceeding at all and now A
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he has taken a complete change and now he wants
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the till.
I ~ frankly don't object strongly to z
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I do.
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Mr. Kane answered your question
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20 one way and then he said, but if you are regarding 2If stability, that he did consider I think that that was l
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a valid --
23 ;
MR. ZAMARIN:
Okay, what he said was, and 1:
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is 3651, he said:
25l "That's correct, but you say the shear strength, i
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and I would agree with that, but the ultimate I
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do at this point with questions of the soil N
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to improper compaction or sand or something of J
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10 And then after some colloquy among counsel and i.
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I note particularly at 4136, I asked him, he
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'he necessary freeboard above that. 'This is a t
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hydraulogical consideration.
It seems to =e these 1
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20 1 connected with plant fill problems."
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The response was:
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"You.1urst'. answered the question..It is not'
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It is 1
24 i a new proble= that is probably the operating 25 l license.
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" WITNESS KANE:
That is correct."
2l When Kane earlier used stability, I think he 3l used it in the sense, properly so, that once the probable i
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properties of the dike.
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111koc-1 instability if any MR. PATON:
The cause of the si.
1, would not be related to the soils.
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That is exactly right.
l 4l MR. PATON:
That is what I understood.from i
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this issue can be postponed.
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7j MS. STAMIRIS:
Okay, my concern is that I want R
understand if this Board is to rule on the
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to make sure I Js 9, stability of the dike per se, I would not like to see E
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the Board rule that the dike is stable without having
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considered the probable maximum flood. In other words, i
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12 you are not going to give some overall ruling of stability.j 4_
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13 CHAIRMAN BECHHOEFER: Our ruling will not be on j
j 14 matters that we have not taken up yet.
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15 MR. IAMARIN:
That is right.
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Anything that has to do w
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18 had to do with soil.
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I think you hava stated exactly
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20 what the Board intends to do.
They do not intend to nake i'
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a ruling on --
22)
MS. STAMIRIS: Overall stability of the dikes?
I' 23)i MR. IAMARIN:
We would not ask them to do that.
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24j CHAIRMAN LECHHOEFER:
Not at this point.
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25 l MR. IAMARIN:
Again, I would suspect that it i
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would be, our submitted finding would be more precisely 2l worded than t hat rather than stability, because that is I
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it is not in this hearing and it should not be and we I
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would ask that the Board agree with us.
6 CHAIRMAN BECHHOEFER:
Okay.
I might add that R
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- Okay, p'
16 CHAIRMAN BECHHOEFER:.
So I take it you would have '
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3 18 at a hearing, you would have no objection to Ms. Stamiris c
19 participating at least in that aspect?
a 20l MR.
AMARIU:
You mean consider the probable 21 ! maximum flood as it relates to the dike?
12)l CHAIRMAN BECHHOEFER:
Yes.
23 MR. CAMARIN:
Frankly, Mr. Chairman, I haven't 24 censidered that.
I am not prepared to respond to that.
25 [I could let you kocw, but s*mply sitting here rignt now, t
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I honestly don't racall how it works h
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I am going to have to take a 1
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I don't know whether it would in any event, i
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.i 8078 l23-3rtl CHAIRMAN BECHHOEFER:
All right.
Well, my real nOw j
I 2l Problem would be that I would not want to rule that we I
I 3l postpone it and then cutoff Ms Stamiris f rom. participating ',
1 in this, 4
5l MR. ZAMARIN:
That is right, and I do not think a
2 1
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we are asking you to rule to postpona it.
I think what 7, we are doing is taking the position that it is not in E
8l' this hearing at all because it does not relate at all c
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to the properties of the dike, the. scil, the fill and till 4
9 i$'to properties of the dike.
It is not really a matter of i
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d 12 here in the first place, that it is outside of the scope 1
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It is obviously something that we E
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I might say, we will be i
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willing to rule that it is part of the operating license
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17 proceeding, but as to this one where Ms. Stamiris has x=
18 expressed concern about it, I tnink we would want to nake
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20 I do not want to rule that way until I have heard your 21 position on that.
If you would want us to rule now, t
22 I will say we will do that, but that Ms. Stamiris will, 1
23, at leas *. to that issue, if shs wishes, she would be allowed, I
24 l to participate.
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25 l MR. ZAMARIN:
Unfortunately, quite frankly :
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do not have a position on that because I just do not recall l
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3i certainly have to consult with my client.
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MR. PATON:
Mr. Chairman, I think I support the l
applicant in that.
I think that is a very, very important E.
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issue to the extent which Mrs. Stamiris participates in e
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has nc contention about it just because she happened to 2
4 12 be involved when we get near the issue -- y'ou know, I would!
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15 MR. Z AMARI:i :
Why don't I*1et you know what our
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I am not asking fcr a E
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Right, and if we do take tne 20j 21 position that she ought not to be participating in the i
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22j operating license preceeding, then we will take that matter 23 l, up and you can do it on a briefing schedule.
24 '
CHAIRMA:: SICHHCIFIR:
On that particular issue.
25 '
MR. I A:tA R I:i :
Right.
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a desire or an interest in the operating license issues.
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I will let everybody know what e
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our position is as soon as I find out what it is, sir.
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Okay.
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Thank you.
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Because that may come up i
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But I don't really want to havs to rule on it N
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We also have a proposed schedule w
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18, March 15 the Applicant file proposed supplemental findings, 19 4on March 26 the Staff files its and on March 30th Mrs.
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MR. PATON:
Yes.
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Mr. Chairman, Ms. Stamiris indicated 1
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Oh, at the hearing?
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So it would save her some mailing
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And the Applicant, Mr. Chairman, has agreed to I
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You mean method of delivery?
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Yes.
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Obviously.
Sure.
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The grand reply?
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Is that something that will be j
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No, we just have a chance :0 E.
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That is the way the rules M
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work.
You didn't reply to the other.
l 21 MR. PATON:
You have the burden o f proof, so 3
you get two chances.
22 i
23 CHAIRMAN BECHHOEFER:
We'll keep you busy.
1 I
24j MR. ZAMARIN:
I would say that assuming there 25l is a possibility we may go into that first week of April, s
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first full week of April, the 23rd of April.
That is a 2
Friday. What I am looking at is the possibility of us 3
receiving that at the hearing on the 30th and that 4,
hearing running over into the-next week and that would 5
give us just two weeks just to prepare it.
E Ol MS. BLOOM:
The week after is Easter, too, so 7
it's better the 26th.
O MR. ZAMARIN:
It's not a problem for me but it's d
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Does the Staff have any i
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Stamiris?
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No, Mr. Chairman, we wanted to-file s
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prefer to file on the day.
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MR. ZAMARIN:
They
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Since the issues are limited,
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19
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If it were a full hearing, we might want to go after 20 '
Ms. Stamiris.
But unless the Board instructs us other-I 21 -l wise, we would just as soon file them.
22 CHAIRMAN BECHHOEFER:
We won't.
It's usually 23 the Staff's preference and the rules contemplate you get 24 a couple extra days.
MR. PATON :
Considering the issues involved, 5
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2I CHAIRMAN BECHHOEFER:
I might add the supple-3 mental findings are not on the corrective action.
4 MS. BLOOM:
77-32, MPQAD and SALP.
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MR. PATON:
That is correct.
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I guess to the extent 7l they raise management issues, if any party thinks they l
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To the extent they reflect management f
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11 MS. STAMIRIS:
I was going to say that I said s
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I was done and I forgot to ask two questions on this E
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Why don't you do that and ag 15 than the Applicant.
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BY MS. STAMIRIS:
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Mr. Gardner, did you say that the Comstock a
f18 employee was a former Comstock employee?
cI 19 A
Excuse me, which e=ployee are we talking abcu:7 M
20 Q
The anonymous one.
21 A
I didn't say.
1 22i Q
Is he a former employee of Comstock?
I 23 MR. :AMARIN:
I think the problem may be 24,
because of the anon?mity.
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He can't say.
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May we have just one -- I - don't see i
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Could we have one minute, Mr. Chairman?
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MR. PATON:
Mr. Chairman, could we ask the j,1 witness if answering that question could possibly lead 2
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Right.
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May I ask him that question.
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There's a possibility.
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We would prefer --
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I am not going to ask that.
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We would ask that she not ask that j
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Well, the question about who
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That is the answer he gave, answering i 5
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There are a lot of people, it's not A
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21 't MS.STAMIRIS:
The reason I want to know is becacsa 22 I wonder if hs is a former employee, if that is part of 23, the reason he is unable to provide specificati:ns at this i
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THE WITNESS:
I can only speculate as to why, and 8
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3 BY MS. STAMIRIS:
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Well, what about if he wanted to but he could not?
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I must object to that.
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I know it is.
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MR. WILCOVI:
The NRC asked the anonymous en 9
gentleman to provide the answars to those questions and I
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We don't know why. We cannot say why.
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You said that regarding the lack of specificity l
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That's correct.
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I wondered if you ever considered the possibility 22 of locking into the records of the work performed by thesa 23, two people,
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I believe that Mr. Gardner said, 4
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Correct ma i
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if I'm wrong.
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That he looked in the records if 3
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I'm sorry.
I apologize.
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BY Ms. STAMIRIS:
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Did the NRC ever consider that they could lock at
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Okay.
I don't have any other s
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I7 CHAIRMAN BECHHOETER:
Ms. Bloom?
5 II MS. SLOOM:
Thank you.
C 19 CROSS EXAMINATION i
5 20.j l
SY MS. BLCOM:
21 l 0
Mr. Gardner, when the certification process has 21 l'been discussed so f ar, it's been discussed in terms of 23loralexamination.
It's true, isn't it, that the certification 1
24 process of a quality control inspector also involves 25 training and an applicant must perform -- do a performance
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test in the actual narrow area of inspection to which the 2
individual is being certified?
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That's correct.
4.
MS. BLOOM:
No further questions.
5 EXAMINATION BY THE BOARD h
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BY JUDGE DECKER:
R 7l Q
Mr. Gardner, why were these nine people selected i
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These nine inspectors were the inspectors that I
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3 12 Q
Now, it strikes me a little odd for eight of 3
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Can you explain that?
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As I stated, they originally informed a
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stop at that point, that we did not consider 250 to be l
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in context and make a determination based on the results l
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Thus far, out of',1,094 cables over-inspected, i
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Is that a satisfactory error factor in your
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But that will be done when we receive 21 ;their report.
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Q Well, while all this over-inspection and rsinspect-a 1
23 i icn ars going on, are these nine people still at werk in 24 the areas making inspections in the areas that are now 25 ' being inspected?
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some of them are.
As I stated, the period that 2
we request a licensee to look was from the period at.
3 which the inspector. was certified to a period'at which,a 4
non-conformance report was written and he was given 5
remedial training and racertified.
3 0
JUDGE DECKER:
I think that's all.
7 BY CHAIRMAN BECHNOEFER:
A
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Did that 5.6 percent -- is that applied to all
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That applies to all nine.
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Q Were any cignificantly higher or lower as tne 5
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Urbany since there are approximataly 700 cables that are 21 indeterminate as far as their acceptability, and I want 22I to get data specifically relating to him and, of course, i
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And I did not calculate for each individual 24 inspector.
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I would appreciate that.
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As indicated in our inspection report 8112, three' sj 8'
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M 20 ' He also had a master electrician ID from the State of 21,
Mr. Urbany has at this time the highest percent 22 j of errors.
That is why I stated I don't see a correlation 23 lj between the percentage of errors and education and 24j experience.
That is another reason why we asked tne 25 ; licensee to make a report on this and to provide us with i
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Now, do any of those nine inspectors -- were they qualified through use of what at least some othe.
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Do you know what I am referring to?
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Q What about those other three, the ones that E
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than those who did?
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Q Are you familiar with the recommendation of 3
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precluded from using any of the provisions which permit
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education and experience factors are not absolute and 1
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can be substituted for with proficiency or testing of i
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The reason
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Q Well, would you have any recommendations for O
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one way of preventing that is to have a CA l
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overview.
That pertains to Midland site.
There are t
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4 14 information for my opinion on that, but they would not l
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Well, that is okay.
I assume they would not g
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I mean, I assume it wouldn':
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Well, I think that when A:lSI was considered, n
20l that they could have made a better job in defining seme i
21 critoria for allowing a waiver, let's say.
They could a
22 i have specified that QA should overview certifications l
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of those people for which the waiver will apply, for i
24; one, or they, as an alternative to that, they could have 25 stated that they recommend that CA certify QC inspectors.
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Do you think that such a requirement would be 1
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Yes, I believe the former for which-they are now committed to as of my talk with Mr. Marguglio, that 4l 5l the former, which is the overinspection by QA or over-e
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You understand they will continue to do that?
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Q Does this apply to civil AC inspectors as well
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I informed Mr. Marguglio of my concern that
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His commitment to me was that.
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Now, my understanding of what the licensee
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Are there adequate requirements for detailing j
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that an over-viewing organization can determine whether the 3l 4l waiver r exception was warranted?
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they may or may not make the overview.
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make the overview, will they-have enough information E
for the overview to be effective?
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My understanding is that when they participate 22 in the overview, they will know the inspector's background, 3
23 ) that is his previous education and experience, and that part of that overview will insure that he demonstrates sufficient 24 i
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Will there be a paper record?
In other words, 2
will all this information be adequately documented?
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You mean will the QA document in some for= or 1
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inspector's qualifications'?
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Yes.
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- CHAIR!!AN BECEHOEFER:
That is all the questions E
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ths Board has.
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I have one question en redirect.
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17 REDIRECT EXAMINATION
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18 3Y MR. WILCOVE:
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Q Mr. Gardner, is Mr. Urbany, is he still s= ployed
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22 MR. WILCOVE:
Thank you.
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CHAIR 2iAN SECHHOEFER:
Ms. Stamiris?
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'4S. STAMIRIS:
I don't have any questions.
25 '
i CHAIRMAN BECHHOEFER:
Ms. Bloom?
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MS. BLOOM:
I don't have any questions.
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CHAIRMAN BECHHOEFER:
I think Mr. Gardner may 3
be excused.
4 (Witness excused.)
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i 5l CHAIRMAN BECHHOEFER:
Let the record reflect that e
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We approve the supplemental findings schedule.
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not sure we said so before.
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MR. ZAMARIN:
Thank you.
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9l-CHAIRMAN BECHEOEFER:
I believe we are l
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adj ourned until 9:00 o' clock March 30, 1932.
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11 (Whereupon, at 7:00 p.m.
the i
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