ML20095F107
| ML20095F107 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 08/18/1984 |
| From: | Kostal K COMMONWEALTH EDISON CO., SARGENT & LUNDY, INC. |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20095F073 | List: |
| References | |
| OL, NUDOCS 8408270172 | |
| Download: ML20095F107 (5) | |
Text
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ATTACHMENT A.
August 18, 1984 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
~
In the Matter of )
)
COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-454-OL
) 50-455-OL (Byron Station, Units 1 )
and 2) )
AFFIDAVIT OF KENNETH T. KOSTAL Kenneth T. Kostal, being first-duly sworn, deposes and says:
- 1. My name is Kenneth T. Kostal. I am a partner-and assistant manager of the. Structural Department at Sargent
& Lundy. I assist the manager of the Structural' Department in coordinating all structural, architectural, and civil engineering design for Sargent & Lundy. During the recent hearings in July and August, 1984 conducted by the Atomic Safety and Licensing Board, I provided testimony on the capacity of various Systems Control-supplied components to carry design loads.
- 2. I have reviewed the pre-filed testimony of Charles Stokes with' respect to his criticisms of the design criteria contained in the Byron /Braidwood Structural Project Design Criteria, DC-ST-03-BY/BR (Design Criteria), referenced on Page 8 of Mr. Stokes' proposed testimony, and in the Review of Category I Conduit Supports Typical Support Types 8408270172 g40939 DR ADOCK 05000454 PDR
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. 4 and Load Tables (Load Tables), referenced on page 25 of Mr.
Stokes' -pre-filed testimony. I have also reviewed Mr. j
= Stokes' pre-filed' testimony with respect to. calculations performed by.Sargent & Lundy relating to the Reinspection Program. I amffamiliar with the Reinspection Report and its-Supplement. The Report covered only safety-related work performed by several contractors at the Byron Plant.
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The Design Criteria document is an internal Sargent & Lundy document that sets forth the criteria used Eby Sargent'& Lundy to design the Byron' plant. As such, it
-was-used as the basis for the calculations which. support the information in the drawings that were sent out to the field.
These drawings were, in turn,.followed in constructing the plant.
- 4. bk . Stokes' criticism of specific formulas, design assumptions and equations relates only to the standards by which the plant was designed. The criticisms of the Design Criteria are in no.way tied to any of the evaluations performed by Sargent & Lundy of the discrepancies discovered
' during the conduct of the Reinspection Program. Similarly,
- the-Load Tables' document that is referred to in Answer 37 is an internal Sargent & Lundy document that sets forth
-design criteria. Mr. Stokes' criticism of it relates only to the design criteria contained therein and is not tied to evaluations of discrepancies performed by Sargent & Lundy.
'5. In-addition, Section 12.2.4 of the Design
(
Criteria document relates to the design of below-grade ;
structural building outside walls, which is concrete work performed by Blount Brothers ~ Corporation.
- 6. Section 19.5.d of the Design Criteria document relates to reinforced concrete turbine foundation which (a) is not safety related and (b) is concrete work performed by Blount.
- 7. Sections 32.3.2 and 32.4.2 of the Design Criteria document relate to buried piping which (a) is not safety-related and.(b) is work performed by William A. Pope Company.
- 8. Section 34.2 of the Design Criteria document relates to embedded plates erected by Blount.
- 9. With respect to calculations performed by Sargent & Lundy relating to the Reinspection Program found in Calculation Book 19.1.2, the welds in the following sections were all produced by Blount:
(a) Sections 2.1 and 4.1; (b) Section 21, pgs. 77, 78, 78A, 97A, 109, 113.
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Kenneth T. Kostal SUBSCRIBED AND SWORN TO before me this /f.f] day of August, 1984.
$Y gSOTARY P'UBLIC MAJ h Commission bpires December 6, Igy
9 UNITED STATES OF. AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOKIC SAFETY AND LICENSING BOARD In The Matter of )
)
COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-454-OL
) 50-455-OL (Byron Nuclear Power Station, )
Units 1 & 2) )
CERTIFICATE OF SERVICE The undersigned, one of the attorneys for Common-wealth Edison Company, certifies that he filed the original and two copies of the attached " MOTION TO EXCLUDE TESTIMONY
- OF MR. CHARLES C. STOKES" with the Secretary of the Nuclear Regulatory Commission and served copies on the persons and at the addresses shcun on the attached service list. Unless otherwise noted on the Service List, service on the Secretary and all parties was made by deposit in the U.S. Mail, first-cla~ss postage prepaid, this 20th day of August, 1984.
W One of the Attorneys f5r Commonwealth Edison Company ISHAM, LINCOLN & BEALE Three First National Plaza Chicago, Illinois 60602 (312) 558-7500
F .
I
-o SERVICE LIST COMMONWEALTH EDISON COMPANY -- Byron Station Docket Nos. 50-454 and 50-455 OIvan W. Smith, Chairman Dr. Bruce von Zellen Administrative Judge Department of Biological Sciences Atomic Safety and Licensing Board Northern Illinois University U.S. Nuclear Regulatory Commission Dekalb, Illinois 60115
. 4350 East West Highway West Tower - Room 439
- Douglas W. Cassel, Jr.
.Bethesda, Maryland 20814 BPI 109 N. Dearborn St.; Suite 1300 t CDr. A. Dixon Callihan Chicago, Illinois 60602 Administrative Judge Union Carbide Corporation *Mrs. Patricia Morrison i P.O. Box Y 5568 Thunderidge Drive Bear Creek Road Rockford, Illinois 61107 Oak Ridge, Tennessee 37830
- Mr. Steve Lewis
'Dr. Richard F. Cole Mr. Michael Wilcove Administrative Judge Office of the Executive Legal Atomic Safety and Licensing Board Director U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission 4350 East West Highway 7735 Old Georgetown Road West Tower - Room 439 Room 9604 Bethesda, Maryland 20814 Bethesda, Md. 20814
- Joseph Gallo, Esq. Atomic Safety and Licensing Isham, Lincoln & Beale Board Panel Suite 840 U.S. Nuclear Regulatory Commission 1120 Connecticut Avenue, NW Washington, D.C. 20555 Washington, D.C. 20036 ;
Atomic Safety and Licensing Region III Appeal Board Panel i U.S. Nulcear Regulatory Commission U.S. Nuclear Regulatory Commission I Office of Inspection & Enforcement Nashington, D.C. 20555 799 Roosevelt Road Glen Ellyn, Illinois 60137 Docketing & Service Section Office of the Secretary
- Ms. Betty Johnson U.S. Nuclear Regulatory Commission 1907 Stratford Lane Washington, D.C. 20555 Rockford, Illinois 61107
- Ms. Diane Chavez SAFE 405 South Fourth Street Rockford, Illinois 61108
- Served in Hearings
, - - - . _ . - . _ _ _ - - w., ,-.y
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Ull!TED STATES OF AfiERICA NUCLEAR REGULATORY CO.relSSIOi.
BEFORE THE ATOI:IC SAFETY .MD LICE 11SIliG BO.GD i
In the matter of: .
COEIOiWEALTH EDISUN CO:iPANY, : Docket ros. 50- 454 OL
- 50 455 OL Eyron Nuclear Power Station, ;
(Units 1 and 2) :
---____________x 51st Floor Conference Room Isham, Lincoln & Beale Three First !!ational 1-laza Chicago, Illinois 60602 Friday, August 17, 1984 DEPOSITIO!! OP:
CHARLES CLEVELA!!D STOKES VOLUME II
/ Pb f{Cu W t ) 0 Ann Riley & Associates Court Reporters 1625 i St. N.W. I Suite 1004 !
Washington. D.C. 20006 (202) 293-3960 t
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1 VOLUMN~II:
2,
. UNITED STATES OF AMERICA 3
. NUCLEAR REGULATORY COMMISSION d
BEFORE_THE ATOMIC SAFETY AND LICENSING BOARD-5 -
- - - - - - - - .. _ _ - - _ _ - _x 6 In the matter of: :
7 COMMONWEALTH ~ EDISON COMPANY, : Docket Nos. 50-454 OL
- 50-455 OL 8 (Byron Nuclear Power Station, : .
9 Units 1-and 2) :
- - -X 10 11 51st Floor Conference Room Isham, Lincoln & Beale 12 Three First National Plaza Chicago, Illinois 60602 Friday, August 17, 1984 13 14 DEPOSITION OF.
15 CHARLES CLEVELAND STOKES, 16 Called for examination by Counsel for the Applicant, 17 Commonwealth Edison Company, pursuant to notice and 18 agreement of counsel, in the offices of Isham, Lincoln'&
19 Beale, commencing at approximately 9:45 o' clock, a.m.,
20 before ANN RILEY, a Uotary Public and court reporter.
21 22
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~ APPEARANCES OF'CCUNSEL:
2 For _the' Applicant Commonwealth Edison C_ompany:
3 JOSEPH GALLO, ESQUIRE MICHAEL GOLDFEIN, ESCUIRE 4 Isham, Lincoln 1h Deale 1120 Connecticut Avenne, Northwest 5 Washington, D.C.- 20036' 4 ~
6 For the-Nuclear' Regulatory Commission Staff:
7 STEPHEN H. LEWIS, ESQUIRE Office of the_ Executive' Legal Director 8 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 9
For the Joint Intervenors:
10 DOUGLASS CASSEL, JR., ESQUIhE & TIMOTHY WRIGHT, ESQ, ,
11 Business and Professional People for the Public Interest -
12 109 North Daarborn Street Chicago, Illinois 60602 13 14 ,
15 16 ALSO APPEARING:
17 '
Robert Hooks 18 Lou Del Gecrge 19
. James Muffett 20 21 22 l
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. 2-WITNESS:- Examination by: Page:
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CHARLES CLEVEIAND 5 STOKES- Mr. Wright .4 6- Mr. Gallo 7 7
Mr. LOWiS' 162 8 170 Mr. Cassel' .
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n 2 This is the'second deposition ~of MR. GALLO:
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3 Mr.' Charles
- Stokes, being scheduled in accordance with d
the agreement of the parties, and I think we will refer 5 to.this deposition officially as the second deposition 6
of Mr. Charles' Stokes. '*
7 Whereupon, 8 'CHARLNSCLEVELANDSTOKES, 9 was called as a witness and, having been first duly sworn, i
10 was examined and testified'as follows: $, -
Il MR. GALLO: Mr. Cassel, you have some corrections, ,
12 or Mr. Wright,.do;you have some corrections you want to
'13 make to the testimony? t i
Id MR. WRIGHT: 'Ies, we do.
15 EXAMINATION 16 BY MR. WRIGHT:
17 0 Turn to page 4 of your prefiled testimony. Do is you have any corrections to page 4?
19 A Yes, I do.
20 And what are those corrections?
Q 21 A In roughly the middle of the top question, it
.22 says in ny review, I have reworked a number of engineering
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- mgcl-2 calculations. It should state, "In my review, I have-2 reworked aspects of a ' number of engineering calculations.'
MR. GALLO: Wait a minute. I missed that.
A What line are you talking about on page 4?
THE WITNESS: It's roughly the middle of the page.
6 MR. CASSEL: It's.the twelfth line,-Jim. We're 7
on page 4, line 12.
8 THE VITNESS: That should be " aspects of a 9
number.of engineering calculations."
10
- BY MR. WRIGHT:
Q Now, Mr. Stokes, why are you making these 12 corrections?
I A Because the documentation I reviewed, I only had parts of the calculations. I did not have the entire D
calculation to review, and therefore I only reviewed
'6 aspects of the calculations.
'7 Q Okay, Mr. Stokes, do you have any corrections l8 on page 10 of your prefiled-testimony?
A Yes, I do.
o O And what are those corrections?
21 A It's the bottom of the second paragraph of 22 question -- or Answer 12. "The result would be an l
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6 I
allowable. stress larger than allowed by code," rather than 2
"the higher" -- it would be higher,-but it's also. clearer.
3 MR. CALLO: Do you want to repeat that correction?
5 THE WITNESS: "The result would be an alowable 6
stress larger than allowed by code."
7 DY MR. WRIGHT:
8 Q Now, Mr. Stokes, why are you making that correction?
10 A Well, the answer as stated is correct, but it's II not precise enough. It's more correct with the change 12 that's made.
13 Q Okay. Now, Mr. Stokes, do you have any corrections
'd on page 26?
IS A Yes.
16 Q And what are those corrections?
37 A Well, after the 200 -- after the KL/R in the
'8 first paragraph, and the 300, the foot and feet should 39 be canceled. The 200 does not have a units term.
20 MR. GALLO: I didn't understand the correction.
21 Do you want to -- just tell us what the correction is.
22 THE WITNESS: KL/R is 200, period -- exceeded e b
7
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-mgcl-4 1 lthe 200, period. One I noted was 300, period.
2 MR. GALLO: So you have deleted " feet" from the 3 third line, and you've deleted " feet" from the fifth line; d is that it?
5 THE WITNESS: And " foot" on the third line at 6 the end.
7 MR. GALLO: Oh, okay.
8 BY MR. WRIGHT:
9 Q Now, again, Mr. Stokes, why have you made 10 these corrections?
11 A As I said, the factor is unitiess. This section 12 of the testimony was typed up at my direction, but 13 n inadverte'tly overlooked. It was handled by my attorneys, 14 and undoubtedly there was a misunderstanding as to that 15 section of the testimony.
16 Q Are there any other corrections that you have to 17 make to your testimony?
18 A No.
19 MR. WRIGHT: Okay, Joe, I think that ends our 20 portion.
21 EXAMINATION 22 BY MR. GALLO:
23 Q Mr. Stokes, would you state your full name and l
8 (b Cgcl-5 1
_ business address for the record?
2 A: It's Charles Cleveland Stokes. As I have stated 3 ' earlier, I have no specific business address. I use my 4 permanent residence address as such -- Route 1, Box 223, 5 Cottonwood, Alabama.
-6 .O And is the organization you are with called 7 P-S-Associates?
8 MR. WRIGHT: Joe, let me just ask a question 9 before we proceed with this. A lot of the information 10 we've gone into in the first deposition, and to that extent, 11 it's repetitive, and if we're just seeking a little 12 background information to gat us started, I think that's 13 contained in the first deposition.
14 If there's any other reason for these questions, 15 I would like some type of an explanation.
16 MR. GALLO: Well, I just want to affirm that 17 P-S Associates operates out of the address he just gave me.
is I don't know if that's in the first deposition or not.
19 .MR. WRIGHT: I think it is.
20 MR. GALLO: Well, I'd like to get an answer to 21 the question, in any event.
22 THE WITNESS: The question is if P-S Associates
[ . . . --- - .
9-mgcl-6 1 works out of that address?
2 MR.'GALLO: Yes, I know.
3 BY MR. GALLO:
-4 Q But is that the name of your organization, that 5 you're with, as indicated in Answer 2 to your testimony?
6 A I am a member of P-S Associates, or the*. is an 7 organization which I belong to, yes.
8 Q. All right. Well, does P-S Associates have a 9 business address?
10 A No.
End 11 Q Your testimony says that you graduated from 12 Auburn University in 1975 with a BCE degree. What do 13 those letters stand for?
14 A Bachelor of Civil Engineering.
15 0 Was that a four-year clirriculum at Auburn?
16 A It was. ,
17 Q And if I understand your testimony, this is your 18 only engineering degree?
19 A It is.
20 Q Did you take any course work at Auburn in the 21 field of structural dynamics?
22 A I did.
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10 mgc2-1 :1 0 'What was that course work?
2 A I took structural mechanics, dynamics, strength 3 of materials, st el design, concrete design --
4 Q Wait a minute. . Wait a minute. You're going too 5 fast.
6 You say you took structural dynamics?
7 MR. CASSEL: No. He said structural mechanics.
8 Then he said dynamics.
9 BY MR..GALLO:
10 0 I'm sorry I interrupted you, but go a little 11 slower.
12 A Structural mechanics, dynamics, as an ME course.
13- Q .Okay.
14 A Strength of materials. Three different courses 15 in structural analysis. One of the final courses in that to area was structural analysis. The first two were subparts 17 of structural analysis.
18 O Can you remember what those were?
19 A Not specifically, no. They were involved with 20 structural design, but leading up to structural analysis 21 as a whole, and then structural steel design, concrete 22 design, foundation design as a structure, and I consider a
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. mgc2-2 course which might be excluded'from structures per se, 2
but applicable to. structures, soil analysis and a soil 3
. stabilization course, d
Q Now I take it that these are the names of 5
-individual courses that you took while you were enrolled 6
in Engineering School at Auburn; is that correct?
A Yes, the three that I listed as a group in 8
structural-analysis, I didn't break do'wn to names, but the rest of the course names per se.
10 Q But you are telling me that in the structural II analysis area, you took three courses, the last being 12 structural analysis?
13 A Yes.
'd Q Now you say you took a course called " Dynamics,"
15 and what did that involve?
16 A It was an-ME course in dynamic loading, dynamic 37 forces and the use of those forces in calculations and 38 stresses.
I' Q And involving what design?
20 A Anything -- structural, aerospace, any mechanical 21 component, machinery -- any item.
22 Q So this course work -- this particular course was a
12 mgc2-3 1 course in structural dynamics;.is that right?
2 A It was_ mechanical dynamics.
3 Q Mechanical' dynamics?
. 4 A Yes.
5 O Did you take any course work in seismic analysis?
6 A No.
7 Q Now I've got a series of questions I want to ask 8 you about your work experience. .
9 Based on my review of your testimony, it appears 10 that you worked for two and a half years as a draftsman 11 and detailer for Southern Services; is that correct?
12 MR. WRIGHT: Objection. Joe, this is the 13 second part of the testimony. In the first part, these 14 questions were asked and answered, and that's the basis of 15 my objection.
16 MR. GALLO: Okay. Objection noted.
17 MR. CASSEL: Well, I think we may go farther than 18 that, JU . Is there a need to go -- you know, this 19 material -- his resume was available at the first 20 deposition. All these things were listed. I forget whether 21 it was you or 11ike that asked this series of questions 22 about this whole area.
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I Well, the resume was made available mgc2-4 . MR. GALLO:
2 just prior to the deposition starting last time.
3 Mike Miller took the deposition, and it was an illegible copy _for.the most part.
I don't recall that these 5
questions were asked just in the way I am about to ask 6
them. In any event, I want to ask them, unless you are 7
going to instruct the witness not to answer them~.
8 You can object on whatever grounds you see fit, 9 but I want to ask the questions, and I expect answers.
10 MR. CASSEL: Well, I may want to instruct the II witness not to go over again the same ground that was gone 12 over-before. It's unusual, as you know, to make a witness
'3 available for a second deposition in a case. We are doing Id it here, because he now has prefiled testinony.
15 MR. GALLO: Well, I guess we're going to get in 16 an argument , then. Mhat do you mean, it's unusual, 17 because the unusual circumstances stem from the fact that is you weren't prepared and able to go forward at the tirac l'
the schedule was set by the Board, due to the fact that 20 you just couldn't get your witnesses together and get it 21 done. The understanding was that we would have a second 22 deposition; isn't that right?
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14 mgc2-5 .1 MR. CASSEL: The understanding was that we would 2 make him available for a second deposition, based on his 3 _prefiled testimony, which was the reason --
1 4 MR. GALLO: And I am asking questions from his 5 prefiled~teetinony.
6 I'm sorry. Go ahead.
7 MR. CASSEL: If you have a particular area or
.8 point that you think was not sufficiently addressed in 9 the first deposition -- we don't want to be unreasonable, 10 but I don't think any of us want to sit here and spend the 11 -same two hours that Mike spent the first time.
12 To the extent that resume was illegible, 13 Charles explained the answers in the first deposition.
14 MR. GALLO: Well, be that as it may, these are
.15 the questions I want to ask and as I believe it's l
16 appropriate to ask them, and you will just have to take 17 whatever action you think is necessary.
- 18 MR. CASSEL
- Well, let me tell you what our l
19 position is. Our position is, if you can give us a 20 particular reasons why you need to go over this same 2i territory again, a particular line of inquiry you want 22 to piirsue that wasn't pursued before, we'll entertain that.
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15 dgc2 But otherwise we.will instruct the witness not to answer 2
a whole series of questions about his resume, which was A extensively answered in the last deposition.
MR. CALLO: Well, I don't think I have to
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' justify and establish a reason why I want to conduct this 6
line. I think it's an appropriate line, and I intend 7
to ask the questions.
8 MR. CASSEL: Well, I'm telling you right now, we will instruct'the witness not to answer any questions
'O about his work background, unless you can state a II specific reason how this goes beyond the first deposition 12 or --
I3 HR. GALLO: I don't have that burden. You have
'd that burden. My recollection is, I have a question here, 15 "What is a detailer?" That question wasn't asked, and to y,m about to ask it.
I7 MR. CASSEL: Well, we'll listen to All right.
is them one by one.
" MR. GALLO: All right.
20 BY MR. GALLO:
21 O Let me start again with the question prior to 22 that time. -- am I reading your testimony correctly,
16
'4c :m g2-7 1 Mr. Stokes -- that you worked for two and a half years 2 for Southern Services as a draftsman and detailer, 3 approximately?
d MR. CASSEL: I am going to object to that S question and instruct the witness not to answer that. That 6 was specifically asked and answered at the last deposition.
7 MR. GALLO: You are instructing the witness 8 not to answer? -
9 MR. CASSEL: That's right.
10 BY MR. GALLO:
11 0 Mr. Stokes, what is a detailer?
12 A A detailer is one who has responsibility for 13 doing certain aspects of a design. He does do design
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14 work, but he's a member of the drafting department.
15 Typically he would be considered a designer in the drafting-16 department, rather than a draftsman, 1:7 0 Do I understand, then, a detailer is a higher 18 level of competence than a draftsman in the order at 19 Southern Services?
20 A Yes.
21 0 All right. So the draftsman, then -- what 22 were your duties as a draftsman for Southern Services?
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.a gc2-8 l' A . Well, as a draftsman, I did neat line 2 reinforcing drawings for concrete, neat line drawings for 3 structural steel. I did the rebar takeoffs, figured the d splice lengths required for embedment, and I did do some 5 detailing as a draftsperson, in that I detailed rebar 6 around openings, expansions. I detailed molded connections.
7 All right. I'm sorry to interrupt, but I want Q
8 to try to get'the record clear. .
9 My question was limited to draftsman. I'm 10 going to ask-you about detailing, but I have some 11 follow-up questions about your duties as a draftsman, 12 based on the terms you just used in your answer.
13 When you said you did neat line drawings for i
14 concrete and structural steel, what does " neat line 15 drawing mean?
16 A It's the line diagram showing the extremities 17 of the concrete in the poured condition, locations of 18 openings. It shows embedded items, placements, locations, 19 the item numbers, the slope on the concrete for drainage.
20 0 These are all noted on the drawings?
21 A Yes.
22 0 What kind of drawings would these be?
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mgc2-9' A Neat line drawings.
2 O They are called neat line drawings?
3 A The specific title.
O And what are they used for?
5 A Building the rebarsupporting structures, forming 6
the concrete, decking the pit if it's below ground, grading for pouring the concrete, all --
8 Q And what are rebar takeoffs?
I '
A A rebar takeoff is a listing of the steel 10 straight lengths, bent pieces, the necessary pins il required to form the piece. It lists the tonnage, the 12 sizes of steel, the tonnage per size. It may list a 13 l few other items, but that's basically it -- the strength
'd of the steel required in the rebar.
15 0 What kind of structures were involved with these 16 particular drawings that you were working on?
'7 A I worked on both fossil facilities and nuclear 18 facilities -- neat line drawings and rebar drawings.
O Can you be a little more specific as to what 20 elements of these facilities you were involved with in 21 this work? Take the fossil first.
22 A Well, over the timeframe that I was doing this
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work, I worked on, I believe, the main slab for Miller.
2 What is Miller?
O 3 A It's the Miller steam plant. It's a fossil d
plant. It's called Miller steam plant, but it's a fossil 5 plant.
6 I worked on pool boxes, miscellaneous outdoor 7
structures on Farley nuclear plant.
a Can you identify one of thoge structures for me?
O 9 You called it an outdoor structure.
-10 A Well, one of the type things I worked on was 11 the pumproom, the box. It was -- ,
12 The pumproom box?
O 13 A Yes.
(
Id Q Did this involve safety-related equipment, do 15 you know?
16 A Yes, it did.
End 2 17 Q Explain to me the difference, then, between 18 a draftsman and a detailer.
19 A Well, a draftsman typically may do some detail 20 functions, whereas a detailer, that's classified a 21 detailer, specifically does nothing but detail functions.
22 Our designers at Southern Services when I was r.
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~Egc3-1 there were primarily responsible.for doing detailing. But 2
as a draftsperson, I was not just a draftsperson, in that 3 '
I was there as a co-op, and engineer co-op, and so I was d
allowed to do detailing functions that normally the 5
designer would do as training in the co-op function.
6 O Can you explain to me what that program was?
7 I am referring to the engineer co-op program.
8 A The program is set up, allows a student to attend college one semester or one quarter and then work 30 with the company. The work in the company is geared towards what he will be doing upon his completion. In other words, 12 he'll be working in the same aspect as his degree would 13 be -- civil engineering. It would be in functions -- the
'd duties he would be assigned would be functions that would is be important to make that person, that graduate, a better 16 engineer upon graduation, knowing what should go in a
'7 drawing, neat line, reinforcing, how to detail rebar,
'8 detail molded connections, draf t a document -- necessary training for an engineer after graduation, in that if he 20 was to review that document, he should first have done it 21 to know what 'as on it.
22 The tasks varied from semester to semester. As I
., - _ _ . e_.. ., _,
21 I
mgc3-2 said, every other semester I was in school, and.every other-
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semester I was at work. I was rotated around the various departments from the concrete fossil, structural steel
, department,'to nuclear concrete and nuclear steel department.
5 That's the way Southern Services is set up.
6 So if I understand your testimony, you worked Q.
7 one semester.and didn't go to school and then went to 8 school the next semester but didn't work?
9 Did I understand that correctly?
H) A I didn't go to school, but I was going to school il for my degree, and while I was co-oping I took courses 12 at Birmingham, the University of Birmingham, an extension 13 of Alabama', at night.
Id Q Were these engineering courses?
15 A Yes.
16 0 Well, just for my information, when did you then 17 first enroll at Auburn?
18 A I transferred to Auburn in the fall of - let's 19 see, I believe I went in early -- the fall of '70.
. 20 I would have to look back at records. I attended a 21 junior college before I went to Auburn.
22 What junior college did you attend?
Q
22 I
A George C. Wallace State Technical Junior College 2
in Dothan, Alabama.
3 Q How many years were you there?
d A It's more'like quarters, but roughly four, I 5
think.
6 O Four quarters?
7 A Yes.
8 Q Then you transferred to Auburn from out of that school?
10 A Yes.
II Q Did you transfer directly into the Auburn 12 Engineering School?
'3 No, I didn't.
A Id Q Can you explain why not?
15 A Well, when I first started college, I started
'6
! in aerospace engineering. The aerospace had roughly
'7 l 20,000 men laid off one year after I was in school. I also
'8 was sick. It changed my aspects toward life and what I felt I wanted to do with my life.
20 I attended a drafting department course at 21 George C. Wallace for six months. As a result, I decided 22 7 d be an architect. I transferred to Auburn in the b
-(.
23 mgc3-4 1 architectural department. In the late fall of '70 or '71, 2 I'm not sure.
3 0 I see. So you essentially started out afresh d'
in either the fall of '70 or '71 at Auburn, is that it?
5 A Not exactly, All.the course work I had taken 6 for aerospace was more advanced than the course work for 7 the architectural department. The courses applied, though, 8 in the case of technical electives in'the architectural 9 curriculum, and what that did was it upset my schedule.
10 and to counter that upset, I took courses in the building 11 technology curriculum and was working on a double degree.
12 O I see. Now after you graduated in May of '75, 13 you became an assistant engineer at Southern Services; 14 is that correct?
15 A Yes.
16 0 Your testimony indicates that you designed 17 outdoor structures on the Miller steam plant. What were 18 those outdoor structures?
19 A Right after I graduated, I worked on the ash 20 trench system, which was a system of structures. It was 21 primarily a trench, concrete canal. It also involved 22 . road structures which were in compliance with ASSHO.
e
- ._ _ wr.._. _ , - _ .
C '$ '
24 p
p.
L- _
mgc3-5 1 Q_ :With what?
f 2 A Bridges, basically.
3 0 What'was the term you just used?
4 A ASSHO.
5 0 Spell that, please.
6 A It's ASSHO ---A S S H O (spelling acronym), I 7 believe. It's American -- that may even be an incorrect 8 one. It's basically the Highway Department code 9 requirements.
i 10 Q For the state of Alabama?
11 A Yes. And I think the federal government 12 requirements were met.
13 0 All right. I'm sorry I interrupted you. You 14 said that you were involved in the design of a concrete is canal trench system and road work?
! 16 A Yes, the road work. I also did piers and l
l 17 abuttments for a pipe bridge that spanned a creek. I did l
18 the concrete piers and abuttments for a bridge for trucks 19 which carried wet fly-ash to the storage pond or dump t
20 area. I basically handled structures at various locations 21 along the piping system from that point on to the storage 22 facility, supporting structures, kick blocks for that I
r= a is 25 mgc3-6 1 system. I. designed the abuttments and. piers for a
-2 rail coal-unloading bridge that spanned that tunnel or that 3 . trench for the coal-unloader at the plant.
4 I designed a roadway to facilitate transportation 5 of the wet fly-ash trucks from the transfer point from 6 where the ash was separated from the slurry, so that the 7 trucks could cross the bridge to this storage facility 8 without making a very sharp turn. -
9 I worked on makeup water lines offsite, thrust 10 blocks, cut-and-fill drainage, and other things. There 11 was many other things I did.
12 Q Let's return to the concrete canal or trench 13 system. What exactly were your design responsibilities 14 there?
15 A It was designed to withstand side loading from 16 soil and water pressure, large cranes sitting next to 17 this structure, surcharge from trucks, because many of the 18 canals ran right next to the road structures. On top of 19 that, it was designed for these large soil-moving machinery 20 loads as surcharge.
21 Q Did you do all the design work yourself?
22 A I did it, and it was checked by another engineer.
f 26 Emgc3-7; I But you were the principal engineer in charge Q
2 of this design; is that --
3 A Yes.
d Then in -- and I take it again, all these items Q
5 you enumerated involved structures associated with the 6 Miller steam plant, Correct, the ones you just --
7 A The ones I just, yes, yes.
8 Then in July of '78, if I understand your testimony Q
9 correctly, you were promoted to an engineer classification 10 called Engineer Roman II?
11 MR. CASSEL: Wait a minute.
12 THE WITNESS: This is my resume, and it's coming 13 off my testimony, but it's a little bit different.
14 I want to check your resume, though.
MR. CASSEL:
15 It's from your testimony, page 10. I just wanted to see 16 if it was on your resume.
17 THE WITNESS: Well, the thing with my resume ---
l 18 okay.
19 MR. GALLO: Do you have the question?
20 THE WITNESS: Would you repeat it?
21 BY MR. GALLO: #
22 0 were you promoted to an engineer classification, 4
n -
27
'70 while you were working at mgc3-8 1 Poman II, in July of 2 Southern Services?
3 A Yes.
4 MR. GALLO: Can I go off the record?
5 (Discussion off the record.)
6 MR. GALLO: Let's go back on the record.
7 (Discussion off the record.)
'DU-2'End 3 8 MR. GALLO: All right, let's go on the record.
9 BY MR. GALLO:
10 0 Mr. Stokes, during the time that you were working 11 at Southern Services as an Engineer Classification Roman 12 Numeral II, you indicate in your testimony that you 13 performed 'what is called NRC 79-02 analyses. Just what 14 is that type of analysis?
15 A Well, actually it was NRC Bulletin 79-02 and lo 79-14 analyses. It's analyses to meet the requirements 17 of those two bulletins. 79-02 is anchor bolts, I believe, 18 specifically anchor bolts, and 79-14 was baseplate.
19 The analysis primarily required a complete reanalysis 20 of structures.
21 0 So the record is not confused, tell me what 22 type of analysis you did with respect to 79-14.
i
28 mgc4-1 1 A -I-performed STRUDL calculations, the structural
=2 . steel stiffness calculations, stress calculations, 3 calculations on the plates.
d What was the purpose of these calculations?
Q.
5- A To ensure that components were within code l
6 allowables.
7 And is the component we're talking about the Q
8 '
L baseplate?
9 A It was primarily geared to the baseplates but L 10 as I said, we redid the entire structure for this work.
l Il Q When you use the term " entire structure," what L
12 are you talking about?
13 A It covered every component from the point of Id attachment to the pipe down to the plate and the bolts.
15 We reverified the entire structure. The attachment to hardware that was purchased was reverified. The load i
17 l capacity, the stiffness, the flexibility of the system l- 18 was reverified in complete, in effect, in performing I'
these calculations, which were specifically bolts and 20 plates. We redid the entire work that had been done.
21 Q Now where were these plates and bolts located?
l 22 A In the Farley nuclear power plant.
e l
l'
[
29
~
mgc4-2 1 0 1Was11t in.the turbine building or the containment 2 building'or where?
3 A The-stuff I worked.on was containment, main d l steam,.all over the auxiliary building. Predominantly 5 all I worked on_was containment. A lot of this stuff 6 was Westinghouse's original scope that we redid ourselves.
7 Westinghouse kept the whip restraints. I don't ' remember 8 -working on any whip restraints during*that time, although 9 I think I did do some field work for Westinghouse as to 10 determining whether or not something would work for.them.-
11-Q What was the purpose of these baseplates?
12 A Baseplates were the transferring load mechanism 13 between the structure and the bolts to the concrete Id structure or supporting structure.
15 Q So on the one end you had the building structure 16 and at the other, the baseplates. Were the embedded in the 37 concrete for the building structure; is that it?
18 A The ones that were embedded in concrete were 19 not part of this program. 79-02 limited the work to those 20 with expansion type anchors, I believe.
21 We're talking 79-14 now?
Q 22 A Yes.
f L .,
e- .
30 4
-i I
~
~mgc4-3 O And the b'seplates, a whet i attached to the 2
baseplates? You? told me one end'ils the structure. What 3
is attached on the other end?
d
-A There's nothing. It sits on concrete.
5 Q What-are they used for?
6 A To transfer load to the concrete. -
7 0 What component sits on the baseplate, if any?
8 A The structure that's attachsd to the plate,
'small-bore, large-bore piping systems, HVAC, electrical 10 conduit structures. Primarily this work that I worked on here was all large and small-bore piping systems.
12 Q All right. I guess that was the source of the
'3 confusion. When you use the term " structure," you are referring to both the building and the equipment components; 15 is that right?
16 l A It is both the structures, yes. One is -- I
'7 use ' structure," if it's the overall building structure
'8 as a structure, and I use " piping support structure" as I'
a structure. HVAC supporting steel is a structure and l~
t 20 electrical conduit supporting steel, all the way including 21 the building is all one continuous structure, as far as I 22 am concerned, if that clarif.ies what I was trying te say.
f l
1 1
^'
l
s 31 I
' mgc4-4 Q- Now-what did you do, what type of analysis did 2
you preform under I&E Bulletin 79-02?
3 A Well, they were mixed. Both functions were d
performed at the same time. I verified that the anchor 5
bolts were acceptable, that the loads being transferred 6
to them through these plates from the structure. I' verified 7
that the concrete could take the load from these anchor a '
bolts.
O All right. You testified that you redesigned
'O the precipitators structural steel on the Miller steam II plant. Can you tell me what a precipitator is?
12 A Well, I said when I was co-op, I worked on the
'3 ash trench system.
That system primarily originated from the precipitator. The precipitator is an electrostatic 15 precipitator. All the smoke and exhaust from the plant to went through the precipitators before going to the stacks.
'7 The precipitators electrostatically removed the fly-ash 18 particulates down to a certain criteria. It was rinned or I'
transferred to water, a slurry system, which was actually 20 pumped from the precipitator area out to the storage 21 facility. It's a very large machine, very large.
22 O You indicate that you were involved in the design t
l
- - l ,, ,
, a- ;
32 Cgc4-5 1
'of the structural steel aspects of the precipitator. Can 2 you explain to me what those aspects were?-
3 A Well, basically like I said, the precipitator is d
a large structure. I'll give you some dimensions. It's 5 maybe 400 feet tall. .It's.400 feet high, 200 wide, 400 long.
6 It's large enough for a football field, roughly. The 7
structural steel then is like a very large building. It's a
built to enclose all the equipment and support it for 9
this --
10 0 That's all right. Did you do the design work 11 for'the structural steel?
12 A The initial design work was done by someone else.
13 And what design work did you do?
O Id A Well, when I was assigned to the project, they 15 wanted to enclose the roof. They wanted to put a crane 16 on top of the roof to remove certain very heavy objects.
17 They didn't want to bring around one of these big boom 18 cranes to lift things off every time, and so they were l'
wanting to add a crane on it. My job was to redo the 20 structural steel analysis for the frame to determine the 21~
loads from this new support, the new structure, to design l 22 it for the wind loads at the plant. It had to be designed 8
{
'ib 33 1
-mgc4-6 1 to withstand a thermal expansion of the precipitator-2 - steel as it heated up to nearly 500 degrees or higher, 3
and at the same time I had to determine the locations on d
the precipitator itself that we could attach this structure, 5.. because the structural steel itself did not go up to that
. 6 level. The top two 40 feet or so was precipitator entirely.
7 There was no structural steel there.
8 And I had to review the precipitator drawings 9 to determine where it could support the loads I was 10 talking about putting on it. I spent some time in doing 11 that analysis.
12 O What code did you design to?
13 A The structural steel was designed to the AISC
(
Id Code. STRUDL was used, as had been used in the original 15 analysis. The STRUDL design code check was used to 16 facilitate verifying that each member was capable of taking 17 the stresses. In STRUDL, the termal loads from the 18 expansion were used to force the frame to stretch. It was 19 used on the analysis of the roof to force the side members 20 to expand outward against the bolts which were attached 21 to the precipitator.
22 The reason for it was the precipitator grew out,
(-
34 L
I. mgc4-7 1 and there was_no assurance that the frame on top would 2 ' expand equally. We did the thermal expansion laterally.
3 It displaced the frame, and the frame was verified for 4 the loads, and the connections were designed to take that 5 load component at the precipitator location.
6 0 STRUDL is S T R U D L (spelling)?
7 A Yes.
e 0 That's a computer code? ,
9 A Yes.
10 0 And this is what you were talking about, applying ti this computer code in the design work you did?
12 A Yes.
13 Q Were you involved in the development of the 14 computer code?
15 'A No. ,
16 0 This design analysis for the structural steel 17 on the precipitator that you performed, did it involve is any seismic analysis that you performed?
pp A Not on the precipitator at Miller, no.
20 0 You also testified that you performed some design gi work involving structural steel of the coal conveyors 22 ~for a fossil plant called Scherer, SCHERER (spelling).
R e
5" L_
c __
35 mgc4-8 1 .Can you explain to me what your design 2 responsibilities were in that effort?
3 A- To design the structural steel again. It was a 4 conveyor system that went from the building, which was 5 roughly'a couple of hundred feet off the ground level. .The 6 system went from that grade, transferred -- it-was a slope 7 structure, went down to grade. It was a series of vents e and towers in between to support the ends of these frames.
9 It, too, was enclosed.
10 Q Was STRUDL used on that work?
11- A No, it wasn't.
12 Q Was any computer code used for assistance in that 13 work?
14 A Not in the steel design, no.
15 O Did the steel design for this conveyor involve 16 any seismic analysis?
17 A Not on the.fosil plant; no, it didn't.
m O Then your testimony-indicates that you left 19 Southern Services in May 1980, and you went to work for 20 Bechtel. And you testimony indicates that you performed 21 analyses for Bechtel. Again,-they're called 79-02 and 22 79-14 analyses.
TT~
-36 i
'Ege4 1 .I assume -- and correct me, if I'm wrong -- that
=2- these are the same as the ones we just_ finished discussing 3 that you performed with Southern Services; is that correct?
d A They were similar in the respect that they were 5 79-02 and 79-14, but Bechtel had their own requirements 6 for meeting those_ bulletins, which differed from the 7
requirements of Southern Services,oso they were different.
8 Q But the I&E Bulletins were the same.
9 A Yes.
10 Now as I understand your testimony, you left Q
il Bechtel in October of '80, and as I understand it, you 12 went to work for Nuclear Services then; is that correct?
13 A Yes. That's --
14 Q You indicate that you worked on Zimmer. What is was the nature of your work on Zimmer?
16 - A Reverification, I believe, primarily. The 17 structure was already there. We reanalyzed the entire 18 structure, the pipe supports.
I' Q You're going to have to help now. What kind 20 of structurr.s?
21 A Pipe supports, the work that Quadrex was working 22 on for Sargent & Lundy was geared to the small-bore piping l
I 1
37 mgc4-10 i systems predominantly. There was some large-bore worki
'2 given to us to do.
3 I also did pipe stress calculations in relation d
to-that work.
5 Now we're talking Zimmer, right?
0 6 A Yes. I was -- well, Guadrex, in the office, 7 they had decided to form a special team that could do pipe 8 stress and pipe support calculations to resolve several 9 systems in the field. It seemed several lines had been 10 run at some distance from any supporting structure, and 11 it-was very difficult for the stress group to decide where 12 to put supporting steel, because they primarily didn't have 13 hanger background, and in any case, I was part of the 14 special team that was taught in-house pipe support and 15 pipe stress design and then sent to the field.
16 0 I see. Now you have to bear with me because 17 I don't understand this engineering analysis very well.
18 When you did these small-bore piping and pipe 19 stress analyses, just how did you perform these 20 calculations? Did you develop the loads, or were those 21 loads given to you by someone else? I'm trying to pinpoint 22 just exactly what your responsibility was.
w :, e- .- -m.- ,
38 1
mgc4-11 1 A Well, the loads were' determined in relation to 2 the pipe supports by a stress group. Now the group that 3 did~that for us in the work we were doing on Zimmer at d ~
Quadrex was another Guadrex group. Later, I became sort 5 of a part~of that group and part of the pipe stress group.
6 And for part of the work, I generated my own pipe stress 7 loads and did the analysis of the structure, but for the 1
8 most part, it was just me taking loads that were given 9 to me and designing the structure or reverifying the i 10 structure for adequacy. I 11 Q How did you accomplish that? Can you explain to 12 me how you accomplished that?
13 A It was the use of hand calculations and computer Id analysis.
15 0 And what kinds of loads were furnished to you?
16 What kinds of loads are we talking about? Static loads, 37 dynamic loads, which one?
18 A Both, l' Did it include seismic loads, too?
O 20 A Yes.
21 What computer code was involved?
O 22 A I believe in doing the computer analysis, a program
39 I
mge4-12 called PIPSYS,'but I wasn't in that group,.and I'm just 2 relying on memory of the system they used, but I believe 3 it was PIPSYS.
d Q- 'P I P S Y (spelling)?
5 A Yes.
6 MR. LEWIS: SYS (spelling).
'End-4 l l
7 MR. GALLO: Excuse me? What did you say it was? l 8 PIPSYS (spelling).
MR. MUFFETT:
9 BY MR. GALLO:
10 Were you involved in the development of this 0 l 11 particular computer code?
12 A Oh, no.
13 Your testimony indicates that you were assigned 0
Id to LaSalle. Did you actually do any work for Quadrex on 15 LaSalle?
16 A Yes, I did.
17 0 And what was that work?
18 A Computer analysis.
19 You'll have to elaborate more.
Q 20 A Piping systems, pipe supports.
21 The same sort of unrt you just deceribed for 0
22 Zimmer?
y 9
40 mgc5-1 1 A Yes, I was primarily running SAGS, computer 2 runs on structures.
3 0 What was the name of this code?
d A SAGS -- S /. G S (spelling).
5 And what function did this computer code serve?
0 6 A It generated stress It's similar to STRUDL.
7 levels.
8 Q Did you work on the development of this code?
9 A No.
10 Q Was your work similar then to Zimmer? You were il given loads, and then you calculated -- determined whether 12 or not the pipe supports were adequate to meet those loads?
13 A Yes. That part of it, I was given loads, yes.
14 0 Did you do any other work at LaSalle besides 15 analyzing pipe supports?
16 A No.
17 Q After you left Zimmer -- I'm sorry -- strike that.
18 After you left Quadrex, you went'to work for 19 Laurence Livermore Laboratory, correct?
20 A Yes.
21 Q Your testimony indicates that you were a stress 22 analyst on the injector to the advanced test accelerator?
O e ?
~
41 mgc5-2 1 A ion the advanced test accelerator.
2 What is-the advanced test accelerator?
O 3 Basically it's a particle beam injector, but I A
d don't think I should get into the ramifications of how it 5 works or anything, because it's part of the Department 6 of Energy's research contract with the lab, and I do'believe 7 I signed an agreement to the effect that I wouldn't really a go beyond what I think I've listed in*my resume or in this
~
9 -document in any discussion of what I did.
30 Well, was it classified defense work?
Q 13 A I was asked if I had ever been rated as a defense 12 security rating. I'm not aware that it's banned.
13 Well, I've asked the question poorly. Did your-Q Id work on the advanced test accelerator involve classified 15 work?
16 A In some respects, yes.
17 0 Was the research work classified that was involved 18 with this particular facility?
'9 A I don't think the research is classified, because 20 it's been listed in a lot of magazines.
21 That's what I thought.
Q 22 A The work I did on the design of the instrument M
42 I
mgc5-3 -
itself I don't believe was -- I've never seen in a magazine.
2 They've got some discussion as to how it works, but not 3 to the knowledge level that I hold.
- d Well, can you tell me what the advanced test O
5 accelerator does? What is its function?
6 MR. CASSEL: Before you answer that -- Joe, --
7 THE WITNESS: I did. I've said it already.
8 It's a particle accelerator. The injector creates the 9
particles that are --
10 BY MR GALLO:
Il O Is it involved in the research of high-energy 12 physics?
13 A Yes, among other things.
I4 Q Now your testimony indicates that you were the 15 test analyst on the injector to this machine. What is 16 the injector?
17 MR. CASSEL: I'm just concerned about getting 18 into any areas that may be --
19 (The witness and counsel confer.)
20 THE WITNESS: I'm not going to go beyond what 21 Ieve already said. It created the particles that were 22 injected -- electrons, protons. I mean, I'm not going to l
7.
43 mgc5-4 get into how it did it. I'm not going to describe it in 2.
- more detail. I'm.just going to say that it created those
, 3
. particles for acceleration by an accelerator.
A If you want to know more about how it works, 5
I suggest you call the lab and ask them for a tour.
6 BY MP.. GALLO:
7 O Do you know how it works?
8 A Yes, I do. Most definitely. i 1
9 I Q Now you indicate in your testimony that you were j a stress analyst. Just what did your job responsibilities 11 involve as a stress analyst?
12 MR. CASSEL: To the extent you can say without
, breaching any confidentiality.
14 THE WITNESS: Well, there was a mechanical 15 designer who did basic layouts for the components. It 16 was also a group project by Physics and other groups for 17 the component shapes. So initially there was some drawing 18 made up of a component. I analyzed that drawing, shape, 19 object, for the loads that would be exerted on it from 20 the machine -- electrical, mechanical, pressure, vacuum, 21 lack of pressure, radiation, seismic load. I analyzed 22 that component for every possible load that could be applied
44
(:i I
-mgc525- to that-componentLin California.
2 BY MR. GALLO: ,
3 0 Did you define those loads, or were they given d
'to you by some other group?
5 g 7 defined those loads predominantly. I was given 6
the magnitude of the electrical field that would be 7
exerted on them by the Electrical Department. The Physics 8
Department specified certain other criteria that they had 9
to comply with, but I generated the loads myself.
'O Q And did you generate the seismic loads yourself, il too?
12 A Yes.
I3 0 How did you do that?
Id MR. CASSEL: Are we getting into a confidential 15 area with that question?
16 THE WITNESS: No. It's a UBC, at the University I7 of California --
18 MR. GALLO: I would like to state for the record that it's my belief that what we're talking about is a 20 part of the Department of Energy's high-energy physics 21 program, which is unclassified, and the only thing one has 22 to concern oneself about is whether or not it involves l
1 E l
I
'45 mgc5-6 1 proprietary information, and most DOE work does not involve-
- 2. proprietary information. Otherwise it would not be a 3 national laboratory.
4 MR. CASSEL: I-have no reason to agree or disagree 5 with your belief, Joe. .I'm not familiar with the program.
6 I'm only concerned that I want the witness to be very 7 careful that he doesn't go beyond any agreement that he may 8 have signed, whether it's based on proprietary or security 9 or whatever. He's not charged with knowing what the basis 10 for the agreement was.
11 MR. GALLO: Let's establish that for the record, 12 BY :IR. GALLO:
13 Q Did you sign some kind of agreement when you left t
14 LLL?
15 A I think I signed some when I started at LLL.
16 Q What was the nature of the agreement?
17 A It had to do with drawings, calculations, 18 references to this instrument. No removal, taking nothing 19 with me. I don't believe I -- I'm not sure if it stated l 20 I shouldn't discuss it.
21 Q Do you remember whether or not it was a 22 confidentiality agreement that barred you from talking G
s
,.a
46 I
~
mgc5-7. about certain things?
2 A At this moment, no, I can't say that it barred 3 me from discussing it. It's on my resume.
1 All right.
Q 5 A But I don't think.they want me to sit down and 6 draw the parts out and build -- you know, show you how 7 to' build one yourself. If that's what you mean by a confidential, I think they want me to keep it in my head.
9 I don't think they'd want Russia knowing how they built 10 theirs, if that's what you mean. I think that's confidential, i
)
11 yes. l l
1 12 Well, Mr. Stokes, do you or do you not know O
13 whether the work you were involved with was classified?
t Id I submit to you that --
15 A It wasn't classified as top security classified, 16 if that's what you re getting at.
17 Was it classified as restricted data?
0 -
18 A It was restricted, yes.
19 It was restricted data, as that term is used by Q
20 the Department of Energy?
21 A I don't know what you're saying, "by the 22 -Department of Energy." I was working for the lab, and it mismo 4
47 i: I mgc5-8 was restricted as to how the lab could use it when I left 1 2 the lab.
3 0 'Now you say you signed this agreement when you d took the job'at the lab. Did you sign anoth'er one when 5 you left the lab?
6 A Iem not aware. I don't remember signing one, no.
7 0 Do you have a copy of this agreement?
8 A No. '
9 Let's get back to the definition of 0 'All right.
10 the seismic loads for the stress analyses you did. I' asked 11
-you the question how you performed -- how you determined 12 or defined the seismic loads that you used in your 13 analysis. Can you tell me that?
Id A I consulted the UBC, the Uniform Building Code, 15 which is used in California to discuss the seismic loadings.
16 0 So you went to the Uniform Building Code. And 17 did it have a load value that you took out of the code 18 and used in*your analyses?
19 A It had equations for deriving the loads.
L 20 0 And that was the load that you used, then, in 21 your analysis or -- strike that.
22 That was the load that was used in your stress
(
48
'(
lmgc5-9 1 analysis for the injector?
2 A I may have factored the load myself, but --
3 0 What do you mean by " factored the load?"
d A I may have added an additional margin or safety 5
factor of my own to the load rating to ensure that the 6
component's integrity would not be damaged.
7 Q Do you remember whether or not you did?.
O A At this time, I can't say for sure, no.
9 Q After you left Lawrence Livermore Laboratory, 10 you went to work for Reactors Control, Incorporated.
II According to your testimony, you worked on control rod 12 design systems for Grand Gulf.
13 MR. CASSEL: Control rod drive systems, I think Id it says, Joe, not design' systems.
15 MR. GALLO: You're correct. Let me restate the 16 question.
17 BY MR. GALLO:
18 0 What was the nature of your work with respect l'
to the control rod drive system that you worked on at Grand 20 Gulf?
21 A I was hired as an interface between the Hanger 22 Group, which was handling the -- the Hanger Group was RCI.
49 L.
mgc5-10 1 They had in-house personnel doing hangers. I was an 2 interface with the Piping Analysis Croup, which was being 3 done -- or I was contracted to a firm that all I know is d I was hired to-perform field functions by an acronym, ECIIO.
5 for those two groups, and primarily to interface between 6 the two groups as to whether or'not a support could or 7 could not be built at a location as affecting stress to 8 the pipe and as to whether or not, from a hanger analysis 9 approach, could or could not be built.
30 My background in both stress and supports was il the primary reason for me being given that position. I 12 resolved problems when Stress requested a hanger that 13 couldn't go where they wanted it because of hanger Id configuration problems, by suggesting different locations, 15 based on my stress analysis background, which would be 16 accepted on a point-blank basis.
17 I was responsible for verifying the system's 18
. flexibility, that the surge from the pressure suppression 19 pool, deflection of the slab it sat on, could be taken 20 without jeopardizing the system.
21 I was responsible for verification that there 22 is no non-safety-related system or component within the L--..
F g ., 50 mgc5-11 vicinity of those Class I lines which would interfere 2
with that'line in a seismic event. I basically was like-3 the mother to.that system. I did a let of-things to ensure d
.its integrity.
5 0 Now if I understand what you just told me, 6
you a re talking about supports for piping systems; is that 7
correct?
8 A It's the control rods, their piping systems.
They're three-quarter, one, two-inch lines, inch and a half to lines that control the drive lines. I don't remember if they have water or air. It seems like they were water-12 filled. Water was used as the hydraulic medium in that
'3 plant.
Q And these piping systems, are they located inside 15 containment?
16 A Yes.
37 Q And if I understand your function, if a support,
'8 piping support, was required to be installed at a certain location and there was something in the way, an 20 obstruction, and it couldn't be located there, then it was 21 your job to make a recommendation as to where it might be 22 BU3 located?
l.
1 I
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mgc5-12 A .That was one of my functions. I 2
Q How did you go about making that determination?
3 A I relied on the years I've spent in engineering, the training, the knowledge I've gained.
5 O Did you corduct any kind of analysis to determine-6 that you had selected the right location?
7 A It was based primarily on experience, background a
knowledge of the system operation. I. basically -- basically 9
pipe systems are an intuitive analysis approach. If 10
.you've got a restraint on one end, the pipe is thermally II growing somewhere, it has to grow to the other end. If 12 it's restrained on two ends, you have to have sufficient 13 offset to allow it to deflect at both locations.
There's many aspects to making that kind of a 15 determination, but basically it was walkina the system 16 down, looking at it, looking at how it was restrained,
'7 1
looking at its attributes, how it was designed initially,
'8 getting a feel for how it moved when it's heated or exposed to certain load displacements of certain types, 20 and then making a decision. And they wanted someone who 21 had enought experience to make that decision and suggest that location and not have it turned down, not have to do e
rs- I
.. :: l l
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'? mgc5-14 l' care what- was on the. original _ design. We as-built it l 2 as'it was there, period, irregardless of what was there 3 on the original design.
d O So you recorded the as-built condition on drawings 5 and sent those to your home office?
6 A Yes.
7 End'5 0. Did you have any other job responsibilities 8 besides the two we just mentioned?
9 A I worked with the Hanger Group in suggesting' that 10 certain loads be placed on different hangers, by requesting 11 that Stress not hang a support in a certain location.
12 I also assisted the Hanger Group in suggesting 13 ways of design that they could do in the field, based Id on constraints of construction which the office wasn't 15 knowledgeable of.
16 I generated ECNs eventually, Engineering Change 17 Notices, modifying the structural steel on the supports to 18 the configurations necessary to comply with both the l9 Stress Group requirements and Hanger requirements, and they 20 were issued from the field, and I worked with the 21 Construction Department, because in many cases some of the 22 stuff we wanted to do, I had to get their inputs because k
i l
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53 ya
)
.'mgc6-1 of constraints of~ space and visibility of whether it could 2
be done, and I also worked with the QA Inspection 3
Department, because they were working on other parts of the d
systems we were assigned to.
5 I said I was primarily working in the control 6
rod drive system. I also assisted other engineers in 7
other groups which were working all throughout the Reactor 8
Controls' work. I resolved interferences on drainage lines 9
that were jeopardizing the systems. Quite a few other 10 functions.
" Q Now you left Reactor Controls, Incorporated, and 12
.then went to work for Bechtel and was assigned to the I 33 Diablo Canyon plant; is that' correct?
(
Id A I was assigned to the Diablo plant when I went 15 with Bechtel, yes. Actually it was with PG&E.
16 Q Did you do the same kind of support work you've 17 just described for Grand Gulf and Diablo Canyon?
18 A No. I performed calculations similar to what l'
I did in the office, as well as providing the same functiens 20 which I provided at Grand Gulf, for the most part.
21 0 What calculations in the office are you referring 22 to?
l l
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54-I Computer analysis, hand analysis, pipe analysis.
-mgc6-2 A-~
2 These were analyses of the supports to determine 10-3 whether or not they.could withstand'the loads that had been determined?
5 A Yes.
6 0- Did you define'these loads, or were they furnished to you by others?
8 In some cases I determined the loads, as I had A
at Zimmer'for-~the Zimmer plant.
IO Q What loads did you determine?
II A Piping loads.
12 Did you determine the Q What loads on_the piping?
I3 static loads?
I#
A Static, thermal, thermal accident, seismic.
15 Q You determined the seismic?
16 MR. CASSEL: Had you finished your answer to I7 that question?
'8 THE WITNESS: Yes.
I9 BY MR. GALLO:
20 Q For Diablo Canyon, is it my understanding that 21 you defined the seismic loads for the piping systems that 22 you were involved with?
'\=
.L' 55 mgc6-3 1 A- ,I' derived the seismic loads for some of the
-2 : systems, yes. I didn't say all-of them.
3 O How did you do it-for the ones that you did do it 4 for?
5 A How did I do it?
6 Q Yes.
-7 JL I determined the location in the plant of the 8 system. The system was within a certain span requirement 9 which dictated the flexibility of the system and frequency, 10 used the seismic acceleration curves for that particular 11 area of the plant to determine the acceleration of that 12 component, based on its frequency or damping factors for i
13 the structures attached,-and then applied the accelerations 14 for.the structure, generated-the seismic forces.
15 Q Now did you develop the seismic acceleration 16 curve yourself?
17 A No.
18 0 Who did that?
'19 A I believe they were generated by a company called 20 Blume & Associates.
21 Q BLUME (spelling)?
22 A I saw that frequently on the forms, yes.
56 mgc6-4 l Did'you develop the accelerations for the-
_Q 2 - building ~ itt, elf ?
3 A' No.
d ,That was' furnished to you by others?
0 5 A Yes.
~
6 So I understand you took-this information out O
7 of documents that were furnished to you-and then. conducted 8 the seismic' calculations; is that correct?
9 A 'Yes.
"3 Q Now, Mr. Stokes, in your work experience, have 11 you ever performed a structural dynamic analysis of a 1
12 reinforced concrete building?
13 A Yes.
~
Id And can you tell me what building you performed Q
is that analysis-for?
16 A I believe it had to do with the structure that 17 was supporting the injector at the lab. I did some work 18 on the review of that building.
19 Well, did you do it or -- yes or no?
0 20 3- I didn't do the original design of that building, 21 no.
22 I guess I'm confused by your answer. Are you Q
O
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mgc6 I telling.me'that while you were working at Lawrence L
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2 L'ivermore Lab that you' performed the structural dynamic 3
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analysis on a. reinforced' concrete building?
d A Not at the lab, not on the building per.se.
5 On the components'that I was working on, which were steel, o
and they came off the concrete, so I had to'do some 7 ~
analysis, but it wasn't directly related to the building --
a the' design.
9 Have you ever performed any dynamic modeling_on Q
10 a reinforced concrete structure?
11 A I have performed computer modeling for dynamic 12 load cases of concrete and steel at various times, yes.
13 Now I'm talking.about reinforced concrete Q
L Id structures.
i 15 A Yes.
! 16 You said you did computer modeling?
Q 37 f A Yes.
18
, -Q Could you identify what type of modeling you l
39 l are referring to?
20 A Well, a computer model for seismic could be a 21 very detailed analysis of the structure itself. If it was 22 a column, it could be simply a stick model, a cantilever s
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58 e mgc6-6 l' stick.model. All you'need1is to generate a displacement 2: and chsck the; frequency lof it. You don't really need 3 a computer model'for simpleJcantilever. You can do it by 4
' hand ~ calculations.
5 For a complex structure, boxed structure, 6 something with shear walls _and reinforcings of.different 7 natures and shapes,.you could do it simplistically using-8 a hand _ analysis, but to get a much better feel for what's 9 happening, a computer analysis would'be required.
10 Have you ever done that?
Q' II A Yes.
12 Where did you'do that?
O 13 A I did some work at Southern-Serv ices before Id I ever started working as a consultant.
15 So while-you were at Southern Services, you did O
16 some dynamic modeling of a reinforced concrete structure?
17 A Yes.
18 Now could you tell me when this occurred?
Q 19 A .Not specifically, no.
20 Can you identify the structure?
0 21 A The actual item? Not at this time. I've done 22 an awful lot of things over the years.
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.O But you're sure youve done dynamic modeling
, 12 of a, reinforced' concrete'struc'ture? ,
~ 3- A- Yes. :And' steel struct'ures.
'DoLyou consider yourself an expert in'the field-d Q
..5: of structural engineering? -
h 6- A You'd have to" define " esp'ert." I'm sorry.
7' I' don'tl consider mysel. an expert in my term of the 8 knowledge'oflthe word "expe'rt." I'm not'sure thatnif I
' lived-to be 'a'hundred and I continued to work in the field,
~
- 'O I'lliever consider myself an expert. Some other people 11
'might consider me an expert, ba' sed on my knowledge of what 12 I've.done and background.' But to be real honest, I don't 13 -consider myself an expert at anything. I'm not sure Id that there is such a thing, if you want to know the truth 15 of the: matter.
16 MR. CASSEL: What was the field that you 37 ' identified just then, Joe, in your question?
18 MR. GALLO: Structural engineering.
19 BY.MR. GALLO:
20 Can you tell me what NRC Reg Guide 1.60 is?
Q 21 A 1.60?
22 Yes.
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.ngc6-8i il - A .. Not' right of f: the top l of my head.
s - 2 Q. :Have you finished your answer? \
3 .A Lyes.
'd Q Doesithe term " rock site"~mean anything to you?-
5 A~ URock ' site?. SITE (spelling)?
6 0 Yes.,
7 A The two..words-mean something to me, and as used 8 in conjunction,;they mean.something to me, yes.
9 Q Can-you tell ne what they mean to you?
10 A It me,ans the. site is rocky, I would assume, 11 rather than being sandy or some.other structure.
12 0 - Have you ever' been involved in determining the 13 seismic response spectra for a reinforced concrete 14' ' structure?
15 A For determining the spectra? No. j 16 Q For any kind of structure?
17 A I've never done any spectra generation.
18 Q Do you know what the SSE for Byron is?
19 A Safe shutdown earthquake is what SSE stands for 20 in most places.
21 Q Yes.
- 22 A Do I know what it'is specifically?
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e p 2 A- LNot right'off~the top of my head.
j; 3' O. Do you know-what it.is for the operating basis 4 earthquake?
e 5' A No, not right off the top of my head.
.6 -Q .All right, Mr. . Stokes,'we're going to make 7 - Mr.nCassel happy. 2We're going to get off your professional u
8 qualifications.
9 MR. GALLO: Let's take a short break.
End 6 10 (Recess.)
I' MR. GALLO: Let's go back on the record.
12 BY MR. GALLO:
13 Q I have a series of questions I want to ask you 14 about your testimony, Mr. Stokes. but first I want to make 15 sure that I understand the thrust of the testimony. I am 16 going to characterize it, and you please correct me if 17 I'm wrong. l l
18 Does your testimony raise questions concerning 19 the general design criterion assumptions used by Sargent & 4 1
20 Lunder in~the design of the Bryon plant?
21 A That's the whole question?
22 Q Yes.
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62 i
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mgc7-1 1 A Raise questions about?
2 O Yes. Do you want me to repeat the question for 3 you?
d A I believe my testimony is that I have questions 5 about -- not raise questions about. I have questions about.
6 Q. You have questions about the general design 7 criterion assumptions used by S&L with respect to the 8 design of the Byron plant?
9 A Yes. Yes, some of them.
10 Q Well, you are cuestioning generally the adequacy
? of the design assumptions and design criteria, as you have 12 explained it in your testimony; is that correct? ,
13 g yes, Q Would I also be correct in concluding that is because, in your judgment, inadequacies exist with respect 16 to the design criteria and assumptions used by Sargent &
17 Lundy, that you believe an independent design review should 18 be conducted at Byron?
19 A At this time, that's my belief; yes, sir.
20 0 All right. In Answer 10 of your testimony, 21 you refer to a design document, and I believs i+.'s clearly 22 a Sargent & Lundy design document.
y
/
63 mgc72 2' Can-you tell me what-your understanding is of 2
the purpose of that document?
3
'A The purposeJof that document, as explained in
- that document, I believe was that it would be the working 5- document for the Engineering Department, developing the FSAR.
6 requirements into a working document to be applied, but that 7 it would-not exceed the FSAR-requirements nor change any of t'.e FSAR. requirements, that-it was'to be specifically 9
-a_ document geared.to meeting the.FSAR requirements for the 10 design of the plant.
O Is that the general design document, then, that' 12 was used at Byron, as you understand it?
'3 A' Yes.
14 Q Now you point to several shortcomings, as you've 15 said, in this document in your testimony. I have a series 16 of questions with respect to those.
l' On page 9, what you identify as Point 1, you
'8 refer to a mistake that occurs in the formula, Section 12.2.4.
i Can you tell me what type of design work is covered by 20 Section 12.2.4?
21 The area is subgrade walls in structures.
A :Yes.
22 When I read this, I should I believe that's the section.
- 7.
I w p5 ~- 164
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mgc7?3 't state,'Section 12 has a specific. title, and I wasn't-
'2- looking-at'the' title..so much, but-the formula applies-to,-
, .3- -I believe, a subgrade wall'.
4 -Q This would be the design of concrete structures 5 below grade; is that correct?
6 'A Ye S '.
-7 Q Now do you know what contractor at the Byron 8 site'did the work involving the pouring of the concrete 9 'for.these structures governed by Section 12.2.4?
10 A- Not really. I don't.
-11 O And to your knowledge, you just don't know who 12 did this work; is that correct?
13 A I know who did the design work, S&L. I don't 14 know'what~ contractor actually built those structures in the is field or all the structures, if it was one contractor or 16 multiple contractors, if that's what you're looking for.
17 Q All right. Turning the page, you refer in
.is Answer 12 to Section'19.5.d. Do you know what design up ' work this'particular section concerns?
20 MR. CASSEL: Objection. It's ansacred right 2L .there in the answer, to the extent the witness knows.
22 THE WITNESS: Yes.
P i
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-BY MR..GALLO:
s.
2 -Q Well,cis-it' involved - -is my' understanding-correct th'at'it involves the concrete turbine foundation?'
~
3 d'
A Yes.
5 :0 And are you concerned with the torsional. stresses 6 to that foundation?
7 ;A I am concerned with'the equation, and that is-8 concerning'the. torsional stresses,.so yes.
9 Do you know whether or not this-is safety-related Q:
10 work?
11 A The turbine foundation?
12 O Yes.
l 13 A I believe it is safety-related, but I can't-14 -guarantee that at this time.
15 Q But you believe it is?
L 16 A Yes.
17 Q Do you know what contractor at the Byron site
~18 did this work?
19 A Again, I don't know who would have built the 20 turbine pedestals themselves, no.
21 .Q The bottom of -- the last paragraph in your 22 Answer 12, you refer to Section 32.3.2, and you state that i
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mgc7-5' ~1 this section relates to buried piping.
- 2. Could you define better for me what you mean by 3 buried pipe?
d A Section 32 is concerned with buried piping. .That's 5- piping-that's had a hole dug for.it, and dirt or gravel 6 or some kind of fill material placed on top'of it. I don't
.7 believe'that-section covered buried piping in the relation 8- -that it was encased in concrete, but I'd have to review 9 the.section-to get any more specific.
10 0 Do you know whether or not this buried piping 11- covered lar this section involved safety-related work?-
12 A Not specifically, no.
13 Q Does that mean you don't know, or it doesn't 14 involve safety-related work?
15 A I can't say. Some of the things I raised here 16 were not' safety-related. I simply went through the 17 procedures and pulled out things which were questionable 18 from just visual contact, and then I reviewed it in a 19 document to ensure that it was incorrect. I never intended 20 here to be strictly safety-related items. This item 21 could be safety-related. There are some systems that may 22 be, just-like I said --
, , , s, ~ , . . ,
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- .67
,. s limgc7-6I'" 1 0 1But:Lat thc. moment, you just1do'n't know?'
'2. A. No, sir.: Specific knowledge, no.
, -3 g- 'Do you know-who-the contractor was'who installed'-
4 'the: buried piping-covered by.this section?
S ~A- ENo', I. don't.
~
r-4 16 -g. Now you refer again to! buried-piping in Answer 14',.
~7 Land you also refer'to the section that covers this buried- ,
'8 piping,132.4.2. Is thisithe same type of buried piping 9 -covered by.the previous section'that we just' finished 10 discussing?
11- A It's.in Section 32. I would assume it's the_same, 12 yes.
L E 13 Do you know whether or not this piping is Q
Id . safety-related?
15 A I'm afraid I don't, no.
16 Do you know who the contractor was who-installed Q
17 this buried piping?
18 A No, not at this time.
19 Mr. Stokes, I think perhaps in Answer 14 there I O I'- 20 may be another typographical error. Is the reference 21 to " Attachment 1," should that be " Attachment 2."
' 22 A In 14?
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2 MR. ~ CASSEL: The next to the last'line there.
3 ~Yes, it should. Yes, Attachment 2, THExWITNESS:
d I'm sorry about that.
~not 1. -l'is my resume.
it S- BY-MR. GALLO:
6 O Now in this sentence it refers to what we've 7
~
f now corrected to be Attachment 2. You refer to other 8 apparent errors that are listed on the attachment. I am 9 just getting Attachment 2 out for my own use.
"3 First of all, did you prepare this document?
i II A Yes, I did.
12 Now are you suggesting by your testimony that O
13 beyond the items'that you've already testified to in your ld testimony -- and I think you've numbered them 1 through 6 --
15 that these other items also represent errors or deficiencies 16 in the design criteria used by Sargent & Lundy?
17 A Some du. Some were placed on this list as 18 being the section that caused me the concern about others.
l
'9 So in some respects, it is -- the other things are 20 deficiencies, errors, oversights, whatever you would like 21 to term then, but some of the things are -- well, for 22 instance, take the fifth one down, Section 18.1.1 on i.
l l
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- ,mgc7-8L j
- Attachment 2.
2 MR. CASSEL: 'That's the fifth-one down on page
'3. 2.of Attachment 2?-
~
4' THE WITNESS: -Yes. Section 18.1.1. It;says, 5 "Allcdesign assumptions, methods, references-and materials 6: shall be defined for each area of design using standard 7 calculational summary sheets."- That, in'itself, is not 8 _ an error, not a' deficiency. If anything, it's what should 9 have been done. Other listings here indicate that wasn't 10 done in.all cases,1or other aspects of my testimony. state 11 that it wasn't done.
12 BY MR. GALLO:
13 Q All right. Let's take that one. What other 14 aspects of your testimony indicate that this wasn't 15 -done?
16 A Well, in my deposition earlier, I stated there 17 was a phone conversation that was not documented. Specifically 18 in my testimony at this state, it would be, on these 19 items listed here --
20 Q In Attachment 2?
21 A In Attachment 2.
22 O Can you tell me what item that is?
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- mgc7-9 1- A 'Well, these are-all.the.S&L procedures.
2 cI'm sorry. There won't be any here, because 3- the things:.I'm discussingfhereiwould be'inithe calculations.
24 That wouldLhave tx) be a: listing of the calculational-25 deficienciesiinstead of the S&L~ procedural.--
6 Q Are'these calculational _ procedures you just 7 referred to,'are they contained in your. testimony 7' 8 A 'At the moment, I think I didn't raise any. I-
~
9 think I omitted them. I can't remember a specific example 10 where I did mention any calculations.. I know in my haste 11' to do this,-I may have just simply omitted things that I had-12 . initially planned to put in my testimony.
13 There are others beyond what's in my testimony.
14 MR. GALLO: All right. This is a good break 15 point for me. Why don't we just break for the noon lunch 16 and come back at one o' clock?
17 MR. CASSEL: Fine.
18 MR. GALLO: Okay.
19 (Whereupon, at 11:50 a.m., the taking of the
~
20 deposition was recessed, to reconvene at 1:00 p.m. this 21 .same day. )
22 l
1 l
71 ml mgc8-1 1 -AFTERNOON SESSION
-2 (1:10 p.m.)
3 -Whereupon, 4 CilARLES CLEVELAND STOKES 5 resumed the stand and, having been previously duly sworn,
- 6 .was examined and testified further as follows
7' EXAMINATION (CONTINUED) 8 BY MR. GALLO:
9 Q Mr. Stokes, referring to Answer 15, does 10 Section 34.2 deal with the general subject of the 11 installation of embedded plates?
12 - A- I'm not sure if that's the overall topic for 34.
13 I would assume it was, the way the rest of the dccument 14 was structured.
15 0 All right. What are these plates embedded in?
16 A The plates are not embedded. They're -- well, 17 they're recessed in concrete when it's poured. The 18 attachments on the back of the plate are embedded in 19 the concrete. Studs are embedded in concrete.
20 0 What are the plates used for?
21 A Attaching various components in the plant to 22 the foundation.
L
7 72 mgc8-2 i- Q Do you know what contractor installed these 2 plates at_the Byron site?
3 A- No, I don't.
4 Q In your Answer No. 17, you say that you saw a 5
12-inch line that had a strut to the embed plate on the 6 wall. Can you tell me what 12-inch line you are referring 7 to?
8 A This was the Saturday that I come in to the NRC 9 Judges, and it was -- we stopped at this location, and to it was pointed out and discussed in thorough detail. I 11 attempted to write down the line number, and I did write 12 down a number, but I don't believe I have it with me. I 13 didn't put it in the statemant because I felt it was 14 obvious to enough people that were present that day that 15 I wouldn't have to have it, and I'm not sure the number 16 I had would be valid for the line anyway.
17 Q Do you know what kind of line it was?
is A I don't remember what system it was on, no.
19 Q Where was it in the plant?
20 A You're asking the wrong person. I wasn't leading 21 the trip. It was in the auxiliary building, I believe, 22 but not having a lot of familiarity with the plant, I couldn't e
n7, -
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[ 73
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p P mgc8 'l say, bec'ause I wasn't ---I was' led, so to ~ peak, to the
'2 point, and that's.all I can say.
[
3 .What type of strut was it?.
[ .Q b d A .Indon't know who made it, if that's what you mean.
l 5 Just a steel beam?
Q.
6 g L Well, it was made out of a Combination of pipe, 7
~a couple of swivel connections, a threaded section, some 8 nuts, I believe. There was a pipe clamp, an end bracket 9
for attaching it to the steel,.a pin.
IO You say in your Answer 17, in the third sentence, Q
11 you' indicate that if there were a large load on the strut, 12 then you could conceive of a problem.
h I
13 Do you know whether or not there was, in fact, 14 a large load calculated for that particular strut?
15 A No, I don't. I base that statement on the fact 16 that the large strut would not have been required, had it 17- not been such a large load. They could have used a much 18 smaller strut to take the load, and I based it on my 19 previous knowledge of how large the strut was and the 20 load ratings for various components, and estimated the 21 load for that structure based on that.
22 0 You say you estimated the loading for that
- N
O 74 mgc8-4' I structure?
2 -A: Yes.
3 0 'AndLwhat was that estimate? 15 to 20 kips?
d I would guess the load would have'been A' Yes.
5 .that magnitude or more.
6 And this observation is based-solely.on your 4
O' 7' visual observation of this strut? -
8 A That and'the pipe, how big the. pipe was and the-9 location to the-elbow which was very close by. Various l' factors. But I was very.- I tried to be on the 11 conservative side of that estimate.
12 Did you see other examples'such as this when O'
13 you toured the plant?
14 A I didn't actually get to tour the plant in the is way that I like to say it, and for that reason, I didn't 16 see any more on the tour that I was on that day, no.
17 I'd like to add a few lines to that. The tour is was a quite fast-paced tour, just watching where I was 39 walking and trying to keep up with the group required my 20 utmost attention. I tried to get the tour slowed down, 21 so that I could actually sort of stroll along and look 22 outside of along where I was standing. That was not Lf
y 75-
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- 1 imgc8 ~1 possible.
2' It appeared thattthe tour was st'ructured more
~
3 for the Judges, and'that they. wanted to keep. it at a very.
4 fast-pace for them. For that reason, I didn't see any more.
5 Q' Thel tour that you're referring to is the one that 6 the Judges = requested be conducted for them during the' 7 . hearings at.the last session?
8 A - Ye s . -
9 Q Let's assume that your visual observation.is 10 correct,-that-the load on this particular strut and baseplate-11 appears to be 15 to 20 kips. Do you know whether or not 12 that particular strut and baseplate -- embed plate, I should 13 say - -could withstand the safe shutdown earthquake for 14 Byron at the load that you estimated?
15 A On my past experience, if that's the load, the 16 anchor bolts embedded in the concrete would pull out if 17 the concrete or the allowable stresses would be exceeded at is that point, at some point below that, even if they were 19 immediately under it or off to one end of it, and I would 20 say,. based on my experience, that I would question that 21 - particular embed capability of taking that load, yes.
-22 Q Do you know whether or not the safe shutdown 1
l
n'
~-
76 9
mgc8-6 1 Learthquake for Byron could generate that load at that 2 : point?
3 -A No, I've not done enough research to determine d- that.
5 -Q Let's refer'to Attachment 3. Before we do that, 6 I have another question I want to ask you about your 7 Answer 17.
8 Do. you know -- again referring you to the 9 strut and embed plate that you observed in the field --
H)- do you know what the type or the size of the studt were on 11 the back of the plate for that particular location?
12 A In relation to the section that we discus.ied 13 carlier, 30 -- under the embed loading plat design section, 14 which I-can't seem to find at the moment --
15 0 34.2.
16 A Yes, I believe that's it.
17 It appeared to me that in the structural analysis, 18 there is only one size bolting used for a specific width 19 plate. They used three-quarter-inch plate of nine inch 20 width. They.put studs on it in a particular pattern at 21 a particular spacing. There was no variance in that, 22 according to the criteria. There is a six-inch plate that I
l
p ,.;-, - - - - . . -
o 77
-mgc8-7 - was a half inch thick, and the stud pattern on it was
~
2 varied, but what was on the'nine-inch plate, it was 3
- staggered from one side to'the other. There was a specific d size stud used on that plate, and according to the criteria, 5 -
both type plates were designed for_the exact same loads, 6
10 and 12 kips, I believe.
P 7'
O So you are assumine that the studs around the 8
plate -- ,
A Were exactly as the criteria require them to lx3
'O for the width of that plate, yes.
II O And that's based on your reading of the 12 Criterion, Section 34.27
'3 Not seeing a calculation, just seeing the A Yes.
'd criteria.
IS All right. Now let's try Attachment 3.
Q 16 Now did you write this document, at 1 east the ,
37 first page of Attachment 3?
18 A I prepared it, yes, sir.
l O All right. And the balance of the page that is 20 Attachment 3, where did they come from?
21 A I believe they were prepared by me or typed from
- 22 a document and prepared by me.
ch
( '
78
! . l I
_mgc8-8 -Q: 'Are you sure?
2-A= Oh, wait a minute. No. It appears to be a ---
~3'
.oh, it's copies of a document, DC-ST-03-BY/BR. Those are id
'the specific r.ections that-are referenced in the document 5
'on Attachment 3 that I've noted.
It shows exactly how 6
they're. stated,-listed and so forth.
7 OL Now looking'at the first-sheet of Attachment'3, 8
you've got various section numbers listed in the next.to the lefthand margin, and then there are statements appearing 10 after each section number.
What is the significance of these statements?
12 Perhaps I'll let you take them one at a time for you to
'3 answer them adequately.
A Well, the significance to me -- in some cases
-" I spelled it out, like, "Section 37.2. No definitive 1 6 statement that torsional stresses should be checked."
'I If you look at Section 37.2, it says these
'8 eccentricities can cause torsional shear and warping eccentricities. Now it lets you know that they are 20 concerned about this, because they state-it, and the 21 problem with it is, there's no definitive statement as to 22 how you should approach this torsional shear and warping
- . - - . - - -- , , - - , - ,--,-_y
r.
~
79 V
-? _mgc8-9 I stresses'or whether'or.not you_should check for it. -It just 2- says these can cause-problems..
3 0; 'Do you think this statement should contain that d ' statement?
5 iA This one or subsections of.this, which the later1 6 . sections,.if you_look at':37.2.1.g.2.C, 37.2.1.g.3.C, all' 7 'the C's seem to.be' torsional analysis not required, so they-
-8 did address it. They said you don't have to address it, 9 basically _is what the bottomline came to -- the total 10 section.
11 -Q So did that cause you some concern, then?
12 A- Yes, it-did.
13 Q What is your concern?.
14 A That they were neglected.
- 15 0 The
- j should have been considered; is that right?
1 16 A They should have been considered as to the level
'17 of criticalness as to the allowable stresses that they l 18 could-have affected.
l 19 Q Looking at the second item on the first page 20 of Attachment 3, you indicate a statement that says,_
21 " Deflection and rotation of primary structural steel 22 ignored in deflection check," and then there's in m
.~
80 mgc8-10 1 parentheses a question mark, and then the-words, " Members
- 2. with pinned ends."
~
3 .What does that mean? What'did you intend by 4 this question' mark?
5 A' It's a question. mark. It's a question to myself.
6 This was made.up to flag things to me. Everything on here 7 was a question. If you want to know-the truth of the 8 matter, inimost respects one way or the other, in this 9 particular case, I already knew what-it was, because I just 10 wanted to have it there for future reference.. But in any 11 case, the question, " Members with pinned. ends,' indicates 12 that I questioned whether the absolute ignoring of 13 deflection was valid for members with pinned end connections,
! .14 primarily structural steel. That's what the section is 15 addressing. Pinned end connections cannot take any
- r. 16 deflection and rotation in the torsional aspect of the i
17 word, and the absolute omission of any deflection check, is omitted to check whether the member could even take that 19 kind of loading, and the end connections would have been 20 the place to check. I have seen pin-connected members that
- 21 have to be modified to fully-welded moment connections 22 because the torsional loadings were so great. The thing e
l i
l L.
= +. _
,t'.
81
. mgc 8- Il -I
. failed with' pin' connections.
2-0 Didlyou determine'this to be a problem at Byron?
'3 A It's in'the-criteria. It indicates a problem
.could-exist at Byron. But no, I haven't been able to visit 5
- the plant often'enough or enough magnitude to review enough 6'
supports and end-connected members to determine whether 7'
or not they exist and it is a problem.
8 0 Have you concluded that the fact that the deflection check is ignored, as you characterize it, in 10 Section 37,2.1.f, does that constitue a design inadequacy, II in your opinion?
12 A It does, if they had attachments to pin-connected 13 beams. They could cause rotation of that beam.
'd Q Well, is or isn't it a design inadequacy. Can't 15 you tell from looking at the design document?
16 MR. CASSEL: Objection. Asked and answered.
I7 He just answered the identical question.
18 MR. GALLO: No. He said "if,' and that's not I9
~
giving me an answer to the question. In any event, I was 20 not satisfied.
21 THE WITNESS: If there are no rotational forces 22 applied to pin-connected beams, then, no, there is no problem.
.7
y ,
. = .
82
'mgc8-12' 1 EThe problem is, that was completely ignored in any review 2 program, . an d there could be rotational loads to beams with 3- : pin connections. And in answer to that question, it would.
d 'be a problem.
5 BY MR. GALLO:
-6 0 All right. -Well, let's : identify what kind of 7 problem we're: talking about. Are we talking about a design a problem or a hardware problem at this point?.
9- A It-would be both. It would be a' design problem, 10 because it is oversight of design. It would be a hardware M
~
problem, because it would affect the hardware.
12 So if I look at paragraph (f) on the third page-0 13 of Attachment 3, based on what you just testified, I can Id conclude that you believe this statement in paragraph (f) 15 constitutes a design deficiency, because it says that the 16 deflection and rotation of primary structural steel framing.
17 may be ignored?
18 A That's right. I believe. I was sort of 19 reading when you said that.
- End 8 20 MR. CASSEL: Would you like to have the question 21 reread?
22 THE WITNESS: I would like to have it reread, i'
u - -.
y i 83
[.
mgc9-1 .I' because I was reading Section 37 to see what the title
[i _2 - of Section_37.was about.
p-3 MR .1 GALLO: ~ I'll restate the question.
' 8 THE WITNESS: 37.2.1 is written against Section - (f) ,
5 and it says, " Safety-related Hangers." That's the main 6 category' that -(f) is attached-to.
7 Now there's a main category for 37 as a whole, 8 but because that specific _section was written against
~
9 safety-related hangers, I do have a safety problem with 10 that_ statement being in that section, but I would still 11 like to read the question you stated that I answered to 12 while I was reading it.
13 MR. GALLO: I'll restate the question.
Id BY-MR. GALLO:
15 0 You believe that Section (f) appearing on the third 16 page of Attachment 3 contains a design deficiency, because 17 it permit --
18 MR. CASSEL: Design sufficiency?
19 MR. GALLO: Deficiency -- because it permits 20 deflection and rotation of the primary structural steel 21 framing to be ignored?
22 THE WITNESS: Yes. I would say it is an oversight.
?
'j_
F 84 mgc9-2 1 The components should have been checked. The components 2 should have been verified that didn't have pin connections 3 or could take those kind of loadings, irregardless of d
whether they ignored the displacement or rotation in their 5 displacement of the support point, which is the piping.
6 BY MR. GALLO:
7 Q So the design statement is incorrect as written?
8 A It's not sufficient as written.
9 All right. Now is this particular item referred Q
10 to anywhere in your testimony?
II A Section (f)?
12 Yes. The one we have been just talking about.
O 13 A 37.2.1? Yes, it's Attachment 3, second item.
14 Section 37.2.1.f, " Deflection and rotation of primary 15 structural steel ignored in deflection check. Question 16 members with pinned ends." That's the section we're 17 discussing.
18 Q And where in 'our -- here it is.
19 Then I am to interpret that each of these --
20 strike that.
23 Am I to interpret that each of these items 22 listed on the first page of Attachment 3 set forth what
V k.
85
[
t-I'
- i. mgc9-3 1 you believe to be a design deficiency in the sections 2
indicated?
3 A The way it's stated, it's a design deficiency, d
yes.
5 Each and every one of them?
Q 6 A No. One of them is not. 37.2.1.g.2.C.
7 j' Q Wait a minute. Don't go too fast now.
8 A It's the sixth one down from the top. It says, i 9 " Torsion included here. Question logic." That's the only i
l 10 one I know of that I remember does include torsion, and I 11 put down a comment, " Question logic." I simply am 12 questioning why they put it in one section. They omitted 13 it in infinitely more sections, when in reality, it is id
- my experience in design that if I tried to memorize this i
15 document and design something, I would remember all the l
16 times torsion is to be ignored. I would never remember that 17 one section where it's supposed to be included.
'8 But you consider that section to be adequate, then?
! Q 19 That's why you pointed this out for me?
20 A Yes, that says it should be included. I consider 21 that adequate.
22 Q Are there any others, or are they all examples V
h-L
86 b
- mgc9-4 1 of design deficiencies?
2 A- -Let's see. -37.2.1.g.5. Based on that one line, 3 I don't find that a deficiency,'but the subsections of it 4 make that one'line a very questionable item still.
5 36.2.1.g.5 says, " Exact analysis must be:
- 6 performed for loads greater than 20 kips." I questioned-7 what it would do for loads less than 20 kips, but then 8 the ABC breakdown at the end of 37.2.1.g.5, if you limit 9 ' it to.the first three under that section, it says, '- As sume 10- all masses lumped at shear center. Axial self-weight may 11- be ignored. Torsional analysis not required. So it
.12 appears to me that they liked 20 kips, to include torsion, 13 you don't include self-weight, you don't include the
, 14 eccentricities of joints, but above 20 you do.
15 Now if that indeed is what was done, I have no 1
16 question about above 20 kips, but I have a question for 17 everything below 20 kips.
18 You see what I'm saying?
19 Q Do you believe, then, that the Section 37.2.1.g.5 20 is deficient because it doesn't address what should be 21 done below 20 kips?
22 A Well, it says it should be ignored, from what-b
'.x ----- --. __. - - _ - _ _ - -
87 mgc9-5 1 I gather. It doesn't say.that in all that many words, but 2 I would assume that.from what it says, that it would be 3 ignored, based on thel 5.C torsion analysis not required.
d Based on your review, do you find this section
.Q 5 and-its subsections," A, B and C, adequate for loads greater 6 than 20 kips?
7 If they indeed do~an exact analysis, yes.
A 8 Do you have-any information that indicates that Q
9 they have not done an exact analys.s in this area?
10 A Some, yes.
11 Q Can you be more specific. What information do 12 you have?
13 A- Well, in my review SEISHANG documentation in 14 Sargent & Lundy's office, the program itself omits these 15 things, and you don't have to -- there's no way to do an 16 exact analysis using SEISHANG from what I gathered. The 17 program itself is written to ignore these things. Without 18 further review, I am not going to say that it doesjin all 19 cases, but there was some comment that it could as-built 20 a hanger -- you could do an as-built analysis. In that 21 case, maybe it does include them, but from right this 22 minute,'I question whether SEISHANG, the way it's written,
88
=
- mgc9-6 I -
.just doesn't do it for;anything, period. It --
-2 What's'the name of-this' code you're referring
.Q
-3 to?
4 A SEISRANG, SEISHANG (spelling). It's.
5 a program in Sargent & Lundy's proprietary group which 6 is used to run' HVAC piping,-electrical Conduit, and many 7
other structures.
8 And t your knowledca, that code was developed Q .
9 using, among other things, the design criterion represented 10 by Section 37.2.1.g.5?
11 MR.'CASSEL: Objection. You said ' code.' I 12 think you mean program.
13 MR. GALLO: Same thing, isn't it? Isn't a code 14 You and I are communicating and a program the same thing?
15 thac way.
16 THE WITNESS: I consider a code different from 17 this. This is criteria that's set up by the company.
18 BY MR. GALLO:
19 Q I'm not sure I could pronounce it.
20 A I was going to agree with your question anyway, 21 because it sounded to me like you --
22 0 Well, let me ask you, we have now confused the t
a
?.)
j
b b
89 t-V h
g I' record.- I am referring to the SEISHANG code.
-2 A The computer code.
31 Q And my question was, based on your evaluation of 4 this code, is it your understanding that it is based on, 5- among other' things, the design criterion represented by 6 :Section 37.2.1.g.5?
7 A Is SEISHANG written to comply with this? Is 8- that --
9 Yes. Is it based on that section?
Q
' 10 A SEISHANG is used for safety-related components.
11 That would. imply that from Section 37.2.1 from the previous 12 page, that it was safety-related hangers, and the fact that 13 -this section is written for safety-related hangers and Id SEISHANG performs safety-related hangers, knowing what I 15 read in the review of SEISHANG, I would have at the moment i
16 a lot of questions concerning whether it meets this section 17 at all or any of these sections here.
la Q But based on your review of the code, it's 19 supposed to meet this section; is that correct?
l 20 A From what I gatnered, it should have met the l
21 requirements for' safety-related components, if it was used 22 to do safety-related, which it was, according to the
[
(
F' I
v i
l l l Li _ _ _ _ _ _____ __ ________ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ . _ . __ ___. _______ _ ____ ________
E 90 l
documentation.
2 O What does this code model?
3 A The structures.
d Q For what purpose?
5 A Determining stresses.
6 0 For what loads?
7 The input loads.
A 8
Q For what forces?
9 If there's piping A Loads from the piping.
10 attached to i.t. That's from the HVAC. If HVAC's attached Il to it. Loads from conduit if conduit is attached to it.
12 O What kind of dynamic loads are we talking about?
I3 A Seismic.
Id Q These are the seismic loads?
15 A Yes.
16 Q So that the SEISHANG computer code is the code 17 that models the ground motion through the building to the 18 various hangers; is that correct?
19 A No.
20 No?
Q 21 A The only thing I know SEISHANG does is, it 22 has curves or tables in it as a data base. It computes, a
s
- O- q 91' E
l
/I: guess, the frequency of the structure and determines'the 2
acceleration 1from those curves,.just like you would' going 3'
into the tables yourself. It doesn't model and do the
~'
whole analysis from generation point t'o generation. point.
5 IIt' takes input that's already'been generated and uses it.
6 0- And you say you evaluated the input data to this
'#' code.during your review in'Sargent &'Lundy's office?-
A. Evaluated the input data to this-cede? I read 9
the documentation as to what was required for input. I lo didn't read through that as much as I read through the documentation and assumptions of how it worked. In other 12-words, the programmer's intent, the way he set it up-to function. It doesn't matter what you put into it later.
Those primary asaucptions that he put into it at the 15 beginning of the write-up govern everything that's ever 16 done by it. You can't overwrite it. You can't improve
'7 on it unless you change the computer code. Those assumptions 18 are written in that code.
Q These-are what? The mathematical equations that 20 form a part of the program?
21 A The equations that he would use would have been 22
~ written into it. The assumptions might have also been l
l
wg
~ c I?_
x ;' 92
'T6
' written in.
- 2 Q Can you; identify for me one assumption that you 3
reviewed?
d
.A- Well,_one thing the documentation said was 5 -omitted was, it said that strut members were designed as' 6
pinned-endLtruss members.
~
That would state.that there is 7
.nothing-butlan axial. compressive load placed on a' strut 8 There-is no account for moments, no rotation or member.
whatever of the joint. There didn't appear any lateral IO shear or horizontal shear, and it's strictly the axial Il or compressive loads. And that indicates.that they didn't 12 include the eccentricity of the joint or the torsional
'3 effects or any of that.
'd Q As required by this section of the criteria that 15 you have referenced here in Attachment 3?
16 A Yes, right. 37.
I7 Let's see if I can summarize. I want to be fair.
Q I8 As I_ understand it, th'e first page of Attachment 3 are examples, are statements of design 20 deficiencies, with the exception of one section, and it's 21 37.2.1.g.2.C. The rest are statements of design 22 sufficiency -- I'm sorry -- design deficiencies for one e
a
c' < l
. 93
~1 reason or another?
2 MR.~CASSEL: ,
Just to be clear, you were going 3 down that list, Charlie, in answer to.his earlier d . question. Have you reached the bottom of th e list?
5 THE WITNESS: Yes. The only question was the 6 "above 20 kips" section. -
That should be omitted if they 7 did an exact analysis above 20. I didn't intend to -- if-
~
B they did an exact analysis, I have no question about that i
9 statement.
10 MR. GALLO: Let's go off the record for a minute.
l 11 -(Discussion off the record. )
End 9 12 BY MR. GALLO:
BU5 13 Q Attachment 4. Now if I locate your Answer 20, 14 which appears on page 13 of your testimony, you indicate
, 15 that you have other concerns with the Sargent & Lundy 16 design criteria, and these concerns are listed in r
17 Attachment 4.
I 18 Now are these -- and you at one point call them
! 19 potential problem areas -- my question is, have you l
20 determined whether or not these matters listed on 1 21 Attachment 4 are design deficiencies or design inadequacies?
22 MR. CASSEL: Objection. That's answered in
_.._______.__ ______ __._.__._______.________________ _____ _ ______ _ ___ _ ______ _ _ _ _ _ _ _ _ ,_ _..e u
4 '
94 s
I I - Answer 20,' Joe. It says right there, "I have gaestions 2
which.have-not been resolved."
3
.BY MR.'GALLO:
d So these are' unresolved concerns on your part,
_Q 5 Mr. Stokes?
6 As far as I can -- yes.
A Yes.
7 Let's look at
.Q -Now let's turn to Attachment 4.
a the first item. Can you tell me just what that item is?
9 A Well, in reviewing the documents, I had a 30 I read everything several times.
procedure
98 4
'l -Q Can you remember where that is, what-letter that 2 was?
Not at'the moment.
3 A I'd have to look back through !
4 most of.the letters that I' looked at, but it was listed
- 5. in another document as.being a problem, too.
6 Q Do you remember that document?
JN Or.it1was written about also--- no, I can't
[ . .
8 remember the letter number.or.the date of the letter or 9 anything at this moment. If you would wish it, I can 10 . determine-that.
11 Q No, that's all right. Did you attempt to gather-12 - all the documentation that might exist on this question 13 by asking Sargent'& Lundy for it or Commonwealth Edison?
l 14 A. In the production of documents, we've asked l 15 for everything that's has been ever written on this plant, l
l 16 I believe, in relation to the review program, and I L
17 believe they've supplied everything that's possible to be i
18 supplied. But if that's not the case, maybe I should ma}.e i 19 the request now that any additional information be giver.
20 me on this subject.
21 Q The time for discovery is past, Mr. Stokes. But 22 you made a statement in your previous testimony that in all m
h y 'i m
, gey, T- -r ats- ,-w. - - - - , - -+y c. w- ,r-.y m-+. - - -i, 5 y ,- r-y- .---v-- -,-ra.--v--ye p w,---yy grw a -,-,--,--w-e-9 -pe49 m ya9--? www-g,-ims--wmy 9+-7e .y-a-=--u.e9.r*weg*=- -Ty-
V -
S 99 l
l the documentation.that you looked at, you didn't see this
~
l' 2 matter addressed anyplace, the matter of -- is it in-splices 3 or end-splices?
d A End splices.
5 IN or E N D (spelling)?
Q 6 A END (spelling).
7 Q End splices addressed anywhere. And I'm trying 8 to determine --
9 MR. CASSEL: Wait a minute. That's not what he 10 said, Joe.
II THE WITNESS: Could you refer me to where you're 12 getting this from?
13 BY MR. GALLO:
Id O I'd written a note while you were testifying 15 about something that was omitted from a program as being to end splices; is that correct?
17 A I said there were end-line splices, as far as 18 I could tell, in the butt review program -- were omitted.
39 There was a butt review program, as far as the documentation 20 7.ve seen. There was supposed to be 100 percent review of 21 butt connectors.
22 You mean butt splices?
O m___._____.
- 13 100 l
I A Butt splices.
2
, Q -I see. And you saw documentation on this
~
3 question?
A On butt splices or butt connectors. I didn't 5
see any on end-line splices.
6 0 And it's the end-line splices you're concerned 7
about. Okay.
8
. ,. 3 -7,m concerned about crimp connectors, period.
They could be end-line, butt or wherever located. That's
- j. 10 not my concern. It's review of crimp connectors.
0 All right. And I guess what I've lost the thread 32 of is whether you have not seen any documentation on butt
'3 splices or end-line splices or both.
I' A' I've seen lots of letters on reviewing butt II l
connectors or butt splices. I've seen a few, I think, NRC 16 inspection comments about faulty end-line splices at II penetrations. End-line splices don't necessarily exist 18 l at all penetrations. They exist end line, wherever they I'
want to splice a cable. For that reason, the addressments 20 or letters I've seen only address certain connectors in that
. 21 end-line splice category. At penetrations, they did not 22 address the end-line splices totally as to crimp problems.
t I
e
- e 1
._m ___.m._m..__.-.._________mm._m- - -
,7 101 e
1
'O 'But you cannot identify right now any correspondence 2 that'you specifically have in mind?
3 A- Other than this one letter on butt end-line d
splices. That's the only one I have written down here at 5 the moment. There was another one,or two, I remember. I 6 'didn't want to write down redundancy when I was doing this.
7 I'm'sorry. I was attempting not to --
8 Let me-ask you this question. Did this letter Q
9 of May 31, 1983, from the NRC specifically address a L
10 problem with end-line splicing, or did it just trigger a 11 memory response in your head that caused you to say, " Aha , '
12 here's a potential problem," as you've explained it here.
13 A Well, it addressed a problem with that particular t
i Id type of one, NRC-363 with an end-line splice at the l
15 penetration.
l That one is addressed by that letter. Now --
l 16 Q Does the letter raise the --
17 MR. CASSEL: Let him answer the question.
18 l THE WITNESS: It did raise -- it didn't raise 39 something I'm familiar with. It raises something that 20 everyone here should be familiar with. >
21 After reading the butt connector letter 22 documentation, the whole butt letter or butt splice issue l RB is not butt splices; it's crimp connectors. All you have !
. 102
[-
'l -to do is read all.that documentation, then' read through 21 all-the other stuff, and you see that end-line splices 3 are -- they come.in very sporadically.with being deficiencies ,
'd at penetrations,'but you don't see any documentation as L $ to end-line splice connectors.
- 6. BY MR.'CALLO:
7 Q' Did this letter address that point?
a A 'I don't believe it addressed the totality, i
9 except at penetrations. I think it was specific L
10 penetrations, but I can't give you a more definitive 11 s.tatement. I'd have to pull the letter out and reread it 12 again.
13 Q All right. The next item deals with another 1
i 14 NRC letter.
I 15 A Yes.
16 O And do you remember, was this the letter 17 referring to a -- well, I guess you've indicated for me 18 right in the title, it referred to the integrated design 19 inspection; is that correct?
20 A That was on the letter, and that's where -- ,
21 so it was integrated design inspection program, yes.
22 Q And this particular letter deals with the ;
- I r
s' 1
P L. - _ _ _ . _ _ _ _ _ _ . _ _ _ _ _ _ _ . _ _ _ _ . _ _ _ _ _ . _
103 1 activities of,Sargent & Lundy?
2 A :Yes, among others, but primarily Sargent & Lundy 3 because the -- if you read paragraph 2 or page 2, the f
4 second paragraph, this write-up was a discussion of an 5 inspection done as to calculations concerning, I 'b'e l i e v e ,
o the auxiliary feedwater pump motor evaluation,-environmental 7 evaluation, and the write-up was concerning Sargent & Lundy's i e analysis of the environmental acceptablity of this room 9 for the pump and its environment, because it seems this 10 pump was critical to the safe shutdown.
11 And the question with this that came up to me
! l 12 was, they discussed everything in the calc, but they 7 13 relied on an assumption. It was that IIVAC could take the !
14 heat load, which they probably did a cale on that, but --
l l
15 0 Who is they"?
16 MR. CASSEL: Let him finish the question. You i
l 17 can ask that question when he completes his answer, Joe, [
18 but he's entitled to give you an answer. If it's ambiguous, i
19 you are entitled to ask him what he means, but don't keep f l .
20 interrupting.
21 MR. GALLO: The record is getting confused.
22 I want a cicar delineation of what is in the letter versus a j
- - l 1
l 4
104 i what you have superimposed based on your experience and 2 judgment.
3 MR. CASSEL: You can get that clear delineation 4 by asking one question at a time, Joe, but it's just basic 5 courtesy, among other things, to let the witness finish 6 his answer.
7 MR. GALLO: I think I'm entitled to just get a an answer to the question. I've been pretty lenient in g letting him ramble on. But I think here is the time to io draw the line.
ii THE WITNESS: Well, I'm scrry.
12 BY MR. GALLO:
33 O Let's look at the next item. T h is again is an l 14 NRC letter dated June 6, 1984, and you refer to page 12, l
15 paragraph 3.
16 A YOS*
l i7 0 And you talk about the failure of cables l
l is attrributable to elongation of cable installation. What i p, was the nature of this problem?
20 A It appears they had over exceeded the cable 21 pull and tension load in this letter, and they had attempted 22 to verify the adequacy of the installation, because they l
__._______.-.__.__.__._____-_-_____m__ _
r; -
-3 105 1 wanted to re-pull-the cable and put'it in some other-place.
~2 Undoubtedly they had removed it or something.
3 The documentation I-received was very brief-so --
4 but the whole thing was, they sent a piece of the cable 5 back to Okonite to test. It had passed the same test 6 before~being sent to the plant. In Okonite's write-up, 7 they state, as a result, in-this letter,'that they attribute a the failure of the cable to elongation of cable insulation, 9 because it failed the test the second time.
10 0 Mr. Stokes, aren't these first four items where 11 you refer to NRC letters merely matters that have been 12 identified by the NRC Staff through Region III and remedied 13 by Commonwealth Edison in response to the NRC Staff?
14 A The Staff has raised these questions to some
- 15 extent. Whether or not the solution has been completely 16 documented and is acceptable is another question that I 17 can't answer, because I haven't, as you say, seen everything.
18 I'm only one person. I haven't had the time to read 19 absolutely everything. I don't have a -- I don't have a 20 limitless brain. But in any case, that question is still 21 a question to me from other documents. That document 22 doesn't state specifically that that one was corrected.
23 0 Aren't you just piggybacking your concern to the 0
e
..e _
106 :
^
4 1
- NRC Staff's concern here?
2 A -Let'.s say'I'm not piggybacking; I'm asking 3 concerning~ questions.that.they may-not have' addressed,-.and d - if they had, then there would be no question as to.what-5 ~I'm asking.
6 g .Now who is "they"?
7 ~A The NRC. Now I mean if they. addressed everything-e that'I.would like addressed, you can say it's piggybacking..
9 O And what.is your judgment on that? Have they 10 - addressed everything you'd like to address in these. letters?
11-
- A .I' don't know.
12 O You. don't know? All right.
13 What is this~fifth item that talks about --
~
Id starts out, " Review of Drawing 6E-0-3393E"? What is that End 10 15 item?
16 17 18 19 20 21 22 U
- e
C-107 411.1-1 A It's a Sargent:& Lundy document. That's the 2 drawing number of it.
3- .Q Now this is a potsntial concern. What is the 4 nature of the concern?
5 A There is a load table on this. It's very 6 briefly described. There's a load table on -- these 7 documents are concerning steel Conduit installation and a design.
l 9 Anyway, there is a load table for steel conduit 10 on this document. It's specifically called out, load table, it- steel conduit.
12 I compared that load table with the load table i3 for steel conduit in the unistrut catalogue, which I had, 14 which statement at the bottom stated it was in compliance is with the '71 version of the National Electrical Code. The 16 numbers for the weights in that table in the unistrut 17 catalogue were larger than the numbers in the table of 18 Sargent & Lundy's drawing. The -- this may be answered, and
- 19 I'll go ahead and throw this in.
20 In the Sargent & Lundy documentation, they 21 stated they used an '83 National Electrical Code. If in the 22 '83 version, which I haven't had time to look, the loads are
11-2 108
( i .what is in this table, and all the components listed in this 2 table or the weights for these components were purchased 3 in compliance with the '83 Electrical Code, I wouldn't 4 have any question with this if those things happened.
5 But the problem with this, as far as I see it, 6 is unless the '83 version lists the same load table values, 7 Sargent & Lundy's values appear to be below what the National a Electrical Code requires. Now --
9 Q Have you made this comparison?
n3 A Yeah, I compared the tables, ii O So you compared the table in the unistrut 12 catalogue with the table shown on this drawing?
i3 A Yes, i4 Q And you concluded that the load table on the 15 drawing is inadequate because it doesn't coincide with the 16 unistrut Catalogue table?
j7 A I didn't decide that it was inadequate. I said is if the table was per the '83 code, and the '83 code is pp identical to the table, then I only have one other question.
20 That would be whether or not the components put in the plant 21 were per the '83 code instead of the '71, when purchased.
22 I can't -- beyond that I'm saying it's a question. There's a
(
(
3-3 n. o.
1 lot of things I haven't had time-to look at.
2 --
0 ,Then you don't'know whether or not this table'is 3
-in the '83 code?
d 7 'Well, if it was in the '81, I would presuppose 5
it's in the '83, but I' don't know for sure it's in.the '83.
6 MR. CASSEL: You said it was.in the '81'. You 7
mean in the '71?
8 THE WITNESS: The '71.
9 BY MR. GALLO:
10 Q What's the last item on the page? It refers to an EPRI document.
12 A The same document could have been listed up with 13 the butt splices or the end line -- not that, pulling, the
( 'Id
- cable pulling, the third one down, elongation.
15 -
I just happen to maybe think it could be weird to that I was reading this EPRI document, but I was looking 17 through the EPRI document to see at one time what was 18 relevant for some other work I was doing as a reference 19 source, and I happened to read this one section concerning 20 cable section lengths. And the thing that keyed my mind 21 here, and I remembered, was the fact that there are three 22 stress modes which cable is subjected to during elongation:
-k E
n 11-4 110 C 1 Tension and elongation, torsion and sidc-wall (bearing) 2 pressure and bends.
3 And then later when I was reading the documentation d
on cable pulling, this same article and memory came back, 5
and I pulled it out to make sure that it was stating what I 6
remembered.
7 This arttele is not a problem itself because it 8
addresses factors that should have been addressed in pulling 9
cable. The equations determining safe pulling loads and so 10 forth. This section is here to go back to the elongation 11 program and cable overtensioning, pulling overtensioning, 12 which is a fairly substantial problem at Byron, as I under-13 stand, from reading all the letters and NRC documentation 14 and stuff.
15 There is a few other things that go with this, 16 that they're not linked right in another, but there's a 17 question in a document concerning conduit installation.
18 Q Before you leave the EPRI documents --
19 A Okay, we'll take them one at a time. Sorry.
20 0 What you're telling me is that this really does 21 not represent a potential concern, this is simply a statement, 22 if I can use the word, of criteria against which you would
(
w e
- k. - - - -
111 5 i
( I review other documentation on Byron?
2 A Yes, which I have reviewed other documentation 3 on Byron.
d Now let's turn to the second sheet of Attachment Q
5 4, and the second item. It says, referring to NDE examination 6 reports for Hunter, it says minimum pipe wall thickness not 7 met. Repair performed.
8 What is the nature of this potential problem?
9 A I was reviewing NDE examination reports in the 10 field which were given to me in relation to the reinspection 11 program. Specifically several DRs and solac other NDE 12 exams.
13 Q What are DRs?
14 A Discrepancy reports.
15 0 Okay.
16 A There were some in some DRs and there were some 17 loose NDE exams which were given to me or supplied in the la documentation. When I reviewed these NDE reports, there 19 was several that indicated there were repairs as a result 20 of the NDE exam which if they're repaired, it is not a 21 problem with those repaired, but it's a question that I've 22 boon told several different things during this program. I f
=
m 11-6 112
( i was told that, one, they* wore reviewing cortain things 2 inspected in the plant. NDU is something that can be 3 reinspected by doing another NDE exam.
4 When I raised this with Sargent & Lund, I believe 5 on a Wednesday some number of weeks ago, I was told in that 6 mooting NDE exams were never in question in the reverification 7 and woro omitted.
8 In reviewing all the documentation on PTL, 9 including the reinspection report, I find that PTL was to responsiblo for all NDE exams, but they had the worst 11 failure or worst inspector qualification record --
12 0 Mr. Stokes, you are rambling now.
13 A Well, I'm sorry.
14 0 The question that I asked you was what was the is nature of the potential concern that you had in the second to item, and I repeat, it says minimum pipe wall thickness 17 not mot. Repair performed, is Now what is the concern or potential concern that up statomont represents?
2v A It has two:
21 Ono, the repair performed, if it was part of the 22 reinspection program, would have boon significant from
(.
113 11-7 C I safety and from design.
2 The fact that Sargent & Lundy made the statomont 3 that thoro was nothing safety or design-significant reviewed 4 in this program is contradicted by this line here in some 5 respect.
6 O All right.
7 A Doyond that, it expands the question of whether 8 NDE as a wholo should have boon questioned as an attribute 9 when I was told it was omitted.
10 0 All right. If I understood your testimony just 11 now, you are suggesting that the fact that this minimum 12 pipe wall thickness was repaired contradicts the Sargent &
13 Lundy testimony that none of the reinspection program C 14 discropancies had design significanco; in that correct?
15 A Well, it does to me if, as I said, that repair to was performed duo to an inspection during the reinspection 17 program.
18 0 What discrepancy are we talking about hero?
10 A I'd havo to thumb back through several documents.
20 Thoro's soveral whero they repaired stuff. They're NDC 21 reports, I didn't writo the numborn down. If you'd liko 22 thoso at a futuro dato, I can give them lator, but I don't
(
114 11-8
( L1 know them right off the top of my head. There's three or 2 four, maybe more than that.
3 -Q We'll. accept the proposition that certain of 4 'the discrepancies were repaired that were the subject --
51 let me-state'that again.
6 'We'll accept the proposition that'certain of 7 the discrepancies that were subject to the Sargent & Lundy 8 evaluation were in~ fact repaired. I think we can agree on
-9 that.
10 A Oh, ' we ~can? - Okay. Thank you.
11 Q My question is, is it your testimony that since 12 they were prepared -- repaired, rather, that meant that 13 the Sargent & -Lundy testimony indicating that none of the 14 discrepancies including those repaired, had' design is significance was contradictory?
16 A If they didn't have design significance, I i7 wouldn't have repaired it. There is a definite question is there.
.19 Q So you think there is a correlation between 20 design significance and repair?
- 21 A Well, I've got a question about why they were 22 repairing it, if'it's not design-significant or safety-
.A
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4 W
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-112 9 '
I s'ignificant. Otherwise, why-go to the_ expense of fixing it, 2
if it's capable of taking'the design. loads?
3 Q -Maybe I misunderstood your prior ~ testimony, but d-I thought you were saying 'that the- fact that it was repaired
- 5 indicated definitely that this was a contradiction in the 6 Sargent & Lundy-position?
'7 MR. .URIGHT: Objection, Joe. I think that was 8 your testimony.
9 MR. GALLO: Well, he will correct me if I'm 10 wrong.
11 THE WITNESS: I don't think I said definitely 12 anything in this whole testimony so far that I can say 13
( 14 beyond a doubt that it says anything. I am saying that it-cast a question of what Sargent & Lundy has said.
15 BY MR. GALLO:
16 O All right. If your prior testimony was that it 17 did-definitely cast doubt, you are now changing that?
18 MR. CASSEL: Objection. That's --
19 THE WITNESS: It still casts doubt, but if it 20 definitely casts doubt, I'll change that.
21 BY MR. GALLO:
22 Q Okay. Fair enough.
,,,e w w 9-
, .:--.,.9 fM F
11-10 ,
What is this item on computer printouts by 2 : inspector for Hunter Corporation?-
'3 A Oh, boy. There's a bunch of computer printouts 4 that I reviewed and I have copies of, even though I didn't 5 really want them .myself. But they are listed lar inspector.
6 The inspector numbers here are listed. The document ID.
7 number is what is shown on the documents. Those things 8 appear to be the work that the inspector did on a 9 computerized basis. It listed what was reinspected, what 10 was inaccessible, what was not accessible. There was 11 quite a few things on it.
12 The' thing that -- I initially didn't even care 13 to look at them, and I finally reviewed them primarily for 14 what was inaccessible, and that is why that's listed here.
15 For instance, the first inspector says 16 inaccessible due to a lot of retrofit on feedwater system.
17 Now in reviewing the Hatfield work on ASNE qualified is components --
19 Q I thought this was Hunter.
20 A Hunter. Okay, Hunter. Yeah, Hunter was ASME.
21 In the documentation that I reviewed, I think it was 22 BRP-1 or something like that, the calculations that Mr.
8 r
l l
.=11 t 1 -
Branch testifie'd to concerning a review of ASME and piping, 2L Hunter system stuff,.that documentation, when I reviewed it 3
only.. include'd two-feedwater' system-problems.
Th'is' documentation allowed me to compare the 5
actual-problem with what's on this list of feedwater.. stuff 6
that this guy was listing as inaccessible. The two that-7 were reviewed in the.49.or so that were' reviewed did not-
'8 include'any of this'feedwater stuff that was inaccessible 9
here due to retrofit.
10
- The other thing is, this retrofit was not clear M
if it was being retrofitted right that minute, or if'it had
. 12 F- 3een retrofitted since inspected, and that interfered with
" 13 the reinspection from~the original inspector. That was not 14
' clear. That one' thing is not really -- is a question, 15 because I wonder about that feedwater stuff that was not 16 reviewed.
17 The third one --
18 Q I'm sorry, I was just going to --
19 A The third one is obvious.~ I highlighted the 20 word." cleanliness" and " hydro test." Ilydro test is a very 21 limited timeframe as affecting anything. You can 22
, reschedule an inspection three weeks.after the hydro or a week f
s
. - . , . - ~,, , - ,,e.. , . - - - . - - , . , , . . , , .n. , ,- , ,
118 11-12
( l before the hydro. It is simply a scheduling problem when 2 you let hydro interfere with an accessibility of an item, 3 just hydro.
4 Cleanliness. The word " cleanliness" implies 5 that it's filthy, you can't visually see it or inspect it.
6 There is a category that was omitted from the inspection 7 called housekeeping, and I assume housekeeping is an ongoing 8 practice of keeping things clean. But to make something 9 inaccessible because it's so filthy, when you could go 10 out and clean it, if that's indeed the way this was written, 11 says why did they not look at this? It's not reasonable 12 for them to say it's filthy, we won't look at it.
13 Q Let me ask you --
14 A The fourth one, the same thing.
15 0 I'll let you go to the fourth one in a minute.
16 But do you have these documents that you've 17 referred to here?
18 A Yes, I've got the whole file. They're stamped.
19 They were Xeroxed by Mr. Jayley before giving them to me.
20 Your office should have a copy.
21 Q These are the accurate numbers for these things 22 here?
3 119
~11-13
( 1 A Yes, I double-checked them since this was 1
2 done.
nd 11 3 4
5 6
7 8
9 10 11 .
12 13 14 15 16 17 18 19 20 21 22 c
- g. - ,-
~
120 l l
- 12 11 I
1
- u. I Q This list of items, then, is a series of
- 2 potential concerns on your part?
3 A It's concerns concerning the attributes associated 4 with the review, yes. They are not all-inclusive, I should 5 state,-too. I.only listed four here. It would have been a 6 quite lot longer list. I tried to list the different
~
7
, categories like hot functional, cleanliness, hydro. I
-8 didn' t - try to redo those over and over for di fferent 9 inspectors.
UD There were other inspectors with cleanliness 11 problems.
bu-6 12 MR. GALLO: Can we go off the record for a 13 minute?
( 14 (Discussion off the record.)
15 BY MR. GALLO:
16 Q Mr. Stokes, I believe I interrupted you. You i
17 were about to address this item in the middle of the is page that starts out Table 38.2-1. Where did that table
- 19 come'from?
20 A You didn't interrupt me. I wasn't --
21 MR. WRIGHT: Objection, Joe. I think you 22 interrupted him when he was going to the fourth part. I don't think he actually got onto that point yet.
I E
.'I. .
121
'#12-2 -
( THE WITNESS: You interrupted me when I was on
-2 -Inspector'1313, which was the third inspector for hot 3 functional.
4 MR. GALLO:
5 0 You mentioned cleanliness. I thcaght you had 6 covered that point.
7 A I didn't cover hot functional. Hot functional 8 ' and hydro were quite si'nilar, but they were listed as two 9 _ different problems with inaccessibility. It can be -- I -
10 mean there's hot functional going on the other day when we 11 . toured the plant. It was warm, but not impossible to 12 perform an inspection, I don't believe, just because of this 13 statement, hot functional, without a much more definitive 14 statement,that casts that question, yes.
15 Q All right. Now turning to the item that starts 16 out Table 38.2-1, what document is that table from?
17 A I believe it is from the first document which 18 we were discussing, the main Sargent & Lundy criteria.
19 Structural project design criteria, Byron-Braidwood. It's 20 the only document, to my memory, that went up to 38. It 21 actually,.I think, went a little bit beyond 38.
22 Q The next line refers to -- the next three lines y
122 12-3.
't . start out -- well, indeed, if you.look at the-rest'of the ;
l 2- page,-each line seems.to start'out "omitted."
3 A Yes.
4 Q What does that mean?
5 A Just that.
6 O Omitted from what?
7 A -All procedurals that I reviewed,.everything that a was given~to me, supplied to me, there was absolutely no 9 section, no drawing, IU3 nothing concerning through-bolt to design criteria. There was no flare bevel or bevel weld
~
11 radius tube steel specified.
12 In other words, there'was no table as to what the .
13 radius would be for the design team to use for various tube
( 14 sizes. There was omitted no as-building, 10 percent over-15 stress factor, and I limit that.
1-6 Now there was one document that covered that. It 1-7 was -- this one line was not in the main' criteria. It was 18 not in the DC-ST-03-BY/BR document. There was a proprietary 19 document that I was allowed to review that included 20 several comments on both 10 percent overstress, zero percent 21 overstress, 33 percent overstress, and actual -- just --
22 you could fail one member every so often of a certain type ,
1 i
comment. But at '.he moment I can't give you that document's I number.
1 g.
7,.
-123 12-4' "
- j h i "O
~
So what you are telling me is that where 2 "omitted" appears,-the subject that you describe is not 3 covereu-in any of the documents you reviewed, with the 4 exception that you just noted?
5 A Yes, that's true. ~ It wasn't in'anything I saw.
6 0 You indicate that there was nothing on flare 7 bevel welds and bevel -- I'm sorry, flare bevel weld radius 8 and tube steel?
9 A I said there was no procedure.
10 Q I see.
11 A Design criteria procedure --
12 Q Go ahead, what is Attachment 7?
13 A Well, that's probably one I included for another
_i4 point, and I was just fixing to -- yes. I'm not sure just 15 what that is. It's like I said -- or if I didn't say_it, 16 I'll say it now, it's marked safety-related, it's got no 37 calc number, no revision. It's not reviewed, not approved, 18 it has no client, no project, project number. This thing is pp -- was almost, as far as I can tell, untraceable. But it 20 had -- and this copy is as terrible as my copy had. In 21 comparing several sheats of this thing, I was able to 22 determine this number at the top, the 117.57. It's something 2
L
124 L 12-5' .
If-I STD 117.57.-
I'couldn't even determine.who prepared it.-
you'can read that,Tboy,'I'could use you.
~
2 3 I could determine on secondary'pages what --
Still not-4 who did it. -It's got.Shenean as the preparer.
reviewed and not approved,'but here he finally did stick in 5
-It was CECO, Byron-6 something that helped me a little.
7 Braidwood, and some numbers.
8~
I still have not really found out anything about It's concerning weld reviews. It's obvious 9 this document.
10 from the write-up -- undercut.- boy, that looks like-11 reinspection stuff. You've got the 10 percent reduction, and what really 12 you've got undercut and different sketches, 13 caught my attention when I got through this document was it
( 14 gets over and it didn't even have a page number.
It has a 15 nice picture of tubing intersecting plate, and it calls out to the weld symbol for the tube-to-plate weld, R(E) with a bevel
'17 weld, 18 What really caught my attention, after talking 19 to Sargent & Lundy that' Wednesday several weeks ago was the 20 next page concerning flare bevel groove welds, and it appears i
21 that whoever prepared this did some research, and it states 22 typical field measurements indicate the actual radius is between T and 2.5 T, where T is the tube wall thickness.
I
' ~
125 12-6 an
( 1 Therefore the design assumption of R equals 2 T, 2 effective throat equal to 5/16ths R per AWS D-1.1 is not 3
applicable.
as 4 Now, that states everything in a nutshell 5 I, on Wednesday discussed an far as I am concerned.
6 allegation which I raised at Diablo, and I had absolutely and all of a sudden 7 no proof that it would go anywhere where, 8 I was reading through this documentation and dumped in my lap 9 was a flat-out statement by somebody at Sargent & Lundy 10 stating that their design assumption of R equal 2 T is not 11 applicable to this work, and that there is T-radius steel in 12 the plant.
I3 They make that statement, but they don't sign it.
( 14 I guess it was Shenean.
15 But, in any case, this thing in fact did all the I
16 research that I needed, that I wanted to do in the field.
17 wanted to measure stuff when I got my field trip, if I ever 18 got one that I could go on when I wasn' t too busy.
19 This document did all my revibw work. It says Lundy, 20 flat-out everything that's been assumed by Sargent &
21 if it was based on their design assumption of R equal 2 T is 22 not applicable to Byron. Now --
(s 1
126-
, l'2-7 1 Q Okay, are_you finished?-
2 A Yeah, I think that's plenty.
3 Q So I' guess based on your testimony, this whole a . question of flare bevel weld was not omitted from the 5 documentation you looked at?
6 A It was not -- I said it was omitted from 7' procedures, criteria..
8 Q And this doesn't qualify as any of that, Attachment 9 7 I',m referring to?
10 A No , it doesn't, because I don't knov if this it thing has been' destroyed by -- well, I know it wasn't 12 destroyed,,because they gave me a copy of it somehow. But 4
13 what it' does tell me, because it's not reviewed and not i4 approved, that somebody undoubtedly didn't ever want to use 15 this thing.
16' But, then, on the other hand,-the stuff that' i7 follows the flare bevel stuff on thin plate sheet welding, is D-1.381, and the transverse loading on the weld cales, it pp appeared in the calculations I saw, they used these numbers 20 as the capacities for the welds which says they should have
< 21 been reviewed and approved. But it wasn't.
22 So I've got a contradictory attitude here. I've 4
P 4
.m. _
Oh '
- 12-8 I
, got_ numbers being used out'of this-document without it 2- being finalized and approved or anything, and then I've got 3
' <xi the'other han'd stuff.that would have been very useful in
'd
. expanding, if anything, the review to all these joints.
5
. that this guy is making the statement are in question, and
.6 ~
I've never seen.a'nything expanding the review to these 7
joints. So that's where I stand.
8 O All right.
$nd 12 9 10' 11 12 13 14 15 16 17 18 19 20 21 22
- a 4
L
128
= 13-li I-
. !WR , GALLO: 'Can.we go off the record for a 2
moment?
3
' (Discussion off the. record.)
d BY MR. GALLO:
5 Q Let's refer to Attachment 6, Mr. Stokes, in the-6
-- well,'you tell me what Attachment 6 is. The first page 7
is a page of a letter to Mr. Reed of Commonwealth Edison 8
dated January 30, 1984, and what is the second page?
9
'A It's a letter out of this document. If you note, 10 the first page is F-l~and-the second page is F-13. I 11
_didn't even feel we should Xerox this at all and supply it 12 as an attachment, because I felt all NRC letters and 13
- transmissions would be acceptable as ,in evidence _'already.
14 In any case, we did Xerox the first page just to 15 show that it links it to the page on 11 with'the F number 16 Coding system.
17
-Q So the second page of Attachment 6 is --
18 A Attachment 6, it's that letter containing --
19
- it's an inspection report,' basically, is what that letter was 20 on.
21 Q So page F-13?
22 A Uh-huh.
b
. --,r --e , , , - - - . , , - - - , , -, , .
c .
, ti 13 129
~
. ;. i- - I see .'..
Q 2 .A~ There was an' inspection report.
4 3 0- If I. turn to page F-13, really your second
~
-4 sheet of. Attachment L 6, and I-look under the item that you-o 5 have starred, there is a reference to a . drawing detail.
6 called DV-164. And if I look in the finding, there is a 7 reference to DV-162.
8 A -Uh-huh.
9 Q Do you understand this to mean that what is at to - issue here is'the drawing deta'il DV-162?
11 A No, the. allegation reads in~ quotes:
12 " General surveillance of this project 13 illustrates that approximately 90 percent of the B welds
(,'
- 14. on that drawing are 1/6th undersize where tube steel has ui- been used. In most cases this represents a 40 percent 16 decrease in size and 55 percent in strength."
.17 It was obvious to me by reading that -- maybe is incorrectly -- that they.were discussing flare bevel welds 19 on tubing which someone had made an allegation against the 20 flare bevels being undersized 1/8th of an inch, which is 21 quite similar to the allegation I raised at Diablo Canyon 22 in the relation of' quarter inch fillet welds and requested --
4 4
130 13-3 ,
1 or not fillet, flare bevel was expected, and only 1/8th was 2 installed.
3 Q Do you know whether or not there's a drawing 4 detail called DV-164?
5 A No, I'm not even familiar with what DV-164 or 162 6 or anything is. It wasn't in part -- it wasn't in the 7 document.
8 Q It's my understanding then that you just assumed 9 that the welding involving the tube steel in this allegation 10 was flare bevel type welding; is that correct?
11 A I did, yes. I may have incorrectly. That 12 would be the same quote, almost identical.
13 Q Mr. Stokes, I'm going to show you a drawing 14 prepared by Sargent & Lundy which has on it drawing detail 15 DV-162. We have marked the area for you.
16 MR. CASSEL: Did you say this was 164 or 162?
l 17 MR. GALLO: 162.
18 BY MR. GALLO:
19 Q It's -- where is the drawing number on this thing?
20 MR. HOOKS: Right here.
21 BY MR. GALLO:
22 Q This is Drawing No. 6E-O-3292. Is that right?
l k.
4 '131 c
v.
- -
- 1. MR. HOOKS: Yes.
2 BY MR. GALLO:
i, .3 Q And on this drawing is detail DV-162. I wonder, 4 Mr .' Stokes, if you can-take the'NRC description of the B 5 weld that they are' talking about and look at the drawing 6 detail DV-162 and tell me whether or not the weld shown-7 as the B weld is the flare bevel weld or a fillet weld.
8 A The B weld here is a fillet, which wouldn't 9 apply to a flare bevel, no. So, thank you.
- l 10 Q Did that change your reliance on this Attachment 6
-11 for purposes of your answer?
12 A Well, it could be extracted from the documentation 13 .as far as I'm concerned. If I had presupposed that the
.( 14 allegation was' tube steel,Lflare bevel welds was the issue
! 15 here, if.that's the -- since.you've shown me that it's not, 16 it's obvious that I'm raising the issue for myself, as per 17 the attachment after this, 7.
18 0 All right.
! 19 A I thought it had already been raised. . I'm sorry.
20 It's something new.
21 Q Let's turn to your Answer 29. It's on page 20.
22 If I understand this answer, Mr. Stokes, you i
r
+
=-
7, 132 13-5, -
I 1 'h' ave questions 3on calculations and assumptions found-in 2 Calculation Book 19.1.2, and then'your subsequent 3 questions and~ answers that appear deal with, by my count, 4 four_of those: items.
5 Let me make it easy.for you. By my comparison,-
6 you have not addressed Section 19, pages.1 through 5, and 7 Section 21, page 113 and my first question is -- maybe-you 8 want a change to check that out to see whether my evaluation
- 9. is correct?
10 A I think I sort of looked ' through it the other 11 night, and I noticed that what you are'saying is true. I-12 didn't --
13 Q ~ Well, are there problems in_Section 19, pages 14 1 through 5, and Section 21, page 113?
15 A I believe there are, yes. I think I checked out to all.the numbers per a list that I had.
17 Q But they're not included in your testimony?
18 A In haste -- I'm sorry, I didn't include 19 absolutely everything that I found. I intend, and I had 20 planned on supplying a list to both CECO and the NRC at 21 some point when I get it completely finalized. I'd like to 22 be able to strike some of the things before I give it to
(
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13-6 133 I them. But this list, as.I'have said already, or will state, 2 is not absolutely everything. In some haste-there's been a 3 few things omitted.
I stated that', I think, a little earlier 4
'in relation to the -- I don' t think I included the document
'S on the telephone conversation that was not documented.
6 There was a few others that now that I'm thinking 7 back along the calculational side of things, I didn't 8 include in haste', but they weren't technical as much as 9
documentational issues that are QA-oriented. So. . .
10 Q Now, as I understand, the item that you referred 11 .to in your Answer 30, is this a -- first of all, did this 12 involve a discrepancy that was detected during the course 13 of the Byron reinspection program?
34 MR. CASSEL: I'm sorry, Joe, you said Answer 30 15 we're now on?
16 MR. GALLO: Yes.
17 THE WITNESS: Was it detected during the Byron la reinspection program?
19 BY MR. GALLO:
20 0 Is this a discrepancy that was detected during 21 the Byron reinspection program?
22 A Well, the weld inspection sheets'that I reviewed,
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' 13-7 ' 134 1 which-were supplied here, they were in Section 2.1, page'5, 2 I believe. Yes. _And the calc was actually in Section 4.1, 3 page 7 to 11.
4 According to_ those documents, this was-reinspected-5 'in connection with PTL's scope of work.
6 Q Did the calculation that you reviewed -- was that 7 an evaluation of the discrepancy by Sargent & Lundy?
8 A Yes. These documents,'all the calc books, are 9 Sargent & Lundy's, by the way.
~
-10 Q Do you know what contractor at the site -- I 11 mean what Byron contractor -- let me strike' that and start 12 .again.
13 Do you know v. hat contractor doing'the work at 14 the Byron Station produced this particular weld?
15 A Produced it? No. Whose scope it came under in 16 the review? PTL.
17 Q PTL did the inspection; is that correct?
le A Yes. Well, it was in their scope of the review 19 program. I don't know who actually did the weld to start 20 with.
21 Q PTL didn't do any welding; isn't that true?
22 A They inspected stuff, though.
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- 1. ' O . All right. : if I were-to ask you this same series
'2 of questions ~with respect-to Answers 31, 32-and 33, would 13 ~ youLinfessence_give me the same answers?.'Namely,'thatL 4
there:are discrepancies ~ detected during the reinspection 5
! program, but you don't.know which contractor produced the 6 welds?
.- 7 A That's true, I don't.' I just know they were.in 8
PTL's scope of the reinspection program, which is what I was 9 : supposed to review.
10
.MR..GALLO: Well, we just saved perhaps 10 minutes.
11 I just got a poke.
12 (Laughter.)
13 (Pause.)
14 BY MR. GALLO:
15 O Turning to your very last answer in your 16 testimony, this document you refer to, Drawing 6E-3393B, l'7 is that a Sargent & Lundy drawing used for design purposes?
18 A Yes, I believe it was design installation --
19 initial design.
20 Q Do you know for what component?
21 A Category 1. conduit supports. There's a series 22 of:these drawings. This is the only one I listed, but the
\
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't whole package, which was : supplied tx) me, 'is 6E-3393A, it 2 'went almost through the alphabet. It missed several letters 3 at the end and then came back AA and BB, I believe, if my 4 memory serves me. correct. It was quite a substantial 5 package of drawings on this particular --
6 Q On page 26 of your testimony, you refer to the 7 unistrut catalogue. Is it your understanding that Sargent 8 & Lundy uses the design tables that are contained in the 4
9 unistrut catalogue for design purposes?
-10 A It's not my-understanding. It's sort of obvious 11 -from the questions I raised concerning KL/R that they may 12 have used unistrut, .8-for the~K factor, which would make 13 quite a substantial change in the table that I was looking 14 at,-and the correctness of it for end connections.
15 And so whether or not they used it specifically, 16 I can't say, but it appeared that they may have relied very-17 heavily in the unistrut catalogue on the .8 factor, and 18 possibly the KL/R is listed for that factor, instead of
. 19 doing their own analysis of KL/R for the actual conditions 20 in this table.
21 That was the explanation I reasoned out on my 22' own, but I can't go beyond that.
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You say again on page.26 that you reviewed many l.
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- 2 ~ designs: that exceeded ' the' 200 factor.
3 A' 'Yes.
'4
_ 'Q ~ Can'you identify.these designs for me?
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<(. 14-l' -1 A Not specifically. That was in relation to the !
1 2 - field trip that I went on with the Judges. In that trip, 3 the first thing that I -- we was looking at electrical 4 stuff, and the first thing they carried us to was all these 5 tray supports that were extremely long off the ceiling, 6 and I remember asking one of the CECO people -- I think it 7 was, how long one of these members was, because I wasn't a sure I could estimate it halfway decently, and he said, 9 " Eighteen feet."
10 0 I don't want to interrupt you, but I thought 11 we were talking about conduit supports in these answers on 12 page 26.
13 A Well, these are conduits in HVAC -- not HVAC --
14 cable trays are conduit supports. That's what we were is looking at in the field, a lot of cable tray supports, 16 extremely long members off the ceiling. If I said HVAC, 17 I'm sorry. The same supports, by the documents I saw, is could have HVAC as well as cable trays on the same 19 structure. And if I said just strictly HVAC, I'm sorry.
20 There would have been a combination of those two, maybe 21 just one or the other. The ones we saw in the field that 22 I'm specifically referring to in that statement -- I believe 3
I
139
-t 14.-2 1 11 were cable trays, but I can't say'for sure. They didn't
~
2 have any.HVAC on them.
3 0 Now I'm confused by your testimony. On page 26, d you say that you reviewed many designs that exceeded the 5 200 factor. And what I'm confused about is whether you 6 actually reviewed documents that exceeded.this factor, or 7 it was based on your tour with the Judges that day and a you observed these during your tour.
BU7 9 A Some of both. The documents that I start out with, 10 the table indicates that the table is incorrect. That 11 indicates that many supports designed by that table would 12 be, in effect, incorrect.
13 On visiting the field, to continue, in i
14 extrapolating this, I visually saw many that e::ceeded and 15 complied with this table. I actually saw them. They were l'6 shown to me, and they fit that table exactly.
17 On top of that, in the calculations which I have 18 reviewed, which were towards the weld's end, which only 19 was one very minor part of these things, there was 20 reference by sketches of the configuration in the structure.
21 You can say I presupposed that many of those structures 22 are shown with the in excess of 200 KL/R, because in 1:
.a
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i, 140 14-3 II many cases the lengths of these members'were not indicated,
^2 and I'd have to actually compare,'if I knew the hanger 3 number, back.to the drawings.-
It's a very difficult thing d for me to try to trace allithis stuff back and forth. All 5 I can say is, I reviewed.those three.thi-~s, and the same 6 problem is obvious in all three -- the field trip, the t
7 document, and in the calculations, a O Let me see if I follow you., Based on your 9 review of the table that is discussed on page 25 of your 10 testimony, you conclude that the table is inadequate, and 11 then based on your field trip with the Judges, you actually 12 observed designs where the factor of 200 was exceeded.
13 .Is that a fair statement?
E 14 A In my opinion, I saw stuff. I didn't need a 15 tapemeasure and a ladder to get up and do a real detailed 16 dimensional check. But just off of judgment, I would say I'7 they exceed well over 200.
18 O All right. Are you familiar with the testimony 19 ' of Ernest Branch? .
20 A I have read Mr. Branch's testimony, yes.
21 O Are you aware that he evaluated 49 discrepancies 22 involving ASME welds?
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k ,mgc14-4 1 A .Yes, I referred'to that earlier-in my statement 2 when I was talking about thin wall.
.3 0 Did you review any of those calculations during 4 your review at Sargent & Lundy?
5 A Many didn't have calculations. I've got the 6 document which was given to me. Maybe it's not complete, 7 but there's three documents given to me -- BRP-1, BRP-1(a) e and another document, I think BRP-3. .I won't gurantee 9 that last one , but it's a listing of all those things 10 reviewed.
11 In many cases, they were simply stated " Accept-12 able," with no calc at all.
13 0 We're talking about ' the 49 ASME welds?
i 14 A Yes, yes. There was a little pipe wall thinness is calculation. I don't think that part was in the calc, 16 though, the pipe wall thinness. But they referred to the 17 thickness requirements and what was calculated as being
! 18 the requirement. I wasn't sure there was an actual i 19 document where they sat down and said the thickness and l
l 20 the pressure and all this stuff, and they came up with a 21 number. I didn't see that, no.
22 Q It's Mr. Branch's testimony that 49 ASME welds, 9
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- which were detected with discrepancies during the 2 reinspection ^ program, were evaluatAd^for- their design
'3 significance, and thatInone had design significance. _
d And I am asking if you, in your review at 5 .Sargent & Lundy, looked at any 'f o those evaluations?
6 .A .y. looked'at those three documents, and they 7
were -- -
8
~
Q Were those' evaluations in th'ere, in those three 9
documents,.to your. knowledge?
10 A I can't say it was completely there. There was 11
~
an evaluation in there, yes, as well as the entire listing 12
. of all of the welds.
I3 Do you-know whether the evaluations that Mr. Branch
, Q 5
Id was referring ~to are the same as what you reviewed?
15 A I have no way of knowing'what Mr. Branch reviewed.
16 He's never supplied me with a list of what he actually 17 looked at. ~If I made a statement-on what he reviewed, is I would have to presuppose that -- make an assumption on 19
.that basis, and I'm sorry, I can't do that.
20 0 So you don't know whether'you reviewed the 49 21 ASME discrepant weld evaluations that Branch testified to 22 or not?
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=14-6 1 .MR.' WRIGHT: Objection. I think that's answered 2 in his Answer 36.
3 THE WITNESS: The document was covering the 49 4 ASME. If there's 49 more, what can I say?
5 BY MR. GALLO:
6 Q No. 'I'm talking about the ones that Mr. Branch 7 testified to.
8 A Again, he only testified to 49 ASME welds. This 9 document specifically addresses 49 ASME welds. Unless 10 there's more than 49 and more than one document, I have 11 no -- you know, I can only say I assume this document 12 covers the same 49 he reviewed.
13 Q This is not a trick question, Mr. Stokes. It's i
14 my understanding that to meet your request for a review 15 of documents, that Sargent & Lundy made available, among 16 other documents, all the calculational books that dealt 17 with these 49 discrepant welds, and I'm just asking is whether or not you reviewed those, pp A If they did, then I reviewed them, at least in 20 their office on a very quick scan type basis, and I believe 21 the document that I've got a copy of, these 49, is the 22 entire package, but --
5 1
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- mgc'14-7 -Q Did you note any, deficiencies in those 2 . evaluations?
3 A Did I mention any in this testimony? I don't d
believe I did. I think there is a few comments I had 5 ;on them that may have been something that I felt was not 6
that important. The 49 I looked at, there was -- yes, 7
there was. I'll back-up.
8 The question before 37, the'one you omitted, 9 discusses whether any Sargent & Lundy calculations for the 10 reinspection program had caused concern, and I list BRP-1, 11 okay? So I answered it in that question. There's two 12 welds, 62 and 63 which were accepted, despite the fact that 13 the accuracy of the gauges supplied for measuring the welds
-t Id was only 1/64th of an inch.
15 The actual numbers shown in this cale indicate 16 that this thing fails, period. The only way they got it 17 over was'they used the 1/64th accuracy to say, Well, we 18 assume this gauge was out of tolerance, and we boost it 39 over." So that caused concern. But that was related to 20 weld gauges used in inspecting.
21 Other than that, in those two, I can't remember 22 any more.
O a
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'145 k I mgc14-8' Q 'Go ahead. I'm sorry.
2 Doesn't this comment on the top of page 25 go to 3
the question of the adequacy of the inspection, as opposed d
to the adequacy of Sargent & Lundy's discrepancy evaluation?
5 A It cannot go' to.'both. It goes to the adequacy of 6 -the inspection, in that the gauges in question here, 7 the documentation that I saw, letters from the supplier --
8 his own comments are, "These gauges are only general 9
quality accuracy, and if you need a more accurate gauge.
") then you should use something else, specifically machine il shop type gauges."
12 So it goes to as to what equipment was supplied 13 to these guys to do the calculations to determine the I
14 accuracy or validity of these errors, and then'it.goes 15 to the assumptions on Sargent & Lundy's part to get these 16 things out of any significant level category, instead 17 of assuming that the gauge was above tolerance that was 18 used to measure it on the one hand, and below tolerance
- 19 on the other hand -- 1/64th and 1/64th, s'ich would have 20 been 1/32nd, and added that to their difference -- would 21 have been even more out of scope. Now --
22 0 You think they -- let me see if I understand what h
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146 4 14 1 you're telling me. You're telling me that the dimension 2 of the discrepancy was understated in this instance?
7 A It could have been.
4 0 -And that therefore this adversely affected the 5 . evaluation of these two weld discrepancies performed by 6 Sargent & Lundy?
7 A It could' affect not only those, but many. When 8 you have only an accuracy of 1/64th of an inch, and that's 9 plus or minus accuracy, and you arbitrarily assume that 10 everything you measure is perfect, with that you're --
31 if you use the exact same gauge from here to here to here 12 to here to here in every evaluation that was evaluated 13 in the very first place, then you can say, "Well, this
(
14 gauge is inaccurate, but the inaccuracy is identical to 15 what was used at the beginning, so the determination has
-16 no effect." But when the inaccuracy of the gauge is not 17 consistently applied to the same location of measurement, is then you have a plus with a minus, a plus plus, or a 19 minus minus.
20 In the worst case, this plus minus, that's using 21 a low tolerance, say, a't the end, undersize with an 22 oversize at the beginning, you get two unconservative
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( i 14-10 1 factors. .
2 All right. Let me ask you this question.
O L
3 Were Welds 11-A and 33 -- I think those are d
r the shorthand terms-that I-can use -- referred to at.the 5 top of page 25 of your testimony, were those designated 6 as discrepant Welds?
7 A They were in this batch of discrepant ASME welds 8 which were reviewed by Sargent & Lundy in BRP-1, yes.
9 And did you check those particular evaluations Q
10 to determine whether or not Sargent & Lundy performed them 11 adequately?
12 A Well, from BRP-1, the evaluation appeared to be 13 inadequate.
l \
id Q Based on this criticism?
15 A Yes.
16 Any other reason why it might be inadequate?
Q 37 A Not to my knowledge. I didn't see any pipe wall l
18 thickness calculations in this package.
19 All right.
Q That's two our of the 49. Did you 20 find any inadequacies in Sargent & Lundy's evaluation of 21 the other 47 ASME weld discrepancies?
End 14 22
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.#15.1521- 148 I A I don't believe so. As I said, there may be other 2 minor problems I saw with those, because they were 3 _ assumptions, primarily. That's one of the problems. The d
problem I_saw with a 19 t,of this is.they assumed there was 5 no problem, if you want to get down to the bottom line.
6 There's a whole bunch of that in everything I've seen, and 7 that's assuming that whatever is there is okay, flat, a right off the beginning. They never did a calc, they didn't 9 do no load comparisons, nothing. It was just assumed okay.
10 Now that's a problem as far as I see it, 11 across the board. A problem is a problem. If you want to 12 know the truth.
13 Other than that -- and I'd say that makes up i
14 half of the 49 or more.
15 O Now what was the nature of the ASME weld 16 evaluations performed by Sargent & Lundy? What did they do?
17 A Well, from what I could determine from this 18 document, the nature of the problems primarily were 19 insufficient weld thickness. It appeared they had done a 20 calculation to determine minimum pipe wall thickness. That 21 was not part of the package, and I assumed maybe the guy 22 just did it on a rough sheet of paper. As far as I know, I
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149
'15-2 1
didn't get any of that documentation either. Otherwise --
2 Q Didn't they evaluate the effect of the 3
discrepancy on the pipe?
- 4 A They evaluated pipe wall ~ thickness required by 5 what was there. They made a statement.
6 Didn't they conduct a calculation to determine Q
7 .whether or not the wall thickness was adequate?
A*
8 A I just said they compared the calculated wall 9 I didn't see no cale in thickness with what was there.
") this document, 11 Q You didn't see any calculation?
12 A No.
13 Q So you think they just eyeballed it and guessed?
Id A No, I don't know. I assume the guy did a 15 calculation somewhere else and included it in this document.
16 I didn't See it so I don't have any -- had I seen the calc, 17 I would not have the sufficient documentation to question 18 the pressure, the temperature, and a lot of other factors 19 that would have went into it.
20 There's no way I can draw a conclusion beyond 21 what I'm stating, because to do the detailed type review 27 you're asking is, first I would have to run the pipe analysis
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- i. -1 myself, after rewalking the entire system to determine its 2 adequacy from that standpoint.
3 0 I'm only asking if you checked the Sargent &
4 -Lundy calculation.
5 A I checked what I saw and what -- I can't go 6 beyond what's in BRP-1, 1-A, 3. On the ASME stuff, that's 7 the only documents I saw, I have knowledge of, that 8 discussed ASME issues.
9 Q Now Mr. Branch also testified with respect to lo his evaluation of certain discrepancies involving what are 11 called in the reinspection program objective attributes of 12 Hunter. Did you review any of those evaluations?
13 A Yes. I've got a document that says objective i
14 attributes of Ilunter, as far as I know. Parts of it, I'll 15 say that. I've got copies of parts of that document.
16 Q Did that document address the so-called hardware 17 discrepancies for the objective attributes for Hunter, do 18 you know?
19 A I can't remember exactly what was in those 20 documents, whether it was just strictly welds. I think it 21 was primarily welds, from what I can remember. Whether it 22 was hardware, I can't be specific. I consider everything I
7p. -
15-4 151
'( 1 hardware, structures, attachments. I would assume so.
2 Q Are youJfamiliar with the testimony of Richard 3 French?'
4 A Yes.
5 O Now, Mr. French's testimony addresses various 6 reinspection attributes for Hatfield, and they are called 7 in the reinspection program objective attributes.
8 Did you review any-documentation involving 9 the discrepancies noted during the reinspection progran of 10 these attr.ibutes?
11 A Hatfield?
12 O Yes.
13 A Yes, I've got copies again of excerpts out of 14 Hatfield books.
15 Q All right. I may be unclear in my question.
16 I'm really referring to Sargent & Lundy evaluation of 17 the design significance of the discrepancies noted in the 18 Hatfield objective attributes.
19 Did you review any of those Sargent & Lundy 20 evaluations?
21 A Yes, I think I did, but I'd have to consult 22 with everything that I've got. But just off the top of my i
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"15-5 I i head, I have documents on Hatfield, PTL and Hunter. I can't 2 say I had both objective and subjective in both categories.
3 I tried to pull parts'of documents supplied to me.
4 One of the documents which was sort of in question, 5 I believe, in the hearings under McLaughlin's testimony, 6' came out.was Mr. McLaughlin --
7 Q I'm just talking French now. We're talking 8 objective attributes for Hatfield-Frenbh testimony.
9 A I would say I've seen it. I Can't really be to specific.
ii 0 Can you tell me if you recall, if you note any 12 disagreement with any of the Sargent & Lundy evaluations of 13 the discrepancies that are categorized under the objective i4 attributes for Hatfield?
15 A Mr. French's testimony to Hatfield concerns to cable support trays, and I have got quite a few concerns 17 with the Hatfield calculations on those issues, yes. If is you'd be more specific about what was in the document, i9 whether it was cable tray or whatnot. I can remember that, 20 because that's primarily what I was looking at, was the body.
21 Many didn't have right across the top "this is Hatfield."
22 It had Book 119-2. You had to go back to an index to find i
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l- -( I out who in the hell it applied to,.and it varied from one 2 ~little section to another.
3 I remember looking at plenty of calculations d on conduit and HVAC supports that I have a whole bunch of-5 questions about, yes. I didn't include those here, I'm sorry.
6 MR. WRIGHT: Joe, how long do you intend to go 7 to finish him?
8 MR. GALLO: I probably can finish up in about 15 9 minutes.
l 10 MR. WRIGHT: Okay.
11 THE WITNESS: But, yes, there's a lot of things 12 in that category.
13 BY MR. GALLO:
( I id O Did you review any of the AWS weld calculations 15 . performed by Sargent & Lundy with respect to the evaluation f
l-6 of discrepancies of Hatfield and Hunter AWS welds?
17 A Yes, quite a few. That's primarily the review
, la program, was welds. There was very few things outside of 19 welding that was in question from what I saw. A few beam 20 connections, which were again welding; a few bolted 21 connections; anchor bolts.
22 O Did you review any of the Sargent & Lundy l
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. evaluations of the 356 Hatfield AWS welds testified to by
'2 McLaughlin?
3 A Again, I don't have a list of what Mr. McLaughlin d included in his 356 to compare it to the documentation I 5 have. But just going on what was' supplied to me and what I 6 have seen,,I would assume-that I've at least looked at part 7 of the 356 Mr. McLaughlin testified to, yes.
3 8 Q Again, do you recall any disagreement with those 9 evaluations that you --
10 A I'm sure there's got to be a few in there. I 11 had disagreements with quite a few of his calculations, but I 12 didn't have enough time to include absolutely every calc 13 that I looked at, that I had a question on.
(
Id The other thing is I didn't have time to go back 15 and redo a lot of the cales that I had done preliminary stuff 16 on and had a question over to verify that I was-correct.
! 17 And so I omitted stuff like that. I'm sorry, I --
18 Q You don't have to apologize. That's not needed.
19 So you're telling me you noted disagreement with 20 certain of the Sargent & Lundy evaluations of-the 356 21 llatfield AWS welds, but you didn't note those in your 22 testimony that you filed in this case; is that correct?
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I A That's correct. I didn't have time. I'm sorry.
2 (Pause.)
Cnd 15 3 4
5 6
7 8
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1916 16-1, 156
-1 Q All right. Page 4 of your testimony, Mr. Stokes.
2 You've -- are you on page 4?
3 A Yes.
d Q .I'm looking at the sentence that you corrected 5 in response to a question from Mr. Wright. You say you 6 reworked the aspects of a number of engineering calculations.
7 Are these hand calculations that you performed yourself?
8 A Well, no, I said in my review I reworked aspects I 9 of a number--when I reviewed some of'these calculations I 10 was just talking about, I performed rough cales on sticky 11 tab sheets which I stuck right on the calc itself for future 12 reference. I have not had time to go back and look at my 13 calculations or the other calculation.
t 14 0 What does the term " rework" mean here?
15 A I used it like rework as far as reinspection, l 16 re-evaluate, requalify. It's Sargent & Lundy's work, it's 17 the work they did, as far as qualifying the safety 18 significance, design significance of the joint.
19 Q Did you run an independent calculation yourself f
l 20 when you did this, or do Stokes calculations exist? That's 21 my question.
22 A There's notes on sticky tabs that exist, yes.
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1 Those are not, if you want to say Stokes calculations.
2 They are rough calculations. In other words, I used-those 3 to draw the conclusion that there was possible error in what d had been done in that aspect of the calc. They're not --
5 as far as Stokes calculations, I have an engineering paper 6 that I do a cale on and it's a very formal type thing.
7 MR. GALLO: Can we get copies of what he's 8 '
referring to?
9 MR. CASSEL: Do you have those here in town, 10 Charlie, the sticky tabs?
11 THE WITNESS: I don't think I have all of them, no.
12 MR. CASSEL: Do you have any of them?
13 THE WITNESS: I'd have to look through. There
(
14 are boxes of stuff. I can't say.
15 MR. CASSEL: Could you do that over the weekend?
16 THE-WITNESS: Yeah, I can do it, because I 17 planned on redoing some of those, anyway, just to verify it 18 for the hearing, and so if you'd like, I could give you copies 19 of not only the sticky tabs, but written up what I find cut 20 over the weekend.
21 MR. GALLO: No, I'm just looking for what you've 22 already done. I'm not asking you to do additional work.
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(' i THE WITNESS: Well, I'm going to.
2 MR. CASSEL: He's going to, anyway.
3 THE WITNESS: See, I've committed to it on my own 4 so you won't be asking for anything.
5 MR. CASSEL: We'll be happy to supply as many cf 6 the sticky tabs as Charlie can find over the weekend. Do 7 you want us to just give them to you at the hearing in-g Rockford, or give them to you at the office on Monday?
9 MR. GALLO: No, Monday would be fine.
io MR. CASSEL: But are you ng to be here at in the office on Monday?
12 MR. LEWIS: Could you copy us on the sticky tabs, 13 if possible?
(
i4 MR. CASSEL: The question is, do you want them 15 here or in Rockford?
6 MR. GALLO: We'll get them at the hearing in 37 Rockford.
18 (Discussion off the record.)
l pg MR. GALLO: All right, let's go back on the i
l record.
20 21 During the off-the-record conversation, Mr.
22 Cassel agreed to have Mr. Stokes furnish the sticky tabs and l
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16 159-
.I i the underlying documents referred to in our earlier colloquy 2 at the' hearing to commence on Monday morning -- or Monday.
3 afternoon.
4 MR. CASSEL: To the extent they are physically 5 here in-Chicago. If any of them are physically in California, 6 we won't have them by Monday.
7 THE WITNESS: We won't have them at all, because a some of the stuff when I pulled it to Xerox it, just to make 9 these attachments, I removed the sticky tabs. I didn't put 10 them back on. They're still on the Xerox machine. And when I n got through, I didn't want to go through it, and I threw them 12 away.
13 MR. GALLO: To the extent they exist here in f
14 Chicago.
15 (Discussion off the record.)
16 BY MR. GALLO:
17 0 One last question. I believe this gets us back 18 to the course work you took at Auburn.
19 A Okay.
20 0 I believe I asked you whether or not you took a 21 dynamics course and you said you did.
22 A Yes.
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16-5 160 1
Q Is this a required course or an elective?
2 A It was required at Auburn. At some schools it 3 would probably have been elective. The BCE curriculum per 4 se has many much more technical requirements in the program 5 than a B.S. in Civil would.
6 0 I see.
7 A But it was a required course.
8 0 Now did this required course concerning dynamics, 9 did that deal with structural dynamics?
10 A Yes, it did. Vibration, motors, bodies in space, 11 quite a few different aspects of dynamic properties of 12 structures.
13 0 Did it deal with the dynamics of structures i
14 like reinforced concrete structures -- not steel structures, 15 concrete structures?
16 A The course was more geared not to the designing 17 of concrete and its vibration, but the kinetic energy is transfer dynamic equilibrium states associated with that 19 movement which would apply to any material based on its 20 properties.
21 Q Do you remember what year at engineering school 22 this course was offered? First year, second year?
4 0
- c- - ;
,,.-4.,- -
'16 161 b i A' No, it was -- what year out of the curriculum, I 2 can't say at the moment. I think it was the-third year, 3 junior level. The problem with me, as~I've already stated,.
. .4 is I was in architecture and'then transferred to civil, and 5 I was a junior almost when I started the engineering. I was ---
6 you know, I -- for me, it was a junior level course, or above.
7 MR. GALLO: That's all the questions I have.
8 MR. LEWIS: We want to take a short break and see 9 if we have anything. Five minutes.
10 (Recess.)
cnd 16 11 12 13 l
14 15 16 17 18 19 20 21 22 I
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162
(. 17-1 1 EXAMINATION 2 BY MR. LEWIS:
3 Q We just have a few loose' ends we wanted to tie 4' up. - Mr; Gallo has been so effective that I find myself 5 left with little.
.6 MR. GALLO: I'm going to let you go first next 7 time.
8 MR. CASSEL: Mr. Lewis is one of your finest 9 Staff members.
10 BY MR. LEWIS:
11 -Q Mr. Stokes, I'd like you to look at Attachment 2-F 12 to your testimony. 2-P is simply a one-page excerpt from 13 the Sargent & Lundy design document that we've been talking i.
14 about.
15 Have you located it?
16 A Oh, yes. Okay.
17 0 I'd like to direct your attention to the last is sentence on that page which reads, "A separate embedded 19 plate design shall be made where applied loads exceed the 20 capacity of the grid plate."
21 A Yes, I see that. I read that earlier.
22 O You testified earlier that you were concerned t
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163 17-2 1~ about the loads that might be exerted on embed plates, and 2 I believe you were talking about struts or other members. .
3 A Yes.
4 0 When you read this sentence at the' bottom of 5 2-F, did that indicate to you that the type of analysis 6 'that you felt should be done would, in fact, be done where 7 applied loads exceed'the capacity of the grid plate?
8 A If the person was aware of that one line, 9 my experience in this whole little narrative here on embed to plates, that plates typically are designed for use without 11 knowledge of what's going to go there in many cases. The 12 fact that the thing was on the plate indicated two things 13 from visual. There was a fairly large weld to the embed i
14 plate which had, you could tell, heated the concrete on 15 the edge. The attachment was as wide as the plate almost, to which the plate had to be a six-inch plate. There was a 17 problem with overheating of that half-inch plate, because la it appeared they had put on quite a substantial fillet 19 weld, and then on top of that, you had a very sizeable 20 attachment for the width of the plate, and whether or not 21 this calculation indicates that it should be redone before 22 you attach it, and the guy who did that analysis or did that i
~
L.x.
164 17-3-~1' support was aware.of this at the moment, I'm sort of in-2 question whether that analysis was performed for that 3 -particular one.
d But -- is that clear?,
5 O Well, to some extent. Let ne ask you this. In 6 other words, if I correctly understand you, you are 7 concerned that maybe the person who would do this 8 calculation perhaps would not be aware of this provision?
9 Is that part of what you --
10 A Yes. And the cale's book size is almost of the 11 book, in the early part of the book, there was a series of 12 written documents such as what is attached here to my i
13 testimony,* explaining assumptions, what's relevant, what's i
14 not relevant, such as the undercut discussion. It's 15 obvious to me that in this review it was likely they hired 16 people such as myself without any prior Sargent & Lundy f
17 experience to do with the work, because I heard there had 18 been a layoff some fews months ago before the review was I
l 19 required, and the people may not have had this document, 20 the criteria document. In other words, it may have existed, l
21 but it was something they weren't exposed to due to the 22 rush of doing these recalculations.
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165 17 1
.But in-any case, I got the impression that the 2 people who did these evaluations in some cases did not 3
know what's in this criteria, and that was-obvious by other d
things other than just this.
~
5 Q I'm sorry. I didn't mean to cut you off.
6 A I know. I was going to quit with that.
7 0 Well, assuming that these Sargent'& Lundy - the
.a individual who would do this calculation ~was aware of this instruction, would it then address the concern that you 10 had raised?
II A If he was aware of the instruction and evaluated 12 it, based on that line, it would change that, yes.
13
, O Now if you could look at Attachment 10 to your
'd l testimony, the third page of that excerpt from the 1983 15 NRC annual report, --
l 56 A Oh, yes.
17 0 -- the discussion of water hammer.
18 A I remember that very well.
O There is a statement under " Water llammer which 20 says, "The frequency of occurrence," meaning occurrence 21 of the water hammer, " incidence is low, and damage has 22 generally been limited to piping supports.-
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166 e
1
~ 17-5' -Is that statement the source of your statement --
2 I don't have the exact answer in your testimony, but in 3
your testimony, you speak of piping supports as being d
subjected to fatigue, stress.
5 A: I quoted that last line almost in detail in one 6- of the answers. I can't remember each one.
7 Q Is it Answer 26? Yes, your testimony on page 18 8 in Answer 26 states that you refer to.the NRC annual 9 report.
- 10- A Yes.
11 And you refer to the excerpt on water hammer, Q
12 and you say there that the NRC report speaks of water 13 hammer, and then you say, "A condition that causes Id fatigue loading."
15 A Yes.
16 L 0 What was the basis for your assertion that 17 piping supports are affected by fatigue loading?
18 A They are affected by dynamic loading. Water 19 hammer is the dynamic loading. Seismic loading is 20 dynamic. I've been in some operating plants, you know, 21 that the pipe -- fluid runs through it and it vibrates 22 from one side of the support to the other, rattling quite
=
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-167 t-
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'1 noisily. .That load reversal is just that -- load 2 reversal. The fact it hits one. side and. hits the other 3 side is an operational load reversal.
d O Is that what you meant when you said fatigue 5 loading?
6 A Cycling time. It would be over 40 Part of it.
7 years significant. You'd have to sit there and count how 8 many times a second it changes and then multiply it over 9 a few years. But water hammer is part of tnat, too. You 10 have to take into account how many times a year. You can 11 estimate valve closures are going to occur and these other 12 issues that will cause the extreme magnitude of loading 13 that water hammer causes.
14 For instance, when I was at Southern Services, is in my earlier discussion of what I was doing, I said I 16 worked on the makeup water lines offsite from Miller steam 17 plant. In doing those thrust blocks that I alluded to, 18 I had to consult with the ASME department expert on water 19 hammer. He told me that I had to design for the lines 20 for approximately ten times what the design load was to 21 account for water hammer loads, they were that much larger.
22 I, instead of doing that, after I tried to redo 1 i 4
p-168 l
-( i the analysis to get supports that would take the-loads ;
t 2 for these 24-inch lines -- when I found I had an extreme !
3 ' problem wi_th designing something :for that magnitude of l 4 load, I looke,d at the piping analysis layout drawings, 5 and I found out-that there was potential for a surge tank.
6 ' Now ohe of the courses that no one asked me about 7 here is-pipe flok- theory and fluid. flow theory. I took ,
t a courses in that, too, by the way.'"And I'm aware that 9 another alternative between designing for loads is to put ,
i lo a ,supprossion tank on it or a surge tank or a few other !
11 little goodies that can take out that load. ,
> I l . . .
! 12
'. Well, it just so seems that they have this tank 13 potentiab'but,theydidn'twanttouseit. They were t -
Id keeping it as an ace in the hole, arid, I negotiated to have l ,/. ~
15 the-loads' reduced, based on that surge tank and have *
/.
16 it installed, rather than have them' design thrust loads l
17 and then have them put the tagN in later.
l 1a C. So from that respect, II m quite familiar with ;
j .
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19 piping.thrus't loads, water hammer, and jet impingment and l r- '
! End 17 20 a lot of,otheF'stbff. /
'i , !
21 Q Mr.' Stokes,'do you know what position the NRC 22 has taken? There ja a reference in the annual report that 9
agu* .
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d e,
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169 48-1 1 you referred to doing your report, do you know whether 2 the NRC has-required any hardware changes as a result of --
t 3 A Yes. According to the article, their d requiring changing of valves to reduce closure times I
5 was part of it. I don't remember anything else, but that 6 was the one thing I remember from it, and that with some 7 certain systems rather than maybe the entire plant. ,
a
Q ' But focusing on suppprts on. hangers, because 9 that was what your Answer 26 was one --
10 A It concerns stresses to hangers. Yes, specifically 11 the bolting aspects. ;
12 0 Right. Do you know whether or not the NRC t 13 has required any changes to hanger supports as a result Id of water hammer considerations?
l
- IS A Changing of supports? Could you clarify that 16 for me? Specifically what kind of changes?
17 0 Whether or not, as a result of --
18 A Are you talking about an I&C Bulletin maybe?
19 0 Hell, it could have been, I suppose, by .in I&n 20 Bulleting.
21 A Oh, boy.
22 MR. WHIG 11T: Steve, can I ask you to restate that
f:
170 Ia 1 question?
2 MR. LEWIS: I'll be happy to.
3
.Y B MR. LEWIS:
4 Q Do you know'whether or not as a result of the 5 - +
investigation of water hammer currents in nuclear power
' ' ~
6 plants, which is discussed in this excerpt from the annual 7
report, the NRC has required'any changes or redesigns to 8 .
be done to pipe hangers because of the concern over the 9
loads imposed by the water-hammer phenomenon?
10 A I'm not aware of them requiring any changes in
- 11' the design of the hangers as.a result. The thing I'm aware 12 of is the valve change closure'ti~me.
13 -
4 MR. LEWIS: Thank you. That's all I have.
14 EXAMINATION 15 BY MR. CASSEL:
16 0 Charlie, just a few questions o'h redirect.
17 Do you recall Mr..Gallo asking you this morning 18 about whether yc ar testimony raised concerns about the 19 design adequacy'of Syron? ~
20 A Yes, I remember that question.
21 Q Does your testimony
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also raise concerns other 22 than the design adequacy?
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171
'(- 1 A Yes, it does.
2 O Do you recall Mr. Gallo also asking you whether 3
your testimony recommended an independent design review?
d A Yes.
5 0 And are you aware of the fact that Bechtel has 6
been. conducting an independent design review for Byron?
7 A Recently I became aware, yes.
8 Q Have the results of that review been supplied 9
to you or, to your knowledge, been supplied to Intervenors 10 in this case?
11 A No, it's not been supplied, to my knowledge, to 12 anyone including myself.
13
(
Q Does your testimony also recommend an independent 14 review of the safety-significance of the disc: mancies 15 found in the reinspection program?
16 A Yes. My testimony is geared to everything that's 17 been done in the reinspection program, from the verification la aspects of the program to the design calculations, the 19 safety-significant aspects, all areas.
20 MR. CASSEL: I have no further questions.
21 MO. GALLO. I have no questions.
22
[ l 172 :i l
I i
,./I- .I- (Whereupon, at 3:50.p.m., the taking of 2 the deposition was concluded.)
3 It .
5 (Witness' signature waived, 6 pursuant to agreement.)
'7 8 '
9 10 11 12 13 14 ,
15 16 17 IS 19 20
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173 1 STATE OF MARYLAND :
i 2 COUNTY OF MONTGOMERY :
3 4' I, ANN RILEY, a Notary Public in and for 5 Montgomery County, Maryland do hereby certify that I 6 reported the deposition of CHARLES CLEVELAND STOKES, the 7 witness herein.
8 '
I further certify that the foregoing 172 pages 9
contains a true and accurate transcription of the answers 10 given.to the questions herein asked.
11 12 I further certify that said transcription was i3 done either by me or under my personal supervision.
14 I further certi.fy that I have no interest, 15 financial or otherwise, in the outcome of this litigation.
16 j7 Given under my hand and seal of office this 18 17th day of August, 1984.
19 20 Ann Rileyr
?!
My Commission Expires:
22 July 1, 1986 i
i J