ML20137V017
| ML20137V017 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 02/13/1986 |
| From: | Shevlin E COMMONWEALTH EDISON CO. |
| To: | |
| Shared Package | |
| ML20137U946 | List: |
| References | |
| OL, NUDOCS 8602190404 | |
| Download: ML20137V017 (200) | |
Text
CORREspon I \
V 1 UNITED STATES OF AMER g g7g USNRC 2 NUCLEAR REGULATORY COMMISSION 3 BEFORE THE ATOMIC SAFETY & M C S $$G g h 4
ICE CF d. ;q ;;4 ,
METING 4 3rgeg,g.
5 - - - - - - - - - - - - - - - - - - - -x BRpycy 6 In the aatter of: :
UC os.
7 COMMONWEALTH EDISON COMPANY : "f 4 8 (Braidwood Nuclear Power Station, 50-457 9 Units 1 alid 2) :
10 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x 11 12 Isham, Lincoln & Beale 13 Three First National Plaza L .~~/.N.h' 14 Chicago, Illinois Thursday, February 13, 1986 15 The Deposition of EDWARD M. SHEVLIN, called 16 for examination by Counsel for Intervenor, taken before 17 Suzanne B. Young, a Notary Public in and for the District 18 of Columbia, at the offices of Isham, Lincoln & Beale, 19 Chicago, Illinois, on February 13, 1986, when were present 20 ____________________________________________________________
21 ANN RILEY &. ASSOCIATES, LTD.
22 1625 I Street, N.W. 293-3950 Washington, D.C.
B602190404 860218 m' PDR ADOCK 05000456 T PM
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k- 1 on behalf of the respective parties:
2 APPEARANCES:
3 For the' Licensee, Commonwealth Edison Company:
4 PHILIP P. STEPTOE, III, Esq.
Isham, Lincoln & Beale 5 Three First National Plaza Chicago, Illinois 60602 6
For the Intervenors, Rorem, et al.:
7 ROBERT GUILD, Esq.
109 North
Dearborn,
Suite 1300
~
8 Chicago, Illinois 60602 9
For the NRC Staff:
10 ELAINE CHAN, Esq.
11 Office of the Executive Legal Director U.S. Nuclear Regulatory Commission 12 Washington, D.C. 20555 13
^
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\m) y ,4 15 16 17 18 19 * *
- 20 21 22 i i ws 9
4
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L/ 1 INDEX Witness Examination By: Page No.
3 EDWARD M. SHEVLIN Mr. Guild 4 5
Mr. Steptoe 62 6
Mr. Guild 66 7
Mr. Steptoe 70 8
Mr. Guild 71 9
10 11 12 13 EXHIBITS
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(_/ ja Exhibit No. Description Identified 15 Shevlin No. 1 Intervenors' Notice of Deposition 1/3/86 8 16 Shevlin Group Exhibit . Drawings, memos, reports, 12 j7 No. 2 etc. 17 and 18 19 20 21 C\
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i-4 5
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' dyen 1 PggCEEDIEQS
[ 2 10:10 a.m.
1 3 Whereupon, 4 EDWARD M. SHEVLIN, 5 , called for examination by counsel for Intervenors, afterf' 6 being sworn under oath, was examined and testified as 7 follows:
8 EXAMINATION
. 9' BY MR. GUILD:
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10 O' Mr. Shevlin,.would you: state your full name and'
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11 your-business address for the record, please?
12 A .,M y full name~is' Edward M.-Shevlin, and my
, 13 business address is Braidwood Nuclear Station, Braidwood.~
1 U 14 Q- And by whom are you employed?
, 15 A I am employed by-Daniel International-Corporation. .;
16 Q And in what capacity?
.17 A~ I am currently working as a consultant in'the 18 Phillips-Getschow Mechanical Contractors organization, i 19 Q You~ submitted an affidavit in this proceeding-in 20 support of Commonwealth Edison Company's Motion for Summary _
k 21 Disposition regarding a portion of Intervenors' quality-22 assurance contention, and I want to show you a~ document i
i 5
4 f .
'- I that is entitled " Affidavit of Edward Michael Shevlin on
-2 Rorem QAlSubcontention 12J, and it appears to-be your 3 signature. Is that your signature?
4 A Yes, it is.
t 5 0 And is that your testimony, a document of 30 -
6 pages with attachments that follow that affidavit?
7 A yes, ,
1 8 Q For'the record, my name is Bob Guild. I am 9 counsel [for.the..Intervenors Bridgette Rorem and others,
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3 10 in the Braidwood licensing proceeding on the quality
]
11 assurance contention, and I have got some questions for-you-
- 12 -
concerning your affidavit, Mr. Shevlin.
' 13 Before I begin, I understand that you may have g
14 some corrections to your testimony.
- 15 A Yes. *
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- 16 Q Could I ask you to make those at this time, I 17 please?
18 MR. STEPTOE: We sent a letter out last week, ,
, 19 -
but why don't you go ahead and'do it again just for 20 completeness.
21 . MR.. GUILD: I would appreciate that.
6
- 22 THE WITNESS
- Okay. There are, first, a number j - -
1 4
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,e 8 E- 1 of typographical errors.
2 MR. GUILD: Why don't you just leave off the 3 typos unless they change the meaning of the testimony.
4 THE WITNESS: No, they mean nothing.
5 Second, on Answer 26, page 20, the second line 6 from the bottom, the number 20 should be 21. Oh, excuse 7 me. The second line from the bottom on page 20, the figure 8 0 foot, 0-3/8 inches should be 0 foot, 0-3/4 inches.
9- BY MR. GUILD:
10 I am looking at the last line.
Q Is that what your il reference is? There is one word on the last line. I 12 apo.logize. Thank you. That should read 3/4 inch; correct?
13 A Right.
14 Q All right. Thank you.
15 A Answer 35 on page 26, the second line from the 16 bottom, 20, should read 21.
17 All right, sir.
Q 18 A On Exhibit E, the page numbered E-521, in the 19 right-hand column, top, the number "7" should be number "8."
20 And the bottom number in that column, "12," should be "13."
21 All right, sir.
Q Are there any others?
22 A Yes. Answer 13, page 11, the fifth and sixth t
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7
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(/ 1 lines from the top, in both cases the word " bottom" should 2 be " top."
3 Q And how should the sentence read?
4 A It should then read, "In the other case, the 5 BCAP Task Force recorded a 10-inch dimensional difference 6 from the top of the slab to the bottom of -- to the top of 7 a riser."
8 On the same page, the bottom line and the second 9 line from the bottom, " lower" should be " upper," and 10 " bottom" should be " top."
11 Q Could you tell me how the sentence should read 12 as corrected?
,,, 13 A It should then read, "The 10-inch dimensional 14 difference noted by the CAT was a simple error-on the is inspector's part. She measured from the top of the slab to 16 the weld at the upper end of the. riser."
1'7 MR. STEPTOE: Bob, if I can interject, the 18 correction which Mr. Shevlin made to his own affidavit
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19 substituting "21" for "20" also has to be carried over, as 20 I indicated in my letter last week, into Mr. Kostal's~
.21 affidavit at page 6, line 2, and I believe it also appears 22 in my statement of material facts on page 7, the sixth line (3
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I 8 l l
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"w J 1 from the bottom.
2 BY MR. GUILD:
3 Q Are there any other corrections that.are a part 4 of your testimony?
5 A No.
6 Q Mr. Shevlin, I want to show you a document that 7 has been. marked for identification as Gieseker Deposition 8 Exhibit 1. It is entitled, "Intervenors, Rorem, Et Al, 9 Notice of Depositions," dated 1/30/86. It is directed to 10 you, among others, and I ask if you can identify that 11 document.
12 (Witness reviewing document.)
,, 13 A I have seen it.
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V 14 Q And what I would like to do is provide the is reporter of this Gieseker Exhibit and ask that it be marked 16 as the first exhibit to Mr. Shevlin's deposition.
17 (Shevlin Deposition Exhibit No. 1 18 was marked for identification.)
19 BY MR. GUILD:
20 Q Mr. Shevlin, the second page of that notice asks 21 that you and the other deponents bring with you documents.
22 Have you brought any documents responsive to
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(_,) i that request?
. 2 A The copies of the drawings which you were t
3 furnished.
4 r Are there any other documents that are responsive 5 to _he request that you bring with you, all documents in 6 your possession or subject to your control which are 7 the basis for your affidavit in support of the December 20 8 Motion for Summary Disposition?
9 A In my affidavit I quoted Juran, the quality' 10 handbook. I have the handbook with me.
11 Q Are there any other documents that are the basis 12 for your testimony? I believe your counsel before the 13 deposition identified additional documents that he has a
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14 copy of that are responsive to that request.
15 A I used or referred to a number of papers that 16 are in the BCAP files, l'7 Q All right. What'I would like you to do, Mr.
is Shevlin, is to identify those documents for the record, pg and we may want to copy them and have them made a part of 20 the record in this deposition; but if I could ask Mr.
21 Steptoe to make available to you the stack of paper.
22 MR. STEPTOE: Why don't you take a look at that
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E 10 k_) 1 stack of papers and see whether you used any of those 2 documents in preparing your affidavit.
3 (Witness. reviewing documents.)
4 BY MR. GUILD:
5 Q' I'll tell you what, Mr. Shevlin. Before you do 6 that, let me get you to identify the drawing that you just 7 had reference to first. If you could take the stack of 8 paper that was made available first and tell me what those 9 are, please, if you would go page by pa~ge and identify 10 them.
11 (Witness reviewing documents.)
12 A Identify these drawings.
13 Q Yes, please. 2 ell me what they are.
' 14 A Okay. The top page is a copy of Phillips-Getschow 15 construction piping drawing 1AAF8.
16 Q All right.
17 A A copy of the Sargent & Lundy support drawing 18 1CS03029V.
19 A copy of a Westinghouse support drawing 1CS04002S.
20 A later revision of the same drawing.
21 Q Can you identify the revision?
22 A Revision D.
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(_) 1 Q To the Westinghouse drawing?
2 A Yes. The difference being that with Revision D 3 it has Sargent & Lundy's title block on it.
4 Q What was the revision of the first document you 5 identified, the first Westinghouse document?
6 A Okay. The same drawing, 1CS04002S. It's 7 Revision *l, which has to do with engineering change notice 8 152471.
9 Q And is the Rev. D a later revision?
10 A Rev. D is a later revision.
11 Another copy of the same support drawing with 12 a Westinghouse title block, Revision *2. And the *2 13 relates to engineering change notice 16959.
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14 Q And is it, Rev. *2, before or after Rev. D?
15 A Rev. D'is the later.
16 Q All right.
17 A Now, the next one is Westinghouse drawing 18 support 1SX06028R.
19 And the final drawing is a blowup of one portion 20 of the one I just mentioned.
21 MR. STEPTOE: One portion of the what?
22 THE WITNESS: Of the Westinghouse drawing I just
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12 O I mentioned.
2 BY MR. GUILD:
3 Q Okay.
4 A It's just an enlargement of one corner of the 5 drawing.
6 MR. GUILD: I would like to ask that the 7 reporter mark the drawings, to begin with, as the first 8 portion of Shevlin Group Exhibit 2, and we may add some 9 documents to that as we ao forward.
10 (Shevlin Deposition Group Exhibit 11 No. 2 was marked for identification.)
12 BY MR. GUILD:
13 Q Mr. Shevlin, I interrupted you when you were V 14 beginning to look through the stack of papers that Mr.
15 Steptoe made available to you.
16 (Witness reviewing documents.)
17 MR. STEPTOE: Bob, what I did in compiling the 18 stack was I just got all the reference documents that 19 were included in Commonwealth Edison's response to your 20 Interrogatories 58 and 59 with respect to Contention 12J.
21 Based on the previous conversations with Mr. Shevlin, I had 22 reason to believe that those were the documents. At least O
13 O)
\- I those included the documents that he had relied on other 2 than the ones he brought today.
3 I asked our paralegals to copy these documents, 4 and that's haw we got this stack. Now, the paralegals did 5 not find in our files three of those documents, and there-6 fore, Mr. Shevlin has not looked through those three 7 documents. They are listed on the front of the report, and 8 maybe Mr. Shevlin could look at them. They are items 6, 7 9 and 8 in our reference list dated November 22, 1985, 10 which was included with our response to your Interrogatories 11 58 and 59. He might be able to tell just by looking at the 12 brief' caption whether or not he relied on those documents.
13 THE WITNESS: I don't believe I did. I don't 7
14 recognize them.
15 BY MR. GUILDi 16 Q Mr. Shevlin, you have had an opportunity to 17 review the documents thatJir. Steptoe just described, and 18 can you.tell me, of those documents, which were the basis 19 for your affidavit? Can you go through the stack that you 20 have found, please?
21 A This one.
22 Q Can you tell me what it is?
A b
14 7-(._ 1 A It's a summation, pages E453 and 454.
2 A memo from Clinton to Byers, page E458. An 3 attachment to that memo, page E459. Another attachment, 4 Attachment 2 to the same memo, page E460.
5 MR. STEPTOE: Excuse me, Mr. Shevlin. Is that 6 a two-page attachment?
7 THE WITNESS: Well, page E460 through E465.
8 An analysis sheet, pages E466 and 467.
9 A memo to Byers to Orlov, page E468.
10 A memo from Shevlin to Clinton, page E469.through 11 E473.
12 Summary sheets of the pipe support reverification.
7_
13 BY MR. GUILD:
('"') I4 Q Do those bear Bates stamp numbers, Mr. Shevlin?
15 A I don't think they do.
16 Q Well, how many documents are there, how many 17 pages?
18 A Well, some of them do and some don't. Oh, there 19 it is. Okay. One stamp is illegible. It would appear that 20 it's probably 474.
1 21 Q And the letter "E" to start? Well, I will. buy 22 that it's illegible.
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(_) 1 A Sequentially it would be 474.
2 Q And the rest of them all have "E"? You can make 3 out the "E" on the pages?
4 A Yes. I would say it's E474 through E482.
5 A stack of BCAP observations, page E483 through 6 E507.
7 An analysis of the new observations for the 8 reverification plan, E515 through E521.
9 Q Let me stop you. The BCAP observations, E483' 10 through 507, are they the observations from the reverification 11 program?
12 A I believe they are. At least some of them are.
13 Memo from Shevlin to Clinton, page E523 and E524.
14 Attachment 1 to BCAP Memo 530, page E527 through 15 E533.
16 BCAP Memo 593, which is page E536.
17 A memo from Shevlin to Clinton, page E537 through 18 E539.
19 A draft reverification plan, page E717 and 718 20 and 719.
21 Memo from Shevlin to Clinton, page E722.
22 Memo from Shevlin to Clinton, page E723.
16
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(_-) i Employee evaluation forms, page E724 through 2 729.
3 Memo from Shevlin to Clinton, page E730.
4 And a couple of statements or some figures 5 from the Braidwood -- from the BCAP report, which the cover 6 is page 731.
7 Q And you have the entire report there in front a of you?
9 A Yes. I didn't use much of it.
10 Q All right. That report has been filed in the 11 proceeding and it's a little bit voluminous. Let's leave 12 that out of the stack, and if in the course of your
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13 deposition you need to make reference to a particular page, I,__l 14 if you could just identify that.page; but other than that, 15 I would like to ask that the documents _before you got to 16 the BCAP report be included within the Shevlin Group l'7 Exhibit No. 2.
18 And if we could borrow your copy, Mr. Shevlin, 19 and make a copy of it.
20 MR. STEPTOE: That's no problem, Mr. Guild. I 21 did notice that as the witness went through those documents, 22 in some cases he did not identify all of the documents that G
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17 k/ 1 were stapled together, if you want to address-that.
2 MR. GUILD: Yes. I would like to only include 3 those that he has identified.
4 MR. STEPTOE: Okay. Shall we unstaple them?
5 MR. GUILD: Yes, if that's okay.
6 MR. STEPTOE: We would be glad to do that this 7 afternoon.
8 (Shevlin Deposition Group Exhibit 9 No. 2 additions were marked for 10 identification.)
11 BY MR. GUILD:
12 Q Mr. Shevlin, who prepared your testimony that
,_ 13 appears -- the 30 pages behind your affidavit?
k-) 14 A I did.
15 Q Did you have any assistance in preparing that 16 testimony?
17 A Editorial.
18 Q And by whom?
19 A By one of my supervisors.
20 Q And who was that, please, that gentleman or 21 lady?
22 A Mr. Marquardt from PGCo to read it for editorial f%
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18 i._/ 1 comment, language, English, spelling, punctuation, that 2 sort of thing.
3 Q And who is Mr. Marquardt? Do you have his full 4 name?
5 A Gary Marquardt.
6 Q Do you know how to spell his last name?
7 A M-a-r-q-u-a-r-d-t.
8 Q And what is Mr. Marquardt's position?
9 A I don't know his position title. His position 10 is a lead over a small group of quality consultants.
11 Q And you are among that group?
12 A Correct.
13 0 Is he employed by..Phillips-Getschow?
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14 A Correct.
15 Q All right.
16 Did anyone else assist you in your testimony?
17 A No.
'18 Q How about your counsel? Did you work with any 19 of the lawyers in preparing your testimony?
20 A They furnished the questions; I furnished the 21 answers.
22 Q Did they participate in the editing process?
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19 k/ 1 A Possibly for editorial.
2 Q And who.was that, by name?
3 A Phil Steptoe.
4 Q All right, Mr. Shevlin. Can you go through your 5 testimony, please, and identify any changes that you made 6 after the draft answers that you prepared to the questions 7 that were submitted to you by your counsel?
8 A I don't think I understand.
9 Q Can you identify any changes that were made to 10 your testimony?
11 A In substance?
12 Any changes at all, sir.
Q
,g 13 A I don't really understand what you are trying to V 14 get at.
15 Is this testimony that has been filed, Mr.
Q 16 Shevlin, identical to the testimony that you prepared?
17 A Except for grammar, punctuation, spelling and 18 the changes that we discussed earlier.
19 Q Can you identify any of those changes, any 20 changes at all that have been made to your testimony in 21 the drafting and editing process?
22 A I doubt it.
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20 7~..
(_), . 1 Q Take a moment and review the testimony, and if 2 you can identify any, I would appreciate it, please.
3 (Witness reviewing document.)
4 A Some asked me to explain --
5 Q Where are you at, Mr. Shevlin?
6 h The top of page 12. Someone asked me to explain 7 what I meant by the term " takeout." I remember that.
8 Q All right.
9 And you prepared Exhibit A in response to that 10 question?
11 A Right. And the handwritten sketches, the hand-12 prepared sketches shown as exhibits, I was asked to prepare 13 those as a visual aid.
14 Q And you prepared those?
15 A I prepared those.
16 Q Those are Exhibits B through --
1:7- A I think A through E. No, A through D.
18 Q All right.
19 Any other changes?
20 A I think that's all. At least that is all I 21 recognize.
22 Q Okay.
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k/ 1 Who prepared your attachment -- it doesn't 2 appear to have an 2dentification. It follows Attachment D, 3 and it has the Bates number of E521.
4 A That is part of the BCAP files.
5 Q Who prepared that; do you know?
6 .A No, I don't remember.
7 O What is it? Can you identify it, please?
8 A It's a summary of the findings of the support 9 verification program that we did about a year ago.
30 Q And Exhibit E, can you tell me who prepared 11 that?
12 A I prepared that. It was recovered from the BCAP 13 file. It's my analysis of the findings that occurred during 14 the support reverification program.
15 Q All right. And those are your comments that 16 appear in the right-hand column?
17 A That's correct.
18 Q Mr. Shevlin, I am referring to the documents 19 that you reviewed that your counsel made available to you, 20 and I would like you, if you can, to help me identify some 21 of these, please.
22 Who prepared the document that you described as O
22
(^h K/ 1 Summation, E453 and 454?
2 A I don't know. It would have been someone in the 3 CSR Assistant Director's Office, probably.
4 Q And who is the CSR Assistant Director?
5 A Mr. Byers.
6 Q Is that Bob Byers?
7 A Yes.
8 How was it made available to you?
Q 9 A It is part of the BCAP file.
10 Q Who is Mr. M.A. clinton?
11 A He was my immediate supervisor during the BCAP.
12 Q And what was Mr. Clinton's position?
~s 13 A His BCAP title was inspection supervisor, and he
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LJ 14 is a contract employee with Daniel International Corporation.
15 Q Is he currently employed at the Braidwood site?
16 A He is currently employed as the Director of 17 Quality Services, Daniel International Corporation, 18 Greenville, South Carolina.
19 Is he still at the Braidwood site?
Q 20 A No, he is not.
21 He is in Greenville?
Q 22 A Greenville.
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K._/ ' 1 0 -The memorandum, Clinton to Byers, January 22, 1985, 2 BCAP memo 530, with attachments E458 and following, was 3 that prepared by Mr. Clinton?
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4 A It is signed-by Mr. Clinton. ,
5 Q Do you know whether he prepared it or not?
6 A It is just an internal office memo advising 7 Byers what we were doing at the moment.
8 Q Did you have occasion to prepare memos for Mr.
9 Cinton? I 10 A For his signature?
11 Q Yes.
12 A No.
7_
13 Q So as far as you know, he prepared it himself?
!v) 14 A Yes.
15 Q All right. That appears to be workpapers, one 16 entitled " Piping Support Reverification Plan, Analysis of 17 New Observations by Attribute versus Population," page 18 E466 and 467. Do you know who prepared that document?
19 A It was prepared by people working under my 20 control.
21 Q Can you identify who th'ose people are, please?
22 A I can't tell you for sure who prepared that one.
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l 24 I Well, who worked under your control onthis Q
2 task, or on the task of the analysis of the reverification 3 observations?
4 A David R. Walker.
5 Who is Mr. Walker?
Q 6 A' Walker is a certified lead quality inspector 7 who works for Daniel.
8 A BCAP inspector?
Q 9
A He was a BCAP man.
10 Who else?
0 II A Howard M. Sigrest.
12 How do you spell it?
Q 13 A S-i g-r-e-s-t.
7s
(~'I id Q All right. And who is Mr. Sigrest?
15 A Certified lead quality inspector kdth Daniel 16 working for BCAP.
17 Q Were either of these gentlemen BCAP inspectors 38 who were performing the inspection work th'at was the subject 39 of the reverification?
20 A They were performing special duties during that 21 reverification. They didn't actually do any of the 22 reverifications.
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(_,) 1 Q Did they do any of the initial BCAP inspections 2 that were the subject of the reverification?
3 A Probably.
4 Q They are among the BCAP inspectors who were under 5 your supervision?
6 A Correct. Walker probably did. Sigrest may 7 have.
8 Q Okay. They were BCAP inspectors in the mechanical 9 area, mechanical welding area?
10 A Correct.
11 Toward the end of the end of the plan, I used 1; some of those guys to help just tabulate the information on
,_ 13 those spread sheets and things.
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'"' 14 Q All right.
-15 I am looking at a stack of papers that begins 16 with'E483. It's a BCAP observation record, Mr. Shevlin.
17 MR. STEPTOE: .Could you read that number.again?
18 Excuse,me.
19 MR. GUILD: Sure. It's E483 and following 20 pages through 507.
21 BY MR. GUILD:
22 Q Can you identify some of the names on this, please, for me, Mr. Shevlin? It's difficult to read, but under
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26 p
kJ 1 Block ll, Prepared By?
2 A That is Frances Irene Starr, Frances with an 3 n e,"
d Who is Ms. Starr?
Q 5 A BCAP inspector.
6 Q In the mechanical' welding area?
7 A. Correct.
8 Do you want them all?
9 No, sir. Let me just have that back. Some I Q
10 can make out and some I can't.
11 Mr. Sigrest on the bottom, is that his name?
12 A That's correct, 13 Q And that is your signature, Mr. Shevlin?
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14 A That's correct.
15 Q E486 in Block ll, Prepared by?
16 A Gary J. Sutton, a BCAP inspector.
17 Also a mechanical welding inspector?
Q 18 A All of them are in mechanical welding.
19 And there is a line on that same page, E486, Q
20 that says "I concur" with initials.
21 A Sutton.
22 E494 in the Block ll, Prepared by?
Q 13 N.,I
27 g ~.
(_,) 1 A Thomas R. Young, a BCAP inspector.
2 O E495, Block ll?
3 .A Frances I Starr, BCAP-inspector.
4 Q E500, Block ll, please?
'S A ~ Phil S. Jones, BCAP inspector.
6 Q Document numbered E715 and 16 appears to be from 7 Mr. Clinton to -- I can't make it out.
8 A I did not use that.
9 Q Is that Mr. Clinton's handwriting? Can you 10 identify that?
11 A Yes.
12 Q E717 and 18, titled " Reverification Plan." Whose 13 handwriting is that?
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14 A I wrote that.
15 Q And 719. Is that your handwriting?
16 A Yes.
17 0 720?
18 A It's not mine.
19 Q I's that Mr. Clinton's, if you know?
20 A I don't think I can say for sure.
21 Q Mr. Shevlin, have you had occasion to review 22 the affidavits by Mr. Smith and Mr. Kaushal that were filed I~T
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A in support of the Company's Motion for Summary Disposition 2 along with your'own?'
3- A- ,Yes, I have.
4 -Q Mr. Smith in his-affidavit page 18' refers.to
- 5. a1 performance evaluation program employed for use with the
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. 6 reinspectors, the'BCAP QA overview-inspectors. Are you 7 aware of that evaluation program?
i' 8 A No.
9 'Q. Was there an' evaluation program for,the'BCAP' 10 inspectors that you supervised?
11 A .Yes, there was. That's' pretty well described in 12 my. affidavit.
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13 O All right.
'O 14 And documents that you identified earlier,fE724
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15 through E729, are they the product of the evaluation 16 program for your inspectors?
17- A They'are a partial product of it.
18 Q .What else is there that is a product of that 19 . evaluation program?
i 20 A Ce"tification examination.
21 Q- Was there an industrial. psychologist involved 22 in the design or implementation of the evaluation program 4
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(_) i for your inspectors?
2 A I don't know.
3 Q Mr. Smith describes an involvement of an 4 industrial psychologist in the design of what he identifies 5 as the performance evaluation program that was employed for 6 the BCAP QA inspectors.
7 Do you know whether there was any comparable a program for the BCAP inspectors that you supervised?
9 A Not to my knowledge, n) Q More particularly, Mr. Smith describes a program 11 in which an industrial psychologist was involved, which he 12 describes as initiated to determine the extent to which an
,., 13 overinspector would agree or disagree with the initial e
t, J i
'~'
14 inspection results of the original inspector. Again, that's 15 page 18 of Mr. Smith's affidavit.
16 Was there any comparable program that you are aware 17 of for your inspectors,for the BCAP inspectors that you is supervised?
19 A No.
20 Q Looking at E724, the employee evaluation for one 21 of your inspectors -- this is one of your inspectors, is it 22 not?
o
30 A' I A Correct.
2 Q Under the " Remarks" section, the notation of a 3 component identification, one or more component identifica-4 tions. What is the significance of the notation in the 5 " Remarks" section?
6 A It's a number of component support inspections 7 that this individual performed, and then at my direction a a lead quality inspector went out and reinspected them.
9 Q Why was that?
10 A In this particular case because a question had 11 come up about some of this person's work during the CAT.
12 Q A question by whom?
g- 13 A The CAT inspector.
(',
Id Q By an NRC CAT inspector?
15 A Correct.
16 Q With respect to those specific components?
17 A No.
18 Q What is the significance of the identification 19' of those specific components?
20 A They are randomly selected pieces of work that 21 the individual did.
22 Q Is that a part of the reverification program?
/'
t_]-
31
.n
\_) 1 A No. They are.part of a follow-up action that 2 is described in my~ affidavit.
3 Q After the reverification program?
4 A That particular item has nothing to do with the 5 support reverification program.
6 Q- All right.
7 Well, a follow-up to what, then, M:. . Shevlin?
8 A It's a follow-up -- that particular individual 9 is one that was involved in the CAT finding on the piping 10 configuration. After I was satisfied with the resolution 11 of the piping configuration, I directed two lead inspectors 12 to separately and independently go out and look at some more 13 of this person's work.
7 ,\
+U' 14 All right. And instead of in the piping configu-Q 15 ration area, you looked in the component support area.
16 A Specifically, configuration, which is the same 17 ID.
18 Q But configuration of supports instead of piping?
19 A Configuration of whatever the inspector happened 20 to be looking at.
H Q By the inspector, you mean the subject of the 22 review by the lead?
, [h u>
32
(*)
s - 1 A No, by what the inspector was working on.
2 Q The original inspector?
3 A Correct. The original inspector would be 4 assigned a piece of work and then randomly the lead 5 inspectors would pick up some of that work and go back out 6 and look at it, overinspect.
7 Q And you directed the lead to do that?
8 A _ Correct. They were designees or delegated.
9 Q And did you direct the leads to look at a specific 10 type of work?
11 A Specifically, to go after that inspector's work 12 on configurations, which would include dimensional verifi-13 cations, location orientations and such as that.
g ,)
U 14 Did you as: him to look at configuration other Q
15 than piping configurations for that inspector?
16 A I asked them to look at several of the next 17 pieces of work that that employee had completed. As it 18 happened,.as it turned out, the next several pieces of work 19 happened to be' piping supports rather than piping.
20 Q You didn't specify the type of work, though, just 21 the next work that he did?
22 A The next work. I specified the type of informa-tion or the type attribute or the type of operation.
l
33
/~N
(,) 1 Q And that was configuration?
2 A Configurations, dimensions.
3 Q And were there any adverse findings by the lead's a overinspection?
5 A No.
6 Q There appeared to be six separate employee 7 evalutions, five other than the ones we have just 8 spoken of, and were each of those inspectors subject to an 9 overinspection by a lead at your direction?
10 MR. STEPTOE: Objection. May I see that for a 11 moment, Bob?
12 (Discussion off the record.)
,_, 13 MR. STEPTOE: On the record.
~
14 Mr. Guild, my problem is that on those forms, 15 some inspectors are listed more than once, and I'm afraid 16 that your question implies that there were six inspectors 17 that were overinspected.
18 MR. GUILD: Oh, I didn't mean to misstate it.
19 I stand corrected.
20 BY MR. GUILD:
21 Q Let me see if I can clar2ty. Maybe you can help 22 me clarify it, Mr. Shevlin. There are six evaluation forms, O
\_)
34 I and it appears that they do cover several forms for the 2 same individual. I see an inspector P.J.T. You use the 3 initials to identify these inspectors in your testimcr.y, do 4 'you not? Are the initials that appear in your testir.iony --
5 A In my testimony? I don't remember using any 6 initials.
7 Q Well, perhaps it was Mr. Smith's, but there are 8 references to inspectors. I am just trying to use the same 9 form of reference that was employed. If it wasn't in yours, 10 it was in one of-the other affidavits.
11 This is an inspector, Pam J.-Thompson, and 12 that's the inspector who is the subject of the overview by
,s 13 the. lead at your direction.
()
'~'
14 A Corrtet.
15 Q And for that inspector, which appears on E724, 16 there is -- and E727, another employee evaluation listing 17 the same inspector.
18 Why is there more than one?
~
19 A I asked that an effort be made that morc than one 20 lead inspector do it. I think you will find that the lead 21 inspector doing.the overinspection is not the same person 22 in each case.
V
35
. O(_/ 1 Q All right. And 724 appears to be Mr. -- is'it 2 Norris?
3 A Right.
4 O And 727 is Mr.-Norris again.
5 A Okay.
6 Q Are those two separate overinspections?
7 A Yes.
8 O By the same lead, though.
9 A Yes. I had two guys doing that.
10 Q The second document, E725, is Mr. Jones, the 11 inspector, and the evaluator is Mr. Sigrest?
12 A Yes.
,, 13 MR. STEPTOE: It's Mrs. Jones.
14 MR. GUILD: Mrs. Jones.
- 5 Phil S. Jones?
16 MR. STEPTOE: Oh, I'm sorry. I have confused 17 this whole thing. I'm sorry.
18 BY MR. GUILD:
19 0 Phil Jones, by Mr. Sigrest, and then the 726 is 20 Phil Jones by Mr. Norris; yes?
21 A Yes.
22 0 '728, Phil Jones by Mr. Sigrest.
O
36 t'.
b 1 A Right.
2 0 729, Phil Jones by Mr. Norris.
3 A Right.
4 BY MR. GUILD:
5 Q Mr. Shevlin, the series of documents that begin 6 with E483 and the following documents, they appear to be 7 BCAP observation records, and I believe you stated that 8 some of these were records of the observations resulting frota 9 the reverification program? >
10 A I believe so.
11 Q Now, there appear -- the documents are headed 12 "BCAP Observation Record," page 1 of 3, and suggest that
, 13 there are additional pages to the BCAP observation record
~'
14 form? Is that correct? 2 and 3?
15 A Well, partially correct. The page numbering 16 system is part of a format. Page 1 was always prepared 17 by the inspection group. Pages 2 and 3 were never prepared 18 by the inspection group. They were subsequent actions.
19 Q All right.
20 E483 is page 1 of 3, as is 484, 485, 486, 487, 21 489, 490, 491, 492; 493 happens to be page 2 of 3, and that 22 bears the title at the top that says, " Evaluation and 1
37 1 Determination of Validity."
2 By whom is that portion of the observation 3 record prepared?
4 A That portion was prepared by the Engineering 5 Department.
6 0 Whose Engineering Ocpartment?
7 A BECAP's?
8 Q There appear a series of initials on this page 9 E493, page 2 of 3 of the BCAP observation record. Do you 10 know who that is? It appears to be initials "BWG."
11 A I don't remember. It's not anyone from the 12 inspection group.
- 13 O All right.
id Who are the engineering people that perform the 15 evaluation and determination of validity, the BCAP observa-16 tions?
37 A I don't think I understand?
18 Q Well, who are they employed by?
19 A Primarily they were employed by Stone & Webster.
20 Q Were there any Sargent & Lundy people performing 21 evaluations and determinations of validity?
22 A I don ' t '-know.
38
(~)
(.) 1 Q You are not aware of any?
2 A Not in the areas that I dealt with, I don't 3 remember any.
4 Q Was Stone & Webster under contract to Edison to 5 Perform the engineering evaluations of validity for BCAP 6 observations?
7 A Yes, they.were part of the BCAP organization.
8 Q How many Stone & Webster people were doing that 9 work?
10 A I don't know. A fairly large number.
11 Q More than ten?
12 A Yes.
,_ 13 Q How about in the welding and mechanical area?
14 A Our engineers were primarily Stone & Webster.
15 Q Yes. And how many Stone & Webster people in the 16 welding and mechanical area that performed the evaluations 17 and determinations of Validity?
18 A' I don't know.
19 Q Do you have an estimate? More than ten?
20 A Yes. Way more ten.
21 Q More than 100?
22 A No.
O
\_/
1
39 1 Q Somewhere between 10 and 100?
2 A Yes. It was a fairly large number. There were 3 a number of groups, sub-organizations.
4 O And all of them did evaluations, BECAP observations 5 for validity?
6 A Within their own area of interest.
7 Q All right.
8 This is not a real good copy, Mr. Shevlin, but 9 this page 2 of 3, that is, E493, appears to accompany page 10 1 that precedes it, and it appears to be observation No.
11 CSR-1-M-3, and the rest is blocked out, but there is a 12 package number under it which appears to be 008. Would that 13 be the BCAP observation number?
O 14 A The package number is the BCAP package, which is 15 traceable to a discrete item. That number is also the root 16 of the BCAP observation number.
17 Q Can you tell what the observation number is in the 18 document that I am showing you? That is E492.
19 A Not from that copy.
20 Q Are there more digits than there are in the package 21 number?
22 A It is the package number, suffixed by another number, 1, 2, 3 sequentially.
O
40 1
Q The pagn 2 for that observation reflects a 2 determination that that's a valid observation, and then 3 below that appear to be the initials "BWG." Would that be 4 the person who made the evaluation?
5 A Yes.
6 0 And you don't know who that is, by name?
7 A Not by those initials.
8 Q Will you describe the process of determining 9 the validity of a BCAP observation?
10 A It was a number of steps. When the inspector 11 prepared the observation, either myself or one of my desig-12 nated lead inspectors reviewed it to determine its 13 suitability for further processing.
f- If it was determined
('gl 14 suitable, it would go to the engineering group. They would is review it for validity, validity meaning that the 16 Observation described was, in fact, a Violation or a failure 17 to comply with the inspection instructions given to the 18 inspector.
19 And item could be deemed invalid by the engineering 20 group coming up with additional information. For example, 21 if the instructions said everything shall be painted green 22 and we found sor.iething painted red, we would prepare an O
41 I
(')T
\_ 1 observation. The engineer, then, might say, ah, but here 2 is something that came out that the architect engineer 3 issued or something that changed that requirement, and 4 therefore, what you found is acceptable, your observation 5 is not valid.
6 If they determine that our observation is not 7 valid, it had to be returned to us for our concurrence.
8 0 Whose concurrence, Mr. Shevlin?
9 A Inspection. Generally the original inspector.
10 If he was not available, then it was my responsibility.
11 Q Did the BCAP procedure specify that the original 12 inspector concur or have an opportunity for concurrence in 13 validation of an observation?
O' 14 A If it was valid.
15 Q And did the procedure specify that in the f
16 absence of his availability, that would be your task?
17 A His immediate supervisor. Yes, that was clearly 18 defined in the procedures.
19 Q How do you use the term " suitability" that you 20 employ when you describe your review of the observation that 21 was written by your inspector?
22 A My general approach there was an outright comparison of the requirement against the finding to assure O
42
(- 1 that the inspector was not reporting something that did,- in 2 fact, meet the criteria he was given up front. So, unlike 3 the enginee) g evaluation, my evaluation was.straightfor-4 ward. Yes, what is written here does violate these 5 instructions.
6 Q Well, in your example about the green and red 7 paint --
8 A I would have made that observation suitable 9 because the instruction in my had says everything has got-10 to be green. I did not pursue it-any further to see if 11 there was some other document that made it all okay. That 12 wasn't my business.
13 Q Even if you knew that there was another document?
7-U 14 A It didn't make any difference. It wasn't ~
15 part of my inspection package. I would hava made it to suitable.
17 Q Well, how is the judgmenc that there was some 18 further direction that.said that, yes, a color was 19 acceptable -- green or red, or red or green, whichever was 20 the case in your example -- how was that an engineering 21 evaluation?
22 A They were-responsible to assure that what we wrote up was, in fact, a deficient item. They were responsible to go research all of the deficiency documents O
43
/~'s
(_) 1 or design changes or wnat have you that might make that 2 item unique instead of part of the general population.
3 Q Well, in your example, shouldn't any change 4
in the specifications, such as an instruction by Sargent &
5 Lundy that a green was acceptable or red was acceptable, 6 shouldn't that have been included in the package that was 7 used by your inspector?
8 A If it was known up front, it' would have been.
9 Known up front by whom?
Q 10 A By the engineer who prepared tne package.
11 Shouldn't that engineer have made sure that the Q
12 BCAP inspection was to a current revision of the drawing or 13 specification?
O 14 A No. It was to the revision at x date. Subsequent 15 developments might have changed the requirement for that as to a discrete item as opposed to the rest of the population.
17 0 Well, let's be clear, then. BCAp was inspecting 18 to requirements as of a particular date?
19 A The physical inspection, yes.
20 Q As opposed to current specifications.
21 A That was a subsequent step.
22 Q And that subsequent step, determining whether a O
v
44
' ,/~\
Y/ 1 failure to meet historic acceptance criteria was, nonethe-2 less, acceptable given subsequent revisions to those 3 acceptance criteria, that was made by the engineering 4 evaluation of validity?
5 A Correct.
6 MR. STEPTOE: Objection. I'm sorry. I couldn't 7 follow the question.
8 MR. GUILD: I think the witness followed it.
9 BY MR. GUILD 10 Q. Is that an accurate statement?
11 MR. STEPTOE: Well, I couldn't follow it.
12 .Would you read back the question, please?
13 (The reporter read the record as requested.)
%s 14 MR. GUILD: Mr. Steptoe, do you have an 15 objection?
16 MR. STEPTOE: No.
17 BY MR. GUILD:
18 0 You heard the question the first time and it was 19 reread, and your answer is still yes, that was correct?
20 A Yes.
21 Did the BCAP procedure, Mr.Shevlin, specify your Q
22 role in making suitability determination?
t
~-
d
.-_-.y:. . . - . _ _ . , .,# - _ . ,.
45 A
El 1 A Yes.
2 Q Did it use that term, " suitability"?
3 A Yes.
4 Q Did it define the term?
5 A I don't remember.
6 Q Can you give me a reference? Do you recall.the 7 procedure citation. describing your role in making a suita-8 bility review? It will not be held against you if you cannot 9 recite chapter and verse, Mr. Shevlin.
10 A It could have been either of a number of 11 procedures. There was a procedure that dealt exclusively 12 with processing observations. There was a procedure that 13 dealt with performance of inspections. It may have turned up 14
^
in either of those. I don't remember which.
15 Q How about the procedure as it detailed the 16 concurrence of the original inspector in the validity 17 determination by the engineering people?
18 MR. STEPTOE: Objection. Is your question can 19 he identify that procedure?
20 BY MR. GUILD:
21 Q Sure. 7es. Can you do that?
22 A I think it is in the observation procedure.
O
46
/~
(_T,1 1 Q What is the practice if the original inspector 2 declines to concur in the invalidation determination?
3 A That was provided for procedurally.
4 Q In the observation processing procedure?
5 A I don't remember. I am not prepared with this 6 much ta e elapsed to state what provision was in what 7 procedure. It has been too long.
8 Q .All right, sir.
9 A I do know that it was in the' procedure manual.
10 0 All right. And what did the procedure manual 11 specify in the event that the original inspector declined to 12 concur in the invalidation?
13 MR. STEPTOE: I will impose a general relevance
' 14 objection. I'm not instructing the witness not to answer, 15 but I think this is far afield from the contention without is some sort of foundation that that occurred in this case.
17 BY MR. GUILD:
18 Q Can you try to answer the question?
19 A Would you repeat it, please?
20 0 Sure.
21 What did the procedure call for in the everit the 22 original inspector declined to concur in the invalidation of 0
v
47
- I 'his observation?
2 A Some series of tiered evaluations, with the 3 ultimate decision by the director, I think.
4 And the director of BCAP, Mr. Kaushal?
Q 5 A Yes. I believe that's what it said.
6 Q And the procedure also provided the same process 7 in the event your inspector was unavailable and it was you 8 that declined to concur?
9' MR. STEPTOE: Objection. Lack of foundation.
10 THE WITNESS: We are getting too far into the il
. specific procedure requirements, which I have not looked at 12 in quite some time, 13 BY MR. GUILD:
g-)
%J 3d Q Okay. Just tell me that if you don't recall.
15 A I'm not able to quote what is in the BCAP 16 procedures at this time.
17 All right.
Q is Did you ever decline to concur in an invalidation 19 determination?
20 MR. STEPTOE: Continuing objection to relevance and 21 lack of foundation.
22 THE WITNESS: I don't remember.
O
l 48 A
k_) 1 BY MR. GUILD:
2 Did any of your inspectors ever decline to Q
3 concur in an invalidation determination?
4 A Not that I recall'.
5 MR. STEPTOE: Was your question directed -- I 6 didn't mean to interrupt the witness' answer.
7 Was your question directed to an observation and a
validation made'in connection with the reverification of
' 9 pipe supports and restraints which are the subject of the u) witness' affidavit?
Il MR. GUILD: It was a general question.
12 BY MR. GUILD:
13 And the answer was you don't recall?
Q v 14 A I don't remember it happening.
15 Would you have known about such an action if it Q
16 had occurred?
17 A Yes.
18 Q Do you know whether it ever occurred, who'ther a 19 BCAP inspector ever declindd to concur in an invalidation 20 determination?
21 At this point we are MR. STEPTOE: Objection.
22 really going far afield, not only from the contention but s
I
49
,s
( 1 from the agreement that you had with Mr. Gallo that you 2 would limit your questioning to the subject of the 3 witness' affidavit. This witness did not come prepared to 4
talk about BCAP program in general, nor did I come prepared 5 to represent him in the deposition in which things like this 6 would be gone into.
7 MR. GUILD: All he has to do is answer yes or no 8 if he does or doesn't, and I would like an answer to the 9 question.
10 MR. STEPTOE: So is your representation that you 11 will move on after that and not go on?
12 MR. GUILD: I don't know what the answer is, Mr.
13 Steptoe, but I believe that the matter is obviously relevant.
14 It is relevant to just not this contention; it is relevant 15 to the quality assurance contention generally. I am 16 entitled to ask the question, and I would'like the answer 17 of the witness.
18 MR. STEPTOE: Mr. Guild, do you deny that you had 19 an agreement with Mr. Gallo?
20 MR. GUILD: I don't want to get into a fight with 21 you about it. My time is valuable. I intend to press on 22 and get the deposition done as quickly as possible. But my O
50 1 notice of deposition asked the witness to be prepared to 2 respond generally on the subject of quality assurance at 3 Braidwood. The obvious focus of the examination is on the 4 subject of his affidavit, but I don't waive any right to 5 ask what is an obviously relevant question.
6 If you want to instruct your witness not to 7 answer the question, I would be more than happy to take it a
~
8 to the Chairman a d get it resolved. I just think that if 9 you intend to interpose objections on what are obviously 10 unsupportable, narrow grounds of relevance, then perhaps the 11 most efficient thing to do is to get a Board decision on 12 the question.
13 I think you will find, Mr. Steptoe, that the
' 14 practice in these depositions has been to recognize that is the rules of the Commission permit discovery deposition 16 questions that are calculated to lead to the identification 17 of relevant evidence, and I represent to you that the last 18 question certainly was designed to do that.
19 MR. STEPTOE: I have no difficulty about 20 discovery which is intended to elicit information relevant 21 to the quality assurance contention; however, I asked you 22 a question, whether you deny that you had an agreement with Mr. Gallo that the questioning in these depositions would be limited to the subject matter of the deponent's affidavit.
O
51 5/ 1 MR. GUILD: And I am not going to be cross 2 examined by you, Mr. Steptoe.
3 MR. STEPTOE: Do you refuse to admit or deny that 4 you had such an agreement?
5 MR. GUILD: I am not going to be cross-examined 6 by you, sir, on that subject or anything else. Mr. Gallo's 7 agreement with me about the circumstances of conducting these 8 depositions will speak for itself. The notice of depositions 9 speaks for itself. I am not going to fight with you about to it.
11 Now, if you think that your position is such 12 that you want to instruct your witness not to answer the 13 question, please do so and let's move on, but I don't want fs
(') 14 to get into any kind of acrimony with you, Mr. Steptoe, on 15 that subject. Please don't bait me, please don't cross-16 examine me on this point.
17 If you think that the question is improper and 18 feel comfortable instructing your witness not to a nswer, 39 plese do, and let's just move on.
20 MR. STEPTOE: Let me just state for the record 21 that my understanding from Mr. Gallo was that he had an 22 agreement with you that these depositions would be limited to i
s
\-) ,
52
(}
(_/ 1 the subject matter-of the witness' affidavit. Now, I 2 have not interposed an objection to questions that seemed 3 to me to be within the parameters of that subject matter, 4 and indeed, we have gone beyond that, but there has been 5 no showing of a foundation that this question, the pending 6 question, is directed towards either the affidavit or 7 Contention 12J, and I did not prepare myself or prepare the
-
- 8 witness to go through open-ended discovery in this case about the 9 results of the BCAP report.
10 I am aware that the Notice of Deposition did 11 state that the deposition shall be on the subject of the 12 witness' knowledge of the quality assurance deficiencies 13 at the Braidwood Nuclear Power Station alleged in Intervenors' 14 amended quality assurance contention. However, I subse-15 quently spoke with Mr. Gallo, who told me specifically that 16 you had an agreement and understanding. On that basis, on 17 the basis of an understanding which you, for reasons which 18 are beyond me, refuse to discuss, I am going to instruct 19 this witness not to -- I am going to advise this witness that 20 he is not required to answer your question.
21 I am delighted to take this up in front of the 22 Board, and then you can tell the Board what your understanding O
53
(~T
(-) 1 of your agreement with Mr. Gallo is. And I find --
2 MR. GUILD: Mr. Steptoe, if you would just tone 3 down the voice. Ther2 is no need to raise your voice to me.
4 If you would just'ask me what your agreement was, I would be 5 happy to tell you, but I am not going to be cross-examined 6 by you, sir. I am not going to be treated like I am 7 obligated to respond to what is just a tactless and arrogant 8 approach to trying to resolve a matter in dispute.
9 There is no need to fight about this. Now, if 10 you would like to know what the nature of the agreeuent is, 11 I will be happy to tell you, but I'm not going to be 12 cross-examined by you, sir, or anybody else.
,_s 13 MR.' STEPTOE: Well, I certainly was not tryin'g --
is Q-) 14 MR. GUILD: Now, do you want to instruct your 15 wi, ess not to answer the question and trouble the Chairman to with resolving this dispute, or do you want to be civil about 17 it? If you would like to be civil about it, i will be happy 18 to try, but you are trying to be provocative and there is 19 no need for it.
20 MR. STEPTOE: I don't think I'm trying to bait you.
21 I don't think I'm trying to be provocative. I don't think 22 I an: being uncivil. I don't think I have been raising my O
r-l 54
(~)x
(_ 1 voice unduly, certainly no more than you.
2 MR. GUILD: Only in response to you, sir.
3 Now, do you want to know what the agreement is?
4 Do you want to get down to that or do you want to haggle, 5 for purposes that are unclear to me?
6 MR. STEPTOE: I do want to know what the agreement 7 is, and you are refusing to answer.
8 MR. GUILD: No, sir. You didn't ask me. If you 9 would just ask me, I would tell you. But I am not going to 10 be cross-examined by you and I'm not going to be compelled 11 to respond to questions with yes or no answers. I'm not 12 under oath and I'm not testifying here, sir.
13 Mr. Gallo, who is well known for transgressing 14 agreements in this proceeding, is hardly in a position to 15 be dictating terms to me on'this subject.
16 MS. CHAN: Mr. Guild, perhaps you can just --
17 MR. GUILD: The fact of the matter -- excuse me, 18 Ms. Chan. The fact of the matter is Joe Gallo asked me: How 19 much do I have to prepare for these depositions, Bob; do I 20 have to be prepared to answer -- to have my witnesses 21 respond to general discovery on the quality assurance 22 contention?
I said: Joe, I have got a Tuesday, February 18th k_/
55
. /~N
(~) I deadline to respond to your motions for summary disposition; 2 as much as I would like to ask the bulk of my discovery 3 questions of the witnesses between now and then, I simply do 4 not have the time to do that, and I can assure you that I 5 am going.to do the best I can to focus on the subjects 6 which are the summary disposition questions. I told him just 7 that, or words to that effect.
8 I signed nothing in blood, and my notice speaks 9 for itself. All right?
10 Now, if that is troubling to you, sir, and you 11 don't wish.to have your witness respond to questions, 12- including the pending one, please tell him not to answer the
,s 13 question and we will go to the Board with that.
k_) 14 I tried to accommodate your colleague in the 15 face of a notice that you have in front of you, sir, by 16 trying to give him some informal representation about what 17 the scope of my examination would be. I entered no agree-18 ment with Mr. Gallo, and it, frankly, sticks in my craw.that 19 someone from Isham, Lincoln & Beale would have the gall to 20 try to suggest to me that honoring agreements is a matter of 21 question on my part, a firm that I represent to you has not 22 demonstrated a particularly sound track record of honoring i
1 l
'/ l N_) l l
- - - - , . - - , . . . , . , , - . , , , - - . . - - - , , , . - , , r.......,,,- ,-n-
56 g
(_) 1 agreements in this proceeding with this counsel.
2 Now, - hope, Mr. Steptoe, that you don't intend 3 to enter on to time tradition that your colleagues have a established in this proceeding in that regard, but the fact 5 of the matter is the notice speaks for itself. I told you 6 what I represented to Mr. Gallo, and I represent the same 7 thing to you, sir. I don't believe the question I last 8 asked him in any respect transgresses any understanding, 9 agreement or representation I have with your colleague, Mr.
10 Gallo.
11 Any further questions?
12 MR. STEPTOE: Ms. Chan, did you have something p_ 13 to say?
14 MS. CHAN: I was just going to suggest that the 15 notice of deposition says that the inquiry will be into the 16 information which serves as the basis for the witness' 17 affidavit in support of Applicant's December 21, 1985 18 Motion for Summary Disposition, and that any subsequent 19 discussions that you might have had, Mr. Guild, with Mr.
20 Gallo I assume would not have broadened that' notice.
21 MR. GUILD: Ms. Chan, I appreciate your effort 22 to help, if that's what it was, but you neglected to read the part that you initially read of the notice of deposition (O
_/
57 I which very clearly states that it's on the subject of his 2 knowledge of quality assurance at the Braidwood facility.
3 Mr. Steptoe, do we have a problem?
4 MR. STEPTOE: Yes, I think we do have a problem.
5 I don't intend to respond to your statements about my firm 6 or my co-Counsel, but I reject them. I am instructing the 7 witness or advising the witness that he need not answer the l 8 question that is pending. However, I want to make it 9 absolutely clear that you may pursue questions, for example, 10 whether there were any -- questions reasonably related to 11 Contention 12J or the subject matter of his affidavit.
12 For. example, you may ask him, and I have no j - 13 objection, whether there were any observations compiled'dur-V 14 ing the course of the reverification program which were 15 subsequently deemed to be invalid, and of those, whether 16 there were any which a witness -- which the original 1:7 inspector refused to concur in. All of that is perfectly 18 legitimate inquiry. But the open-ended inquiry which you 19 seem preparing to embark upon seems to me to be beyond the l 20 scope of the representation and understanding you had with 21 Mr. Gallo.
l 22 MR. GUILD: The simple question that is pending l
l l
58 is whet 1er he is aware of any instance where there has .been i< sis '
\~' "
a failure to concur in BCAP observation invalidation.
2 MR. STEPTOE: Yes, sir, and I believe --
3 MR. GUILD: And you believe that is an objection-4 able question? That is your position, sir?
5 MR. STEPTOE: Without limitation to the subject 6
matter of the reverification program?
7 MR. GUILD: .The witness has stated that he 8
cannot recall to the series of questions that preceded that.
9 Now, I believe I am entitled to an answer whether he has 10 any knowledge there has ever been a failure to concur in a 11 BCAP invalidation decision.
12 If you want to stick by that and instruct your 13 witness not to answer that question, let's be absolutely
()
(_e y, clear. That is the question. I am trying to probe the 15 witness' knowledge.
16 MR. STEPTOE: That's correct. I am advising him 17 that he need not answer that question, but a more limited l 18 l
question certainly would be appropriate.
l 19 l MR. GUILD: There is no reason in the world why
~
I need to limit my questions to satisfy this scope notion I 21 l that you have. I am entitled to know whether he has any 22 knowledge on that subject.
i I
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l l
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59
( "'1
\_/ i Mr. Steptoe, where are you coming from on that?
2 MR. STEPTOE: You can notice up his deposition 3 again and'we will have time to prepare for it, but having a been misled by your representation to Mr. Gallo, I am not 5 going to see you run roughshod over me simply because you --
6 MR. GUILD: Let's go off the record.
7 (Discussion off the record.)
8 MR. GUILD: Back on the record, 9 Just to be clear, the record should be reflect 10 that the documents that Mr. Shevlin identified that were 11 provided by his counsel, beginning with E453 and, not 12 necessarily consecutively, but ending with E730, should be 13 included in what has been marked as Group Deposition ~ Exhibit 14 2 to his deposition.
15 Mr. Steptoe, on the basis of your position that 16 you stated and your instructions to the' witness not to 17 respond to my last question or series of questions, I intend 18 to recess the deposition at this point.
19 MR. STEPTOE: Before you do, sir, your first 20 statement was documents E453 through E730 should be 21 included as exhibits to the deposition?
22 MR. GUILD: The last number was 730, yes.
~ ,
u
60 s
( I s/ 1 They are not necessarily consecutive. That just happens to 2 be the bottom of the stack of paper that the witness went 3 through.
4 MR. STEPTOE: Okay. Now, you will recall that 5 the witness did not indicate that all of those documents 6 were used as the basis for his affidavit, and we earlier 7 had an agreement that I was going to go through and pick 8 out the ones that he had not identified and remove them 9 from the stapled packages.
10 Do you still want me to do that?
11 MR. GUILD: Yes, please. The record should 12 reflect the documents that he identified, and those are 13 the only ones that I intend to have included in the 73 d 14 Deposition Exhibit 2.
15 MR. STEPTOE: Now, as for your intent to recess 16 the deposition, that is your prerogative, of course. I want 17 to make it clear that I am not interposing any objection l 18 to discovery during this deposition of any facts which are 19 relevant to his affidavit, the scope of Contention 12J.
20 If you want to limit your pending question or try to 21 establish a foundation, any foundation,between that and the 22 scope of Contention 12J or Mr. Shevlin's affidavit, that is
61 (3
'v' I fine.
2 MR. GUILD: I would --
3 MR. STEPTOE: Excuse me. Let me just finish one 4 more thing. I'm sorry.
5 I understood your line of inquiry to be an 6 open-ended inquiry into BCAP procedures in general arid BCAP 7
observations in general rather than something confined to 8 the subject matter of his affidavit and your representation 9 or agreement with Mr. Gallo.
10 MR. GUILD: I think our positions are clear, and 11 I disagree with yours, sir, and stand by mine, and 12 represent to you that the questions I have posed that you 13 have instructed him not to answer a're relevant to the subject g_g V Id matter noticed, the subject matter of his affidavit, and are 15 within the scope of any agreement that I have with your 16 colleague, Mr. Gallo.
37 Well, if you will explain to'me MR. STEPTOE:
38 how it is relevant to his affidavit, I will be glad to 39 withdraw my objection.
20 MR. GUILD: I-have done stated all I need state, 21 Mr. Steptoe, and I don't intend to debate the matter with l
1 22 you any further. For my part, the deposition is recessed i
l
~
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62
.m
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\/ 1 at this point.
2 MS. CHAN: The Staff has no questions.
3 MR. STEPTOE: I would like to take ten minutes 4 to talk with the witness and see whether redirect is 5 appropriate at this time.
6 (Recess.)
7 EXAMINATION 8 BY MR. STEPTOE:
9 Q Mr. Shevlin, referring to pages 26 and 27 of to your affidavit, you discussed the results of the reverifica-11 tion program for supports and restraints. I believe, as 12 corrected, you referred to 21'new observations were issued 13 against a population of 160 supports.
.t ,- s't
\~) 14 Do you follow where I am reading from?
15 A Yes.
16 Q How many of those observations were valid'and 17 invalid?
18 A Probably about half and half.
l 19 Q Okay.
20 In determining the results of the reverification 21 program for your purposes, what was the relevance of the
! 22 determination of validity or invalidity?
i i /~T l
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I e w ,,. m - - -
l 63
.* I A None.
2 Q Did you know whether those observations were 3 valid or invalid when you analyzed those 21 observations?
4 A No.
S Q Did you know whether those observations were 6 valid or invalid when you made your recommendation to your 7 superiors as to whether BCAP inspections of pipe suppors 8 and restraints could continue?
9 'A No.
10 0 Why didn't you know whether those observ0tions 11 were valid or invalid?
12 A I didn't see it as being relevant to what I was 13 doing. The validity determination came later, and what we 14 were trying to find out here was based on the instructions 15 in hand, had the inspector donevhat he was supposed to do or 16 had he not?
17 So the fact that it may later turn invalid based 18 on something that we didn't know about at the time of the 19 inspection really shouldn't have entered into it.
20 Q Do you know whether any of the 21 new observations 21 which resulted from the reverification program for supports 22 and restraints were later invalidated and the original
.l*}
64
(_) 1 inspector contested that determination?
2 A No. I mean yes, I do know. No, there was no 3 contest.
4 Q Do you know why Exhibit Nos. E483 through -- I 5 need to see them, excuse me -- through E507 do not in 6 general contain pages 2 and 3 of the BCAP observation 7 record form?
8 A Depending on what point they were obtained or 9 removed from the system for copying, they may not have 10 supposed to have been. Pages 2 and 3 were not used by the 11 inspector. If the inspector needed additional room to write 12 or to provide a picture or something, he would have made an
- 13 attachment to page 1.
(*) 14 Page 2 was then used by the BCAP engineer, and 15 page 3 was then used by the architect engineer. Normally 16 we would never receive a copy of it. We didn't need it for 17 anything.
18 Q Why did you order an overinspection of Mr.. Jones' 19 work?
29 A Because some of the findings -- some of the CAT 21 team findings were on work that Mr. Jones had done.
22 Q What are the similarities or differences between O
65 em k-) I configuration inspections of piping and configuration 2 inspections of pipe supports?
3 A Not a lot. The idea is dimension, location, 4 orie. cation in relationship between the parts, angles,
-5 slopes. In that respect, there is probably not an 6 appreciable difference in inspecting the configuration 7 of anything versus anything.
8 Q Do you have an opinion as to the relevance of 9 the results of overinspections, configuration inspections of to pipe supports and restraints in assessing the ability of 11 an inspector to perform configuration inspections of piping?
12 A In this case, the case of the overinspection
.. 13 sheets we hhve seen, the relevance is clear in that the
\_) 14 interest was is this. inspector paying close and careful 15 attention to what she is doing in her configuration 16 inspections? That was the object, not the object of trying 17 to find out whether a given piece of hardware was any good.
18 The object was trying to find out is this inspector going 19 out here and paying attention to what she is doing or not,
, 20 or what he is doing or not.
21 Q Do you have an opinion as to whether the BCAP 22 inspectors who performed the reverification program inspec-tions of work which had initially been inspected by BCAP
66
\_._ / 1 inspectors were likely to agree or disagree with the
-2 results of the original inspections?
3 A Well, there is no opinion to that. They didn't 4 know the results of the'. original inspections.
Therevas no 5 opportunity to agree or disagree. It was as if it were a 6 brand new inspection.
7 Q Were the BCAP inspectors who performed those 8 reinspections the same BCAP inspectors who performed the 9 Original inspections?
10 A No.
11 MR. GUILD: Asked and answered.
12 MR. STEPTOE: By whom?
,_ 13 MR. GUILD: By you. It's'in his own document, and
( )
14 there is really no necessity for you asking questions that 15 are already asked in the man's own affidavit, Mr. Steptoe.
16 MR. STEPTOE: I am not sure whether the witness' 17 answer -- you got the witness' answer?
18 THE REPORTER: Yes, I got the witness' answer.
l 19' MR. STEPTOE: That concludes my redirect.
20 FURTHER EXAMINATION 21 BY MR. GUILD:
22 O When did you find that there were 21 observations 9
i L)
67 k/ 1 resulting from the reverification and not 20?
2 MR. GUILD: Do you have something to say?
3 MR. STEPTOE: Well, it seems to me outside the 4 scope of redirect, but if you want to continue with this 5 deposition whether than recess it, that's fine.
6 MR. GUILD: No, sir. You raised the point. I 7 believe it i= in the scope of redirect.
8 BY MR. GUILD:
9 0 would you answer the question, please?
10 A The little spread sheet that showed 20 was-wrong, 1.1 and I found it to be wrong by studying my own analysis of 12 the individual observations. I just noticed, hey, this is
,s 13 not 20, it's 21.
i )
14 Q Was it an arithmetic error?
15 A Or a transposition. Arithmetic or a transposition.
16 Do you know?
Q 17 A No. That sheet was made,by who, I don't know 18 when,.a long time ago. I got it out of the files.
19 Q And when did you identify that error?
20 A Recently. Since I prepared my affidavit.
21 When were the determinations of validity or O
22 invalidity made for the observations t hat were identified
/~S L)
i 68
(,) 1 during the course of the reverification program?
2 A Well, as we finished the-inspections, the 3 reinspections, we turned the packages and the new observa-4 tions to Engineering, and then their validity determination 5 would start. So it was after we finished, on.a package-by-6 package basis as opposed to the whole thing. The validity 7 determination would start on an item-by-item basis after we 8 finished the inspections.
9 Q For any item, was the invalidation or validition 10 determination made before you reported on the results of the 11 reverification program?
12 A Possibly. It's possible.
13 Q In which instances?
fs
J 14 A I don't know. I don't know that it was or it was 15 not. I'm saying by the system under~which we were working, 16 that possibly might have happened. It may not have, too.
17 I don't know.
18 Q And those' determinations of validity or invalidity 19 came back to you or to the original inspector for concurrence 20 after the decision was made, after the determination of 21 validity or invalidity was made?
22 A Yes.
3 (V
69 7s E- 1 Q And so you would have had knowledge of what the 2 decision was on validity or invalidity at that point?
3 A Yes.
I 4 Q Is the counting error that you corrected, Mr.
5 Shevlin, the change to "8" from "7" and "13" for "12" in 6 the totals, related to the error in counting observations 7 in 21420?
8 A I'm sorry. I don't think I understand.
9 Q Okay. You made corrections at the outset of to your deposition, and if you want me to --
11 A No,'I know the correction you are talking about.
12 Q All right. Is there a relationship between
.- 13 those corrections, the numbers "8" and "13", and the
'~
14 correction of the total observations 21420? Is it the 15 same error?
16 A Yes. Yes. This document --
l'7 Q You have to identify it for the record so we all 18 know what you are talking about.
19 A E515 and its subsequent pages is a description of 20 the new observations found.
21 O Yes, sir.
22 A There are 21 items on there. The corrected
70 v.) 1 document miscounts the "21" here to "20."
It's just a 2 tabulation, a quick graph type thing for someone to look at.
3 The real information is here.
4 Q And that is the. source of the same -- the same 5 error led to the correction of the totals, "13" for "12,"
6 and "8" for "7."
7 A Yes.
8 MR. GUILD: That's all I have.
9 MR. STEPTOE: May I have 30 seconds outside with to the witness, please?
11 (Recess.)
12 FURTHER EXAMINATION
,, 13 BY MR. STEPTOE:
(
14 Q I believe Mr. Guild asked you about when you 15 heard back if an observation is valid or invalid, Mr.
16 Shevlin. Did you receive notice when an observation was 17 determined to be valid?
18 A No.
19 Q When did you receive notice of the disposition 20 of a BCAP observation by Engineering?
21 A Only if it was invalid.
22 MR. STEPTOE: I have no further questions, j#h
().
m l
71
(_) i FURTHER EXAMINATION 2 BY MR. GUILD:
3 Q And half of the reverification observations, by 4 your testimony, approximately, were determined invalid?
, 5 A That's a guess, but yes, somewhere in that neigh-6 borhood, over a period of time.
7 Q Do you know which ones were determined invalid?
8 A No.
9 Q Is it reflected in the documents that you 10 produced today?
11 A It is reflected in the BCAP files.
12 O But not the documents you produced today? Unless s 13 there is a page 2 of 3 for the observation --
("~J 14 A That's exactly where it would be.
15 Q I only found one page 2 of 3.
16 A Yes. .These were apparently recovered from the 17 system and copied with the other documents that were 18 assembled in my office such as this before Engineering even 19 got their hands on them, and that's why you don't have those 20 pages 2 and 3. But during subsequent processing, they would 21 have been added.
22 O Why, then, was the one page 2 of 3 that was w w ~ 9
-. . . . . - . .. . . .- -.. .. . _ - ~ . . .. .
b?
- 72 1- -i .cluded in the documents reflective of .a ' determination 4~~
2 'that the observation was valid?
l
- 3 A I have no idea.
4 Q That shouldn't have -- you shouldn't~have gotten
$ 5 that second~page back if, as a matter of course, you never 6 received anything other than invalid determinations; correct?
7 A I normally wouldn't have gotten that,'that's 8 true. You see, I don't know at what point this reproduction j 9 was made.
10 Q The copies of the documents?
i .
4 11 A .Yes. It could have been.anywhere. They could l 12 have.been done in the engineer's officeLjust as he started 13 to work on them. I have'no idea.
A V 14 0 'Or there could have been attached pages 2 and 3 4 15 that reflected a decision on . validity that just didn't get
'16 copied.
l'7- MR. STEPTOE: I will object.
18 BY MR. GUILD:
l l19 Q Do you know whether there were pages 2 and 3 that l 20 were include that just simply were not copied?
21 A I really don't know.
22 MR. GUILD: All right. That's all I have.
4 6
e l
i i
- .--. . . - , _ ~ . , _ . . , , . , _ . - . . . - .- - . - . . , ~ . . , , , . . . . , . . . _ . . . . , . . , _ . . , - . , , . - . . . . . - . . - ~ -
73
,rx k) 1 MR. STEPTOE: I am prepared to continue if you 2 would like to continue, Mr. Guild.
3 MR. GUILD: I would, but I would like to continue 4 and pursue the line of questioning that you instructed the 5 witness not to respond to, among other things.
6 MR. STEPTOE: Well, if you would like to go into 7 the other things, Mr. Guild, I am here. We are ready to go 8 now.
9 MR. GUILD: I would like to conduct the 10 deposition the way I would like to conduct the deposition, 11 Mr. Steptoe, and you have instructed the witness not to 12 answer the line of questioning, and I have reached the 13 determination to recess the deposition.
7_s 5
' , )
14 (Whereupon, at 12:40 p.m. the taking of the 15 deposition was concluded.)
16 17 18 19 20
'2 22
74 i
t h,/')
d i 1
I CERTIFICATE OF NOTARY PUBLIC 2 l 3
I, Suzanne B. Young, the officer before whom 4
the foregoing deposition was taken, pages 1 through 74, 5
do hereby certify that the witness whose testimony appears 0
in the foregoing deposition was duly sworn by me; that the testimony'of said witness was taken by me and thereafter 8
reduced to typewriting by me or under my direction; that 9
said deposition is a true record of the testimony given by 10 the witness; that I am neither counsel for, related te nor as%
.(f\_sI
' '11 '
employed by any of the parties to the action in which this 12 deposition was taken; and further, that I am not a relative I3 or employee of any attorney 'or counsel eraployed by the 14 parties hereto, nor financially or otherwise interested in i 15 the outcome of the action.
16 c' -
l 3g L L de uss - %W
' U
' g/UZANNE'B. YOUNG 19 Notary Public_in and for the 26-District of Columbia 21 22 My Commission expires: ,
ur a $6 /M /9/f
. l .
1/30/86 f$[gf UNITED STATES OF AMERICA )2 NUCLEAR REGULATORY COMMISSION 'o M Do ~ Yi:2c:aw BEFORE THE ATOMIC SAFETY AND LICENSING BOARD on;,
In the Matter of: )
)
COMMONWEALTH EDISON COMPANY ) Docket No. 50-456
) 50-457 (Braidwood Nuclear Power )
Station, Units 1 and 2) )
INTERVENORS ROREM, ETAh.
NOTICE OF DEPOSITIUNS 0
Pursuant to 10 C.F.R. 52.740(a), Intervenors Rorem, et al.
hereby give notice that they shall t uke the depositions of the following witnesses, who are employees of Commonucalth Edison Company or its contractors: James W. Geiseke; Kenneth T.
Kostal; Edward M. Shevlin; George Orlov and Thomas E. Quaka. ,
The depositions shall commence on Wednesday, February 12, 1986, at 10:00 A.M., and shall cont ue thereafter until completed, at the offices of Isham, Lincoln and Beale, Three First National Plaza, Chicago, Illinois; or at such time and place between February 12-14, 1986 as the parties may agree. The depositions shall be taken before a certified court reporter, and shall be on the subject of the witnesses' knowledge of the quality assurance deficiencies at the Braidwood nuclear power station alleged in Intervenors' Amended Quality Assurance Contention.
o \
%-~- :. .
I The deponents shall bring with them all documents in their possession, or subj ect to their control, which are the basis for the witnesses' affidavit in support of Applicant's December 20, 1985, Motion For Summary Disposition.
DATED: ~ January 30, 1986 Submitted by, w
Robert Guild [#"
One of the-Attorneys for Intervenors Rorem, et al.
J Douglass W. Cassel Robert Guild Timothy W. Wright, III 109 North Dearborn Suite 1300 Chicago, Illinois 60602 (312) 641-5570 1
1/30/86 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of: )
)
COMMONWEALTH EDISON COMPANY. ) Docket No. 50-456
) 50-457 (Braidwood Nuclear Power )
Station, Units 1 and 2) ) ,
CERTIFICATE OF SERVICE I hereby certify that I have served copies of Intervenors 4
'Rorem, et al. Notice of Depositions on each party listed on the attached Service List by having said copies placed in
~
envelopes, properly addressed and postaged (first class) and deposited in the U.S. mail at 109 North
Dearborn,
Chicago, Illinois 60602, on this 30th day of January, 1986; except that NRC Staff Counsel Mr. Traby was served via Federal Express overnight delivery and Mr. Stahl, counsel for Edison, was served by messenger on Friday, January 31, 1986.
1 [ /er\.
l'"/
^ _ . _ -...._ _ - -
BRAIDWOOD SERVICE LIST 50-456/50-457 OL IIerbert Grossman Elaine Chan, Esq.
Chairman and Adadnistrative Judge NRC Staff Counsel Atomic Safety and Licensing Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington D.C. 20555 Washington D.C. 20555 Dr. A. Dixon Callihan Administrative Judge Joseph Gallo, Esq.
102 Oak Lane Isham, Lincoln & Beale Oak Ridge, TN 37830 Suite 840 1120 Connecticut Avenue N.W.
Dr. Richard F. Cole Washington D.C. 20036 Administrative Judge Atomic Safety and Licensing Board Docketing & Service Section U.S. Nuclear Regulatory Commission Office of the Secretary Washington D.C. 20555 U.S. Nuclear Regulatory Commission Rebecca J. Lauer, Esq. Washington D.C. 20555 Isham, Lincoln & Beale Three First National Plaza Atomic Safety and Licensing Chicago, IL 60602 Board Panel U.S. Nuclear Regulatory Ms. Bridget Little Rorem Commission 117 North Linden Street Washington D.C. 20555 Essex, IL 60935 -
Atomic Safety and Licensing C. Allen Bock, Esq. . Appeal Board Panel P.O. Box 342 U.S. Nuclear Regulatory Urbana, IL 61801 Commission Washington D.C. 20555 Thomas J. Gordon, Esq.
Waller, Evans & Gordon Michael I. Miller, Esq.
2503 South Neil Isham, Lincoln & Beale Champaign, IL 61820 Three First National Plaza Chicago, IL 60602 Lorraine Creek Route 1, Box 182 Manteno, IL 60950 Region III U.S. Nuclear Regulatory Commission Office of Inspection & Enforcement 799 Roosevelt Road Glen Ellyn, IL 60137
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- l Page 1 of 2 SUPMATION i
on January 18, 1985 CSR Mechanical / Welding inspection activities were suspended in the piping support populations predicated upon NRC CAT concerns.
[ Actions taken and results achieved are as follows:
- 1. A Reverification Plan was developed by the BCAP Level III Mechanical Inspector and approved by the BCAP CSR Inspection Supervisor on January 19, 1985. The plan contains definitive acticas to be executed and special checklists to document the reverification results. These checklists included a special instruction for reverification of each of.
the four (4) areas of interest. A separate checklist was prepared for each of the three affected support populations to provide appropriate references to the applicable approved BCAP checklist instruction in all cases. The Reverification Plan, including checklists, are enclosed as Exhibit *C."
- 2. prior to performing the reverification, each inspector was instructed in the objectives and methods outlined in the plan, the attributes to be reverified, and the specific instructions applicable to each attribute.
Attendance rosters are enclosed as Exhibit "D."
I - 3. Control measures were established to assure that no inspector was tasked i
to reverify his own previously performed inspection. A log which lists each CSR Package number, the name of the original inspector and the name of the reverification inspector is enclosed as Exhibit "E."
- 4. The inspectors who performed the reverification were provided only with the applicable drawings, instructions and special checklists. They were thus aware of neither the results of the original inspections or the
-identities of the original inspectors.
, NOTE: Prior to implementing this plan, two CAT findings were reverified by the original inspectors. The inspectors concurred with the CAT findings, and issued Observation Records I-M-02-054-3 and I-M-03-008-4. These observations were treated under this plan as new observations, and are included in all resultant statistics.
The two supports were also independently reverified as described in paragraph 3 and 4 above.
ii
- 5. Findings made by the reverification inspectors were entered on the special checklists. A specially designated team of Certified (Lead) Quality i Inspectors were tasked to determine the validity of each finding. This was done by reexamination of the hardware items and/or comparison with the approved BCAP accept / reject criteria outlined in the applicable j :i . instructions in Exhibit "H" and were processed as follows:
9 I
Ea000453 *
(1680J) ,,.
l - __ ___ _ ____ _ _ _ ___ . _ -
k Page 2 of 2 )
a.
~
Where the finding was determined to be valid, an Observation Record was initiated in accordance with Procedure BCAP-06.
- b. Where the' finding was determined to be invalid, the reverification inspector was shown, to his/her satisfaction, the reason for the determination. The justification for a determination of invalidity was entered on the special checklist and signed by the certified Lead Inspector. As evidence of concurrence, the reverification inspector initialed the entry.
- c. The plan provided for processing of contested new observations. No invalidation of findings were contested.
- d. One Observation Record was initiated, and later closed by the Level III Mechanical Inspector as not suitable for further processing, with the concurrence of the reverification inspector.
- e. Observation Records initiated as a result of this plan are being processed in accordance with BCAP-06. Copies are enclosed as Exhibit "F.*
- 6. Copies of the checklists used to implement this plan are enclosed under separate cover as Exhibit "G."
~1. BCAP CSR reinspection package documents affected were corrected to incorporate the new observations initiated as a results of this plan.
- 8. Analysis of the results of implementing this plan are enclosed as follows.
Program analysis by group Exhibit H Evaluation of new observations Exhibit I t
Contlusion:
Based upon the number of new observations (20) versus the total attributes reverified (640) the results indicate a 96.8% inspection accuracy rate. In addition no significant deficiencies were identified during the reverification plan which had not been previously identified.
All questionable areas of concern were thoroughly addressed through implementation of this plan.
Predicated on the results of the assessment / reverification plan, we consider the NRC CAT Team concerns to be effectively resolved.
E.3000454 (1680J)
January 22. 1985 BCAP Memo 8 530 TO: R. L. Byers FROM: M. A. Clinton
SUBJECT:
CAT Concerns with BCAP Reinspections of Piping Supports As discussed on 1/18/85, we have initiated an internal reverification program to address the CAT' concerns and questions related to the Task Force reinspections in the piping support area. The reverification program is focused on four areas of concern which are summarized in Attachment I.
Evaluation of each of these four areas of concern and the fact that they were revealed in a relatively small number of reinspection packages (5) led to a conclusion to reverify the affected attribute areas for the 160 piping support packages completed through 1/18/85. The 160 completed packages are distributed in the random sample portion of three populations in the following porportions:
M-002 Large Bore Pipe Supports (Rigid) - 50 completed.
M-003 Large Bore Pipe Supports (Non-Rigid) - 51 completed.
M-006 Small Bore Pipe Suppports - 59 completed The Mechanical / Welding Level III Inspector was assigned to develop a Reverification Plan to cover the areas of CAT concern and to obtain my concurrence prior to beginning any inspector reverification activity. The draf t plan was reviewed orf 1/19/85 and approval to begin implementation was also given on 1/19/85. The resultant Reverification Plan and implementing checklists and forms for recording reinspection results are presented in Attachment 2.
We are performing the reverification program on a priority basis and expect to have a majority of the reverification activities completed by 1/25/85.
There will be a small number of piping supports in restricted access areas and these may not be completed by 1/25/85; however, these should not materially affect the results to be available by 1/25/85.
I will keep you informed of the progress of this program on a regular
.I basis.
l M. A. Clinton 0828J E9000458 n_ , , . , - - , - . - - . - - -,- ~ - -
Attachment 1 page 1 of 1 Areas of Question or Concern
- 1. Cat Inspector identified that a 6" angle iron stiffener specified on the drawing and the Bill of Material Gas not installed. BCAP Inspector had reported this piece inaccessible for verification in the checklist Remarks column, due to its parent in place beam being boxed in. (M-003-032)
- 2. CAT Inspector identified that the shelf bracket angle irons for the supplementary steel on one support were not the specified size or weight. BCAP Inspector failed to transcribe this observation from his notes to the reinspection documentation. (M-003-008) .
- 3. CAT Inspector identified that a welded attachment to in-place steel on one support was incorrectly located. -BCAP Inspector failed to identify this discrepancy. (M-002-054)
- 4. CAT Inspector was concerned that instructions did not provide for verifying specified location of support attachments to supplementary steel (Generic) e E0000459 0828J .
l Attachment 2 Page 1 of 2 Reverification Plan
- 1. Checklists to provide for reverification of the characteristics identical to or similar to the areas of concern are to be developed by the BCAP Mechanical Level III Inspector, and approved by the Inspection Supervisor.
- 2. Inspectors involved in the reverification are to be provided with instructions to assure a complete and uniform understanding of the attribute areas to be reverified. Specific training on the use of the reverification checklist and applicable CSR instructions will be provided.
- 3. Control measures are to be established to assure that no inspector will be tasked to reverify his/her own work.
- 4. The inspector performing a reverification is not to be provided with the results of the original inspection. He/she will be furnished with the applicable drawings, instructions and the reverification checklist. The reverification inspector will not be made aware of the identity of the original BCAP inspector.
- 5. Observations made by the reverification inspectors will be compared with the results of the original inspections by a team of specially designated inspectors. Where an observation is made during reverification which was not made during the original inspection, a Certified Lead Quality Inspector (Mechanical) will reexamine the subject characteristic to determine the validity of the new observation. If valid, the new observation will be processed in accordance with current BCAP procedures. If the new observation is determined by the Certified Lead Quality Inspector to be invalid, the reverification inspector will be shown, to his satisfaction, the reason for the determination of invalidity. The reverification inspector's acknowledgment of invalidity will be documented on the reverification checklist. Contested new observations will be processed in accordance with current BCAP procedures.
1 l
E0030460
Attachment 2 .
page 2 of 2
- 6. Results of the reverification will be analyzed to determine individual inspector or group deficiencies. In the event that such deficiencies become apparent, appropriate instruction or training will be developed, submitted to BCAP Management for approval, and presented to the inspectors. At the time of decision that additional training is indicated, further support inspections by individuals or by group will be discontinued until such training has been completed.
~1. Support inspection attributes outside the scope of the NRC CAT questions and concerns are not addressed by this plan.
l 8. Documents controlled by BCAP procedures initiated or corrected as a result of this plan will be processed and retained in accordance
- with the applicable procedures.
9, checklists, notes or other documents initiated as a result of this plan but not controlled by BCAP procedures will be processed and retained as directed by BCAP Management.
f Forms to impleme,nt this Plan are attached. ,
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h f nr. , t.' ' . - 4 January 31, 1985 BCAP Memo #593 TO: R. L. Byers FROM: G. M. Orlov
SUBJECT:
Observations resulting from Pipe Support Verification Plan The additional observations generated as a result of the BCAP-Pipe Support Reverification Plan have been reviewed. It is apparent from this review that the BCAP inspections should, for future inspections, continue to verify dimensions of vendor supplied " catalog" items that .
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constitute hanger assemblies in the manner in which these verifications vere performed during the " Reverification" activities. This action vill provide assurance that pipe support components are installed in accordance l with the specified design and will address questions identified by the CAT.
G. M. Orlov BCAP Assistant Director GM0/jan cc: N. Kaushal M. Clinton BCAP File QG 69.60.3 E0000468
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Date: /3/85 l
! I To: /1?iNZO EUNION FROM: Ed Shevlin
SUBJECT:
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- 1. OBSERVATION blo.r*E" ' 2.'- L PART 1 -
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- 13. SUITABLE FOR FURTHER PROCESSING: gg gg 1 I Biena'tur/ Date DCAP Foru 06-1 (Rev. 5) E0000502 t - --
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. Page 1 of 3
- 1. OSS ERVATION WO. 's" '. fF ' ' ' -
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- 12. COMMENTS / CLARIFICATION: //BA/E
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PART 1 OBSERVATION IDDrTIFICATION & DESCRIPTION 2 DESCRIPTION OF ITEM (Equipment, Material,Ctaponent , Procedure):l3. PACKAGE NO.
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- 12. COMMENTS /CIARIFICATION: A/SA/8
- 13. SUITABLE FOR PURTHER PROCESSING: 14.R B:
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aCAP OBSEPVATION RECORD Page 1 of 3
- 1. OBSERVATION NO.f Lf ! IT 6 - 2 PART 1 OBSERVATION IDENTIFICATION & DESCRIPTION
- 2 DESCRIPTION OF ITEM (Equipment, Material, Component, Procedure):l3. PACKAGE NO.
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- 10. DESCRIPTION OF OBSERVATION:
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- 12. COMP @rrS/CIARIFICATION: M64)f
- 13. SUITABLE POR FURTHER PROCESSING: 14.REVIEVED BY g4
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- 1. CSSERVATION WO.C?i .c F- ': '
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PART 2 OBSERVATIOW C1ARITY, COMPLETENESS, AND ACCURACY REVIEW 12.CopMENTS/CIARIFICATIOW: A/d # 5-l
- 13. SUITABLE POR PURTHER PROCESSING: 14. EV1 YS l __. , Y: /
m_t wur /-tr; Si h tu/e Date o35u-2 ochP Porn 06-1 (Rev. 5) E0000507
t Page 1 of 7 i
i PIPE SUPPORT R8 VERIFICATION PLAN ANALYSIS OF NEW OBSERVATIONS ATTRIBUTE, INSTRUCTION DESCRIPTION OF NEW COSERVRTION COBOIENT f
i configuration - verify 8.0.M. specified a WGX15.5. While the instruction attachments do not describe the j thtt all items of the W6X16 installed. W6x15.5, the inspectors have been provided with copies of 1 installed support are the dimensions for detailing for the comanonly used I tha same as those structural shapes from both the seventh and eighth j indicated on the bill editions of the AISC Manual. This is a site fabricated of materials. g piece, and there are significant differences between the l W6X15.5 and W6X16. The difference in flange width is readily apparent. Level III Mechanical Inspector
- recoussends that this item be treated as attributable to inspector technique.
i Stiffener clamps installed where While it was not the intent of the CSR Engineer that i
8.0.M. indicated use of standard vendor fabrication dimensions be reverified. The clamps. (Two instances.) difference between a standard clamp and a stiffener clag l
i is readily apparent. Level III Mechanical Inspector 2
recessmends that these items be treated as attributable to inspector technique.
Incorrect parts installed in Two clamps and one rear bracket. Detailed verification of vendor supplied pre-engineered vendor fabrication dimensions is not normally associated support assemblies. (Three with installation inspections. The bill of materials instances.) spec 1fies itens by aize and vendor part nusber. Only those dimensions necessary to erect the assembly are normally given on the 8.0.M. and the drawing. The vendor drawings are provided to the inspectors only to enable m 'them to verify that the correct assembly was installed, by C
part number and size. It was not intended that stock C
sizes of subassemblies be reverified. Level III CA Mechanical Inspector roccessends that these items not be
- treated as attributable to inspector technique.
Cn
Page 2 of 7 PIPE SUPPORT R5 VERIFICATION PLAN ANALYSIS OF NEW OBSERVATIONS COfSIENT ATTRIBUTE, INSTRUCTION DESCRIPTION OF NEW OBSERVATION Rod couplings installed with two Hardware is correctly installed. The checklist Configuration - verify jam nuts where bill of materials instructions refer to S&L Drawing M-919 for authorized that all items of the calls for one jam nut. (Two additions, substitutions and tolerances. M-919 specifies installed support are that two jam nuts be used with the rod coupling. The tha same as those instances.)
inspectors interpreted the use of the extra nut as an indicated on the bill approved tolerance. Level III Mechanical Inspector of materials ,
recomunerds that these items not be treated as attributable to inspector technique.
8.0.M. specified rod couplings visual examination of these couplings shows them to can not be dimensionally apparently be ITT Grinnell Fig. 79. Size is determined by verified to approved vendor rid diameter, which is corroct. Normal installation catalogs. (Dso instances.) inspection does not include dimensional verification of vendor fabricated parts. Level III Mechanical Inspector recosamends that these items not be treated as attributable to inspector technique, s.O.M. specified an ITT orinnell visual examination of this assembly shows it to apparently be an ITT orinnell Fig. H.s. 45. Length and depth of C Fig. H.S. 45 asseeably. Locations of welded washer plates on the shapes is correct. Normal installation inspection does no assembly do not agree with vendor include verification of vendor fabrication dimensions.
fabrication dissensions. Level III Mechanical Inspector roccessends that this item not be treated as attributable to inspector technique.
B.O.M. specified a 307N snubber. The 306N and 307N snubbers are identical, except that the g
A 306N snubber is installed. 307N is fitted with an extension piece. In this case, it O
'O would not be possible to install the specified 307N, there is either a detailing error on the drawing or a clerical
$ error on the B.O.M. The difference between a snubber with ca or without the extension piece, is readily apparent.
H Level III Mechanical Inspector recomumends that this item O
be treated as attributable to inspector technique.
4 u _ _ _ _ _ _ ,-. ,
Page 3 of 7 PIPE SUPPORT REVERIFICATION PLAN ANALYSIS OF NEW OBSERVATIONS COfGEENT ATTRIBUTE, INSTRUCTION DESCRIPTION OF NEW OBSERVATION configuration - Verify B.O.M. specified a W8X17. A While the instruction attachments do not describe the W8X21 is installed. Attachment W8X17, the inspectors have been provided with copies of that all items of the the dimensions for detailing for the comanonly used in2talled support are to beam is not located as shown on drawing. structural shapes frous both the seventh and eighth the same as those editions of the AISC manual. The dimension given for indicated on the bill locating the attactument to this beam was unworkable with a cf materials. g W8X21, and apparently would not have worked with the specified W8X17. While the differences between the installed and the specified item may not have been readily ;
apparent the attachsent d1serepancy should have been.
Level III Mechanical Inspector recosumends that this item be treated as attributable to inspector technique.
.l l
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- H i 4 l
p;ge 4 cf 7 PIPE SUPPORT REVERIFICATION PLAN ANALYSIS OF NEW OBSERVATIONS t
COpWIENT ATTRIBUTE, INSTRUCTION DESCRIPTION OF NEW OBSERVATION component dimensions - 8.0.M. specified L 4" x 4" x Hard dimensions for these L shapes were shown on the vsrify the component 1/2" x 0'-6". L 3 1/2" x B.O.M. The inspector identified the discrepancy and falle dimensions to the bill 3 1/2" x 3/8" x 0*-6" installed. to transcribe the information from his notes to the B.O.M. specified [ 3" x 3" x inspection documents. Level III Mechanical Inspector cf materials and the cupport sketch. 3/8" x O'-1 3/4". L 3" x 3" x recossends that this item be treated as attributable to 1/4" x 0'-1 3/4" installed. inspector technique, s
B.O.M. specified a 1/2" x 0'-9" The increase from 1/2" to 3/4" in thickness of the is x O'-9" C.S. 3/4" x 0'-9" x acceptable. The increase form O'-9" to O'-10" exceeds O'-10" C.S. installed. allowable tolerances by O'-1/2". This information was available to the inspector. Level III Mechanical I Inspector recommends that this item be treated as attributable to inspector technique.
Component dbeensions - Drawing specified 1/16" typ. The hard contact on one side is acceptable. The varify that the clearance pipe is in hard cumulative clearance on the opposite side exceeds allowebt '
installation tolerances contact on one side with 5/32" tolerance by 1/32". small bore piping moves about for components comply clearance on opposite side, relatively freely within this type support. It is likely with CSR checklist that the original inspector did not have contact on either in2tructions. side, with the excess 1/32" distributed on both sides.
Measurements of less than 1/32" taken from both side of a moveable object can easily contribute to minor errors.
Level III Mechanical Inspector recommends that this item not be considered attributable to inspector technique.
M 3
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p ge 5 cf 7 l PIPE SUPPORT REVERIFICATION PLAN ANALYSIS OF NEW OBSERVATIONS l ATTRIBUTE, INSTRUCTION DESCRIPTION OF NEW OOSERVATION C0fGEENT Component dimensions - "C" dimension on clasp by vendor "C" dimensions is a vendor fabrication dimension for a varify that the fabrication dimensions should be spacer between the clasy ears. This is not a dimension installation tolerances 1 7/16". *C" dimension on which is normally associated with installation l
) for components comply installed clamp is 1". inspection. The clamp is part of a higher vendor supplied with CSR checklist assembly, and by type visually appears to be correct.
instructions.
Level III Mechanical Inspector recommends that this item ,
not be treated as attributable to inspector technique.
"A" dimensions frem. centerline This dimension was specified as 1 3/4", with e i 1/2" l U-Bolt to end of hanger member tolerance. (Min. dim. 1 5/16".) Installed at 1 1/4". By is 1/16" out of tolerance, design, the bolt holes are larger than the U-Bolt. The U-Bolt is not centered in the holes. If it were, the tolerance would be met. Note that the only tightness inspection is " hand tight." It is not unlikely that at the time of the original inspection, there was no discrepancy. Level III Mechanical Inspector recommends 1 l
' that this item not be treated as attributable to inspector I technique.
Near Bracket installed out of This rear bracket is welded in place, out of specified location tolerance. location. Hard dimensions are shown on the drawing, and tolerances are provided as attachments to the instructions. Level III Mechanical Inspector recosmonds that this item be treated as attributable to inspector l technique.
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I Page 6 of 7 l
I' PIPE SUPPORT REVERIFICATION PLAN ANALYSIS OF NEW OBSERVATIONS l
l COIWert DE9CRIPTION OF NEW OBSERVATION ATTRIBUTE, INSTRUCTION Location of Attactument of support This item was not a specific step in the original Location of Attactueent to to supplementery atee1 out of inspections.It is secondary to the specified centerline drawing. The CSR cupplemental stee1 - allowable tolerances. g (Two location of the support relative to the pipe.
where the support instances.) checklist instructions and s&L drawings specifically subeequent state to the ettcches to supplementary that location is relative to the pipe.
cteel, verify that the original inspections, clarification was requested
-Application and of the now, 4 loc: tion of the attach- received from CSR engineering.
ment does not deviate correct interpretation of the instructions resulted inLevel from that specified on these items becoming observations.
on the design drawing. Inspector recommends that these items not be treated as attributable to inspector technique.
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ATTRIBUTABLE ATTRIBUTABLE TO TO INSPEC'!OR REVERIFICATION ATTRIBUTES FACTORS OTHER THAN TECHNIQUE TECHNIQUE ATTRIBUTE S1 (CONFIGURATION) 5 7 ATTRIBUTE 92 (COMPONENT DIMENSIONS VERIFIED TO 2 SUPPORT DRAWINGS AND BILL OF 0 MATERIAL)
ATTRIBUTE S3 (COMPONENT DIMENSIONS VERIFIED TO 1 INSTAL 1ATION TOLERANCES 3
't ATTRIBUTE S4 LOCATION OF ATTACHMENTS TO O SUPPLEMENTARY STEEL 2 TOTAL 8 12 (1687J)
E0000521
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TO: /7JiNZO Cl/N704f FROM: Ed Shevlin SUB3ECT: ((f-IM Z o CIA-Z'N h ESS-Z M*L (NEfflAT /N1TAulRMS.
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Attachment 1 Pcg? I cf 1 l
1 Areas of Question or concern
- 2. CAT Inspector identified that the shelf bracket angle irons for the supplementary steel on one support were not the specified size or weight. BCAP Inspector failed to transcribe this observation from his notes to the reinspection doctanentation. (M-003-008)
- 3. CAT Inspector identified that a welded attachment to in place steel on one support was incorrectly located. BCAP Inspector failed to identify this discrepancy. (M-002-054)
- 4. CAT Inspector was concerned that instructions did not provide for verifying specified location of support attachments to supplementary steel (Generic) o i
4 l
l 0828J E0000527
t.t l ' i " '. 55 '
Attcchm2nt 2 l page 1 of 2 Reverification plan
- 1. Checklists to provide for reverification of the characteristics identical to or similar to the areas of concern are to be developed by the BCAP Mechanical Level III Inspector, and approved by the Inspection supervisor.
- 2. Inspectors involved in the reverification are to be provided with instructions to assure a complete and uniform understanding of the attribute areas to be reverified. Specific training on the use of the reverification checklist and applicable CSR instructions will be provided.
- 3. Control measures are to be established to assure that no inspector will be tasked to reverify his/her own work.
- 4. The inspector performing a reverification is not to be provided with the results of the original inspection. He/she will be furnished with the applicable drawings, instructions and the reverification
! checklist. The reverification inspector will not be made aware of the identity of the original BCAP inspector.
1
- 5. observations made# by the reverification inspectors will be compared with the results of the original inspections by a team of specially designated inspectors. Where an observation is made during reverification which was not made during the original inspection, a Certified Lead Quality Inspector (Mechanical) will reexamine the subject characteristic to determine the validity of the new observation. If valid, the new observation will be processed in accordance with current BCAP procedures. If the new observation is j determined by the Certified Lead Quality Inspector to be invalid, i the reverification inspector will be shown, to his satisfaction, the reason for the determination of invalidity. The reverification inspector's acknowledgment of invalidity will be doctamented on the reverification checklist. Contested new observations will be processed in accordance with current BCAP procedures.
l f
i E0000528 -
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- 6. Results of the reverification will be analyzed to determine individual inspector or group deficiencies. In the event that such deficiencies become apparent, appropriate instruction or training will be developed, submitted to BCAP Management for approval, and presented to the inspectors. At the time of decision that additional training is indicated, further support inspections by individuals or by group will be discontinued until such training has been completed.
- 7. Support inspection attributes outside the scope of the NRC CAT questions and concerns are not addressed by this plan.
- 8. Documents controlled by BCAP procedures initiated or corrected as a result of this plan will be processed and retained in accordance with the applicable procedures.
- 9. Checklists, notes or other documents initiated as a result of this plan but not controlled by BCAP procedures will be processed and retained as directed by BCAP Management.
Forms to implement this Plan are attached.
o 0828J E0000529
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6cu rw o o m 1 ATTAC H M E ur 4 January 31, 1985 BCAP Memo #593 TO: R. L. Byers FROM: G. M. Orlov SUMECT: Observations resulting from Pipe Support Verification Plan
.The additional observations generated as a result of the BCAP Pipe Support Reverification Plan have been reviewed. It is apparent from this review that the BCAP inspections should, for future inspections, continue to verify dimensions of vendor supplied " catalog" items.that constitute hanger assemblies in the manner in which these verifications were performed during the " Reverification" activities. This action will provide assurance that pipe support components are installed in accordance with the specified design and will address questions identified by e
the CAT.
M G. M. Orlov BCAP Assistant Director GM0/jan ec: N. Kaushal M. Clinton BCAP File QG 69.60.3 E0000536
b(.A P fnf_ M O 71 7 AmamEm 5-Date: /X85 To: HliNZO CON 70W FROM: Ed Shevlin SUB3ECT: ESE IMZ > CSR-Z-/713. cst-I /n-f. CHErkUST /HJTAUCTIMS.
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E0000719
8 Date: / Ib6'l TO: MEh70 CUN70N FROM: Ed Shevlin
SUBJECT:
NRC CAT l'INd/N(.t5 /. CSR-I MOV 024 : NRC fcXJNb OVE DINENS/ON AXEPIED BY BCAP /N.VECTN lt)HKH 5'la')Lb NAVE BELN RETECTEDs ANDME REJECTEA luMKHMS ACCEPTA&E CW' CUR. TN' E NM/ZONTM D/MENSION 4/R1/NCMRECTLY PRESENTEb MTh' E MAki/N(t, IN THAT THE l'HAIN 7MMENS/QVS MAM Da'INE UM W 7NE TKKKhE35E5 Of 71/0 RAN6E.S. THE /Mp%VER FAEPRfAT/M OF THE DeRkHMCs ('OVTA/807ED D 7NS /NPEClM ERRM. 130TH THE BCAP ANs NRC INSPECKAS ItE.AE IN EAROL IN RESMTJ OATRINED W THE HM/ZONTRI. MERSUEEMENT THE WATdM NMEN5DN WAS IN(MREETLY MAllMLD BY THE BCAP /NUECTM. 1NE l' NEE 5 0 bot'N /N(MAECT MER30AE)%NTJ MVE BELN MTERMINEb RNb N5(.LI55Eb itJITH THE IN3PECTM . /38 MC/1/DNS> 3 EB3tS C17.B L ACCUKACY). W-I-M-O4-Gf(-I REVIMD TOMCM/ MATE NEklFINblN(15. A' , I smoggNM twI E0000722
l'OMECTEb ODPY- /7EM S Date: / //dr To: MENZO Cl/NTM FROM: Ed Shevlin
SUBJECT:
NRC CAT f/NDINGS
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EMPLOYEE EVALUATION NAME ! * # 5 BADGE 8 f2I'80-f0STLEVEL 1 Enter (S) for Satisfactory or (U) for Unsatisfactory EVALUATION DATE: /- /f-(( on applicable line: (1) Knowledge of Procedures, Specifications Codes, 'OVERALL RATINS (Check one): and Standards 5 SATISFACTORY v (2) Knowledge of duties S UNSATISFACTORY (3) Performance of duties S (4) Accuracy of reporting duties S LIST SPECIFIC PROBLEMS A/O NI nEnARKS dwE4vaartex l d'Mwr &nf.essar PA'G Ah, fSff-A-64-09
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0043J E0000725
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9 EMPLOYEE EVALUATION NAME // 6- 40 BADGE e 523-go.SeSp LEVEL f Enter (S) for Satisfactory cr (U) for Unsatisfactory EVALUATION DATE: /-'8' 8 5 on applicable line: (1) Knowledge of Procedures. OVERALL RATING (Check one): Specifications Codes, and Standards 5 SATISFACTORY & (2) Knowledge of duties 6 UNSATISFACTORY , (3) Performance of duties 5 (4) Accuracy of reporting duties S LIST SPECIFIC PROBLEMS OM# . I w* ric,arn T r i s.' RHP COM90^'"kT Dt!/Cn'.3tt sv;
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e EMPLOYEE EVALUATION MAME MN E #Aff5dd BADGE g Sr2 74 6fM LEVEL ll a ernter (S) for Satisf actory or (U) for Unsatisfactory non applicable line: EVALUATION DATE: _ /-/5-85 (1) Knowledge of Procedures. Specifications, codes, OVERALL RATING (Check one): and Standards S SATISFACTORY (2) Knowledge of duties S UNSATISFACTORY (3) Performance of duties 5 (4) Accuracy of reporting duties .S LIST SPECIFIC PROBLEMS ND ade' w e,w en,wa Aan Con M ani Do H G Nb's% hG. rdos. C 3 2-Z+t 06_-o34,
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" 33 E0000727
. s. s EMPLOYEE EVALUATION NAME 8. #NS BADGE # 52I'80-fosiLEVEL E Enter (S) for satisfactory or (U) for Unsatisfactory EVALUATION DATE: /- /f-(( on applicable line: (1) Knowledge of Procedures. Specifications, codes, OVERALL RATING (Check one): and Standards 5 SATISFACTORY v (2) Knowledge of duties I UNSATISFACTORY (3) Performance of duties 5 (4) Accuracy of reporting duties .5 LIST SPECIFIC PROBLEMS A/O NI REMARKS bwfMW/247?aW l bMMfM7 hs)fMSteM lY6 Ab. ($f-f-A-6/-040
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s EMPLOYEE EVALUATION NAME // 5- 344 ~o sADGE e 51J-3 35p trygo 7 Enter (S) for Satisfactory or (U) for Unsatisfactory EVALUATION DATE: /-<5-85 on applicable line: (1) Knowledge of Procedures. OVERALL RATINO (Check one): Specifications. Codes, and Standards -5 SATISFACTORY & (2) Knowledge of duties 5 UNSATISFACTORY (3) Performance of duties S (4) Accuracy of reporting duties S LIST SPECIFIC PROBLEMS OM# coaric,aew rio,.' Rao CoMPer*ca Distra'sims R:G. ges. a c.y. n .ot.-cI4, REMARKS C 12- I-M-Q3 oo 4 AND C3 P .7- M- 0 6 -02 6. D Vtf /NSPt clie d
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go00072 i 0043J
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4 Date: /.N A 5 l l TO: MENZO CL/NIZW FROM: Ed Shevlin
- l. SUB3ECT: 17)ECH/ WElb /MSffrTMSkarMERN6.
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- l. NK CNERINSPECTIM1 FOR DECEMBLR.'Nd GUESTMS LM LDWERNS.
- 2. NfC LWT f/NSNGS: THE MILLENCES BETitMEN BCAP RMb CRT /NSPECT/M K5M75 i trJCRE BKMSEb. -
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F)EW AGES 70 QJtun DalMENT3.
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