ML20155A521
| ML20155A521 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 03/24/1986 |
| From: | Hooks K COMMONWEALTH EDISON CO., NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20155A518 | List: |
| References | |
| OL, NUDOCS 8604090060 | |
| Download: ML20155A521 (39) | |
Text
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p uyen COPRESPONDENCt 1
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._UhITEDSTATES-OFAMERICA o/
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NUCLEAR REGULATORY COMMISSION 3
'86 APR -8 P1 :16 4
0FFICE U.a 00CHETihG^ :tn 5
In the Matter of:
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6 COMMONWEALTH EDISON COMPANY
]
Docket Nos. 50-456 O b-7 (Braidwood Station Units 1 & 2) ]
50-457 O (_-
8 9
Bethesda, Maryland 10 Monday, March 24, 1986 11 12 Deposition of:
( )
13 KENNETH R. HOOKS, 14 a witness herein, called for examination by counsal for the 15 Applicant, pursuant to notice and agreement of counsel as to 16 time and place, at the offices of the Nuclear Regulatory 17 Commission, Maryland National Bank Building, 7735 Old 18 Georgetown Road, Bethesda, Maryland, before MARILYNN 4
19 M. NATIONS, a Notary Public in and for the Commonwealth of 20 Virginia At-Large, commencing at 11:05 o' clock a.m., when were 21 present on behalf of the respective parties:
22 o
8604090060 060400 PDR ADOCK 05000456 i
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2 l
1 1
APP 2ARANCES:
2 On behalf of the Applicant:
3 JOSEPH GALLO, Esquire i
j 4
Isham, Lincoln & Beale I
i 5
1150 Connecticut Avenue, N.W.
2 6
Suite 1100 7
Washington, D.C.
20036 I
8 4
9 On behalf of the Intervenor:
i 10 TIMOTHY W. WRIGHT, III, Esquire
]
11 Business and Professional People for the Public i
12 Interest 4
(
13 109 North Dearborn
{
14 Suite 1300 I
j 15 Chicago, Illinois 60602 l
l 16 l
17 On behalf of the Nuclear Regulatory Commission:
)
i 18 STUART A. TREBY, Esquire l
19 Office of the Executive Legal Director I
20 United States Nuclear Regulatory Commission 1
21 Washington, D.C.
20555 j
22 1
1
!!O I
l
1 3
1 1
C0NTENTS r
2 Examination by Counsel j
3 Deposition of:
for Applicanc for Intervenor for NRC l
4 i
5 KENNETH R. HOOKS 4
32 35 0
i 6
)
7 Further Examination by Counsel
)
8 for Applicant for Intervenor for NRC
}
j 9
36 i
10 l
j 11 i
A 12 13 EXHIBITS 14 HOOKS DEPOSITION EXHIBIT NOS.
marked for identification -
I 15 f
l 16 No. 1 (Professional Qualifications]
4 l
17 a
i 18 i.
19 l
20
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5, 21 22
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i 4
1 PROCEEDINGS 2
MR. GALIO:
This is the second deposition today of 3
CAT *eam participant and it is the deposition of Mr. Kenneth 4
R. 3ooks and it has been arranged by the cooperation of the 5
NRC staff.
6 I have been furnished a copy of Mr. Hooks' 7
professional qualifications.
It is a ons-page document and I l
j 8
would like to have it marked for identification and included l
9 in the transcript as Hooks deposition exhibit number "1."
l 10 (Whereupon, the document 11 previously referred to was 12 marked for identification as
( )
13 Hooks deposition exhibit
{
14 number "1.")
15 Whereupon, 16 KENNETH R. HOOKS, j
17 having been called as a witness on behalf of the Applicant, was first duly sworn, was examined and testified as follows:
18 2
)
19 EXAMINATION BY COUNSEL ON BEHALF OF THE APPLICANT 20 BY MR. GALLO:
4 21 Q
Mr. Hooks, would you state your name and business 22 address for the record?
i i O
5 1
A My name is Kenneth Hooks.
I work for the United 2
States Nuclear Regulatory Commission, Washington, D.C.
3 Q
Is your office in Bethesda?
4 A
Yes, actual office location is in East-West Towers 5
in Bethesda, Maryland.
6 Q
I see your educational background is included in 7
your resume or your statement of professional qualifications 8
and I won't have to ask those questions.
When did you receive 9
your Masters Degree?
I 10 A
In 1964.
j 11 Q
When did you receive your degree in physics?
j 12 A
In 1962.
( )
13 Q
What type of research and development activities l
14 were you involved in during your time in the Air Force from l
15 1962 to 1968?
i 16 A
From 1962 to 1964 I was in graduate school as an 17 officer in the Air Force and from 1964 to 1968 I was in 18 research programs involved in ground electrical power systems 19 for remote bases and missile silos including nuclear reactors.
20 Q
What research project did you work on at Bechtel?
1 21 A
Fast flux test facility.
i 22 Q
At Hanford?
i
' O
t 6
1 A
Yes.
2 Q
What were your duties with respect to that activity?
I 2
3 A
I was in a mechanical nuclear engineering group and i
4 my job was to essentially translate the work of the reactor J
l 5
vendor into terms that could be understood by the designers 6
that Bechtel had doing the plant design.
7 Q
You were involved in mechanical systems?
l 6
A Pipes, pumps, valves -- that kind of thing.
9 Q
What were your duties while you were at i
10 Westinghouse?
11 A
I spent almost three years as a systems design 12 engineer again working on pipes, pumps and valves for the
[
}
13 auxiliary systems for pressurized water reactors and the rest 14 of the time I was there was as a project engineer for the l
15 Comanche Peak plant.
i i
16 Q
Are these auxiliary systems that you refer to, are l
17 they a part of the NSSS system?
18 A
Yes, chemical and volume control system, that kind
)
19 of thing.
20 Q
What were your duties when you were a project 2
21 engineer at the New York State Power Authority?
22 A
I was the project engineer for the Greene County a
1 3
0
..~s.4.._._
7 1
plant that was subsequently cancelled.
2 Q
What were your duties before the cancellation?
3 A
I was in charge of the review of the work that was 4
done by the architect / engineer, Stone and Webster, and the 5
reactor vendor which was Babcock and Wilcox.
6 Q
What were your duties at Gibbs and Hill?
7 A
I was on the comanche Peak project as a project 8
engineer responsible for the mechanical and instrumentation 9
and control systems for roughly two years and then I was on l
two different gas turbine projects, one for the industrial 10 11 city of Yanbu in Saudi Arabia and the other one for Taiwan.
12 Q
You might as well spell that one for the reporter 13 now.
4 14 A
Y-A-N-B-U.
l 15 Q
What were your duties when you worked at Stone and I
16 Webster?
17 A
I was on two different field assignments, one at 18 Shoreham on Long Island and I was involved in the management 4
19 of a group that was doing as-built piping drawings and 4
j 20 subsequent to that, I spent some time at the clinton project 21 in charge of a group of QC inspectors doing the 22 over-inspection program.
l I
i o
i 8
s 1
Q You joined the NRC in April of 1984, is that 2
correct?
4 f
3 A
Yes.
i 4
Q Have you been working primarily on CAT team j
l 5
inspections during that time?
6 A
CAT team, I have done four of those and also working 7
on TVA.
1 1
l 8
Q What does that mean, " working on TVA?"
9 A
Doing inspections at Tennessee Va* ley Authority I
i
?
i 10 plants.
l t
l 11 Q
Is this a recent assignment?
I
}
12 A
Unfortunately, no.
I got it essentially right after i
( )
13 the Braidwood CAT inspection was completed and I have been 14 doing that ever since except for a break to do the Palo Verde 15 CAT.
16 Q
These inspections at TVA are not CAT inspections, 17 are they?
i 18 A
No.
t 19 Q
They are inspections for the region?
20 A
They are team inspections on specific questions that l
r 21 have been brought up.
'I h
22 Q
All right.
I congratulate you on your statement of r
i a
i 1
i j
i
l l
t 9
1 professional qualifications.
The information is very l
2 succinctly laid out.
3 A
Thank you.
4 Q
You say you participated in four CAT inspections.
5 What plants were those inspections conducted at?
6 A
The first one was River Bend and then Shearon Harris 7
and Braidwood and then almost a year gap and then Palo i
8 Verde-3.
i l
9 Q
Was your inspection duties the same each time?
i 10 A
Yes.
11 Q
Design control.
12 A
Yes.
i
( )
13 Q
Do you have the CAT team inspection report?
14 A
I have the portions of it that I was responsible i
15 for.
i
]
16 Q
What portion is that?
l 17 A
I prepared all of section VII and the last paragraph 18 on page A-3 which is entitled, " Design Change control."
1 19 Q
So paragraph A-3, was that taken from Appendix A of 20 the so-called Executive Summary?
]
21 A
Yes.
The Executive Summary, the last paragraph on 22 the bottom of page A-3.
i l
O
10 1
MR. TREBY:
May I interrupt for one second?
Do you s/
2 have a correction to make to that paragraph on A-3?
3 THE WITNESS:
Yes, if I may offer a typographical 4
correction in the second sentence on page A-3.
It should say, 5
"In the area of document control the most significant 6
finding..."
7 MR. TREBY:
Is that the only typo that you have I
8 identified?
9 THE WITNESS:
That is the only one.
i 10 MR. TREBY:
Thank you for your indulgence, 11 Mr. Gallo.
I meant to mention it and it skipped my mind when j
12 we first came in the room and I thought we should point it out
()
13 to all the parties at this time.
14 MR. GALLO:
All right.
15 BY MR. GALLO:
(Resuming) l 16 Q
You heard Mr. Heishman indicate that he had reviewed i
j 17 the document, that is a draft of the CAT inspection report, i
18 for Braidwood.
Do you recall any comments he made with 1
19 respect to the paragraph on page A-3 that you just corrected?
20 A
No.
1 21 Q
Did he make any comments with respect to section VII f
22 of the report?
L__.-._--
1 11 1
A He had comments but I don't remember any specific 2
ones.
I would say in general there were very few comments 3
from him on that section.
4 Q
Did you keep his draft of section VII with the red j
5 ink marking on it?
6 A
No, sir.
7 Q
Has that been destroyed?
I j
8 A
Yes.
9 Q
Are you familiar with Intervenor's QA contention in i
10 this case?
11 A
I have read through it.
12 Q
Are you familiar with at least that portion of the
( )
13 contention that deals with design control?
14 A
I wouldn't want to say familiar.
{
15 Q
Have you read it?
16 A
Yes, I have read it.
17 Q
I am going to show you a copy of the contention, the j
18 sub-contention, item submitted by intervenors that deals with 19 or relies upon section VII of the CAT inspection report as its 20 basis.
l l
21 I want to ask you if the statement of the 1
l 22 sub-contention varies in any significant way from the finding
12 1
that you made in the CAT inspection report with respect to
)
2 design control?
3 (Document proffered to witness.]
4 MR. TREBY:
Could we identify what sub-contention 5
you are referring to?
I 6
MR. GALLO:
Yes.
I am showing the witness a 1
j 7
statement, actually it is dated May 24, 1985.
It is a motion 8
to admit amended quality assurance contention which was filed l
9 by the Intervenors in this case.
It includes the statement of i
10 the contention with all its subparts.
I am showing him an 4
1 11 item on page 29 which should translate subcontention 5(a).
I i
12 represent that it is the same version of the subcontention l
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}
13 that was admitted by the Licensing Board.
14 (Witness reviewing document off the record.)
15 THE WITNESS:
It appears to me that the 16 subcontention "A" is essentially exactly the same as the i
17 paragraph that I provided to the executive summary.
l 18 BY MR. GALLO:
(Resuming) 19 Q
That was my assessment as well.
According to the 20 witness list provided by the NRC staff you have been nominated 1
21 as a witness on this question.
Is that your understanding?
22 A
Yes.
4 i
i i!O
13 t
1 Q
Have you begun to draft any testimony on this issue?
2 A
No, sir.
3 Q
Have you begun to formulate in your mind any type of 4
organization with respect to your testimony?
5 A
Not really.
t 6
Q Have you been furnished an outline of questions by 7
the staff counsel?
8 A
No.
I don't think so.
I 9
Q All right.
Are you aware that this particular 10 subcontention item was the subject of a motion for summary 1
11 disposition by both applicant and staff?
4 I
12 A
Yes.
i
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}
13 Q
Do you know what that means?
14 A
Not really, i
15 Q
All right.
I am sure that Mr. Treby will inform you 16 after this is over.
Your section VII of the CAT report 17 indicates that the objective of at least your inspection was i
18 to determine whether or not design change activities were 19 conducted in compliance with regulatory requirements and i
20 whether changes to hardware were recorded on design drawings.
l 21 Is that a fair statement of the objective?
I 22 A
Yes.
14 1
Q Turn to page III-4.
2 A
(Witness complying.)
1 3
VII-4?
4 Q
Yes.
I am sorry.
I have III on the mind here from 5
our last witness.
Actually, it is VII-3.
i 6
A (Perusing document.)
7 Q
You state in paragraph four that the most prevalent 8
and sustained deficiency identified in the QA audits and 9
surveillances of the various document control system is 10 incorrect annotating of design change documents.
11 Who conducted the QA audits and surveillances that 12 you are referring to in that paragraph?
()13 A
My recollection would be that it was both members of 14 Commonwealth Edison's QA staff and members of Sargent & Lundy i
15 and the various vendors or I should say subcontractors on I
i 16 site, mechanical and electrical.
l 17 Q
When you say both members of Commonwealth Edison's 18 QA staff, what do you mean by that?
1 19 A
I am sorry.
20 Q
Maybe I misheard you.
21 A
What I meant to say that I looked at audit and 22 surveillance reports that had been done by Commonwealth O
f
15 1
Edison's QA staff, by Sargent & Lundy's staff and by the 2
staffs of various contractors on site.
3 Q
These audits and surveillances had identified the 4
problem you referred to here?
5 A
Yes.
6 Q
What does it mean to incorrectly annotate design 7
change documents?
8 A
The system that they had in place on all except one 9
of the subcontractors document control was to write on either 10 the front or the back of the design drawings that were in the 11 document control stations the outstanding but incorporated 12 changes that affected those drawings and the types of errors
( )
13 made varied from not putting on a design change that should 14 have been on there to leaving ones on that had been 15 subsequently incorporated and should have been eliminated or 16 conceivably although I don't remember finding it, f,bstsimply i
17 mistranslating a number from the list onto the drawing.
18 Q
What you are talking about is a failure to note on 19 the design drawing that design changes had been made?
20 A
Yes.
21 Q
Then on the other hand, the failure to eliminate the 22 note if the change in fact had been effective?
l w
I
16 1
A Yes.
2 Q
Is the change we are talking about a revision to the 3
design drawing itself?
4 A
Yes.
It would generally be some physical kind of 5
change to the drawing although not always.
Some design 6
changes don't actually affect the base drawing.
7 Q
What causes these design changes that require 8
annotation just in general terms?
9 A
An example would be a drawing for a pipe support and 10 upon actually going out and attempting to install the pipe 11 support the construction crew finds that due to some 12 interference it won't fit and you have to change the size of
(
13 the base plate or the location and you write a design change 14 against the support drawing and issue it rather than revising 15 the entire drawing and then at some later date you collect 16 those changes if there is more than one and you revise the 17 base drawing.
18 Q
Who at Braidwood does the revising to the base 19 drawing?
20 A
Sargent & Lundy.
21 Q
Who issues the design changes you refer to?
22 A
If they are ECN's, they are issued through Sargent &
O
17 1
Lundy and if they are FCR's, that is a field change and they 2
are issued through Commonwealth Edison.
3 Q
Can the site contractors themselves issue changes to 4
the design?
5 A
o.
Sargent & Lundy is in control of the design and 6
the FCR's even though they are issued by Commonwealth Edison 7
have to be signed by Sargent & Lundy as accepting the change 8
before they can be issued.
9 Q
Again looking at paragraph four on page VII-3 you 10 say the more serious deficiency is failure to list 11 unincorporated design changes on design document.m "and i.iten in i
12 parenthesis there are the words, "poasible lost information."
13 What did you mean by that?
14 A
I meant that if there is a failure to list on the 15 base document a design change to that document, the system 16 that is in place or was in place at Braidwood when I was there 17 was that the users of the documents are entitled to believe 18 that all the approved but unincorporated design changes are 19 listed on the document.
So they are not required to 20 cross-check and if a significant design change was not listed 21 on the document, it is possible that work could be performed 22 from that document that would be incomplete, wouldn't match IO I
l
~ - -
18 1
the latest design.
O-2 Q
The last sentence in paragraph four, you refer to 3
substantial efforts meaning corrective actions have been made 4
in each of the various document control programs.
For 5
which contractors, are you referring to in that sentence?
6 A
I would have to review the text to be certain.
7 Q
Please do.
8 A
(Perusing document.)
9 I looked at Comstock who is the electrical 10 contractor, Newberg who I believe was the civil contractor and 11 Phillips, Cetschow who was the mechanical contractor and 12 Pullman who was the HVAC contractor.
()
13 So those would be the subcontractors' programs who I 14 reviewed.
I also looked at Sargent & Lundy's document control 15 and Commonwealth Edison's document control.
16 Q
What are the substantial efforts that you are 17 referring to in that sentence on page VII-3?
18 A
I considered the efforts were substantial based on 19 findings in the QA audit and surveillance reports of similar 20 types of problems, the statements of corrective action 21 required and the reports of corrective actions that had been 22 taken.
O
19 1
Q How many and perhaps you need to refresh your memory s/
2 to answer this, but how many drawings did you look at to 3
determine whether the annotations were properly recorded?
4 A
(Perusing document.)
5 I am not sure I put it in the report.
I would guess 6
that I looked at something between 200 and 500.
7 Q
Do you remember how many examples you found where 8
the annotations were not properly noted?
9 A
My mistake.
It is on the next page on VII-4, item 10 six, 150 documents and then I state where there were some 11 annotation problems, several cases, so I would say three to 12 five.
Item seven, another 50 documents with no problems and
( ) 13 then I cross-checked some of those same documents again at 14 other document station and found discrepancies on about 15.
15 Q
Were those annotation problems as well?
16 A
Yes.
17 Q
of that number do you know how many involved a 18 situation where the missing annotation was for a change that 19 had not been incorporated in the design drawing?
20 A
I think it is in the text of my report.
It looks 21 like at the top of page VII-5, I state that there were 22 s'everal.
My recollection overall would be certainly a number i
O
20 1
less than ten from the total I looked at.
2 Q
We referred earlier to the summary disposition 3
action, have you had occasion to read the affidavits that have 4
been filed in support of that motion?
5 A
I read I think it was by Muffett.
6 Q
Muffett's affidavit?
7 A
Right.
8 Q
Did you read the affidavits of either Mr. Gorski or 9
Mr. Kostal in support of the applicant's motion?
10 A
I don't remember reading those.
11 Q
There was another problem that you noted.
It had to 12 do with an engineered change notice.
I guess you found one
(
)
13 example where the ECN was issued against a superceded revision 14 of the drawing?
15 A
Correct.
16 Q
Are you aware of the circumstances as to how that 17 happened?
18 A
The understanding I had was that Sargent & Lundy's 19 field engineering office and their home engineering office in 20 Chicago were working simultaneously on that drawing.
The home l
21 office revised the base drawing at the same time that the 22 field office was making a change notice against the base
(
l i
1
21 1
drawing and they failed to communicate adequately so that 2
their timing was off.
3 Q
Do you know what corrective action if any that 4
Sargent & Lundy took with respect to this particular 5
observation that you made?
6 A
I understood from reading Mr. Muffett's testimony 7
that they had decided to freeze changes against a drawing when 8
it started revision and until the revision was completed and 9
the drawing issued, no changes would be issued against the 10 drawing.
11 Q
Do you know what they did with respect to a 12 retrospective action?
13 A
We had requested them while we were still on site 14 for the inspection to go back in their system and look to see 15 if they had other examples of this problem.
I think I 16 repor,ted that in the report.
17 (Perusing document.)
18 on page VII-12, section seven, the second paragraph, i
19 it says, " Subsequent investigation by Sargent & Lundy 20 identified the following additional six previously 21 unidentified supports for which ECN's had been issued against 22 superceded revisions of pipe support drawings."
0
22 1
That was at our request that Sargent & Lundy went 2
back and looked to see if they could find other examples.
3 Q
Do you know how many pipe supports were the subject 4
of that re-inspection of which six problems were reported?
5 A
No, I do not.
I think that I remember that they 6
went back over about a year's time which would necessarily 7
cover some hundreds of support drawings but I don't really 8
know.
9 Q
If the CAT inspection had not occurred, to your 10 knowledge was there a procedure or process in place that might 11 have caught this particular problem involving the issuance of 12 ECN's against superceded drawings?
)
13 A
Yes.
Again, I think I have made a statement to that I
14 effect in the report in section VII next to the last paragraph 15 where it says that the discrepancies might have been identified and resolved when the final revision of the support 16 17 drawing incorporated all design changes was issued prior to 18 the final Pullman /Getschow Company walkdowns.
19 Both myself and Mr. Compton who was one of our 20 mechanical inspectors looked at the situation and we felt that 21 there was a substantial probability that such problems would 22 be picked up.
O 1
23 1
Q Let me ask the same question with respect to the 2
annotation problem.
Would that have been subsequently picked 3
up if the CAT inspection had not been conducted?
4 A
It was being constantly picked up.
I just happened 5
to find some of those types of errors at the time I was there i
6 and they had ongoing audits and surveillances both before, 7
during and after I was there picking up the same kind of 8
errors.
9 Q
How would you characterize the significance of your 10 findings and I am talking now both the annotation problem as i
11 well as the ECN problem being issued against superceded 12 revision of a drawing?
4
( )
13 MR. WRIGHT:
Just a clarification.
What do you mean 14 by significance, counsellor?
15 MR. GALLO:
A synonym for significance in the 16 context of my question is important.
17 THE WITNESS:
I can give you a feeling.
I don't 18 have any absolute measures.
I felt that the proper annotating 19 of design changes on the design drawings was not very 20 significant.
There are thousanos of changes being put out 21 against hundreds if not thousands of drawings and the i
22 annotations are being made at a number of stations where they j
4
- O
24 1
have design drawings and I was not surprised to find that 2
there were some errors.
+
3 The problem of making changes to a design drawing 4
while it was being revised at another location, I considered 5
more significant than that but based on the fact that they did 6
have a procedure which should have been able to catch that 7
problem at the end, it was probably not significant.
8 BY MR. GALLO:
(Resuming) 9 Q
This last matter that you have described, is that 10 the issuance of the ECN against the superceded version of the 11 drawing?
12 A
Yes.
( )
13 Q
As I recall, you found one example of that?
14 A
Yes.
15 Q
Then at your request Sargent & Lundy reviewed 16 installation drawings over a certain period of time and found 17 six more examples?
18 A
Yes.
19 Q
Did the number of examples that were disclosed play 20 any role in your judgment as to whether or not this was a 21 significant matter?
22 A
To the extent that six didn't seem like a large i
1 25 1
enough number to show that there was a breakdown of any kind 2
in the system but rather to me it indicated that there were 3
human failures and that the procedures were not sufficient to 4
catch those human failures.
5 Q
Now these opinions that you are offering both the 6
one we have just been talking about and the one I think you 7
characterize as a feeling with respect to the significance of 8
the annotating problem, what is the basis for those opinions?
9 A
Experience.
10 Q
Is that your experience working at the various 11 architect / engineer firms over the last whatever period of time 12 it was, 1968 through 19847
( )
13 A
Yes, that and the two previous inspections that I 14 had been on.
15 Q
How did the results of your inspection at Braidwood 16 compare to the results at Shearon Harris?
17 A
Well, --
18 MR. TREBY:
Objection, relevance.
19 MR. GALLO:
All right.
20 THE WITNESS:
Shearon Harris did not have the same 21 kind of drawing control system so there was not a direct 22 comparison.
They had an overall computer listing that O
26 1
everyone was required to refer to rather than annotating on 2
the drawings.
3 BY MR. GALLO:
(Resuming) 4 Q
How about at River Bend?
5 A
River Bend also had a computer listing system.
6 Q
Is it your understanding that they installed such a 7
computer listing system at Braidwood?
8 A
I don't know.
At the time I was there, Gust Newberg 9
had just gone to such a system or was just in the process of 10 implementing it and I understood that commonwealth Edison was 11 looking at the possibility of changing to that kind of a 12 system.
C-)T 13 Q
To your knowledge is there any regulatory 14 requirement specifying the mechanism that should be used for 15 design control purposes?
16 A
Not to my knowledge.
17 Q
Have you seen the annotation approach used in your 18 work when you worked at Stone and Webster or one of the other 19 AE's?
20 A
Yes, and also at-Palo Verde, they used a modified 21 system of that sort.
22 Q
Which AE did you work for that used the annotation
\\
27 1
system?
We have Gibbs and Hill and Stone and Webster.
2 A
I would say Gibbs and Hill.
3 Q
Thank you.
Do you have the Muffett affidavit with 4
you?
5 A
No.
6 Q
I do someplace.
You say you have read the Muffett 7
8 A
Yes.
9 Q
This is the affidavit of James W. Muffett which was i
10 filed in support of the staff's response to applicant's motion 11 for summary disposition of Rorem QA subcontention 5(a).
12 (Document proffered to witness.)
()13 A
(Perusing document.)
14 Q
You see, there is Mr. Muffett's signature properly 15 notarized and it is entitled, " Affidavit of James Muffett."
16 MR. GALLO:
Counsel, have you had a chance to see 17 this?
18 MR. TREBY:
Yes, I did.
I 19 MR. GALLO:
All right.
Do you want to see this?
20 MR. WRIGHT:
Yes.
21 BY MR. GALLO:
(Resuming) 22 Q
In paragraph eight of the Muffett affidavit,
28 1
Mr. Muffett opines that the comment in the CAT inspection 2
report was motivated by an interest in improving an acceptable 3
process.
For this reason this item did not represent a 4
significant breakdown in the -- strike that.
I think that is 5
Mr. Muffett's opinion at that point.
Let me start again just 6
to limit my question to the first sentence I quoted.
7 Mr. Muffett opines that he believes that the comment 8
in the CAT inspection report was motivated by an interest in 9
improving an acceptable process.
10 Is that what you had in mind when you made the 11 comment, Mr. Hooks?
12 A
certainly as far as it pertained to the problem of
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13 annotating design drawings, yes.
I think that the process 14 that they had was acceptable.
It is a process that I believe 15 you cannot have 100-percent accuracy in and they were trying 16 to get their accuracy as good as possible.
17 With the problem of having made a change to the 18 drawing while that drawing was itself being revised, I think 19 the number of errors of that type that they identified showed 20 that the process needed fixing but not that it was necessarily 21 inadequate.
22 Q
Is my understanding correct that this latter item
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29 1
was not -- that is, the ECN item was not nominated as an item
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\\ss 2
of non-compliance or a potential item of non-compliance?
3 A
Correct.
I considered it a deviation from their 4
procedures but not a violation of regulatory requirements.
5 Q
Do you disagree then with Mr. Euffett's 6
characterization in paragraph eight of his affidavit?
7 A
Improving an acceptable process.
I think that is a 8
reasonable statement.
9 Q
I just want to make sure that in your judgment it is 10 broad enough.
You seem to indicate some concern in the area i
11 of the one example involving the ECN that was issued against 12 the superceded drawing.
Do you think Mr. Muffett should have
()
13 gone further in his characterization of your position?
14 A
When I read his deposition, the way I took it was 15 that he stated that they had instituted a change which in his 16 mind would preclude the problem from occurring any further and
{
17 that he felt that what I saw and I guess I agree with that was 18 a procens that was overall adequate.
It had a minor problem.
19 They took corrective action.
The problem should not reoccur 20 and we knew befors we left the site after the inspection that 21 they did have a procedure in effect that should have been able 22 to catch those kinds of errors before their final walkdown.
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30 1
Q You indicated when you read his deposition, you mean 2
3 A
Affidavit, yes.
4 Q
Did you read his affidavit before it was filed?
5 A
No.
6 Q
When did you read his affidavit?
t 7
A Last week.
i 8
Q In preparation for this deposition?
9 A
Yes.
J 10 Q
Is there anything in his affidavit that you disagree 11 with including the sentence I pointed out to you?
f 12 A
No.
1
( )
13 Q
Do you agree with his conclusions?
14 A
Yes.
15 Q
Were you in attendance at the famous meeting on i
16 March 10?
+
17 A
No.
I was out of town.
18 Q
Did somebody attend who represented the design 19 control interest?
20 A
I don't know.
21 Q
Did you discuss the outcome of that meeting with any 22 of your colleagues like Mr. Heishman?
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31 1
A No.
2 Q
Any of the other inspectors?
3 A
No.
4 Q
Do you know at all if this particular design control 5
matter was discussed at that meeting?
6 A
No.
7 MR. GALLO:
Your witness, Mr. Wright.
I 8
MR. WRIGHT:
May we take a couple of minutes?
l i
9 MR. GALLO:
Sure.
10
[Whereupon, a short recess was taken.)
)
11 i
12
())
13 14 i
15 16 j
17 18 i
j 19 l
20 21 22 i
]
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32 1
EXAMINATION BY COUNSEL ON BEHALF OF THE INTERVENOR l
2 BY MR. WRIGHT:
l 3'
Q Mr. Hooks, my name is Timothy Wright and I am an l
4 attorney with BPI and we represent the intervenors in this 5
proceeding.
I have just a question or two to ask you.
In 6
your paragraph on page A-3 in the last sentence you state that 4
7 in at least one instance this deficiency resulted in a pipe 8
support being installed and inspected in other than the latest 9
approved design.
j 10 A
Yes.
11 Q
How did you find that?
12 A
that is the instance that is reported on page
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13 VII-12.
It was found by the mechanical group when they were 14 doing an inspection of pipe supports.
15 They went out to inspect a pipe support and in that
]
16 inspection, they discovered that the drawings they had been 17 given to do the support with which were supposed to be the 18 latest approved design drawing and all the approved 19 unincorporated changes did not match the support drawing --
20 the support as physically installed.
21 It was because this change had been issued based on 22 an incorrect version of the drawing.
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--n
33 1
Q Did you determine that there were any other 2
instances?
3 A
No.
The CAT team did not find any other instances.
4 When Sargent & Lundy was asked to go back and check and see if 5
they could find any more, they found six additional.
6 Q
In those six additional, there wasn't a case where 7
equipment had been installed or was that the case?
8 A
I would have to rely on what I said in the report.
9 They found six previously unidentified supports for which 10 ECN's had been issued against superceded revisions of pipe j
11 support drawings.
12 To the best of my recollection there were no
( )
13 significant physical problems with any of those six but I 14 really don't remember the details.
15 Q
Did the members of the CAT team go back to perform 16 this type of if you will a retroactive investigation to 17 determine whether or not any other supports had been built to 18 superceded drawings?
19 A
No.
20 MR. WRIGHT:
I don't have any further questions.
21 MR. GALLO:
I have one.
22 MR. TREBY:
I have one question.
Why don't I ask
l 34 1
mine first and then you can ask yours.
f l
2 MR. GALLO:
All right.
3 l
l i
4 5
6 7
8 i
9 10 11 12 14 15 16 17 18 19 20 21 22 i
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l 35 1
EXAMINATION BY COUNSEL ON BEHALF OF THE NRC l
O2 BY MR. TREBY:
3 Q
In the course of your deposition today, you have 4
used the term "ECN" a number of times.
Could you tell us what 5
those initials stand for?
6 A
It is Engineering Change Notice.
7 MR. TREBY:
Thank you.
8
?
i 9
10 f
j t
11 12 O>
14 i
15 16 17 I
18 j
i 19 20 1
21 22 s
1 1
l i
36 1
FURTHER EXAMINATION BY COUNSEL ON BEHALF OF THE APPLICANT 2
BY MR. GALLO:
3 Q
Are you aware that at the time of system turnover i
4 for various installed systems at Braidwood that a comparison l
j 5
is made between the ECN's and the drawing revisions to make
?
i 6
sure they are consistent?
l 7
A Yes.
I am aware that they have such a system.
i 8
Q Was that system a procedural" requirement at the time
}
9 of the CAT inspection?
10 A
I truly don't know.
As I stated in the report we 11 had indications, in fact, I think Bob Compton actually f
12 reviewed their procedure that said that they were required to
{ (
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13 integrate all approved unincorporated design changes into a 14 final version of the drawing so that they had a single drawing l
j 15 with which to do the final walkdowns rather than having to j
16 refer to the drawing and attached change notices.
i f
17 Q
Was this comparison I referred to the process that i
i 18 you had testified to earlier that would have been the 19 mechanism for catching these seven items but for the CAT team k
20 inspection?
L 21 A
Assuming now that we were correct about their i
j 22 procedure which required that they update and incorporate all 1
'O f
I
37 1
outstanding design changes, barring human error they would 2
have picked it up.
3 MR. GALLO:
I have no further questions.
4 MR. WRIGHT:
I have none.
5 MR. TREBY Thank you and we waive signature.
6 MR. GALLO:
Thank you.
The deposition is at an end.
7 (Whereupon, at 12:03 o' clock p.m.,
the signature of 8
the witness having been waived with the consent of counsel, 9
the instant deposition ceased.)
10 I
11 12 C:)
14 15 16 17 18 i
l 19 i
20 21 22 O
l 38 1
CERTIFICATE OF NOTARY PUBLIC 2
3 I, MARILYNN M. NATIONS, the officer before whom the 4
foregoing deposition was taken, do hereby certify that the 5
witness whose testimony appears in the foregoing deposition 6
was duly sworn by me; that the testimony of said witness was 7
taken by me and thereafter reduced to typewriting by me or 8
under my direction; that said deposition is a true record of i
i 9
the testimony given by the witness; that I am neither counsel 10 for, related to, nor employed by any of the parties to the 11 action in which this deposition was taken; and further, that I i
12 am not a relative or employee of any attorney or counsel
[
}
13 employed by the parties hereto, nor financially or otherwise 14 interested in the outcome of the action.
l 15 16
\\
- m_t, p,,
Nn.. -AEtitmn h
17 MARILYNN M. NATIONS 18 Notary Public in and for the 19 Commonwealth of Virginia 4
20 1
21 My Commissicn expires January 15, 1989.
22 1
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L 1
34Q
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m PROFESSIONAL QUALIFICATIONS Kenneth R. Hooks U. S. Nuclear Regulatory Consnission
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I am employed as a Reactor Construction Engineer in the Office of Inspection and Enforcement, Division of Inspection Programs, Reactor Construction Programs Branch, Bethesda, Maryland.
I received a B.A. in Physics from the University of Colorado, and an M.S.
in Nuclear Engineering from the Air Force Institute of Technology, Wright-Patterson Air Force Base, Dayton, Ohio.
I have been assigned to the Reactor Construction P_rograms Branch since April 1984.
I participate in the Construction Appraisal Team inspections, primarily in the area of design change control.
Prior to joining the NRC in April 1984, I worked for three years for Stone &
Webster Engineering t,or) oration.
I held the position of Project Manager, and was assigned to field jobs in support of nuclear power plant construction.
O' From 1977 to 1981, I was employed by Gibbs & Hill, Inc.
I held positions as Project Engineer and Project Manager on various nuclear power plant and fossil power plant projects.
I was a Project Engineer for the New York State Power Authority from 1975 to 1977, assigned to a nuclear power plant project.
From 1970 to 1975, I was employed by Westinghouse Electric Corporation.
I worked as a Senior Engineer and Project Engineer on a number of nuclear power plant projects.
I was employed by Bechtel Corporation from 1968 to 1970 as a Senior Engineer, assigned to a nuclear research reactor project.
From 1962 to 1968, I served in the United States Air Force, as a graduate student in Nuclear Engineering and as a Research Officer / Project Engineer in research and development activities.
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