ML20195B587
| ML20195B587 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 04/08/1986 |
| From: | Dewald I COMMONWEALTH EDISON CO. |
| To: | |
| References | |
| CON-#286-295, CON-#286-346 OL, NUDOCS 8605290428 | |
| Download: ML20195B587 (198) | |
Text
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6 In the matter of: : Docket Nos. 50-456 Ok 7 COMMONWEALTH EDISON COMPANY i : 50-457 db 8 [Braidwood Nuclear Power Station, :
9 Units 1 and 2] :
10 ------------------x' s 11 s Isham, Lincoln & Beale 12 Three First National Plaza
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14 Chicago, Illinois 15 April 8, 1986 16 Deposition of: IRVING FRANK DEWALD 17 called for examination by Counsel for the Intervenors EPI, et la al., pursuant to notice,'taken before Suzanne B. You!Sg a 19 Notary Public in and for the District of Columbia, when 20 -------------------------------
21 ANN RILEY & ASSOCIATES, LTD.
22 1625 I Street, N.W. 293-3950 Washington, D.C.
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'/ 8605290420 860400 PDR T ADOCK 05000456 PDR
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236 1 were present on behalf of the respective parties:
2 3 APPEARANCES:
- 4 For the Licensee Commonwealth Edison Company
5 ELENA KEZELIS 6 ATTORNEY-AT-LAW 7 Isham, Lincoln & Beale 8 Three First National Plaza 9 Chicago, Illinois 60602
. 10 11 For the Intervenors BPI, et al.:
l 12 ROBERT GUILD, ESQ.
13 109 North
Dearborn,
Suite 1300
( }
14 Chicago, Illinois 60602 15 16 For the NRC Staff:
17 GREGORY ALAN BERRY, ESQ.
I
! 18 Office of the Executive Legal Director 19 Nuclear Regulatory Commission 20 Washington, D.C. 20555 21
( 22 0 -
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237 1' .
C0NTENTS y 2 -
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3 Witness: Examination by: Page:
, . 4 IRVING FRANK DEWALD Mr. Guild 243, 383 j 5 Mr. Berry 350 i
6 Ms. Kazelis 370
, ' 7
.t 8 ***
9 EXHIBITS Puge:
.10 Group Exhibit No. 12: 239
- 11 , ' Transmittal of 4/2/86 with attached 12 computer index.
14 Exhibit No. 13: 244 15 A document dated 5/21/84, Bates -
16 No. B212537.
/
17 18 Exhibit No. 14: 245 l
19 A document dated 1/17/86, Bates-l 20 No. C912910.
21 l 22 lO l
238 1 EXHIBITS Page:
(Continued]
2 Exhibit No. 15: 247 3 A memo from Klena to Quaka.
4 5 Exhibit No. 16: 248 6 Document entitled, " Proposed 7 Formalized Plan and Schedule."
8 9 Exhibit No. 17: 249 10 A package of documents with a 11- cover memo dated 1/2/85, DeWald to Mennecke.
12
( 13 Group Exhibit No. 18: 345 14 Two Read and Reply Memos; one dated 15 6/28/85 and the other dated 7/12/85.
16 17 Exhibit No. 19: 372 '
18 A document to L.K. Comstock from 19 Mazur and Quaka of Edison.
20 21 22 l
l-
}
l 239 l
1 PROCEEDINGS !
2 MR. GUILD: This is the resumption of the Deposition 3 of Mr. DeWald. Mr. DeWald, I remind you that you're still l
4 under oath.
5 Before the deposition resumes, I had asked counsel 6 for the Applicant to assist me in identifying documents that 7 had been only recently made available in discovery, a number 8 of which are identified on a computer index as being authored 9 by or addressed to or in some fashion relating to Mr. DeWald 10 who is the present witness and Mr. Seese who is to be deposed 11 after Mr. DeWald today.
12 Counsel has provided me no additional information 13 on the identification of the documents but has told me simply
)
14 to look at the documents themselves. There are several 15 thousand of them.
16 I would ask that the transmittal of April 2nd, 1986, 17 Phillip P. Steptoe, Counsel for Applicant, and the attached 18 computer index document of about three-quarters of an inch in 19 thickness be marked as the next group exhibit for this 20 deposition.
21 (DeWald Deposition Group Exhibit No.
22 12 was marked for identification.]
l 240 l 1 This is my only copy of this index, so I request 2 that the company reproduce a copy of this printout or get me 3 another copy for my file. I would appreciate it. But I would l
l 4 like this to be a record copy.
5 MS. KEZELIS: And I would like to state for the 6 record that the documents and the indices reflecting those 7 documents to which Mr. Guild has been referring have been 8 sitting in this same conference for at least a week and 9 perhaps longer. Mr. Guild has been perfectly free to peruse 10 those documents at his leisure.
I 11 MR. GUILD: That leisure is rather limited, 12 Ms. Kezelis. Perhaps you've had some s'ince the documents were
( ) 13 transmitted, but I have been here every day for depositions.
14 The record should also reflect that I requested of 15 both your colleagues Mr. Steptoe and Mr. Miller some 16 assistance in identifying the nature of these documents and 17 why they weren't produced earlier, and although they've i
18 endeavored to find out why, they've been unable to do so. And 19 you've declined to provide any assistance on that score this 20 morning.
21 MS. KEZELIS: That's only because, Mr. Guild, I have 22 not had an opportunity to examine the index and I can't tell
- o
241 1 you at this point what is contained in it.
2 MR. GUILD: Ma'am, I would have given you the index; 3 it's here for your examination. You simply told me to look at 4 the documents and offered no help. If you'd like to look at 5 the index and be of any assistance, I would certainly 6 appreciate it, ma'am.
7 MS. KEZELIS: No, I'd prefer to proceed with 8 .Mr. DeWald's deposition.
9 MR. GUILD: I'm sure you would, but as I say, the 10 documents bear an obvious relevance to Mr. DeWald's 11 deposition; I'm trying to complete that deposition and in 12 order to do so at this time or at a later time I'm going to
( ; 13 need to understand whether there are any relevant documents 14 that have just recently been produced. We'll do that at a 15 later time if you choose.
16 MS. KEZELIS: Actually, what I'd like to do at this 17 point is respond to the two specific requests you have made in 18 Mr. DeWald's deposition, and I am making those documents 19 available to you. One is a document that you requested 20 addressing or reflecting a backlog of inspections which 21 Mr. DeWald had identified when he arrived at the site in late 22 1983. That is Bates stamp number 015331, and I am making that O
>-a----r.s _ e,.. - % ,-.,- - , , - - . ,- - . - , - g -----r--_., . - - - - -_m,
242 1 -available to you now.
2 And another document which I received this morning 3 dated 1/2/85, together with a multi-page attachment, and this 4 is my only copy, I'll have another made. The cover letter is 5 a memorandum from Mr. DeWald to Mr. Mennecke. Contained 6 within this package is an inspection checklist reflecting 7 1,166 welds inspected in a grid, and the inspector involved is 8 Mr. Richard Yanketis. I believe you had asked for his 9 inspection document.
10 Additional documentation accompanies the specific 11 request that you had made last week.
12 MR. GUILD: Thank you. In the moments before the
[
13 deposition was resumed, I randomly, or at random, pulled three 14 documents from the file that I believe represent the documents 15 that are identified on the April 2nd, 1986 index. They appear 16 to have some relevance to Mr. DeWald's deposition and to the 17 issues in this proceeding.
- 18 19 20 21 22 i'
i i
1
243 1 Whereupon,
[
\ 2 IRVING FRANK DEWALD, 3 called for examination by Counsel for the Intervenors, having 4 been already duly sworn by a Notary Public, was examined and 5 testified further as follows:
6 EXAMINATION 7 BY MR. GUILD:
8 Q Mr. DeWald, let me ask you first if I can, sir, to 9 identify a document that appears to bear your signature. It's 10 a 5/21/84 document, B12537, DeWald to Mennecke,
Subject:
11 W.O. Puckett, Level III welding. And, sir, have you seen that 12 document before?
(~'} 13 [ Witness reviewing document.]
V 14 A Yes, sir.
15 Q Can you tell me what it is, please?
16 A It's a site approval to bring Mr. Puckett onsite.
17 Q Does this document reflect your review of 18 Mr. Puckett's qualifications? The document states, 19 "Mr. Puckett's qualifications qualify him as a Level III 20 through his background and experience."
21 A This is the initial letter when Mr. Puckett came 22 aboard for CECO's approval of a Level III.
244 1 Q Yes, and it reflects your review of his 2 qualifications?
3 A Yes.
4 Q Thank you.
5 MR. GUILD: Would you mark this, please, as the next 6 exhibit?
7 [DeWald Deposition Exhibit No. 13 was 8
marked for identification.)
9 The number on Exhibit 13 actually is B212537. I 10 think I left a "2" out. I'm not sure what that means, but 11 that is the complete Bates number.
12 BY MR. GUILD:
(}
V 13 Q A document bearing the Bates number C912910, January 14 17th, 1986 document, Seltmann to Paserba. Mr. DeWald, can you 15 identify that, sir?
16 [ Witness reviewing document.]
17 A Yes, sir.
18 Q And what is that, please?
19 A That is the yearly evaluations for myself and 20 Mr. Seese that was sent to Mr. Marino to be signed.
21 MR. GUILD: I'd like to mark that, please, as 22 Exhibit No. 14 for identification.
^%
l l
l
~. - __ . - - -. - . . .
245 1 [DeWald Deposition Exhibit No. 14 was i
2 marked for identification.]
3 BY MR. GUILD:
4 Q Have you seen this document before? Not the 5 transmittal but your evaluation of 12/14/85?
6 A -Yes.
j' 7 Q And have you seen the evaluation of Mr. Seese, 8 4/12/857 9 A Yes.
10 Q You prepared the evaluation of Mr. Seese? Is that '
11 correct?
12 A Yes.
( 13 Q And Mr. Seltmann prepared the evaluation of you?
14 A Yes.
15 Q The third document, again from the file, C912943 and 16 following pages; a January 3rd, 1985 memo, Klena to Quaka.
17 Have you seen that, please?
18 [ Witness reviewing document.)
19 A Yes, I was on copy for it.
20 Q Can you tell me that is, please?
21 A From just a quick glance and a review, that was the
- 22. proposed plan to resolve NCR-1996 to Tom Quaka, the Ceco QA l
4 O
246 1 Supervisor.
(O s- / 2 Q And what is the subject of that NCR, Mr. DeWald?
3 A What I gather from the document, it is on the AVO, 4 avoid verbal order.
5 Q Is that a name for a document?
6 A It's a transmittal type of notice that they use. To 7 avoid verbal orders they would write it down and pass it on.
8 Q Is it like a Read and Reply memo?
9 A No. It just gives direction on the memo.
10 Q Is the name AVO, or avoid verbal order, from the 11 title of that form?
12 A Yes, that's the title of the form.
13 And it's just a blank form that is used to transmit
( ) Q 14 instructions?
15 A Right. It has written on top of it, Avoid Verbal 16 Orders, and then several lines underneath it and the signature 17 area.
18 Q Fine. And it was a document that was used at some 19 point in Cometock to pass on instructions?
20 A Yes.
21 MR. GUILD: Would you mark this, please, the Klena 22 to Quaka Memo, as Number 15.
O v
--m, , ,-. - m -
247 l (DeWald Deposition Exhibit No. 15 was 2
marked for identification.]
3 BY MR. GUILD:
4 Q Now, there are two documents that were made 5 available this morning; first, Bates number -- it's not 6 clearly legible. It appears to be 15331, entitled Proposed 7 Formalized Plan and Schedule. Mr. DeWald, can you identify 8 that, please?
9 [ Witness reviewing document.]
10 A Yes, sir.
11 Q Can you tell me what it is?
12 A That is the amount of inspection backlogs that I had
/~' 13 a hand count taken of when I first got onsite.
V) 14 Q And you referred to that in your deposition on 15 Friday?
16 A Yes, sir.
17 Q Was this document prepared by you or under your 18 direction?
19 A It was prepared by me, I believe.
20 Q How about the handwriting that appears on the 21 document?
22 A That is mine, but I don't recall what I had the O
248 1 scribbles on there for.
^3 2 MR. GUILD: Can we mark this, please, as Exhibit 16 3 for identification.
4 [DeWald Deposition Exhibit No. 16 was 5 marked for identification.]
6 BY MR. GUILD:
7 Q A package of documents next with a cover memorandum 8 dated 1/2/85, DeWald to Mennecke,
Subject:
D. Asmussen letter 9 dated 12/14/84. It transmits a number of attached documents 10 including inspection checklists; a 12/14/84 handwritten letter 11 from D. Asmussen to Ken Worthington dated 12/14/84; a Read and 12 Reply memo illegible, it appears to be to Ken Worthington from 13 Dan Asmussen; a Read and Reply memo of 12/18/84 to Irv DeWald 14 from Ken Worthington with a reply from Irv DeWald, and the 15 cover. No Bates numbers.
16 Mr. DeWald, can you identify that document, please?
17 [ Witness reviewing document.]
18 A Yes, sir.
19 Q Can you tell me what it is?
20 A It's a letter to Carl Mennecke addressing 21 D. Asmussen's concerns that he addressed on the 1166 welds.
22 Q And was this a concern that you referred to in your O
249 1 Friday deposition regarding early inspections performed by a l
) 2 Rich Yanketis?
3 A Yes, sir.
4 Q The subject of one of the concerns expressed by 5 Comstock inspectors to the NRC?
6 A That may have been, I'm not sure.
7 Q I think I asked you that question in that context.
8 I was reading from an NRC memorandum reflecting those 9 concerns. Did you understand this had been investigated by 10 the Quality First organization?
11 A I believe it has, yes.
12 Q I think that's what you were saying on Friday; you 13 were aware that it had been looked into by Quality First.
14 A I think it has been, yes.
15 MR. GUILD: Can we mark this, please, as Exhibit 17.
16 [DeWald Deposition Exhibit No. 17 17 was marked for identification.]
18 BY MR. GUILD:
19 Q Mr. DeWald, you testified on Friday that when you 20 came on the job, you attempted to estimate the then current 21 Comstock inspection backlog by doing a hand count of 22 installation documents ready for inspection; correct?
I O
250 1 A ,
Yes, sir. .
)
[/
s_ 2 Q And that's what this proposed formalized plan and 3 schedule reflects, is your count?
4 A Yes, sir.
5 Q Now to the best of your knowledge, are the 6 typewritten numbers a reflection of your count at the time?
7 A Yes, sir. The initial count.
8 Q Well, was there a subsequent count?
9 A Later, I took a subsequent count which removed all 10 the duplication that I may have in the installation reports.
11 Q And is that what is represented -- the exclusion of 12 duplicates -- by the handwritten number next to the 13 typewritten?
())
14 A That may be. I'm not positive at this particular 15 time.
16 Q Well let me ask the question more directly then. Do 17 you know what the backlog as of 8/31/83 was in the various 18 inspection areas?
19 A I think it says there, 14337 or something like that.
20 Q Yes, that is the typewritten number, but do you know 21 -- was that the actual backlog?
22 A That was the first that I had written up.
O
251 )
1 Q Well, after you eliminated duplications, do you know
[sss/ 2 what the actual backlog was?
3 A I don't recall the actual backlog.
4 Q Is there some other document that would reflect the 5 actual backlog?
6 A There probably is but I don't recall it.
7 Q Did you assist in locating this document? The 8 document that was produced today, did you locate this?
9 MS. KEZELIS: For the record, I believe I asked 10 Mr. Larry Seese to pull it for me yesterday for today's 11 deposition.
- 12 BY MR. GUILD:
13 Q The answer is you were not involved?
( }
14 A I didn't get that one, no.
15 Q You have a column that is entitled Time 16 Required / Inspection. Is that your estimate of the amount of 17 time that was required to perform a given number of 18 inspections?
19 A May I see it?
20 [ Witness reviewing document.]
21 That was the estimated hours and the estimated 22 inspections and the total man hours required, as you can read i
\
1 U
s
252 1 across the sheet.
O s-) 2 Q And do I understand correctly then that if I took 3 welding as an example, and that is line 1.A, you show eight 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> /10 inspections. Does that mean that one could perform, 5 in your estimate, 10 inspections in eight hours?
1 6 A That's the estimated number.
7 Q That's what you used for planning and scheduling?
8 A Yes, sir.
9 Q What was the basis for that, planning basis, for 10 time required per inspection?
11 A I reviewed the number of past inspections that had 12 been completed.
13 Q And on the basis of that review, you determined what
(}
14 the average was per unit of time for an eight-hour day?
15 A Yes. I deducted also -- that is less than the 16 average.
17 Q So this is what you thought was an achievable, 18 realistic inspection rate for planning purposes and scheduling 19 purposes?
20 A Yes, sir.
21 Q The bottom handwriting -- that's apparently your 22 handwriting. Is this, at the bottom of the page?
O
253 1 A Yes, that is possible.
2 Q It says " current" and then it has the same list at 3 inspection areas and numbers by them. Can you tell me what 4 those numbers represent?
5- A I'm not positive what those numbers represent at 6 this time.
7 Q Who was this proposed planning schedule submitted 8 to, if anyone?
9 A I believe I submitted it to Mr. Marino.
10 Q Did Mr. Marino approve it, reject it or respond in 11 any way?
12 A I think, to my recollection, he may have asked me,
() 13 14 Do you think you can do this, and I think I said Yes, I think it's possible, 15 Q Looking at the document that's been identified as 16 Exhibit No. 14, Mr. Seltmann's transmittal to Mr. Paserba of
- 17 the 1985 evaluations for you and Mr. Seese, what is your i
18 reporting relationship to Mr. Seltmann, if any?
I 19 A As of December 1985, Mr. Seltmann is now my 20 superior.
21 Q- You still hold the position of QC Manager at 22 Comstock?
l 10 1
I L -
254 ,
1 A Yes, sir.
/2 Q And Mr. Seltmann is still QA Manager?
3 A Yes, sir.
4 Q Did Mr. Seltmann previously supervise the quality' ,
5 control inspection functions at Comstock?
6 A No , sir.
7 Q Does he now?
8 A No, sir. '
9 Q He just supervises you?
l 10 A He is the manager of the whole Quality organization.
11 Q And you are the manager of the quality control part 12 of that organization; correct? .
13 A Yes, sir.
14 Q And you, in the quality control part of that 15 organization, report to Mr. Seltmann?
16 A Yes, sir.
17 Q So doesn't it follow then that Mr. Seltmann 18 supervises the quality control crganization?
19 MS. KEZELIS: Objection, I think you're arguing with i l 20 the witness.
21 BY MR. GUILD:
i 22 Q Would you answer the question, please?
O
255 1 A You could say yes.
2 Q Has there been any kind of new job description 3 written for you reflecting the change in position?
4 A I believe so, yes, sir.
5 Q Have you seen such a document?
6 A Yes, sir. It's in procedure 4.1.2.
7 Q What is that procedure?
8 A. That's the position delineation procedure.
9 Q 4.1.2?
10 A Yes, sir.
11 Q Is there a particular revision that reflects the new 12 job description, that you are aware of?
13 A Yes, sir, but I'm not surra of the revision number.
(V)
14 Q Is it the current revision?
15 A It would be the current, yes, sir.
16 Q And does that current revision also reflect the new 17 job description for Mr. Seltmann?
i 18 A Yes, sir.
19 MR. GUILD: Counsel, do you know whether this i 20 document, the procedure revision reflecting the new job 21 description, has been made available in discovery?
22' MS. KEZELIS: I don't know, offhand. I can obtain I
O
256 1 it for you if it has not, and make it available to you.
N 2 MR. GUILD: Thank you.
3 BY MR. GUILD:
4 Q Mr. DeWald, do you know whether that revision of the 5 procedure is identified in the April 2nd index to the t 6 documents?
7 A I have no idea.
8 MR. GUILD: Counsel, do you know whether it's 9 identified in the April 2nd index of documents?
10 MS. KEZELIS: No. As I have advised you already, I 11 had no involvement in the preparation of that index, 12 Mr. Guild.
13 MR. GUILD:
( I am reviewing the index trying to 14 determine the answer to the question whether the document has 15 been made available and can be found at this ti.me.
16 (Pause.)
17 I don't see any documents identified as a procedure; i
18 either that or any other, in the April 2nd index. I'd l 19 appreciate it if it was made available, please.
20 MS. KEZELIS: Okay, no problem.
21 BY MR. GUILD:
22 Q Can you tell me in substance how your job i
O
257 1 description has changed, Mr. DeWald?
k_ 2 A I am responsible for the QC portion which would be 3 the inspection portion of the -- the QC inspection.
4 Q I'm sorry, I just missed the last word you used. of 5 the manual?
6 A Of the manual.
7 Q That was your position formerly, was it not?
8 A Well, I was to implement the QA/QC Manual before. I 9 have no control over the QA portion of the manual.
10 Q What responsibility did you have for the QA 11 activities in your former position.
12 A In the former position I was actually in line with 13 the QA Manager, and we talked. Now he is my superior.
14 Q Am I understanding correctly that in the former job 15 relationship you were responsible primarily for the quality 16 control inspection activity?
17 A Yes, sir.
18 Q And you supervised, through a number of supervisors, 19 the Level II inspectors who did the line inspection work?
20 A Yes, sir.
21 Q Mr. Seltmann was the QA Manager and he was 22 responsible for the non-QC/ quality assurance activities at the
258 1 site?
- p 2 A Yes, sir.
3 Q Audits and surveillances, for example.
4 A Yes, sir.
5 .Q Did he write procedures?
6 A Yes, sir, he wrote procedures, took care of the QA 7 portion of that manual. My function still is the QC 8 - inspectors, and I believe it is five direct supervisors and ,
, .9- underneath there are seven additional. !
10 Q Seven additional what?
11 A Supervisors.
12 Q In QC?
13 A Yes, sir.
t 14 Q Let me understand this. Who reports -- or who 15 reported to you in your former capacity that doesn't report to i
. 16 you now, if anyone" 17 A No one.
18 Q Okay. So you have the same people reporting to you?
19 A Same people.
20 Q Who reports to Mr. Seltmann now that didn't report 21 to him before?
22 A The QA Department, myself. Or the QC Department, 10
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259 1 excuse me.
2 Q So you have retained the same duties and he has 3 added the QC Department under his responsibility.
4 A Yes, sir.
5 Q Now your evaluation for the period ending -- it 6 appears to be 12/15/85, a portion of Exhibit No. 14 -- was 7 performed by whom?
8 A Mr. Seltmann, I believe.
9 Q Well, if you look at the document it shows 10 " evaluated by" --
11 A Oh, okay. Larry Seese is another Level III, so he 12 initiated the evaluation. Mr. Seltmann approved it and sent 13 it on to Mr. Marino then for final approval.
( }
14 Q I.see. Did Mr. Seese perform the evaluation?
15 A As a Level III performing an evaluation of another 16 Level III.
17 Q Mr. Seese reports to you.
18 A Yes, sir.
19 Q And did at the time of this evaluation?
20 A Yes, sir.
21 Q Both of you are Level III's, though.
22 A Yes, sir.
O
260 1 Q Was Mr. Seltmann a Level III?
7~m km ,- 2 A Yes, sir, he is.
3 Q Was he at the time of the evaluation?
4 A Yes, sir.
S Q Why didn't Mr. Seltmann perform the evaluation if 6 you. reported to him and he was a Level III? If you know.
7 A I really don't know. That's Mr. Seltmann's 8 decision.
9 Q There is a signature line that says General Manager, 10 QA/QC Services. It is not signed on your evaluation and on 11 Mr. Seese's evaluation. Who holds that position?
12 A Mr. Marino.
13 Q Do you know whether Mr. Marino approved these 14 evaluations?
15 A I believe he did.
16 Q Did you have any other performance evaluation for 17 the period ending December 1985?
18 A Not to my knowledge.
19 Q This is the sole evaluation that you're aware of?
l l 20 A Yes, sir.
21 Q The Exhibit No. 13 document, the May 21, 1984 memo 22 from you to Mr. Mennecke and Mr. Quaka regarding Mr. Puckett's O
i
261 1 approval as a Level III, do you know whether or not a copy of 2 this memorandum was provided to Mr. Puckett?
3 A He is not on copy.
4 Q Does that lead you to conclude that he was not 5 provided a copy?
6 A Yes, sir.
7 Q I had asked you on Friday whether or not any job 8 description in writing was provided to Mr. Puckett, and your 9 recollection or answer at the time was that none was. It was 10 oral?
11 A Yes, sir.
12 Q This document, Exhibit 13, described Mr. Puckett's
() 13 14 duties.
document?
As far as you know, it wasn't given to him, this 15 A That's correct.
16 Q The closing line of the document addressed to 17 Mr. Mennecke and Mr. Quaka reads, "Please reply as soon as 18 possible on your review and approval." Did you receive a 19 reply from either of the gentlemen?
20 A I believe I did.
21 Q And did they review and approve your proposal?
22 A There should be a document that was submitted that
262 1 has Mr. Quaka's signature on there, and I believe also O
k,s 2 Mr. Shamblin's signature.
3 Q You recall a document signed by them responding to 4 this memo?
5 A I believe so.
6 Q Did they write a separate memo, or did they sign --
7 A Just signed on that.
8 Q They signed another copy of this memo?
9 A Yes, sir, I think.
10 Q How about Carl Mennecke?
11 A I don't recall whether Carl did anything or not.
12 Q Your recollection is Mr. Shamblin and Mr. Quaka?
13 A Tom Quaka, right.
{ }
14 Q I'm looking at a package of documents that's been 15 identified as Exhibit No. 17, on top of which is your memo to 16 Mr. Mennecke of January 2, 1985, regarding Mr. Asmussen's 17 concerns in a letter of December 14. Do you have a copy of 18 those documents?
7 19 A Yes, sir, right here.
i 20 Q Can you describe the circumstances in which these 21 concerns were brought to your attention?
22 A Mr. Asmussen, in reviewing the documents in the O
-..-.n., , - - - - - . . - . _. . , . - , - - - .,
263 1 Phase 1 of the document review that was going on at the time,
[/
\s- 2 had come across this document -- well, the weld inspection 3 document that indicated there was 1166 welds that had been 4 inspected by Mr. Rich Yanketis. He also noted that there was 5 an additional inspection report attached to it which was in 6 the back, and was, through his own belief, questioning why the 7 PTL reports which are attached to Rich Yanketis' inspection 8 report had not disclosed any rejectable items when the 9 inspection report for Hanger H023 had been rejected by an 10 individual whosc initials are WB, which I believe is William 11 Baxter.
12 Q Where do you see the initials? I am looking at the
[)N 13 last page of the stack of documents and it's a weld inspection 14 checklist for that hanger.
15 A On the side.
16 Q Which side -- oh, where the rubber stamp mark is? ,
17 A Yes, sir.
18 Q Okay. It's a rubber stamp that says Item open, 19 Reference NCR/ICR, and ICR is circled, number 4805, WB ,
20 3/23/84?
21 A Yes, sir.
22 Q And what does that initial and date indicate?
O
264 1 A That is the date that he had done the inspection and 2 initiated the ICR.
3 Q That is the date that he did the inspection that is 4 reflected in the weld inspection checklist?
5 A Yes, sir.
6 Q On which the stamp appears?
7 A Yes, sir.
8 Q Why didn't Mr. WB -- again, the gentleman's name?
9 A William Baxter, I believe.
10 Q Okay. Why didn't the inspector, Mr. Baxter, date 11 and sign the weld inspection checklist?
12 A Because at the time that he performed this
/N 13 inspection, it was the practice to leave the inspection 14 document open until such time as the ICR -- the' deficiency in 15 the ICR was corrected. Once it was corrected, then the 16 document was signed off.
17 Q As acceptable?
18 A Yes, sir.
19 Q So once the work was fixed, you completed an 20 inspection report reflecting the acceptability of the work.
21 A You would complete the inspection report here.
22 Q The checklist?
265 1 A Yes, sir.
2 Q Showing that all the items were acceptable?
3 A Yes, sir.
4 Q So you never completed a checklist showing -- as a 5 final inspection document, showing rejectable conditions?
6 A At that time, yes, sir.
7 Q Did the interim inspection report at that time, the 8 weld inspection checklist of the sort shown by Mr. Banks, 9 attachment to Exhibit 17, did that become a controlled 10 document, part of the file package for the component?
11 A Are you talking about this checklist?
12 Q Yes.
13 A Yes, sir.
)
14 Q All right. So after the work was finally accepted, 15 there will be another weld inspection checklist completed 16 showing " accept"?
17 A Not at this time. They would indicate the items 18 that was rejectable were then acceptable on this same is checklist, sign it off, Level II it, and then send it to the 20 vault.
21 Q So they would line through the rejectable findings?
22 A No. At the time it was like a figure eight on its O
I 266 1 side, and they would indicate that in the acceptable blocks, i
- 2 .and there would be another stamp with that same indication I
3 stamped on here and they would circle the ICR, put the ICR 4 number, initial and date it and sign off the checklist.
5 Q So the initial rejectable condition would be 6 indicated on the control document?
, 7 A Yes, sir.
! 8 Q So Mr. Banks, or W.B., found rejectable conditions
!. 9 during the course of what, reinspection?
10 A This was caused by a QCUS report, which was a unit 11 concept type inspection. It went over various areas in the 12 plant and followed construction, and if they found ocus 4990
, 13 deficiencies, they . reported them on this 1NMP report. This
+~
Q6usJN40 14 inspection was a result of a-ec& report, as I stated here in 15 the memo.
ccuse9P0
- 16 Q Okay. 90s stands for what?
17 A It's a quality control unit concept, or unit I
18 surveillance. Excuse me.
l 19 Q Help me understand. As part of the unit concept 20 inspection, the work involved in hanger 023 happened to be
, 21 reinspected.
22 A Yes, sir.
O l-
4 267 1 Q And Mr. Banks, inspector WB, was a Comstock i
s/ 2 inspector at the time?
3 A Yes, sir.
4 Q And he was performing part of the unit concept 5 inspection?
6 A He was performing an inspection that was a result of 7 the unit concept inspection.
8 Q I see. Do you know what the finding was by the unit 9 concept inspection that prompted Mr. Banks' work?
10 A Off-hand, I don't know.
11 Q How did you identify this inspection checklist and 12 -
its findings as associated with the unit concept inspection?
( }
13 A The unit concept listed the number of the hanger in 14 that inspection.
15 Q Okay. Mr. Asmussen sent you his memo and it 16 included this weld inspection checklist by Mr. Banks.
17 A Yes, sir.
18 Q All right. Now, what led you to conclude that the 19 Banks inspection was prompted by the unit cenc9pt --
20 MS. KEZELIS: Just for the record, I think his name 21 is Baxter, and you have been saying Banks.
22 MR. GUILD: I'm sorry. Baxter.
O
- ---2 w ~ ~ ?
268 1 THE WITNESS: It is stated in the remarks section s_/ 2 here, I believe.
3 MR. GUILD: Okay. Mr. Baxter. Excuse me.
4 THE WITNESS: The very last portion.
5 BY MR. GUILD:
6 Q Okay. What, in particular?
7 A It's at the end of the statement.
8 Q Can you read it for the record?
9 A It says HR not available at the time of inspection, 10 QCUS 27E03.
11 Q And it's initialed "WB" 3/23/84?
12 A Yes, sir.
Q Now, what is an HIR, or HR?
} - 13 14 A Hanger installation report.
15 Q And what is QCUS? What does that stand for?
16 A Quality Control Unit Surveillance.
17 Q And what is 27E03?
18 A The 27 is the number of the surveillance. E03 is 19 the item number of one of the pages to that report.
20 Q And that is the notation that indicates to you that 21 this inspection was prompted by a unit concept inspection?
22 A Yes, sir.
O
269 1 Q So Mr. Asmussen was doing a document review under 2 phase one, and he identified the initial inspection report 3 that shown the 1166 welds done by Mr. Yanketis; correct?
4 A Correct.
5 Q And the attached PTL overview inspection checklists
- 6 or documents.
7 A Right.
8 Q Showing acceptable conditions for those welds.
9 A Yes.
11 0 Q And that in addition at the same time identified the 11 Baxter March 23, 1984 inspection findings showing rejectable 12 conditions.
[
13 A He gave this all to me in a package.
14 Q And he gave it to you in a package that included his 15 handwritten letter?
f 16 A Yes, sir.-
17 Q Now, who is Mr. Asmussen?
i 18 A He is a Level II inspector.
19 Q Is he still on site?
20 A Yes, sir.
21 Q Is he a weld inspector?
22 A Yes, sir.
270 1 Q And is he still performing weld inspections?
- 2 A Yes, sir.
3 Q All right. So what did you do when you got the 4 letter from Mr. Asmussen?
5 A One of my first directions was given to 6 Mr. Worthington to inform Mr. Asmussen if he felt there was 7 any question concerning the documentation as to the validity 8 of the inspection, to reinspect the subject item or items to 9 ensure a good, valid inspection.
10 Q And you gave that direction to Mr. Worthington, and 11 Mr. Worthington was -- well, what job did Mr. Worthington 12 have?
N 13 A He was Mr. Asmussen's supervisor at the time.
14 Q Okay. So Mr. Asmussen's letter is written to 15 Mr. Worthington.
16 A Yes.
17 Q How did it come to your attention?
18 A Mr. Worthington gave it to me.
f 19 Q Okay. You were passing back down through the chain 20 of command to Mr. Asmussen through Mr. Worthington, then.
21 A Yes, sir.
22 Q And were your instructions documented?
i o
271
> 1 A I believe it was on the read and reply from Ken O
(- / 2 Worthington, 3 Q Okay. I've got a read and reply 12/18/84 to you from 4 Mr. Worthington, and that transmits Mr. Asmussen's concerns?
5 A Yes, sir.
6 Q And in your answer to the last question, you 7 paraphrased a portion of what you wrote back to 8 Mr. Worthington in the read and reply memo.
9 A Yes, sir.
10 Q Mr. Worthington in his portion of the read and reply 11 memo to you states in part, "I explained" -- speaking now of 12 talking to Mr. Asmussen - "I explained that the inspector
( }
13 reinspection program, BCAP and the cable pan walkdown are all 14 planned for the Braidwood site. Each of these programs will 15 check the validity of all inspections performed on this site,"
16 et cetera.
17 Do you agree with those statements?
18 A The "all" part I don't agree with. The inspector 19 reinspection program took a portion thereof. It was a sample.
20 Q All right. And how about as to BCAP?
21 A The BCAP looked at a sample of everything.
22 Q Okay. It was a sample as well?
272 1 A Yes, sir, a large sample.
x_/ 2 Q All right. And the cable pan walkdown?
3 A That covered all the cable pan.
4 Q All right. And did it perform reinspections of all 5 welds?
6 A If the documentation and so forth was not legible or 7 there may be some question to it, it was reinspected.
8 Q All right. But otherwise, did the cable pan 9 walkdown perform a complete weld reinspection?
10 A Not a complete weld reinspection, no.
11 Q Has the cable pan walkdown been performed?
12 A Yes, sir.
, 13 Q Is it done?
14 A Yes, sir.
15 Q Are its results documented?
16 A Yes, sir.
17 Q In what form?
18 A There is a cable pan walkdown IBM readout.
- 19 -
And what does the IBM readout reflect?
20 .i All the attachments of the cable pan to the 21 applicable hangers.
I 1 Q It lists them?
b o
273 4
1 A Yes, sir.
.2 Q And does it reflect a reinspection of those 3 attachments?
- 4 A It will reflect the current inspection of the 5 attachment of the pan to the hanger.
l 6 Q Meaning what, a date when it was inspected?
7 A Yes, sir.
8 Q And whether it was acceptable?
9 A Yes, sir.
10 Q And does it reflect any deficiencies that were 11 identified?
12 A There may be ICRs and NCRs reflected in the report.
13 Q The ICRs and the NCRs themselves would identify
( }
, 14 deficiencies?
15 A Yes, sir.
4
-16 Q I'm sorry. Identify the documents? IBM --
17 A It's the IBM cable pan printout.
, 18 Q P,roduced on an IBM machine?
19 A Yes, sir, j 20 Q Do you know how many ICRs and NCRs were initiated as
. 21 a resulv. c. those deficiencies? :
l 22- A No, sir.
d
274 1 Q Do you have any estimate?
2 A No, sir.
3 Q Are there any?
4 A Yes, sir.
5 Q Did any of those require rework?
6 A I would say yes, some of them probably did.
7 Q Reinspection?
8 A Yes.
9 Q Now, the next page of this stack of documents is a 10 read and reply memo to Mr. Worthington. Is that from 11 Mr. Asmussen?
12 A It appears to be.
13 Q My copy is illegible.
( }
14 A It appears to be.
15 Q "Please acknowledge receipt" -- can you read the 16 rest?
l 17 A No, sir.
18 Q "and respond" --
19 A Something.
20 Q And it appears to be dated 12/14/84? ,
- 21 A It would appear so.
22 Q Does this read and reply transmit Mr. Asmussen's O
i 275 i 1 handwritten concerns to Mr. Worthington?
2 A I believe so.
3 Q The reply appears to read, "I acknowledge receipt.
4 As we discussed Friday, I feel that programs that are in place 5 at present will either confirm or eliminate your concerns with 6 older inspections. I will keep you informed of the action."
.7 Does that appear to be a reading of 8 Mr. Worthington's reply?
9 A Yes.
10 Q Mr. Asmussen in his 12/14/84 handwritten memo on 11 page 1 states in part, "We have come across many final 12 inspection documents that we believe are unacceptable as 13 quality control inspection records. Attached to this letter
}
, 14 is an example." Mr. Asmussen provides the package of i 15 documents with respect to the 1166 welds in Hanger H023 merely
- 16 as an example of the deficiencies tnat he believet axist in i
17 the older inspection documents; correct?
18 A Yes.
19 Q Did you reach any conclusion about the validity of i
20 Mr. Asmussen's general concern, and that is with respect to I~
21 the adequacy generally of the older inspection documents as t
! 22 quality control inspection reports?
f,
- O i
s'-
1
l 276 ,
Through the older document reports, as today, we i 1 A 2 still have a PTL overview as demonstrated back on this page, 3 and PTL did overview ten percent of those, and I feel that was 4 adequate.
5 Q PTL overviewed ten percent of the original weld l
6 inspections that were performed; correct?
7 A Yes, sir.
1 8 Q And in this case, PTL overviewed the inspections
! 9 that were performed by Mr. Yanketis, the 1166 inspections of 10 drawing number 3051H; correct?
11 A Yes, sir.
12 Q And did they identify any rejectable welds or weld
( }
13 conditions in their overview inspection?
! 14 A I don't believe they did. I would have to look.
15 (Witness reviewing document.)
16 No, sir, there are no rejectable items.
17 Q Okay. But Mr. Baxter coincidentally as a result of 18 the unit concept inspection identified the rejectable 19 conditions on Hanger 023 that he documents in his March 23, 20 1984 checklist; correct?
21 A Yes, sir.
22 Q Does that identification of weld deficiencies l
i
277 1 evidence, in your opinion, Mr. DeWald, the ineffectiveness of 2 the old inspection practices?
3 A No.
4 Q Why not?
5 A I feel that the quality is still there, the quality
'6 wao always there, and that the inspectors were efficient at 7 that time.
8 Q Do you question Mr. Baxter's inspection results?
9 A No. Criteria changed over time.
' 10 Q Okay. And the criteria to which the welds that are 11 identified as rejectable by Mr. Baxter on March 23, 1984 were 12 inspected?
13 A Between 1979 and 1984.
( )
14 Q The weld inspection criteria changed?
15 A Yes.
16 Q And in what respect did they change that would 17 account, in your opinion, if any, for the rejectable findings 18 by Mr. Baxter in March of 19847 19 A The undercut requirement had changed, and I didn't 20 personally go out and look at this particular weld to see 21 whether or not Mr. Baxter's inspection quality was there or 22 not.
4 i
Lo 4
4
- r--e-r ---% -~y- e..-eu. . - -%--r ~-e +--=.we-,- ,-,..mwe,-----.. , -- -- e.,,-,%- -- , . - . , - - - -w,. --v-----w-e. , - - - , - - .- ---
278 1 Q Is Mr. Baxter a competent Level II inspector?
(_/ 2 A He appeared to be.
3 Q Had he ever been evaluated as performing less than 4 adequate inspection work, Mr. Baxter?
5 A I didn't have any evaluations of such.
6 Q In what respect did the undercut requirement change?
7 A At the time, we inspected to a thirty-secondth. PTL 8 was going through one/one hundred thousandths.
9 Q Help me understand what that means now. One 10 thirty-second.
11 A Versus one/one hundred thousandths.
12 Q One thirty-second of an inch --
13 A Yes, sir.
( }
14 Q -- undercut was the standard that who inspected to?
15 A We, Comstock.
16 Q Since '79?
17 A In '79 it was in effect. I don't recall when the 18 exact change came about and PTL's procedures were then aligned 19 with our-procedures.
20 Q But the best you recall, one thirty-second of an 21 inch undercut standard has been the standard employed for weld 22 inspections by comstock since the beginning?
O
i l
279 '
1 A Yes, sir. I believe it was when VWAC was brought in, l 2 which is visual weld acceptance criteria.
1 3 Q Okay. And what change did that make in the standard 4 with respect to undercut?
5 A. That explicitly spelled out all the rejectable items 6 to give the figures to the nearest eighth of an inch or 7 sixteenth of an inch, et cetera, or something like this, of 8 what is acceptable and rejectable.
9 Q And how did that change the undercut requirement, if 10 at all?
11 A It gave various lengths you could have. I'm not 12 sure just how it reads right now. I'm not that up to date on
/ 13 that particular criteria. But I believe it goes to a
)
14 thirty-second with three-sixteenths of an inch that you can 15 have undercut in.
16 Q A range?
17 A The length of three-sixteenths, depth of a 18 thirty-second.
19 Q I see. And previously there was simply a one 20 thirty-second undercut standard?
21 A Yes.
22 Q Does that represent a relaxation of the acceptance O
280 1 criteria?
/ ')
(_,/ 2 A No, it better spells out the criteria to more 3 explicit explanations.
4 Q And when did the visual weld acceptance criteria 5 become effective, approximately?
6 A I think it was the earlier part of this year.
7 Q The earlier part of '867 -
8 A I believe it was the earlier part of this year or 9 the later part of last year.
10 Q Late '85 or late '86?
11 A In that neighborhood, I believe.
12 Q Now, what I'm asking about is Mr. Baxter's 13 inspection results in March of '84. What if anything had 14 changed with respect to the inspection criteria that he found 15 established rejectable conditions for the particular 16 installation that he looked at?
17 A I don't believe the criteria -- I probably answered 18 it wrong. I don't believe the criteria had changed. The 19 inspection checklist spells out the criteria, and I think it's 20 fairly well the same as the criteria that was on the checklist 21 that Richard Yanketis had done.
22 Q Okay. So as far as you know, the criteria f
YJ
281 1 themselves hadn't changed between the time Mr. Yanketis
, l' 2 inspected and the time Mr. Baxter inspected.
3 A As far as I know.
4 Q And how about the PTL standard. You said there was 5 a change in the PTL standard?
6 A The PTL standard at one point in time was not in 7 line with the way Comstock was inspecting in that they would suspect &
8 expeet to one/one hundred thousandths on various areas of the 9 hanger, which is transverse to the load.
10 Q Okay. Did they have more stringent or less 11 stringent inspection criteria?
12 A I believe at the time their criteria was more
()
\~/
13 stringent than what we was required to inspect by according to 14 the contractual specifications of L2790.
15 Q That's the Sargent & Lundy specification?
16 A Yes, sir.
17 Q And ultimately the PTL standards were brought in 18 line with Comstock's?
19 A Yes, sir.
20 Q So at the time of Mr. Yanketis' work and the PTL 21 overview of his work, your testimony is that the PTL 22 inspection criteria were more stringent than Comstock's?
/
L) i
282 1 A I feel.it was,-yes, sir.
2 Q But they didn't find any rejectable conditions?
3 A At the time, I wasn't there.
4 Q I mean on the hanger inspections that they 5 overviewed as part of reviewing the 1166 welds on 6 Mr. Yanketis' '79 inspection report, the documents before us 7 appear to reflect they found no rejectable conditions.
8 A Yes.
9 Q Was there any other action taken that you are aware 10 of on Mr. Asmussen's concerns aside from what is reflected in 11 the documents that are Exhibit 17?
12 A I'm not sure, but I think Quality First looked into
()_13 the situation. Again, I'm not totally positive of that.
14 I felt the inspection report itself was adequate.
-15 Q The documentation itself.
~ 16 A Yes, sir.
17 Q And you didn't reinspect the welds yourself?
18 A No, sir.
19 Q Now I am looking at -- after Mr. Yanketis' 20 inspection checklist, the '79 document, two pages of Comstock 21 memo forms. The first is entitled, " Phase Two, Reinspection, 22 Verification of Walder Stamps." It has a signature by a O
283 1 Mr. Miller, 4/11/84. What does this represent?
f k-m 2 A I believe what they was doing was doing that to find 3 out whether or not the welders had stamped those particular 4 welds.
5 Q Was that part of the requirements for the Phase Two 6 reinspection?
7 A That was part of the requirement of the procedure 8
4.3.6.hk 493- at that time.
O Q When you say that time, you mean in April of '84?
10 A Yes, sir.
11 Q Is it still part of the procedure?
12 A Yes, sir, although if they do not stamp the welds,
['\ 13 it is not a rejectable item anymore.
(
14 Q The procedure has been changed?
15 A Yes, sir.
16 Q When was that done?
17 A I don't know the exact date.
18 Q So Mr. Miller was looking in the field as part of 19 Phase Two for weld stamps, and he indicates there are a number 20 of cases where there are no stamps; correct?
21 A Yes, sir.
22 Q And those were rejectable conditions at that time.
I
~284 1 A Yes, sir.
2 Q Then there are the PTL overview lists, and then-3 there is Mr. Baxter's March '84 inspection checklist,.and was 4 Mr. Baxter's checklist completed as part of the Phase Two 5 document review?
6 A No. I said it was completed for the QCUS 27.
7 Q I see. What I am not clear about is.in April of 8 '84, Mr. Miller did a Phase Two review for welder stamps.
9 A Yes.
10 Q There was no Phase Two weld reinspection done.
11 A Right.
12 Q And there just happened to be a March '84 weld 13 inspection because of the unit concept result?
14 A , Yes, sir.
15 Q I see. Why was the Phase Two reinspection looking 16 for welder stamps but not for weld quality?
17 A It was a requirement at that time that the welder 18 stamp their welds, and there was no indication of any welders' 19 I.D.s on either of the documentation that Rich Yanketis had 20 initiated.
21 Q I see. So the absence of a welder I.D. number on 22 Mr. Yanketis' documentation is what prompted the inspector to O
285 1 go to the field to_look for welder stamps.
.2 A Yes, sir.
3 Q But nothing about the Yanketis documentation 4 prompted a reinspection of the welds?
5 A No, sir.
6 Q Well, did your memo in response to Mr. Asmussen's 7 concerns prompt a reinspection of the welds?
8 A No,' sir, not to the best of my knowledge.
9 Q Well, the substance of your comments back to 1
[ .
10 -)Cc. Worthington is that if when a questionable
! 11 document / component is reviewed -- and this is your read and j 12 reply letter of 12/31/84 -- and the validity of the total 13 inspection is questionable, the item / component is to be j 14 reinspected to ensure good, valid inspection has been 15 performed and documented.
16 Now, you sent that back to Mr. Worthington, and 1
17 Mr. Asmussen raised a question about the validity of the 18 inspection document. How come no reinspection of the welds i
j 19 was performed?
I 20 A It was up to the Level II's interpretation at the 21 time whether or not there needed to be a reinspection. He is 22 the one that was doing the review.
O
286 1 Q Well, do you know whether or not your read and reply 2 memo back to Mr. Worthington was transmitted to Mr. Asmussen?
3 A I didn't follow up and walk up and ask him: Did you 4 go tell Mr. Asmussen?
5 Q Did you obtain any additional information to 6 determine whether or not, as a result of your response back to 7 Mr. Worthington, there was a reinspection of the welds in 8 question?
9 A No.
10 Q Do you know whether or not the Yanketis inspection 11 report with the 1166 welds was ever brought to the attention 12 of the NRC7
() 13' 14 A
Q It may have been.
Did you ever talk to the NEC about the Yanketis 15 inspection?
16 A I have talked to them several times about various 17 items. .I don't recall particularly about that particular 18 instance. ,
19 Q Are you aware otherwise of the NRC looking into the 20 question of the Yanketis inspection?
21 A I think they did. I'm not positive, but I think 22 they did.
O
287 1 Q Do you know whether there have been identified any (n_,) 2 other Comstock or Ernst weld inspection documents that 3 document the performance of more than 1000 welds on a single 4 document?
5 A In this manner here?
6 Q Well, in any manner.
7 A There may have been some.
8 Q Have you identified any others besides 9 Mr. Yanketis'?
10 A This is the only one that has really been brought 11 directly to my attention.
12 Q Have you heard of others?
('}
v 13 A Not off-hand.
14 Q I'm looking at the April 5, 1985 memorandum from th 15 NRC files that is entitled -- it is addressed to Norelius from 16 Weil, subject: allegations re: L.K. Comstock quality assuranc; 17 program at Braidwood. This is the subject of discussion we 18 had on Friday in your last sessicn of deposition. These are 19 summaries by the NRC of concerns expressed by Comstock 20 inspectors March 29, 1985.
21 We had gotten partway through them, and I was asking 22 you about, on page 3 of that document, there towards the r
, v i
288 1 bottom of the page, again by a name that has been blanked out
/
Iq,}/ 2 is a concern that reads as follows: "Saklak berates 3 inspectors."
4 Is that accurate, that Mr. Saklak berated 5 inspectors?
6 A I think it would depend on the individual that he 7 was talking to.
O Q Some people he berated and some people he didn't?
9 A It may be his mannerisms and so forth or his figure 10 of speech. It depended on the individual, I would say.
11 Q In the eye of the beholder, so to speak. It might 12 have been understood as berating by some people who heard
("] 13 Mr. Saklak?
%.J 14 A Very possible.
15 Q The same concern, same individual: "Many inspectors 16 have been discriminated against at one time or another by Irv 17 DeWald, comstock QA manager. DeWald's attitude is 'How can I 18 hang you, not how can I help you.'" You obviously were not 19 then and are not now the QA manager.
20 A Right.
21 Q But aside from that, first, are you aware of 22 concerns expressed by inspectors that you have discriminated O
289 1 against them at various times?
2 A I guess there by the conten* ion.
3 Q Well, aside from the contention and aside from the 4 memo I'm reading to you now, had inspectors brought those 5 concerns to your attention or had they come to your attention 6 otherwise?
7 A No, sir.
8
[ Discussion off.the record.]
9 Q Before the recess, I was asking you questions from 10 the April 5th memo, the NRC's memo documenting Comstock 11 concerns. I think you stated that you were unaware of any 12 concern by inspectors that you had discriminated against many 13 inspectors at one time or another. Is that true?
14 A Would you rephrase that again?
15 Q Sure. The statement is that many inspectors have 16 been discriminated against at one time or another by Irv 17 DeWald.
18 A I am aware of that statement.
19 Q The question is is it a true statement?
20 A No, it's not true.
21 Q DeWald's attitude is "How can I hang you, not how 22 can I help you?" Are you aware of inspectors expressing
290 1 concerns to that effect?
2 A I'm aware of that particular statement.
3 Q Are you aware prior to the statement documented by 4 the NRC of concerns to that effect, that that's your attitude?
5 A Not until that came out.
6 Q And is that a true statement of your attitude?
7 A No, it's not.
8 Q Do you know of any basis for inspectors having a 9 concern about your attitude to that effect?
10 A No basis.
11 Q Another unnamed inspector states, " Constantly 12 intimidated by Saklak. Saklak lied to get" -- unnamed person
/% 13- -
" fired." Are you aware of any circumstances in which U
14 Mr. Saklak lied to get someone fired?
15 A Not lied.
4 16 Q How about overstated the facts?
17 A He may have overstated the facts, but I don't 18 believe I have fired anybody just on Mr. Saklak's say-so.
19 Q Well, are you aware of Mr. Saklak trying to get 20 anyone fired?
21 A Yes, he did a few times, asked me: I want this guy 22 fired. I didn't go on his pretense. I looked into it myself.
,- -------wr-. e --~ -
291 1 Q And what instances, what individuals were involved?
i 2 A I think Kermit Williams was one.
1 3 Q Was Mr. Williams fired?
4 A No, he wasn't, not at that particular time.
5 Q But he was later fired?
- 6. A Yes, sir.
7 Q For what cause?
l 8 A Sleeping.
9 Q On the job?
10 A Yes, sir.
11 Q Any other instances where Mr. Saklak tried to get 12 someone fired? i 13 A I believe Rich Martins, which he is still there.
( }
14 Q Mr. Martin is an inspector?
15 A Yes, sir.
16 Q What were the circumstances of Mr. Saklak trying to 17 get Mr. Martin fired?
18 A I don't recall the exact circumstances.
19 Q What was the reason he wanted to get him fired?
20 A I believe it was something to do with his attitude 21 or his documentation, something to that effect. I'm not
, 22 positive just what.
i-O
292 1 Q What was the nature of Mr. Saklak's complaint about ,
f~ \
(, 2 Martin's attitude? '
3 A I really don't recall. I think that was the reason.
4 Q What did you do as a result of Mr. Saklak's 5 complaint?
6 A- I based his complaint, I also viewed as to what the 7 individual was doing, and I'm now using my own judgment.
8 Q Do you mean Mr. Martin?
9 A Yes.
10 Q You looked into the matter yourself, is that what "
11 you are saying?
12 A Yes, sir.
13 Q And what were your conclusions?
('J'}
14 A He didn't need to be fired. He didn't need to be 15 fired. He is still there.
16 Q Did you reach the conclusion that Mr. Saklak's 17 opinions about Mr. Martin were unfounded?
18 A I don't recall exactly whether his opinions were 19 unfounded or not. It was my judgment that I felt he did not 20 require disciplinary action as to firing the man.
21 Q Did you take any disciplinary action against 22 Mr. Martin of any sort?
293 1 A I don't believe I did.
2 Q The statement here says that for several months the 3 unnamed person was the only welding. inspector and everything 4 was done on a hurry-up basis. Are you aware of anyone who 5 fits that description, the only welding inspector for several 6 months?
7 A I have heard the statement but I don't know where or 8 how or what it pertains to.
9 Q Well, was there any circumstances at Comstock in 10 which there was only one person performing weld inspections?
e 11 A I don't recall exactly only one person performing 12 weld inspections. In the early days, according to the number 13 of people that were here, I think there were three weld b(N 14 inspection people there then.
15 Q And who were they?
16 A This is back in 1980, I believe. At the time it was 17 Mike Cast, I believe Davy Thomas, and I believe Rich Yanketis 18 was there then.
19 Q Was there any time when Mr. Martin was the only 20 person performing weld inspections?
21 A Not since Mr. Martins has been employed, no.
22 Q Mr. Martin has been a weld inspector and he has been O
4 -- .y-- -,-r- ------.,-.-r -p m -e.-.y.-. s-+u--.w -- ,w-yy-- c- ---g - - -y
i 294 1 here for a long time, right?
) 2' A Yes, sir.
3 Q And I believe you stated earlier that you trained 4 Mr. Martin in weld inspection.
5 A Yes, sir.
6 Q What was the fewest number of other weld inspectors 7- aside from Mr. Martin at any point in time?
8 A To the best of my recollection, I would probably say
! 9 a half-dozen or eight, somewhere in that neighborhood.
k 10 Q There has always been more than one inspector i
11 besides Mr. Martin doing weld inspections?
4 12 A Yes, sir.
13 Q The statement continues, "Comstock has consistently 14 been undermanned and has one crisis after another." Is that 4
15 accurate?
16 A We have been undermanned, yes, sir.
17 Q Have you had a lot of crises one after.another?
, 18 A There have been rework programs, there have been 19 doc review programs, AVO program, things of this nature. I 20 guess that is what they consider in crises.
] 21 Q I mean are there crises as you use the term?
22 A No.
.i
- O 4
h i
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295 1 Q The unnamed person here is constantly being watched 2 by his supervision. As an example, he recently visited the 3 NRC office. The following day he was transferred without 4 reason from field inspections to a job in the records vault.
5 Do you know of anyone who was transferred to the records vault 6 under circumstances where he had previously talked to the NRC?
7 A Not to my knowledge.
8 Q Do you know anybody who was transferred to the 9 records vault shortly prior to April of 19857 10 A Rich Martins is the only one I can think of that we 11 put in the vault to do a review of the documents versus the CO 12 and HO drawings so that we could status it.
13 Q What is a CO and an HO drawing?
)
14 A Those are the drawings that list the hanger numbers 15 and types that go on to each applicable drawings.
16 Q What do the initials "CO" and "HO" stand for. Do 17 you know?
18 A CO is conduit hangers. HO is for cable pan hangers.
19 Q And who put Mr. Martin in the records vault to do 20 that work? Who assigned him?
21 A I did.
i i 22 Q And for what reason did you assign Mr. Martin to the i
l O
L
296 ,
i 1 records vault?
2 A It was a job that had to be done.
4 3 Q Why did you pick Mr. Martin?
4 A He wasn't certified in inspections at the time.
5 Q Were you aware that Mr. Martin had spoken to the 6 NRC?
7 A - No, sir.
8 Q Did any other supervisor at Comstock participate in 1
I 9 assigning Mr. Martin to that job?
10 A Probably Mr. Seese.
11 Q What was Mr. Seese's role in that assignment?
12 A He was more or less over the vault at the time, in 13 charge of it.
14- Q Did Mr. Seese propose that Mr. Martin be assigned to 15 the vault for this purpose?
16 A I don't recall whether he did or not. Mr. Martins 17 was assigned there. Like I said, he was not certified to do 18 any particular inspections, I believe, at that time.
19 Q Why not?
i 20 A Because his inspections were removed, or his 21 certification was removed, I think it was October 5th, I
- j. 22 believe, because he had been brought up on a CECO general
- O d
i
,e--- -e---e,vw-. , , , , -,.n--v--- e -me----------.w. -.m--w.-,mw,-.-~-.we-, - , - - - - - - +--wn---e- ,-e-,---, -- ---e--, - -. ,-m - - , . , - - -
297
- j. 1 office audit that was held October 25th, I believe, until ,
. 2 october 5th, somewhere it that neighborhood.
4 1
3 'Q September 25th to October 5th?
. 4 A I believe so, 1983.
5 Q '83 or '847 6 A '83.
! 7 Q How did the CECO audit affect Mr. Martin's 8 certifications?
4 9 A Mr. Martins had photocopied various or I should say
, 10 numerous inspection checklists. He photocopied the checklist 11 attributes, the accept-reject items.
12 Q okay. He photocopied a blank checklist?
l 13 A He photocopied the " accept" blocks on a checklist.
14 Well, he photocopied a lot of these. Then he filled in the 15 other information at the top of the Form 19 and signed his i
j 16 name at the bottom of the Form 19.
17 Q So instead of checking the " accept" box manually, he 18 used a preprinted or precopied box that was checked?
1 19 A He photocopied this.
1
- 20 Q He photocopied a form that had nothing but the
i 21 " accept" boxes checked on them.
- 22 A Yes.
i -
1 lO
298 1 Q And that was contrary to procedure?
2 A Yes, sir.
3 Q And his certifications were pulled as a result of 4 that?
! 5 A Yes, sir.
6 Q Did he get recertified?
7 A Eventually I felt he was recertified, but CECO did 8 not feel he was recertified in the welding area.
l 9 Q So what happened?
10 A He has since then been certified in other areas, in 11 cable pulling, in which he does inspections in.
12 Q And Edison was of the opinion that he should not be
("') 13 recertified in welding?
V 14 A Yes, sir.
15 Q Why was that?
16 A It's their opinion.
17 Q Well, why welding, not all other areas?
18 A I could not get it approved.
19 Q You tried to get welding approved through CECO?
20 A Yes.
21 Q Did they approve the other certifications?
22 A The cable pulling and concrete expansion anchors.
i
. - , . - . _ , . . _ . . -. , ,..,.m.._._,mm_ .
299 1 Q And this particular area in which he was using the 2 photocopied checklist was the welding area?
3 A Yes, sir.
4 Q So at the time that Mr. Martin was assigned to the 5 vault, he was still uncertified in all other areas?
6 A Yes, sir.
7 Q He had yet to racertify?
8 A Yes, sir.
9 Q An inspector states a concern that is reflected as 10 follows: " Hangers aren't being inspected, just as built. No 11 inspection reports or nonconformance reports are written.
12 Walkdowns are being done and drawings made to show as-built 13 configuration."
14 Has a concern to that effect ever been brought to 15 your attention?
16 A Yes, sir. That came from the S&L walkdown.
17 Q And what is the basis for that concern? Well, let 18 me ask it differently. How did that concern come to your 19 attention?
20 A Well, the inspectors identified it to one of the 21 supervisors. I'm not sure just which one it was. But they i 22 didn't feel it was right that S&L walked down the hangers and LO i
300 1 made as-built drawings, and then as S&L required or they felt 2 that it would not meet the seismic requirements, I believe, 2~
3 they would then balloon the drawing for a rework if they 4 wanted it reworked; if they didn't, then they as-built it to >
l 5 the prints as the way it was actually installed in the plant.
l
} 6 Q When you say ballooned, they would show a change on 7 the drawing?
. 8 A Yes, sir.
1 f 9 Q Requiring rework?
i 10 A Yes, sir.
I
- 11 Q Did S&L in this walkdown write inspection reports on i 12 their --
1 l 13 A They didn't.
14 Q And did they write nonconformance reports on 15 nonconforming conditions they identified?
16 A S&L didn't, no.
l l
17 Q Did they get anybody else to?
18 A our inspectors were right with them when they were 19 doing this. They redlined the drawings.
j 20 Q They did. The inspectors did?
21 A Yes, sir.
I i.
j 22 Q And did they write nonconformance reports? !
{
i O
1
[
- _ _ . . . , . _ _ , . _ . ~ . _ , _ _ .. _ _ __,_ - _ _.-.___.._ _ _ _ -
301 1 A No, sir.
(~%
'w_) 2 Q So they redlined the drawing to show where there 3 were deviations between the drawing and the as-built 4 condition?
5 A Yes, sir.
6 Q The redlining was the reflection of the as-built 7 condition on the drawing?
8 A Yes, sir.
9 Q When did Sargent & Lundy do this walkdown?
10 A I think it was last summer.
11 Q This is April of '85 when this document was 12 prepared.
i
(~ 13 A I believe it was finished in September, the actual 3
\_]/
! 14 walkdown. I believe it started in early '85. I'm not positive 15 on the actual date.
16 Q What was the walkdown program called?
i 17 A I believe it was an S&L cable pan hanger Walkdown.
18 Q Was this to verify the quality of hanger welding or
! 19 just configuration?
20 A Configuration.
21 Q Just configuration alone?
22 A They also weld-mapped the welds that were on the 4
1
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_ _ _ _ _ _ _ _ _ . . = . _ _ . - _ _ _ . . - - __ . _ - - ..
302 4
1 hangers.
2 -Q By weld-mapped, showed what welds were there? .
3 A Yes, sir.
j 4 Q Did they inspect the quality of the welds that were 5 there?
6 A Not at the time, no, sir.
! 7 Q Was there a weld inspection performed of the quality 8 of the welds after the walkdown?
9 A They may have already been inspected.
10 Q They may have been inspected previously at 11 installation?
12 A Yes.
13 Q Did a Comstock inspector raise a concern about this
(
14 practice?
I 15 A Yes, sir. I believe there was one on that practice 16 that you mention there in the paper.
17 Q Why was the concern raised?
) 18 A Because our people were generating a Form 7, which 19 is a configuration report, and we were letting this i 20 configuration report open until such time as a redline drawing 21 had been incorporated into the next revision.
l 22 Q So the configuration report is an inspection report
'I
- O l
303 1 for configuration inspections?
'O(_/ 2 A Yes, sir.
3 Q And it would identify nonconforming configuration 4 conditions?
< 5 A It didn't at the time, no.
6 Q What I'm saying is when they leave it open, did that 7 mean that they didn't document nonconforming conditions at 8 all or they just -- well, you tell me what they did.
9 A As they generated it, the initial start of it, they
- 10 wanted them to sign off the Form 7 as everything was 11 acceptable.
12 Q Sargent & Lundy wanted the Comstock people to do 13 this?
14 A Yes, because they wanted to take the redlined 15 drawing and put it into the Revision A drawing, and then once 16 the Revision A drawing came out, the redlined drawing was 17 cross-referenced by another inspector. Then the Form 7 was 18 officially signed off as being a good configuration inspection i
19 because then it conformed to what was supposed to be in the 20 plant.
21 Q I see. So essentially, Sargent & Lundy wanted your 22 people to in advance approve the ultimate configuration as l0 i
.-, - , . - - . . , - . . . - , . - , , , - . - - . . . . - , , . . - . . , ~ - . . , - , - - , - - - - , .., ,-, , -r.- .-.- - -___-,
304 1 finally accepted by Sargent & Lundy through the process of
} 2 redlining the existing drawings.
3 A Yes. This came out in a supplement of CECO NCR 708 4 and 709. This was a disposition of the corrective action to 5 these two NCRs.
6 Q By this, you mean the Sargent & Lundy walkdown?
7 A Yes.
8 Q What was the subject of those NCRs?
9 A Had to do with -- I'm not sure just the exact 10 verbiage in it, but it was related to the hangers as they were 11 installed out in the plant, I believe.
12 Q Did it identify nonconforming configuration O
V 13 conditions?
14 A It may have in the body of the nonconformance. I am 15 not positive what was in there.
16 Q Why were they CECO NCRs?
17 A I don't recall just why Ceco initiated these NCRs, 18 but they were CECO NCRs. We were working to their 19 disposition.
20 -Q Had there been Comstock NCRs that were the basis for 21 the CECO NCRa?
22 A I'm not positive.
O
305 1 MR. GUILD: Counsel, do you know whether these NCRs
,O
(.,,) 2 have been identified in discovery?
3 MS. KEZELIS: I don't know.
4 MR. GUILD: We would ask that they be produced.
5 BY MR. GUILD:
6 Q Do you know who expressed concerns about this 7 practice, which inspectors?
8 A I think one of them was Mr. Perryman.
9 Q Larry Perryman?
10 A I believe.
11 Q Do you know whether Mr. Perryman documented his 12 concern?
( }
13 A I don't know whether he put it on a piece of paper 14 or not.
15 Q Did he bring it to your attention?
16 A I think he brought it to Mr. Simile's attention, I 17 believe, first.
18 Q What was Comstock's response to the concern?
19 A Well, we want to CECO, and then we eventually --
20 well, not eventually, but shortly thereafter the supplement 21 was changed and it was reworded as to the first inspector, the 22 second inspector, and so on.
O
306 1 Q The supplement to the NCR?
2 A Yes, sir.
3 Q In other words, to make clear that there was more 4 than one inspection being done of the configuration condition, 5 not simply one final inspection?
6 A Yes, that everything would be in a sequence, the 7 initial walkdown, the redline, the review and the issue of 8 Rev. A, and then the evaluation by another Level II QC 9 inspector, as to assure everything was picked up off the 10 redline drawing to the Rev. A drawing.
11 Q Who did you go to at Ceco with this?
12 A I believe it was worked out through Mr. Giesaker.
13 Q Do you know whether or not Quality First looked into 14 this issue?
15 A I don't know.
16 Q The next concern, the anonymous source, "Comstock 17 management promises more money to inspectors who are certified 18 in multiple areas. Although it is nice to get more money, an 19 inspector cannot remain proficient in all of the certified 20 areas; therefore, the quality of inspection goes down."
21 A When an inspector is changed to another area, he is 22 afforded an opportunity to work with another inspector in that O
307 1 area to refamiliarize himself with that type o'f inspection. l
('
(_j) 2 Also, we have procedure revision reviews as a procedure is 3 revised, so I really think that's a bogus statement.
4 Q Do you agree generally with the proposition that an 5 inspector is most proficient in the areas that he performs on 6 a regular basis?
7 A I agree with that.
8 Q For example, someone may have multiple 9 certifications, may have a certification, for example, in 10 calibrations and receipt inspection but be primarily a welding 11 inspector. He does welding inspection as part of his normal 12 principal duties and rarely, if ever, does calibration
/~' 13 inspections. Would you agree that a person in that situation O) 14 would be more proficient as a weld inspector than as a 15 calibration inspector?
16 A I agree, although if he was changed over into 17 calibrations, he would have the chance to familiarize 18 himself. He also has the responsibility and is issued the 19 procedures that he is certified in. Anytime there is a 20 revision, he gets that revision to the procedure. It is his 21 responsibility to keep himself up to date as to the procedure 22 revisions.
v
i 308 j
j 1 Q You would agree, though, that for that inspector in j s ,/ 2 that example to be proficient in calibration inspections,
, 3 although certified in that area, he would have to have some i
j 4 refresher if he hadn't actually done the work?
I i 5 A Yes, and it is afforded to him.
i 6 Q Is there any system at Comstock for assuring that ll 7 inspectors maintain proficiency in the areas that are not i
2 8 their principal areas of work?
L
- 9 A Yes. They are evaluated every year.
3 10 Q And how does that program work?
11 A Through the training of the various revisions and 12 that they do inspections throughout that year in the various 4
! 13 disciplines.
4 14 Q Now, is there a requirement that you perform a
- 15 certain number of inspections during a year in order to J
l 16 maintain your certification in an area?
- 17 A No.
} !
! 18 Q So it is just one factor among others that is 19 evaluated?
20 A Yes, sir.
21 Q Are there inspectors at comstock who are certified i i
22 areas that they do not customarily perform work in? i i :
a e.. 4_,-,- - ~ - - c_- ,w,,-_,._y.m-- ,e wm---,y. ,-w--
309 1 A I would say yes.
(
(m, 2 Q Is that common?
3 A Yes.
4 Q The last item states that so and so, an unnamed 5 person, is "both an inspector and an auditor." Blank "will 6 inspect something and then do the QA overview audit." Blank 7 " believes this to be a conflict of interest."
8 Are there any circumstances where there is a person 9 who performs both inspection work and auditing work?
10 A That came from -- I don't know the inspector, but 11 the individual they are talking about is Mr. Rissman, who is 12 no longer with us. He now works for Ceco. But he was
( 13 involved in helping Mr. Saltmann draft up the " Good News"
}
14 story, and he, in turn, would be working, when he was working 15 with Mr. Seltmann, he sat in the QA Department office, which 16 he was not doing any audits. This is a feeling or an opinion 17 of some inspector who seen him in there, and that was not 18 exactly what he was doing.
19 Q What he was doing was writing the " Good News" story?
20 A He was putting the material together for the " Good 21 News" story and aiding Mr. Seltmann in getting that all put 22 together.
O
310 1 Q Okay. And that may have involved him reviewing 2 documents and procedures and that sort of thing?
3 A Yes.
4 Q It led someone who didn't know the facts to conclude 5 that he was doing auditing work.
- 6 A Exactly.
7 Q Now, was Mr. Rissman a quality control inspector at I
8 the time?
j 9 A Yes, sir.
10 Q Level II?
P 11 1
A Yes, sir.
12 Q What is his first name?
13 A If my memory serves me right, Samuel, I believe.
( }
14 Q And he now works for Commonwealth Edison?
l 15 A Yes, sir.
16 Q In what capacity?
1 17 A I have no idea.
l 18 Q What was Mr. Rissman's principal area of work at the
{ 19 time when he was with Comstock?
20 A Terminations. I believe it was terminations.
21 Q On Friday I showed you some documents that were 22 copies of surveys completed by Comstock quality control ;
J
)
- ~ ....- __,.. _ .,,,..__..._ _.___,., _. . ,___._._____..__._ .,.. ._ .._. .. _ . . _ _ , . _ _ - _ . - - - - _ _ . . _ _ _ _ . _ .
311 1
1 inspectors sometime in 1984, and you gave me a brief
(
2 description of the circumstances, but would you tell me a 3 little bit more, please, about how those surveys came to be 1 4 circulated and completed?
5 A I felt there was a lot of unrest, and I also heard 6 from Mr. Saklak that the inspectors were, I should say, 7 complaining or griping, so I figured if I put out a memorandum
, 8 -- or not a memorandum, but a questionnaire, that I could get 9 some good, positive criticism from the inspectors. I did not 10 get a sheet from every inspector, and of the evaluation, we 11 did make various changes through some of their 12 recommendatiens. Some of their recommendations were sort of
() 13 opinionated and I didn't do anything about them. I think 14 there they complained about not being able to get a hot lunch 15 or something. I got them a microwave, I got a refrigerator 16 put in for them, things of this nature. That's what came
- 17 about out of it.
18 Q How about any complaints about the inspection work, 19 the way comstock organized its quality control work? The 20 question is did you get any of those and did you take any 21 action?
22 A There might have been. I would have to look through ,
i
- O
r' 312 1 them. It has been so long, I can't recall what just exactly
-m.
( ,) 2 is in there.
3 Q I'm not asking you to recite what the documents say, 4 but can you recall whether or not you got any and whether you 5 took any action in the area of inspection work?
6 A I'll have to answer again I don't recall because I 7 don't remember exactly what all the concerns were.
8 Q Okay. Who saw the results of the questionnaire, the 9 completed questionnaires?
10 A I reviewed it, I believe Mr. Seese reviewed it, I 11 believe Sak reviewed it, I believe Mr. Seltmann reviewed 12 them. I'm not positive.
N 13 Q Did you hand these out on the job site? Were they
("'Y 14 circulated at work?
15 A Yes. I mimeographed a lot of them and left them 16 there, and there was also a box where they could fold them up 17 and stick them in there. I didn't require them to sign them 18 or anything. I was just looking for good, constructive 19 criticism.
20 Q Who wrote the questionnaires?
21 A I don't recall whether I did or Mr. Seese did.
22 Q Did the completed questionnaires go to commonwealth l
!n v I
j 313 1 Edison?
2 A I don't recall whether I sent them over to l 3 Mr. Mennecke or not.
l 4 Q Do you know whether the NRC has ever reviewed the
)
l 5 completed questionnaires?
I 6 A Off-hand, *. really don't know. I don't recall.
7 Q Have there been any other surveys or questionnaires 8 of Comstock inspectors?
9 A I think Mr. Brown done one of the training 10 situation, to see if he could better the training.
11 Q When was that done? Was that before your time?
12 A No, it was after. I don't remember the exact date 13 or even the approximate time.
14 Q Okay. Now, who is Mr. Brown?
15 A He is my other assistant manager which supervises 16 the training department.
17 Q Assistant quality control manager?
18 A Yes, sir.
19 Q And how long has Mr. Brown been on the job?
20 A Approximately a year, maybe a little more.
i j 21 Q so he did this survey since he came on?
22 A Yes.
L
314 1 Q And are you aware of any action that was taken as a 2 result of Mr. Brown's training survey?
3 A I believe we developed packages that we give to each 4 inspector, new inspector when he comes in, telling him what he 5 has to get, how many hours is required, and so on and so 6 forth.
7 Q Training packages? ,
8 A Yes.
9 Q Explaining how you get certification and training in 10 different areas?
11 A Yes, sir. I don't recall just what other items. I 12 think there was a couple other items that he enhanced the 13 training program through this.
)
14 Q Do you recall any other surveys or questionnaires 15 that were circulated to Comstock inspectors?
16 A That's the only one that I know of.
17 Q Were you aware that Comstock inspectors participated 18 in what has been referred to as baseline interviews with the 19 Quality First program?
20 A Yes. They interviewed everybody. They interviewed 21 me, the whole QC Department.
22 Q And are you aware of the results of Quality First O
315 1 interviews of you and the QC inspectors?
2 A I'm not, as you are saying, aware. I know that they 3 done the review and they may have investigated some of the 4 statements by the inspectors, but I don't know whether they 5 came out of this review or they didn't.
6 Q Have you ever gotten a report from Quality First?
7 A No, sir.
8 Q You are not aware of anything that Edison has 9 provided to Comstock that is the result of Quality First 10 reviews of concerns?
11 A To the best of my knowledge, they never printed any 12 result.
, 13 Q Who did you speak to at Quality First?
14 A I don't really remember the gent's name.
15 Q Preston?
16 A I don't think it! was Ray.
17 Q okay. Did you express any concern?
18 A No, sir, didn't have any.
19 Q Did the Quality First people ask you about any 20 concerns expressed by your inspectors?
21 MS. KEZELIS: Are you talking about during his 22 interview?
O
, 316 1 MR. GUILD: Yes.
,O k_- 2 THE WITNESS: They may have mentioned some. I don't 3 recall exactly the conversation. They asked me if I had any 4 concerns and I said I had none.
5 BY MR. GUILD:
6 Q Do you recall anything you said abe t Comstock 7 inspector concerns?
8 A No, I don't.
9 Q Do you know an inspector named R.D. Hunter?
10 A Yes, sir.
11 Q Is Mr. Hunter still employed by Comstock?
I 12 A No, sir.
) 13 Q When did Mr. Hunter leave Comstock's employ?
I 14 A I believe it was a couple weeks ago.
! 15 Q Can you describe the circumstances of Mr. Hunter's 16 termination?
17 A PTL does our overview, and what they do, they come 18 in, their practice today is that they come in and they make 19 copies, they photocopy the inspection reports that are done 20 the previous day. Mr. Hunter had some inspection reports in 21 there in which PTL, when they went out and done their 22 overview, found that he had inspected through paint.
O
317 1 Q How was that brought to your attention?
) 2 A Through the PTL overview.
3 Q Somebody told you that?
4 A Well, I seen the overview report.
5 Q The report came back and it had that documented on 6 it, that finding?
7 A Yes.
8 Q Who did the PTL overview?
9 A I don't know the individual's name.
10 Q It was an inspector?
11 A It was a Level II inspector for PTL.
12 Q Can you identify the document on which the findings 13 were made? Was it like the overview forms that we had been 14 talking about?
15 A It is similar to this, to my knowledge. It is only a 16 piece of paper and has other attributes written.
17 Q Similar to the attachments to Exhibit No. 17?
18 A Right, except it is not laid out in the same format, 19 but it's similar. I think it has the sama attributes and so 20 forth on it, but it's laid out in a little bit different 21 format.
22 Q And it identified an overview of the weld 1
.-,LA
- e J e w 9
318 4
1 inspections that Mr. Hunter had performed?
I 2 A Yes, sir.
3 Q And what did it say, in substance, on the report?
4 A Inspected through paint, and they were rejected.
5 Q Rejected by PTL because of the painted cor.dition?
6 A Yes, sir.
7 Q And what did you do when that came to your 8 attention?
9 A Mr. Simile first went out, he inspected it, and they 10 used the PTL Level III, who also reviewed the condition the 11 field, I reviewed the condition in the field, and I chink 12 Mr. Seltmann reviewed the condition in the field.
13 Q And who was the PTL Level III?
14 A I'm not sure who that is.
15 Q And when did you review the condition in the field?
16 A I believe it was a day or so after the report.
17 Q Is that when they reviewed it, as well? Did you all 18 go together?
19 A No, we didn't all go together. At different times.
20 Q What happened first? You got the PTL report, and 21 what happened next?
22 A Like I said, Mr. Simile reviewed it, went out, and I O
l
319 1 believe he went with the PTL Level III at the time. They 2 reviewed it. I think Mr. Seltmann reviewed it with Mr. Simile 3 before I did, and I went out again and reviewed it myself 4 because I didn't believe that he did it, and in fact, I 5 confirmed it, that yes, it did happen.
6 Q The sequence is what I'm trying to identify now.
7 Simile and the PTL Level III went out, and they came back and 8 reported the results to you?
9 A They sent us the report. Simile gets the report 10 first. Then he got with the Level III. They went out and 11 reviewed the report. Then he came back, I believe, and 12 Mr. Seltmann and he went out and reviewed the report.
13 Q Did it come to your attention at that point? When
-14 did you first learn about it? l 15 A Oh, probably the same day or the next day.
i 16 Q After they had already been out to look at the I l
17 welds?
)
18 A Yes. And I, too, wanted to review it before we had 19 a meeting with BesCo.
20 Q Now, what I want to identify is how you first 21 learned of the circumstances.
22 A Through Mr. Simile.
O V
319 1 believe he went with the PTL Level III at the time. They
/~%
(,,) 2 reviewed it. I think Mr. Seltmann reviewed it with Mr. Simile 3 before I did, and I went out again and reviewed it myself 4 because I didn't believe that he did it, and in fact, I 5 confirmed it, that yes, it did happen.
6 Q The sequence is what I'm trying to identify now.
7 Simile and the PTL Level III went out, and they came back and 8 reported the results to you?
9 A They sent us the report. Simile gets the report 10 first. Then he got with the Level III. They went out and 11 reviewed the report. Then he came back, I believe, and 12 Mr. Seltmann and he went out and reviewed the report.
()
Q 13 Q Did it come to your attention at that point? When 14 did you first learn about it?
15 A Oh, probably the same day or the next day.
16 Q After they had already been out to look at the 17 welds?
18 A Yes. And I, too, wanted to review it before we had 19 a meeting with BesCo.
20 Q Now, what I want to identify is how you first 21 learned of the circumstances.
22 A Through Mr. Simile.
O
320 1 Q Simile came to you and said he had been out to look
( 2 at the thing?
3 A Yes.
4 Q And showed you the PTL overview report?
5 A Yes.
6 Q And he had been -- you said he had been with the PTL 7 Level III?
8 A Yes, sir.
9 Q Now, at that point did you go out and look?
1' 10 A Not at that particular instance. I was busy doing 11 something else.
12 Q When did Seltmann go out and look?
i 13 A I believe it was just prior to my going out.
(
14 Q So Simile and the PTL Level III went out, then 15 Seltmann went out, and did Seltmann tell you what he saw?
16 A He confirmed it was paint. I also went out and 17 looked for myself and confirmed it was paint.
18 Q Now tell me what you saw.
19 A I saw it was painted.
20 Q What was painted?
l 21 A The weld was painted.
22 Q Did you find one weld painted, five welds?
lO 1
l
~_.
321 1 A Oh, several. I didn't count the exact amount. I
(~
\ 2 looked at one brace, the top weld at the brace, I went to 3 another hanger and looked at that particular one.
4 Q So how many welds did you observe in a painted 5 condition?
6 A Probably half a dozen.
7 Q I take it that it is contrary to procedure to 8 inspect a weld through paint; is that right?
9 A Yes, sir.
10 Q Does the procedure say that?
11 A Yes, sir.
12 Q And can you give me a reference to where it says 13 that?
(
14 A The Form 19 says is the weld clean? Not to,*those 15 exact words, but is the weld clean? It references the 16 cleanliness of the weld.
17 Q And that is interpreted to mean that the weld is not 18 only not dirty but it is not in a painted condition.
19 A Yes, sir.
20 Q Is it ever acceptable to inspect treld through paint?
21 A No, sir.
22 Q Now, what kind of an inspection was being performed O
r 322 1 by Mr. Hunter at the time?
2 A This was an inspection that was as a result of the 3 AVO program.
4 Q Was this a reinspection?
4 5 A I don't really know whether it was a reinspection.
6 Like I say, it was an inspection as a result of the AVO
- 7 program because the AVO stated this hanger had been reworked, 8 repaired or something and we needed an inspection after the 9 date of that AVO.
10 Q Do you know whether or not the particular welds that 11 you observed in a painted condition were the subject of first 12 a previous inspection?
( 13 A I didn't look into it that far.
14 Q Do you know whether or not the welds that you 15 observed in a painted condition had been the subject of 16 rework?
i 17 11 That is the reason we went out, because the AVO 18 indicated there had been something done to that particular 19 hanger, so we needed a reinspection.
t 20 y Q Right, but do you know whether the welds that you
- 21 olserved in a painted condition themselves had been reworked?
- , ;!2 A I didn't look into it that deeply.
')
O
i 323 i l'
1 Q Now, I'm looking at a Form 19. This is a Form 19, 2 Rev. E. It happens to be the one that is attached to Exhibit 3 No. 17. It is the one -- I guess Mr. Baxter, is that his 4 name?
5 A Yes, sir 6 Q That he did of the HO23 hanger. The attribute is 7 3.2. Is states on this Form 19, " Weld was sufficiently 8 cleaned as not to impair visual inspection per paragraph 9 3.2." Is that the criteria you are referring?
10 A Yes, sir.
11 Q Is that the substance of what the current form 12 provides?
13 A I believe it's pretty close to the same thing.
14 Q It is in substance the provision that Mr. Hunter was 15 inspecting to.
16 A Yes.
17 Q So you observed paint on at least a half-dozen of 18 the welds that were indicated on Mr. Hunter's Form 19 as 19 acceptable?
20 A Yes, sir.
21 Q Can you describe the paint that you observed?
22 A It was red oxide paint.
s 324 1 Q Is that like the rust-proof kind of paint?
(\_,)
N, 2 A Similar, yes. Heavy paint.
3 Q Heavy paint. All right.
4 How old was the paint that you observed?
5 A Quite old. There was dust on it.
6 Q Does that mean it's old?
7 A Well, dust and dirt on it, and if he had inspected 8 it one or two days prior to myself looking at it, it sure 9 wouldn't have been dusty and dirty, and you could tell the new 10 paint from the old paint.
11 Q You observed new paint on the welds?
12 A I observed the old paint, not new paint.
13 Q Did you observe any new paint?
14 A No, sir.
15 Q Was there any new paint at all that you observed on 16 the hangers in question?
17 A No , sir, not that I saw.
18 Q Were there any other inspectors involved in the work 19 in question?
20 A ArtuhT 6h Yes, sir, Mr. Aentr.
21 Q Do you know what his first name is?
22 A I don't know what his first name is. His last name O
ARNDT ~94b5 1 is spelled-A-r u-t.
(O
\ms/ 2 Q And was Mr. Arnt terminated as well?
3 A Yes, sir.
4 Q Okay. So what action did you take? You went out 5 and looked at the welds. Well, first of all, you said that 6 you didn't believe that Mr. Hunter had done this? Is that i 7 what your statement was?
8 A That's correct.
9 Q Why didn't you?
10 A Because he has previously requested that paint be 11 removed so he could inspect the welds.
12 Q You mean you are aware that Mr. Hunter had asked
. /) 13 that welds be stripped of paint so that he could perform an V
14 inspection?
15 A Yes, sir.
16 Q Well, did that lead you to believe that he was aware 17 that you had to have a paint-free condition to inspect the 18 welds?
19 A That's correct.
l t
20 Q And he knew how to get it done, in short.
i 21 A Yes, sir.
22 Q And how was one supposed to get the welds clean, the l
rO V
i
326 1 paint removed, if necessary, in order to perform this s/ 2 inspection?
3 A You give the item number, the print number to his 4 lead. His lead would then pass it on to Construction, and they 5 would go out and remove the paint, give the checklist back, 6 and he would then go out and complete his inspection.
7 Q After he got the checklist back showing that they 8 had been cleaned and ready for inspection?
9 A The paint list, yes.
10 Q Do you know whether or not Mr. Hunter had requested 11 that paint be removed from any of the welds that he was 12 inspecting?
() 13 14 A To the best of my knowledge, he had not.
Q How did you reach that conclusion?
15 A I talked to his lead.
16 Q And who is that?
17 A Brian Murphy.
18 Q And what did Mr. Murphy say on the subject?
19 A He didn't recall any request to have paint removed.
20 Q Was Mr. Murphy's statement documented?
21 A No ,. sir. I didn't document it. I think Mr. Simile 22 may have written something because he talked to him first.
l 1
, 327 1 Q Simile talked to Mr. Murphy?
2 A Yes, sir.
3 Q Have you seen any document written by Mr. Simile?
4 A I believe there is one, yes.
5 Q Can you describe that?
6 A It describes him going to the field, looking at the 7 condition, talking to Murphy and so on.
8 MR. GUILD: Counsel, do you know whether such a 9 document has been identified in discovery?
10 MS. KEZELIS: I don't think that that document has 11 been produced. I'm not aware of any such production.
12 MR. GUILD: We would request that you make that
/~'T 13 available, please.
O 14 MS. KEZELIS: That's fine.
15 BY MR. GUILD:
16 Q Do you know of any other documents reflecting 17 Mr. Hunter's termination or the circumstances of the 18 termination?
19 A I think there is a package put together that when we 20 sent him back to BesCo for Besco's disposition, I think there 21 is a package that has been put together.
22 MR. GUILD: We would ask for that package.
O
_ - , -- _ _ - + _ . _ ,
328 1 BY MR. GUILD:
2 Q Would that include also the PTL overview report 3 reflecting the painted condition?
4 A I'm not sure whether that's in there or not, but I 5 think it is.
4 6 MR. GUILD: I would like to see that, as well.
7 MS. KEZELIS: In other words, you would just like 8 the documentation surrounding Mr. Hunter's termination?
9 MR. GUILD: Yes.
AnuNT 10 MS. KEZELIS: And Mr. Amat 's, as well.
11 MR. GUILD: Yes. Thank you.
12 BY MR. GUILD:
(~T 13 Q So, what other action was taken with respect to 14 ARubT &
Mr. Hunter and Mr. Arnt? You said you talked to Mr. Murphy, 15 or you and Mr. Simile both talked to Mr. Murphy?
16 A What other action?
17 Q Yes. What other action was taken? What happened 18 next?
19 A Well, I went out and confirmed the paint, and I 29 agreed that he inspected through paint.
4 21 Q Then what did you? What was done?
22 A Then we had a meeting we BesCo and discussed it, and 1
.r-. ~, - - - - ,
--,,-c -,,,-e, - - - -
l 329 I
1 we turned Mr. Hunter over to BesCo. '
%_) 2 Q Did you discuss the matter with Mr. Hunter?
3 A Yes. Mr. Seltmann did. I sat in there with 4 Mr. Seltmann when he talked to Mr. Hunter.
5 Q Do you know when the meeting with Mr. Seltmann took 6 place?
7 A I don't know the exact date of it, but I think it is 8 documented.
9 Q What was said in the meeting?
10 A We asked him did he inspect through paint, and I 11 believe, if my memory serves me correct, he indicated that he 12 did inspect through paint.
l
)
13 Q That is your recollection, that Mr. Hunter said yes, 14 he did?
15 A Yes. He didn't come out and say yes, he did, in 16 that pretext, but the way he stated his response, it indicated 17 that he inspected through paint.
18 Q Do you recall what his response was?
19 A Not exactly, no.
1 20 Q Did Mr. Hunter provide any explanation or other 21 statements about the circumstances of his inspection?
22 A Mr. Hunter was very quiet. He didn't say much at 1
330 1 all.
2 Q That's his general manner?
3 A He is generally a quiet individual, yes.
4 4 Q And he was quiet in this case.
4 5 A Yes.
- 6 Q And do you recall him saying anything else?
7 A He may have said something, but I don't remember the 8 exact words that he said. What I got out of his conversation 9 was that he did inspect through paint in this particular 10 instance.
! 11 Q If he said that or led you to that conclusion, did 12 he provide any explanation?
I I
() 13 14 A
he stated.
He gave a reason but I don't recall the reason that
+
15 Q At the time you met with Mr. Hunter, had you 16 proposed to terminate both he and Mr. hen 4?
Aewer M20 17 A I really didn't propose to terminate anybody at that 18 time. I hadn't made up my mind. And Mr. Seltmann is the one 19 that makes or really sends the individual back to BesCo, I 20 don't.
4
- 21 Q All right. Had Mr. Seltmann made up his mind, as 22 far as you knew?
4 O
i
~ ~ . - - . _ _ _ _ _
331 1 A I think he wanted to wait to see what the results 2 were after he talked to him.
3
$1 R it b r W N Q Talked to Hunter and ATnt?
4 A Yes.
S Q Was *MRNDF rnt at the meeting?
l j)RpbrJ 7 Q What did Mr. Arnt have to say?
8 A He indicated he, too, had inspected through paint, 9 to the best that I recall the conversation.
10 Q Did he provide any explanation?
11 A Something to the effect that if a person who had 12 been here 2-1/2 years could do it, I felt it was the common 13 practice.
14 Q And what was he referring to? What did you 15 understand him to be referring to?
16 A Inspecting through paint.
17 Q Was he referring to the fact that other people had 18 done it, as far as he was aware?
19 A The individual he was referring to was Mr. Hunter.
20 Q And he was saying -- did you understand him to be 21 saying that Mr. Hunter had done it and he thought it was okay
, 22 if Mr. Hunter had done it?
332 1 A That's my impression of the way he came off, yes.
' (-.
2 Q And Mr. Hunter had been there for 2-1/2 years?
3 A I believe it was about 2-1/2 years.
4 nanor J#d Q And how long had Mr. Aent been there?
5 A About 2-1/2 months.
l 6 Q So he was new on the job, relatively?
7 A Yes, sir.
ARNDT abb 8 Q Was Mr.9hent an experienced inspector?
9 A Yes, sir.
10 Q I mean aside from his 2-1/2 months on the job?
11 A Yes, sir.
12 Q He had done inspection work before?
13 A Yes, sir.
14 Q When was the decision made to terminate the two i
15 individuals?
16 A I think it was the following day.
17 Q Did you discuss the matter among yourselves outside 18 of the presence of Mr. Hunter and Mr. Arnt?
19 A I think we did after I looked at the welds and so 20 forth.
21 Q Had you looked at the welds when you talked to 22 Mr. Hunter?
1
- O l
_ - . - - - _ - . - . . . - . . . _ _ _ - . - _ _ . . ~ . . _ _ _
.--m - - - - - _ , , . _ . . . . - - - -
333 1 A Prior, i
C% AR9 bT
( ,) 2 Q Prior to when Mr. Hunter and Mr. ,hent came in?
3 A Yes.
4 ara 0T Q So Mr. Hunter and Mr. , kent are in, the conversation 5 takes place that you.have described. Did you and the other 6 Comstock managers discuss the matter after you met with 7 Mr. Hunter and Mr. Arnt?
8 A Yes, sir.
9 Q And what was the substance of that discussion?
10 A Just as to whether to terminate them or not to 11 terminate them.
12 Q And what was the substance of the discussion?
(~' 13 A Had he, in fact, inspected through paint, which he, V) 14 in fact, did. That was the substance of the discussion.
15 Q And you reached the conclusion that he and Mr. 9enHe ARdbT Q6b 16 both had inspected through paint?
17 A Yes, sir.
18 Q And then what was said?
19 A Then we called in BesCo and we talked to them, and 20 he was turned over to BesCo.
21 Q With the recommendation by Comstock management?
22 A Whatever their disposition was, that we no longer O
334 1 wanted him in our group.
2 Q Essentially, to terminate him.
3 A It was up to them. They hire and fire.
4 Q But you made clear that you didn't want the two 5 individuals -- you weren't prepared to continue them as 6 quality control inspectors at Comstock?
7 A Yes, sir.
8 Q That sort of leaves them to send them someplace else 9 or to terminate them.
10 A Yes, sir.
11 Q Who did you take the matter up with at BesCo?
12 A Besco's manager, Tom Skidmore. I don't recall, but
(~N 13 I think two of BesCo's corporate level people were there at 14 the discussion.
15 Q And what was the substance of that discussion?
16 A R2nor M That Mr. Hunter and Mr. Jund; had inspected through 17 paint and we were turning them over for their disposition.
18 Q Did they ask any questions about the matter?
l 19 A Of course they questioned: Are you sure he did it?
20 We replied that, sure, we went out and looked at it.
21 ARuOT* 45 Q Did they ask what Hunter's and-Awat's side of the j 22 story was?
l l
l O
i L
= -- -- . __ _ ---_- ._ _
^
335 1 A I believe it probably did come up in the 2 conversation.
3 Q Did you relate what their side of the story was?
4 A I think -- Mr. Seltmann done all the talking, and it 5 was implied that yes, we felt they did inspect through paint, 6 through their recognition that they themselves inspected 7 through paint, and we turned them over to BesCo for their 8 disposition.
9 Q Did you talk with BesCo about any alternatives to 10 termination?
11 A No, sir, not to my recollection.
12 Q Any other discussion with BesCo people?
13 A Not after that, that I recall. Bob may,
}
14 Mr. Seltmann may have, but I didn't.
15 Q And what action was taken after that?
16 A We turned them back to BesCo.
17 Q And what happened then?
18 A BesCo terminated them, I guess.
19 Q How do you know that?
20 A They are no longer on the site.
21 Q They are gone, so that leads you to the conclusion
, 22 that they were terminated by BesCo?
O I
336 1 A Yes, sir.
i 2 Q Had any other Comstock inspectors been terminated 3 previously for inspecting welds through paint?
4 A No, sir.
5 Q Had any Comstock inspectors ever been disciplined 6 for inspecting welds through paint?
7 A Not to my knowledge.
8 Q Had any Comstock inspectors ever been identified as 9 inspccting welds through paint previously?
10 A Not to my knowledge.
I 11 Q Had any Comstock inspectors ever been terminated for 12 violating inspection procedures?
() 13 14 A
Q Yes, sir.
Can you identify who?
15 A One was Roy Lewis.
16 Q What was Mr. Lewis terminated for?
17 A Improper inspection.
j 18 Q What was the substance of Mr. Lewis' violation?
19 A We had a special program going, and it was, again, 20 for an NCR that CECO had written, I think it was -- it was to 21 do with butt splices. I don't remember the exact number; 593 22 comes to mind, but I'm not sure that is the exact number. The 7 ,
t O
N 337
, 1 NRC had come in and they were doing a follow-up on it. The 2 first cabinet he opened up, I think there were four butt 3 splices that he looked at. He went to the vault to check and 4 see whether or not Mr. Lewis had identified these because on 5 his paper he had not identified them, on the checklist that he i
6 used when he went through the piece of equipment. ,
! 7 Q Defects in butt splices?
8 A Well, the butt splices had to be replaced on any l 9 butt splice we had because of a concern of Byron, and we were
).
10 looking to see if there were any butt splices that were in the 11 cabinets that we did not have a Form 36A on. When the NRC 1
12 inspector opened up the cabinet, there were four. We went
,- 13 down and looked. We had no paper. The four were not 14 identified by Mr. Lewis, i.
15 We then initiated a reinspection of all the cabinets 16 and so forth that he had done, and I don't recall the NCR we i-l 17 generated now, 3275, I think is the number, but we identified, 18 I think it was, nine more that he'had not identified in his 19 previous overview inspection, and he, too, was terminated 20 under the same pretext, that he did not perform the required i
21 inspection.
4 I
- 22 Q Can you identify any other instances of QC i
i
, _ _ _ _ _ _ _ _ . _ _ . , . . _ . . . _ _ , _ _-- .. , , _ _ _ _ . _ . _ _ _ - _ _ _ _ .- ,_-.m, . _,_
338 1 inspectors at Comstock or BesCo terminated for violating 2 inspection procedures?
3 A Offnand, the only two I can recall, or three that I 4 can recall --
5 GRNoT40
-- are Hunter and Mr. Lewis and Arnt.
Q 6 A Right.
7 Q Can you recall any prior instance where inspectors 8 were disciplined for violating inspection procedures?
9 A Not that I can really recall.
10 Q Warnings, verbal or written, for violating 11 inspection procedures?
12 A Not particularly violating inspection procedures, 13 not on that subject that I can recall right now.
)
14 Q Did you consider taking any less severe action ARnhT 15 against Mr. Hunter and Mr. ,hent, aside from termination?
16 A I didn't, no.
17 Q You believe that was the reasonable action to take 18 under the circumstances?
i 19 A Yes, sir.
l 20 Q Had Mr. Hunter ever violated an inspection procedure l
21 before?
22 A Not to my knowledge.
l O
l
\
339 1 Q Had he ever been subject to disciplinary action C)
\m, 2 before?
3 A I don't recall.
4 Q You recall writing Mr. Hunter up for reading a 5 newspaper?
6 A Not offhand. I may have.
7 Q Do you recall any serious violations of site 8 procedures or policy by Mr. Hunter prior to the instance that 9 led to his termination?
10 A Right at this particular time I don't recall any.
11 Q Do you recall Mr. Simile bringing a matter to your 12 attention where he said he observed Mr. Hunter reading a 13 newspaper on the job and you wrote him up?
14 A I don't recall, I may have.
15 Q Are you aware that Mr. Hunter customarily came in 16 an hour early in the mornings and read the newspaper before 17 work started?
18 A Yes, sir. I used to talk to Mr. Hunter.
19 Q Did you used to observe him reading the newspaper in 20 the morning prior to work?
21 A Yes.
22 Q Is that a_ violation of company policy or procedure O
340 1 A Not before work time, no.
kO,/ 2 Q ent,
- >d HowaboutMr.dk4947didhehaveanyprior 3 disciplinary record?
4 A Not as far as I know.
5 Q Do you know whether Mr. Lewis had any prior record 6 before he was terminated?
7 A I think I had talked to Mr. Lewis once about his 8 sloppiness in his paperwork.
9 Q Do you recall ever having talked to Mr. Hunter about 10 sloppiness in his paperwork?
11 A offhand I don't recall.
12 Q Did you have an opportunity to observe Mr. Hunter's 13 prior work performance, prior to termination?
14 A You mean actually go out with him?
15 Q No, observe him in the course of his work as a QC 16 inspector.
17 A In the office here, yes, he's very busy all the 18 time.
19 Q What is your opinion of Mr. Hunter's work 20 performance?
21 A Well, I thought Mr. Hunter was an average good 22 inspector.
- O
341 1 Q Did you identify any deficiencies in his work 2 performance?
3 A Not that I recall.
4 Q Are you aware of any association by Mr. Hunter with 5 the Local 306, the Union of the Comstock QC inspectors?
6 A I don't know whether Mr. Hunter was for or against 7 it. I know when I -- I never really talked to him on that 8 subject.
9 Q You weren't aware of what position he had on that 10 subject?
11 A No , sir.
12 Q Are you aware of Mr. Hunter having expressed O
G 13 concerns previously about the inspection program at Comstock?
14 A I don't specifically recall that specific one.
15 There were so many concerns that everybody was raising at the 16 time. That individual one doesn't really cross my mind. It 17 could have.
18 Q I'm not focusing on any specific individual concern, 19 but are you aware that Mr. Hunter had, in general, expressed 20 concerns about the Comstock inspection program in the past?
21 A Might I ask to who or how?
22 Q I could be more specific and I will, but are you O
342 1 aware generally of whether Mr. --
2 A In general, I think he did.
3 Q Did he bring any to you?
4 A Not that I recall, that he came to me with any.
5 Q Are you aware of whether Mr. Hunter ever complained 6 to the Nuclear Regulatory Commission, expressed concerns to 7 them?
8 A After the 20 went over there and I found out about 9 the 20, after a period of time I understand he was probably 10 one of them.
11 Q How did you understand that?
12 A I think it was brought out in a discussion that I 13 had had previously with the Commonwealth Edison attorneys.
- 14 Q Are you aware that Mr. Hunter had a deposition taken 15 in the Braidwood licensing proceeding?
16 A I understood he was going to have one.
17 Q Do you have any knowledge of whether Mr. Hunter had 18 any contact with the Intervanors in the licensing proceeding, i 19 with BPI or the lawyers for the Intervenors?
i j 20 A No, sir, I didn't pry into his personal business.
21 Q Are you aware of any statements or concerns that 22 Mr. Hunter made to Quality First?
4 343 1 A To the best of my knowledge, not that I can recall.
2 Q Has anyone brought to your attention a statement 3 Mr. Hunter made to Quality First on or after his termination?
4 A No, sir, I am not aware of what he said to them.
5 [ Discussion off the record.]
6 BY MR. GUILD:
7 Q Mr. DeWald, I'm going to show you a letter that is 8 dated February 7, 1986 from Ms. Kezelis, Counsel for the 9 company, to me. First of all, have you ever seen that before?
10 [ Witness reviewing document.]
q- 11 A I don't recall whether I have seen this particular 12 letter or not.
13 Q The substance of the letter is Notice to the 4 14 Intervenors that the lawyers for Commonwealth Edison Company 15 propose to provide you and a number of other persons, Comstock 16 management people and Mr. Preston of Quality First, with what 17 is described .aus confidential information, again to you among 18 others, subject to a protective order that the Licensing Board 19 in the Braidwood proceeding has entered. And I'll explain i
20 that that confidential information consists of the names or 21 identifying information regarding certain Comstock inspectors 22 who provided statements to the Nuclear Regulatory Commission, i
l O
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+ is #
. . u-3 g. I. 344 s
1- and who have'been identified as -- at the time were identified 2 as prospective witnesses in the proceeding.
3 You signed an Affidavit of Nondisclosure, did you 4 not?
p t
'^ A Yes, sir.
j53 ..
.. y, (6 .;
s Q Apdl you have just testified that Ms. Kezelis or 7 . Counsel forithe Applicant provided you information concerning i '
8 -- the names of persons who contacted the NRC; is that correct?
9 A Yes ,"3dir. ,
10 Q And Mr. Hunter's nams was among those?
.?s -
et 4 11 A Yes, sir.
m' 12 % (Discussion off the' record.] -
13 BY MR. GUILD:
14, Q I show you two documents, Mr. DeWald; they are Read
\ '
s 15 -
N and' Reply memos from Mr. Hunter to you, among others. The
( ,
3 - (
16 '
first is,6/28/85 and the second is 7/12/85, both on the
~
.P 17 general subject of Training. Let me ask if you recall seeing es -
18- th'ose memos.
19 [ Witness reviewing document.] *
.' 20 A I may have seen them. I don't recall every specific 21 piece of documents that is submitted. I may have seen them.
22 . UILD: Let's mark these together as the next
% 4,tm =
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+ w.^*, ,
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y- . . - , , , - ~ < , , , ,,-,-,r-- -n,- ,-, '. . , - - . . - - - , - - - - -
. - . -- = ~. - . - -
345 1 exhibit, please.
, (
~\_) 2 (DeWald Deposition Group Exhibit No.
3 18 was marked for identification.]
4 BY MR. GUILD:
5 Q The 6/28 memo states that Mr. Hunter is requesting 6 training in any complete certification. It's addressed to 7 you, Mr. Simile, Mr. Cordy, Dave Cordy -- who is Mr. Cordy?
8 A He was a training coordinator.
9 Q Was at that time?
10 A Yes.
11 Q Is he now?
12 A No.
/ 13 Q What happened to Mr. Cordy?
}
14 A I think Mr. Cordy quit -- oh, no, wait a minute. I 15 think Besco terminated him because of his absenteeism.
16 Q Mr. Hii -- who is Mr. Hii?
17 A He was a supervisor at the time.
11,8 Q Mr. Hunter's supervisor, okay. There is the memo 19 and then what appears to be added later the notation, in the
- 20. same handwriting, I presume Mr. Hunter's, "No reply was
, 21 given. RDH." I assume Mr. Hunter's initials. Do you recall 22 replying to Mr. Hunter's request for training in June of '857 0
- - ~ , - - , - -. ,, -, ,-. .- ,+-- .--- , , , , - - - ,- ------,--v, - - - - , -
346 1 A I don't recall replying to it, no. Like I say, I 2 get so many of them it's hard to recall whether I replied to 3 them or not.
4 Q The July 12, 1985 memo is entitled Training 5 Configuration. It states, "I would like to take my practical 6 configuration examination as soon as possible. All other 7 aspects for certification have been completed." You don't 8 recall receiving this memo, either?
9 A Like I say, I may have. I don't.
10 Q Again, on the bottom of the reply portion there is 11 the aandwriting, "No reply was given. RDH." Presumably, 12 Mr. Hunter. Do you recall replying to Mr. Hunter on that 13 subject?
14 A Offhand, I don't recall replying to it.
15 Q Do you know whether or not Mr. Hunter was ever 16 provided a practical configuration examination?
17 A Offhand, I don't. But I think he was certified in 18 configurations.
19 Q And if he was, he would have had to have taken a 20 practical exam?
21 A Yes.
22 Q Do you recall how much after July of '85 he was O
347 1 certified in configurations?
2 A No, I don't.
3 Q Was there a specific procedure for the AVO, avoid 4 verbal order, corrective action program?
5 A Yes, there was.
6 Q Can you identify that, please?
7 A I think it was a supplement to NCR-1996 I believe, 8 which was in one of those memos.
9 Q I'm sorry, what memos?
10 A The one you showed me this morning here.
11 Q Oh, the one on the subject of the AVO program. That 12 sounds logical. That is Exhibit 15, January 3rd, 1985, 13 " Attached is the AVO review program," and this is a proposed
)
14 procedure for dispositioning LKC NCR-1996; correct?
i i
15 A Yes, sir.
16 Q And was this procedure adopted?
17 A I believe it was approved from CECO.
18 Q In the form in which it is proposed?
19 A I'm not sure that it is in the exact format. This
- 20 is the method they were going to use in order to review and
?
21 possibly reinspect the AVos if it was necessary, t
22 Q Do you know whether or not -- well. Was this i
1 O
l
348 1 procedure adopted as a formal Comstock procedure?
2 A Not as a formal procedure. It was a supplement to 3 the NCR as to the disposition of the corrective action.
4 Q Was Mr. Hunter and Mr. ggy 7 aMAb and the other inspectors 5 who performed inspections under the AVO program trained in the 6 AVO procedure?
I 7 A I don't recall whether they were or not, but the 8 inspection itself would not actually even fall under the 9 possible procedure. Inspecting through paint would have no 10 bearing at all on that particular thing there.
11 Q Well, aside from whether it had any bearing or not, 12 do you know whether they were trained under the AVO procedure?
/% 13 A I don't know whether they had any training procedure b
14 or not on it.
15 Q Do you know whether they were provided with copies 16 of the AVO procedure?
17 A I don't know that either.
18 Q Was anyone provided with copies of the supplement to 19 the NCR or the AVO procedure -- anyone who performed work 20 under the AVO program?
21 A The people doing the review I'm sure had it, but I
- 22 don't know exactly if they had it in their hands.
\
V l
1 i
1- 349 a l
- I
- j. 1 (Discussion off the record.] l 2 MR. GUILD: That is all the questions I have. Thank 3 you, Mr. DeWald.
4 e
i 5
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350 1 EXAMINATION f
- (}/ ' 2 BY MR. BERRY:
3 Q Mr. DeWald, could you tell me when Mr. Martin -- or 4 when Mr. Hunter was terminated?
5 A I believe it was the end of March.
6 Q This year?
7 A Yes, about two weeks ago. Maybe three.
8 Q You may have answered this question. Have you had 9 an opportunity to review Mr. Hunter's deposition?
10 A No, sir.
11 Q So you are not aware that Mr. Hunter had identified 12 you as one of the inspectors that had inspected 1000 welds in 13 a day?
14- A Not particularly Mr. Hunter, no, sir.
15 Q The welds that Mr. Hunter was inspecting, I think 16 you testified that they were being reinspected?
17 A Yes, through the AVO program or system, and through 18 the AVO program if we do not have an inspection that was after 19 the AVO had been written and closed, then we had to go out and 20 reinspect so that we had an inspection after this AVO had 21 either been reworked, or whatever the case might be, to the 22 AVO.
O f
. . - . -. . , - , - - - -,. -r , , _ , _-.--y.-
.---.y -.- ---
--,-__--y .e, .e...-,-
351 4 1 Q Perhaps you could explain to me just a little better 2 the circumstances. I'm not quite sure I follow.
J
. 3 A The AVO in past years prior to our initiating a 4
- 4 rework procedure was used for reworking of items. It was used r
5 for some other type of direction which you may want to clean 6 the reel yard or -- there was a various conglomeration of 7 different things they used the AVO for. But the one main 8 concern that we had when we initiated the rework program is 9 that there were reworks done in the field through the AVO t-itself, and there was no tracking method as-to the AVO to get 10 4
11 back to us to insure that we had a current inspection and had i
12 inspected what the AVO had instructed to do.
l 13 Q There might be a simple answer to this.
( } Mr. Hunter 14 had inspected the welds through the paint and that was 15 discovered by the PTL when they did their sample reinspection 4 16 of his work.
17 A Yes, sir.
i 18 Q How would you know, for example, that the welds 19 hadn't been painted after the inspection but prior to the PTL 20 reinspection?
21 A The PTL overview, they come in every' day and they 4
22 take photocopies of the inspections. They take a percentage O
~ . _ _ ~ __ ._ _ ... _ .~ _ __.-__ ..~ _.___ _ _ . . _ _ _ _ _ _ _ _ _ . _ _ _ _ . - _ - _ _ . , _ . -
235 1 UNITED STATES OF AMERICA l
2 NUCLEAR REGULATORY COMMISSION 3 BEFORE THE ATOMIC SAFETY & LICENSING BOARD 4
5 - - - - - - - - - - - - - - - - - -x l 6 In the matter of: : Docket Nos. 50-456 7 COMMONWEALTH EDISON COMPANY : 50-457 8 (Braidwood Nuclear Power Station, :
9 Units 1 and 2] :
10 ------------------x 11 Isham, Lincoln & Beale 12 Three First National Plaza
>g 13
[b 14 51st Floor Chicago, Illinois
~
15 April 8, 1986 16 Deposition of: IRVING FRANK DEWALD 17 called for examination by Counsel for the Intervenors BPI, et 18 al., pursuant to notice, taken before Suzanne B. Young a 19 Notary Public in and for the District of Columbia, when 20 -------------------------------
21 ANN RILEY & ASSOCIATES, LTD.
22 1625 I Street, N.W. 293-3950 Washington, D.C.
i
- O
.~ _ _ _ _ _
236 1 were present on behalf of the respective parties:
() 2 3 APPEARANCES:
4 For the Licensee Commonwealth Edison Company:
5 ELENA KEZELIS 6 ATTORNEY-AT-LAW 7 Isham, Lincoln & Beale 8 Three First National Plaza 9 Chicago, Illinois 60602 10 1
11 For the Intervenors BPI, et al.:
12 ROBERT GUILD, ESQ.
I 13 109 North
Dearborn,
Suite 1300 14 Chicago, Illinois 60602
~
15 16 o For the NRC Staff:
17 GREGORY ALAN BERRY, ESQ.
18 office of the Executive Legal Director 19 Nuclear Regulatory Commission 20 Washington, D.C. 20555 21 22 i
O n.-
352 1 of each inspector and they go out and do his work; it may have O
\s) 2 been that day or the following day that they had performed the 3 overview on his inspections.
4 Q You are familiar, are you not, Mr. DeWald, with the 5 Intervenors' -- the quality assurance contention?
6 A Yes, sir.
7 Q I believe it is Contention -- off the record.
8
[ Discussion off the record.]
9 BY MR. BERRY:
10 Q Mr. DeWald, do you know whether in lieu of 11 performing a visual inspection of these welds after having the 12 paint scraped off, Mr. Hunter used an alternative inspection 13 method -- say, magnetic particle, for example?
14 A No, sir. He did not because if he would use the 15 magnetic particle, PTL would have had to have gone out and 16 performed that mag particle. The only thing Comstock does is 17 a visual weld inspection.
18 Q The relationship that Comstock has with BesCo; as I 19 understand it, Comstock provides the managerial administrative e
20 services and BesCo supplies the manpower?
21 A We manage the QA/QC program as per our manual.
22 Besco supplies us the qualified inspectors. We train them,
353 >
1 certify them and we supervise the inspections that they 2 perform.
3 Q BesCo hires them, though?
4 A Besco hires them and BesCo terminates them. BesCo 5 watches over their absenteeism, takes care of their personal 6 problems. All the Union-related problems. Like I say, 7 Comstock just manages the QA/QC portion and the inspections of 8 the work being performed.
9 Q Do I understand your testimony to be that BesCo 10 fired Mr. Hunter, and not Comstock?
11 A Yes, sir. We returned him to Besco for their 12 disposition.
13 Q Now had their disposition been, for example, that it 14 was an honest mistake or an unfortunate occurrence but in 15 spite of his work record and his long history he has been 16 properly counseled and we don't think it will happen again, 17 and returned him to Comstock -- would you have had to accept 18 him?
19 A No, sir. We can either accept him or reject the 20 individual.
21 Q Are there any guidelines or any policies or protocol 22 between Comstock and BesCo that speaks to the reasons or O)
~ -.
354 1 circumstances, the instances in which Comstock can refuse a 2 particular inspector on the work force?
3 A I think there is something in the Union contract 4 that we can refuse the individual, and I think that's where it 5 correlates between Comstock and BesCo.
6 Q Do you know which particular provision or the 7 substance of the provision that would govern in this instance, 8 that would authorize Comstock to refuse Mr. Hunter's 9 redeployment back to the site? Do you understand the 10 question?
11 A Not really fully.
12 Q What I am driving at is what reason does Comstock 13 have -- strike that.
14 What is to prevent Comstock from just telling or 15 saying, BesCo, we don't want this guy and we're not going to 16 take him?
17 A We can do that, but we have not done that other than 18 substandard work such as --
19 Q You see, the concern that I have is what's to say 20 that it's not unfettered or arbitrary authority or power of 21 Comstock to say, for example, this guy, he went to the NRC and 22 I don't want him on the site. And they tell BesCo, I don't 1
355
'l want him on the site. Doesn't that just effectively terminate 2 him? Is there any danger of that?
3 A In my own opinion, no. I think everybody is looked 4 at and given a fair shot. I might add Mr. Lewis would fall in 5 the same category as Mr. Hunter did, under substandard work.
6 Q So for example, if an inspector -- well, I take it 7 an inspector that violates procedures or an inspector where 8 there are serious questions raised about his integrity, for
,9 example, that might be a reason why Comstock would impress
'10 upon Bosco not to deply that person onsite?
11 A The way they send us the individuals is we put in 12 the ordert we'll tell them we want an electrical type or a 13 welding type and they'll -- however they get them through the 14 Union, and then they send one over. And usually, in some 15 cases, they give us a resume; in some cases they don't. They 16 send it over and then we have to take and review to see if the 17 individual is qualified and meets the qualifications.
18 Q The welds that Mr. Hunter inspected through paint, 19 what happened to them? Was the paint scraped off and the 20 welds reinspected?
21 A They were in the process of being reinspected, yes.
22 Q Have any of them been reinspected?
O
356 1 A Not yet. To the best of my knowledge they haven't.
2 Q So they could turn out ultimately -- the welds could 3 turn out to be deficient or be acceptable.
4 A Correct.
5 Q Mr. Martin is still on the site, though?
6 A Yes, sir.
7 Q Was there any investigation to corroborate whether 8 Mr. Martin had, in fact, reproduced inspection checklists?
9 Well, strike that.
10 Mr. Martin, I believe you testified, was identified 11 as a person who copied inspection checklists in contravention 12 of procedures; did he not?
i
() 13 14 A Yes, sir.
Q Do you know why he wasn't terminated, or why he is i
15 still working on the site?
16 A Yes, sir. At first I had wanted to terminated him 17 when I found out. I investigated a little farther and a 18 previous supervisor that had been there by the name of Mike
/n6T .$bb 19 +Gast had allowed that to go and stopped it. Although 20 everything that Mr. Martin had pre-checked we have since then 21 reinspected. And I felt then that he had had bad direction.
22 What was the supervisor's name?
KAsr dad Q Mr. Cast?
O
357 fh5I 1 A Mr. Mas .
O
\s ,/ 2 Q KA6r Mr. <Mude knew that it was a violation of procedure, -
3 did he not?
4 A I would assume he did, sir, because I had worked 5 with him earlier and Mike seemed to be fairly sharp, but he 6 was gone after I got there.
7 Q So you don't know if he was disciplined for --
8 A Not at that time, no. And this was kind of after 9 the fact. He had done this in 1982 and this was picked up in 10 an audit in '83.
11 Q It just struck me that the potential of Mr. Martin's 12 conduct struck me as a little more serious than Mr. Hunter's,
( 13 and I just wondered if you had any thoughts on that.
L
! 14 MS. KEZELIS: Is that a question?
15 MR. BERRY: It wasn't a question but --
16 THE WITNESS: I think Mr. Martin was given some bad 17 direction at the time, back in 1982. And I know Mr. Hunter 18 knew better at this particular point in time.
19 BY MR. BERRY:
20 Q Mr. DeWald, are you aware that the NRC conducted an 21 inspection into the allegations of the various comstock 22 inspectors that came to the resident inspectors on March 29th, O
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358 1 1985?
2 A I'm aware they did.
3 Q Are you aware also that the NRC has issued a report 4 setting forth their findings on that investigation? ,
5 A I believe they did. I'm not sure whether I have 6 seen it. I may have. I have read so many. The reason I'm 7 aware of it is I have sat in on many exit interviews.
8 Q Mr. DeWald, it has come to light in prior 9 depositions that there was a meeting held between the NRC and 10 Commonwealth Edison on March 29, 1985. This was late in the 11 afternoon after the inspectors had gone to the NRC, and 12 Commonwealth Edison I guess was notified -- or NRC notified 13 Commonwealth Edison that they had received various allegations 14 from inspectors, and the inspectors -- Commonwealth Edison 15 indicated that they were going to look into it and come up 16 with an action plan, short term and long term.
17 One of the points of the short-term plan -- well,
- 18 let me back up. Are you aware of these meetings?
19 A I am not sure of that particular meeting, but I 20 think as you are going on here I may be aware of what you're 21 leading up to.
22 Q If at any point you don't understand anything or I O
359 1 am assuming too much, just stop me. But apparently, one of 2 the points in the short-term plan was a neeting that was to 3 take place the following morning. This would have been a 4 Monday, April 1st, 1985.
5 Mr. DeWald, I show you a copy of what has been 6 marked in a previous deposition as Neisler/Mendez Exhibit 7 No. 7. It's a March 29, 1985 memorandum from Mr. McGregor and 8 Mr. Schulz to Mr. Warnick and Mr. Williams. The subject is a 9 telephone conference call with Commonwealth Edison in regard 10 to L.K. Comstock Quality Control Program.
11 You will note that on page 2 of that memorandum it 12 summarizes the short-term action plan developed by 13 Commonwealth Edison to respond to the allegations that had 14 been received by the NRC, and in Part 3 of the short-term plan 15 it's indicated that Commonwealth Edison is setting up a 16 meeting with all of the quality control personnel of 17 L.K. Comstockt u.anagers, supervisors, inspectors, to do 18 various things.
19 Do you recall if such a meeting took place?
20 A Yes, sir, there was a meeting on the 1st of April.
21 Q Did you attend the meeting?
22 A Yes, I did.
O
360 1 Q Could you tell us what took place at the meeting?
2 A Commonwealth Edison assembled a whole group. They 3 indicated that there had been various inspectors who went to 4 the NRC; that there were various allegations made, and if 5 there were anymore allegations they would like them to be 6 known as they were investigating it. And if they didn't feel 7 like coming forth in the meeting,.they were more than welcome 8 to go over to Quality First and disposition -- or let their 9 allegations or concerns be known.
10 Q Do you recall how long this meeting lasted?
11 A Roughly I would say 20 minutes to athalf an hour, 12 possibly.
13 Q At this time, Mr. Saklak had been terminated, or had 14 been placed on administrative leave, I believe.
15 A Yes, sir.
16 Q Were the inspectors notified that that action had 17 been taken at this meeting?
18 A I'm not sure whether that was brought up, that 19 Mr. Saklak had been suspended. They did bring out that 20 Comstock was requested to enforce their policy statement, 21 1.0.0 --
22 Q Which was?
O
361 1 A It's the first section of our QA/QC Manual which 2 says we authorize or delegate the hiring and firing and 3 promoting and so on for the company.
4 Q Well, do you know if at any time the QC inspectors 5 had been advised that Mr. Saklak had been removed from his 6 position because -- or the reasons why Mr. Saklak had been 7 removed from his position?
8 A I think that was brought out in that meeting; that 9 harrassment and intimidation will not be tolerated by either 10 Edison or Comstock.
11 Q Do you recall speaking to either Mr. Mendez or 12 Mr. Neisler or both of them during the period between April 13 30th and September 5th, 1985? And that was the period in 14 which they were conducting their investigation of the 15 allegations.
16 A I may have.
17 Q Your counsel has made available a copy of the 18 inspection report authored by Mr. Mendez and Mr. Neisler 19 regarding the allegations of the QC inspectors, and I would 20 ask you if you have seen that report before.
21 (Witness reviewing document.)
22 A I think I have.
1 O
362 1 Q This is DeWald Deposition Exhibit No. 13; this is 2 the memorandum to Mr. Mennecke and Mr. Quaka from you dated 3 May 21st, 1984. I notice there's a cc to Mr. F. Rolan.
4 That's Frank Rolan?
5 A Yes. He's the project manager.
6 Q That's Construction?
7 A Yes, sir.
8 Q I note that the memorandum itself is regarding 9 Mr. Puckett and his resume. Was this memorandum issued after 10 Mr. Puckett had been hired or while the decision whether to 11 hire him was still being deliberated?
12 A He had been hired, I believe, but it's standard
( ) 13 practice; you bring in supervision type individuals, Level 14 III's, onto the site and Edison has to give their approval.
15 This is the letter asking for Edison's approval.
16 Q So is Mr. Rolan an Edison employee?
17 A I just informed him because our contract is --
18 Comstock is two separate -- one separate company. We have 19 other smaller companies within Comstock. Comstock 20 Engineering, which I work for, is contracted to do QA/QC work 21 for the construction company. It's a matter of formality to 22 let him know --
O
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i <
! 363 i
1 Q so when it says, "Please reply as soon as possible I
( 2 on your review and approval," -- Mr. Rolan doesn't have any 3 approval --
4 A No, sir. This is strictly to CECO. The only thing i
j 5 Mr. Rolan would have to do is billing expenses and so forth. ;
- i j 6 Q You worked with Rick Martin as -- strike that. !
4
! 7 Were you ever Mr. Martin's supervisor, welding i
8 supervisor?
9 A I was acting like a supervisor at the time I was 4
- 10 here before.
11 Q Well I mean, have you had an opportunity, or did you j 12 ever have an opportunity to evaluate Mr. Martin or observe 13 Mr. Martin's work, his welding inspecting performance?
14 A When I was here in 1980 and '81 when he first became li 15 certified. r 16 Q Is he a good inspector?
1 17 A I think he is a conscientious inspector.
j 18 Q Mr. Martin has been identified in a-previous
[ 19 deposition as another inspector that had performed 1000 weld 20 inspections in a day. Had you ever heard of that?
21 A I have heard of it, but I don't believe -- it was 22 over a period of time, several days.
a i
O
364 1 Q Similar to how you described you do your 2 inspections?
3 A Yes.
4 Q Was that the common practice? I mean, was that the 5 practice onsite at that time?
6 A Yes, sir, at that time.
7 Q Mr. DeWald, I direct your attention to page 14 of 8 the inspection report. I believe this inspection report has 9 been marked in a previous deposition as Naisler/Mendez Exhibit 10 No. 8. It is page 14 and there's a concern, and it is heading 11 No. 4. And this concern -- here, the NRC inspectors are 12 addressing a concern raised by one or more of the QC 13 inspectors that apparently some inspector had inspected 93 14 hanger inspections on one checklist containing 1100 to 1200 15 welds, and they were signed off on one day by an unidentified 16 inspector.
17 Are you aware that that inspector -- that was 18 identified to be yourself?
19 A No, sir.
J 20 Q Did you talk to either Mr. Mendez or Mr. Neisler?
21 Did they speak to you about this allegation?
22 A I don't recall whether they talked to me on this i O L
i 365 1 particular one or not.
2 Q Don't you recall Mr. Mendez asking you if you had 3 ever accepted 1000 welds in a day?
4 A That particular statement I really don't remember 5 him asking me.
6 Q I direct your attention to the NRC review, the 7 second paragraph, and it describes that a similar concern was 8 examined by the NRC inspectors regarding another QC inspector 9 who in 1980 had documented the acceptance of 129 hangers and 10 1215 welds on one inspection checklist. Do you know if 11 Comstock or Edison or the Applicant has taken any action to 12 look into, or has looked into this to see if in fact 1215 13 welds were inspected in a single day?
14 A I don't remember. I don't recall if there's any 15 action been taken on that.
16 Q Were you aware of this concern prior to my direction 17 your attention to it?
18 A Now that you have brought it out, yes, I remember 19 reading this.
20 Q I direct your attention to page 25 of this 21 inspection report, Neisler/Mendez Exhibit No. 8, and the first 22 full paragraph.
O
366 1 A Page 24 is the last page I have.
2 Q It's under the heading NRC Inspector Summary that 3 starts at page 24 and it states the inspectors' conclusions 4 and overall summary of their investigation into the 5 allegations that had been brought by the QC inspectors on the 6 29th of March. And in their report they conclude that "The 7 problems between LKC management and QC inspectors generally 8 stem from a lack of communication between management and 9 employees and the bullying tactics of one QC supervisor who 10 was removed from the construction site."
11 A Yes, sir.
12 Q Do you agree or disagree with that conclusion?
13 A of the supervisor? Yes.
14 Q Yes, you agree?
15 A With the supervisor's statement. As far as the 16 management -- I had an open door policy. If they wanted to 17 come in and talk with me on any subject, they were more than 18 welcome to do it and I would sit and listen. But very few 19 came in, if any.
20 Q How about the other managers there? Did they 21 similarly have an open door policy?
22 A Yes, sir. Mr. Seese talked to them all the time.
O
l 367 J l Q There has been reference made in a previous 2 deposition to -- I believe it's in the inspection report as 3 well -- that there has been some companies that instituted 4 some management training programs to, for lack of a better 5 word, sensitize management and supervisors in management 6 skills and things. Are you aware of that?
7 A Yes, sir. Edison supplied the instructor and we 8 went for a week, half days, to a management type training that 9 Edison gets themselves.
10 Q Do you recall when that was?
11 A The exact month, I'm not sure whether it was August 12 or September of '85.
13 Q So it was after the incident on the 29th of March?
( }
14 A Yes, sir.
15 MR. BERRY: I think that's all I have.
16 MR. GUILD: I have a couple of follow-ups from 17 Greg. I can wait until after you.
18 MR. BERRY: I just have one more question.
19 BY MR. BERRY:
20 Q Mr. DeWald, you testified earlier that back in 21 previous years, it was common practice to inspect on a grid i
22 system; that you had your coordinates and you would inspect O
368 1 all the welds within that coordinate and document it at some 2 time in an inspection report.
3 A Yes, sir.
4 Q What is the practice now? -
5 A You document the inspection at the ime of the 6 inspection. /
7 Q Now within that, do you document the individual 8 welds or a component with tha number of welds?
9 A You do a component with the number of welds.
10 Q How does one determine or assure themselves that the 11 particular welds on the component have, in fact, been 12 inspected? I mean -- well, go ahead.
13 A Yes. It is made in the Fab Shop. It has the unique 14 Fab Shop number on it now which would be FS and whatever the 15 number might be. This is inspected in the Fab Shop. When it 16 comes out and is installed it ham.two attachment welds. The 17 inspector doing the inspection at the time will usually 18 document he has done two attachment welds and there were six 19 Fab Shop welds, or whatever the case might be.
20 Q Well, some of these' inspection reports that had 21 accomplished hundreds of welds, do you know if those --
22 generally, was that just an instance of hundreds of components O
a
369 1 with the two attachment welds, or are they inspecting 2 different welds, welds that had been made in the field?
3 A These hangers -- in the earlier part of the 4 construction these hangers were fabricated by Systems Control 5 or Mechanical, Inc., and the only welds that Comstock would do 6 would be the attachment welds either to the ceiling or to the 7 floor, or the attachment welds to the structure somewhere.
8 Q There has been testimony that I believe it was in 9 April of '84 or '85 a new pay schedule went into effect; that 10 there was a uniform pay scale, 50 cents per hour extra per 11 certification.
12 A Yes, sir.
() 13 14 Q Is that pay scale still in effect now?
A No, sir. When BesCo took over, they had their own 15 pay scale and I'm not sure what their pay scale is.
16 MR. BERRY: Thank you, that's all.
17 18 19 20 21 22 O
5~
370
.N'
.s l' EXAMINATION
,.. V b 2 BY MS. KEZI:LIS:
'( ' 3 Q During the earliar-aspects of your deposition, 4' Mr. DeWald, I believe you testified regarding an Exhibit No. 5 5 which was a PTL cover sheet and a Form 19. You may have been 6 asked whether you could tell from that document which welder
- 7 performed the particular welds involved on'the basis of that 8 record. Do you recall --
rd' A Yes.
10 Q -- your testimony in that regard?
11 .A Yes.
12 ,
Q Eow can one establish traceability of a weld to a
- 13 particular welder?
14 A You can go back to the installation report and 15 obtain the welder's name anh go into the welder hammer log and 16 you can identify the welder through that method.
E/
17 Q In other words then, there are other documents which
~i 18 are available through which the identity of the particular 19 welder who performed a particular weld can be determined; is
'/
20 that correct?
21 A Yes.
22 Q The grid locations'by which weld inspections were O
~
371 1 performed in earlier days, as you testified I believe when you p
(s,) 2 were a QC inspector at the site, the grid locations, were they 3 pre-established or were they identified after the fact, after 4 a particular inspection?
5 A The grid locations are identified right on the EI 6 drawings, which is the installation drawing. Such as L to Q, 7 M to P. It may be on one particular drawing that covers 8 various areas in there, and these are still identified on 9 these particular drawings.
10 Q And what are EI's?
11 A That is the Electrical Installation Drawing.
12 Q You also testified in the course of your deposition l
13 last week that Mr. corcoran was quality oriented, not
( }
14 construction oriented, or words to that effect. Can you tell 15 me what you meant by the term not construction oriented, when 16 you used it?
17 A Mr. Corcoran didn't understand the nuts and bolts of 18 the aspect of the installations that takes place with the 19 process; that take place during the construction phase. And 20 through not understanding completely this process, he was not 21 getting the job done that he was supposed to be.
l 22 Q Let me now show you a document which is Bates l
i i
372 1 stamped A0015955 and it is a document to L.K. Comstock from an 2 auditor named E. Mazur and Mr. Quaka of Edison. I believe it 3 deals with a CECO calibrations audit, and I'd like you to take 4 a look at this and tell me if you can identify the handwritten 5 notation on the bottom righthand corner of that document.
- 6 [ Witness reviewing document.]
7 A Yes, it is mine.
8 Q It is? All right. Let's have this marked as the 9 next deposition exhibit.
10 [DeWald Deposition Exhibit No. 19 11 was marked for identification.]
12 Q Can you tell me what your handwritten notation in.
( 13 the bottom righthand corner of that document says?
14 A That's a notation I made on September -- excuse me, 15 July 12th, 1984, indicating that from this memo I knew that 16 previously Mr. Seeders was doing a 100 percent review.
17 Q And that was a 100 percent review of calibration 18 records?
19 A Yes.
20 Q Mr. DeWald, have you personally performed 21 calibration inspections at Braidwood?
22 A I, myself?
f O
1 373 1 Q Yes.
2 A No.
3 Q You also testified during the course of your 4 deposition last week that you had met with Mr. Shamblin, 5 Mr. Seltmann, Mr. Schulz of the NRC and Mr. Gieseker to 6 discuss Mr. Seeders. Do you recall that testimony?
7 A Yes.
8 Q I believe you also testified that you had had a 9 meeting in August regarding Mr. Seeders with those people and 10 that eventually you decided to transfer him effective 11 September 1st, 1984. Are those dates correct?
12 A Would you repeat that once more?
[d
'i 13 Q All right. I believe you testified that these 14 meetings took place in August. Could you perhaps have meant 15 September of 19847 16 A Yes, because I think his transfer became effective 17 on the 1st of October.
18 Q Of 1984?
19 A Yes.
20 Q In connection with your testimony regarding 21 Mr. Worley Puckett, I believe you mentioned Sargent & Lundy's 22 Status 2 comments. Can you explain to me what Status 2 O
4
374 1 comments are at Sargent & Lundy?
{~h (m,) 2 A Status 2 comments are after we sent the procedures 3 through for review and final approval, Sargent & Lundy gives a 4 final approval of the procedures, and if they disagree with 5 something that is written in the procedures, they will send 6 back a Status 2 comment, which we then have to incorporate 7 into the next revision and send it back for approval.
8 Q All right. Do Status 2 comments prevent work to the 9 revised procedure or the procedure under consideration, or may 10 work continue with a Status 2 comment?
11 A Work may proceed with a Status 2 comment.
12 Q And does the work that continues with a Status 2
( }
13 comment revis' ion incorporate the Status 2 comments that 14 Sargent & Lundy has sent back to comstock? In other words, 15 the work that continues once you have received the Status 2 16 comments back, is that work performed in accordance with the 17 Status 2 comments from Sargent & Lundy as well?
18 A Yes.
19 Q You also made mention in connection with Mr. Puckett 20 about some test coupons that were available at Comstock at the 21 Training Department. Can you tell me what those test coupons 22 wero, briefly?
l O
1 l
375 1 A Those coupons were made up by our corporate Level 2 III welding engineer, Tom Vogt, and with that he had left a 3 scoring record or a score sheet as to how to grade these 4 particular problems that were on the coupons.
5 Q And are these the coupons that were presented to 6 Mr. Puckett for his practical examination?
7 A Yes. The last one.
8 Q And that took place in August of 1984?
9 A I think it was August.
10 Q And what is L.K. Comstock's procedural requirement 11 with respect to practical examinations in terms of the grade 12 that must be achieved?
13 A On the accept / reject, it's 100 percent per the (V~)
14 procedure.
15 Q And these test coupons constituted the accept / reject 16 test?
17 A Yes.
18 Q In connection with a discussion regarding the 19 development of a full-time training coordinator position after 20 the April 1984 pay scale changes, I believe you testified that tJ H o c a c ah :.>4TQ 21 Mr. White had come in on June 1st or so to take that position, 22 is that correct?
O
376 1 A Yes.
- 2 Q I believe he had a car accident shortly thereafter?
3 A On the 25th I believe it was, or the 26th.
4 Q And who was his replacement and when did he arrive?
5 A I think it was Jeff Dominique in July, the 15th or 6 somewhere in that area.
- 7 Q This was a few weeks after Mr. White had left?
8 A I believe it was two or three weeks.
9 Q Mr. DeWald, in connection with the concerns that
. 10 -Mr. Asmussen raised to his lead, Mr. Worthington, and your l 11 direction to Mr. Worthington that -- I don't recall the exact 12 words, that if a questionable document cnr component is 13
( ) reviewed and the validity of the total inspection is f
14 questionable, the item or component is to be reinspected to 15 ensure a good, valid inspection has been performed and 16 documented per the required procedure. And I am quoting in 17 some respects from the third page of DeWald Deposition Exhibit j' -18 .No. 17.
19 When you replied to Mr. Worthington in this regard, 20 did you have any reason to believe that Mr. Worthington would 21 then not pass that direction on to Mr. Asmussen?
22 A No, I didn't.
O
377 1 Q In other words then, you would expect
( 2 Mr. Worthington to pass your direction on to Mr. Asmussen; is 3 that correct?
4 A Yes.
5 Q The eighth page of this same deposition exhibit, 6 No. 17, Mr. DeWald, which is the actual inspection checklist 7 signed by Mr. Richard Yanketis, I'd like to direct your 8 attention to the large print stamped " Material" on the face of 9 this document which states, "This is a reconstituted record, 10 .Comstock Engineering QC Department." Let me direct your 11 attention to the initials under the initial section of that 12 document. Can you tell me what those initials are and whose O
O 13 they are?
14 A The initials are DRH, and I believe it's Danny 15 R. Holley.
16 Q And why would Mr. Holley be initialing this kind of 17 document?
18 A He was reviewing the document and he verified that 19 this is a reconstituted document; that the original document 20 was made out in blue ink or blue ink which was a bad practice 21 at the time, back in the early days in '79-and '78, and this 22 is the reason that the documents are reconstituted.
O G
l l
378 1 Q' Are you aware, Mr. DeWald, that Mr. Holley has i 2 complained in his deposition that he had seen documents 4
3 reflecting more than 1000 weld inspections on a single 4 inspection report such as this?
5 A Yes, I am.
6 Q And this stamp on the face of the document leads you
- 7 to conclude that Mr. Holley had made that statement somewhere?
8 A I believe so.
9 Q Do you recall any other circumstances surrounding 10 what you understand about that?
11 A No.
12 Q You also testified about Sargent & Lundy
( 13 configurations walkdown and answered a question of Mr. Guild's 14 reflecting that Mr. Perryman had had a concern about it.
15 After Comstock went to Edison and supplement the NCR and the 16 documentation for this walkdown became sequential so that each 17 aspect of the walkdown was documented, as you testified
'18 already, with the assistance apparently of Mr. Gieseker, were 19 there any additional complaints about this walkdown that you 20 recall or that you heard about?
21 A That cleared up their concern as to the initial 22 inspector signing off for the acceptable inspection.
1 O
J
379 4
1 Q And during the course of your deposition over the
$ 2 last number of days, when you have used the word or the term 3 " signing off" what have you meant when you used that term?
i l
4 A They sign in the " inspector" area, such as on the 5 Form 19 that was previously put out the QC inspector. This 6 is the individual that initially does the inspection has 7 signed off, but the Level II inspector reviews it.
8 Q okay. So in other words, where there is a specific i 9 blank for an inspector to execute or sign and date a document 10 in accordance with procedures, the term " sign off" as you have 7
11 been using it reflects that action; is that correct?
12 A Yes.
() 13 Q There's another term that you have been using, 14 Mr. DeWald, and that is the term " pretense" or " pretext" and
! 15 I'm not sure that all of us use that term with the same 16 meaning or same intention. Do you use that word 17 interchangeably with " context" or " situation"?
i 18 A I say it would be in context. I think that's what 19 you're referring to.
20 Q When you used the word " pretense" have you, at any t
- i. 21 -time that you recall during the course of your deposition, c
22 meant for it to refer to falsification or a pretended O
_ .- - ._ _ _ . ~ . - . . . - -. -. . _ _ . . - - - ..
4 i
380 1 condition of any kind?
l 2 A No.
3 Q You may have used the word " pretense"
]
4 interchangeably -- or the court reporter may have taken it 5 down as " pretext" as well. Is your own use of those words 6 still the same as you have just explained to me; that it is in 7 context or in that situation?
a 8 A Yes.
9 Q You don't mean by pretense or pretext, as you have 10 used those terms in the last few days during your deposition, 4
11 to mean falsification or pretended condition.
12 A No.
O 13 Q Did Mr. Guild exhaust.your recollection in his At.14hr e d 14 questioning of you regarding the Hunter and Arnt situations 15 that you testified about today?
16 A Yes. I don't specifically remember just exactly 17 what was said from one individual to the other individual.
18 Q Do you recall whether during the meeting that you i
19 Aen br 4K7$
attended with Mr. Seltmann and Mr. Aent and Mr. Hunter, 20 whether or not Mr. Hunter or -- strike that -- whether or not 4 21 Mr. Hunter said anything to you along the lines that he had 22 been directed to inspect through paint or that he had been i
?
l
!O l
[
1 l
381 I
1 told to inspect through paint? Do you recall anything along !
-~
'(s / 2 those lines?
3 A He did not indicate that he had been directed, and 4 as far as I know, there was no direction given to inspect 5 through paint.
6 Q Would it have surprised you if there had been such a 7 direction?
8 A Yes, it would have.
9 Q You believe that weld inspectors during the course of their training would understand that inspection through 10 11 paint of a weld is impermissible?
12 A Yes.
() 13 14 Q _Can you describe more specifically the condition of the welds that you recall looking at that Mr. Hunter had been 4
15 involved in?
16 A In the area where they were stamped, if there would 17 have been new paint put on they would have partially covered 18 the stamp, or possibly covering the stamp. Especially in AgghT cV$N 19 Mr. Asnu a case.
20 Q In other words, are you saying that when a QC 21 inspector inspects a weld, he or she places a stamp in the 22 vicinity of the location of that weld?
O
382 1
1 A Yes.
2 Q And Mr. Hunter had placed his stamp, or you saw 3 Mr. Hunter's or Mr. pgubt J>S25 Aent's stamps in the vicinities of those 4 welds?
5 A Yes. It was through paint, and like I said before, 6 if a painter would have came through and painted that, they're 7 not very artistic and they would have gotten some of that 8 particular stamp.
9 Q So that the stamp would have been covered by paint 10 on top of the stamp, had painting taken place after the 11 inspection?
12 A Yes.
() 13 14 Q You also explained or testified that there was some dirt and dust on top of the paint; is that correct?
15 A Yes.
16 Q And that led you and the other people who reviewed 17 these welds to conclude that Mr. Hunter had signed off the 18 checklist for those welds without having the welds cleaned and 19 free from paint?
20 A Yes.
21 MS. KEZELIS: I have no further questions.
22 O
. = - - - .- - _ -
383 1 FURTHER EXAMINATION 2 BY MR. GUILD:
AgdbT 3 Q Just a moment ago you said "especially Mr. Arnt's 4 welds." What did you mean?
5 A We have a policy -- we have changed the weld 6 procedure, 4.1.3 -- or, 4.3.3, excuse me -- and on sheetmetal, 7 the thinner materials, instead of hitting that with that 8 hammer stamp, indenting it, they can mark that with a black 4
9 marker and they put their number, a C and then put their 10 number in there. His was so close to the weld that if 11 somebody would have painted over that they would have
- 12 completely covered the black marker.
!( 13 Q He -- Mr. gar ? 4 14 A Yes.
15 Q As compared to Mr. Hunter's stamp?
16 A Mr. Hunter's was approximately, I would say, an inch
- 17 away from the weld and usually when the painters painted, they-18 are not -- they put the paint over the whole thing. I mean, 19 they are not artistic, and not just in a small area. Like an 20 ordinary painter.
21 Q So when you said especially Mr. meant 22 because his stamp is closer to the weld?
O
+
. . , . , - - - . - -n-. , - - - - , , . .
384 1 A It was very close to the weld.
2 Q This is a particular weld that you were looking at?
3 A Yes.
4 Q One for each; one for Mr. Hunter and one for 5 Mr. Arnt?
6 A Yes.
7 Q You stated earlier, Mr. DeWald, that the practice in 4 8 former times had been to -- the term has been used not by you 9 but by others -- to bank inspections; essentially, do 10 inspections, make notes of those inspection results in say a 11 personal diary or notebook, and document them on a formal 12 inspection document at some later time; correct?
/O 13 A Yes.
. V 14 Q Does that practice continue at all at present?
15 A No, sir.
16 Q How do you know?
4 17 A Because the inspection report is filled out at the 18 time of inspection.
19 Q It was supposed to be filled out at the time of the l
20 inspection the former times as well, was it not?
21 A There was no official direction as to this is when 22 the inspection report should be filled out, at that time.
(
385 1 Q I asked you before, but can you recall now whether 2 there has been any change in the procedure that specifies when 3 the inspector report is filled out?
- 4 A I'm not sure whether the procedure reads explicitly 5 that it will be filled out at the time of inspection, but it 6 is and has been directed to the inspectors that when you do 7 the inspection, it is filled out at the time of inspection.
, 8 Q And can you recall any documentation to that effect 9 of that direction? I asked you that before as well.
{ 10 A I think you did, and I'm not sure. I don't know j 11 whether there is or not.
12 Q Do you know whether or not it was the practice,
() 13 14 under the AVO program, to document inspections the same day that the inspections were performed?
15 A The AVO program, or the Avo's were used from the '
4-2 16 early days up until --
17 Q Let me be clear. I mean to say during the 18 corrective action regarding the AVO program; the closing out J-19 -- the dispositioning of the NCR that addressed the question.
20 The work that Mr. Hunter was doing, in short. Do you know 21 whether the practice followed by the inspectors who were r
! 22 working on the AVO work was to document their inspections at e
O 1
386 1 the time the inspections were performed?
,s-n
\ 2 A To document the inspections at the time they were 3 performed.
4 Q Do you know whether or not in fact the practice was 5 to bank inspections under that program? And by bank, I mean 6 do the inspections at one point, complete a number of 4
7 inspections, and fill out the inspection document at a later 8 date?
9 A It was supposed to be filled out at the time of 10 inspection.
11 Q Do you know what the practice was, though?
12 A When Mr. Hunter done his inspection?
i 13 A Mr. Hunter or others who were doing inspections
( }
14 under the program reviewing AVO.
15 A This is very recent, and they were supposed to fill 16 it out at the time of inspection.
17 Q That's what you're saying they're supposed to have, 18 and I hear you, but do you know what the practice was?
, 19 A Fill it out at the time of the inspection.
20 Q If an inspector -- let me start again. When you 21 looked at the welds in question of Mr. Hunter and Mr. A a&hT rnt and fb 22 concluded that they had been inspected through paint, that was l
O
387 1 on the assumption that the inspections took place just prior
[
\ 2 to the PTL overview?
3 A Yes.
4 Q Now if time had transpired between the time of the 5 inspection and the time of the completion of the inspection Acubrapp0 6 document, or the welds in question of Mr. Jandt and Mr. Hunter, 7 was it more possible that painting of the welds could have 8 taken place in the interim and that you would not have been 9 able to detect the fresh paint?
10 A I really don't understand your question.
11 Q I'm probably being a little obtuse about it. But 12 you looked at the welds and concluded that the paint was not 13 fresh.
[dT 14 A Correct.
15 Q And you concluded that in part because there was 16 dust on the surface, you stated.
17 A ANd where it was stamped.
18 Q Now the dust, you concluded, was not something that 19 would likely have gotten on the painted surface in a matter of 20 days; correct?
21 A Yes.
22 Q And that only a matter of days had transpired
388 1 between the time of the inspection document in question was 0 R RDbT Y 2 completed by Mr. Hunter and Mr. innH: -- the PTL overview took 3 place a day or so later -- and your review of the work.
4 Correct?
5 A Yes.
6 Q My question to you is: if the inspections that were 7
Attc0T $ '
performed by Mr. dent and Mr. Hunter had in fact taken place 8 sometime prior to the date on which the inspection reports 9 were completed, might it possibly have occurred that the welds 10 were painted over in the interim, and that during a period of 11 time dust could in fact have gotten on the surface of the 12 weld?
() 13 14 A
Q I don't believe so in this situation.
can you explain why not?
15 A I don't think the painters were up in that area at 16 this time.
17 Q So you don't believe there was any painting going on 18 at about the time when Mr. Hunter was performing this work?
19 A Yes.
20 Q You mean no, there wasn't any paint?
l I 21 A I mean no. Okay. You've got me confused.
22 Q I'm trying not to.
-l
!O
389 1 Mr. Berry asked you a question about the meeting ,
2 that was conducted with Comstock inspectors and Edison, April 3 1, 1985. He asked you whether or not they were informed at 4 that point of Mr. Saklak's status,- and I think you first 5 answered you.weron't sure whether they said anything about 6 that or not.
7 A I believe they did. I'm not positive what was all 8 conveyed.
9 Q Mr. Saklak had not yet been terminated; correct? He 10 wasn't terminated until the 4th or 5th of April, is that 11 right?
12 A Somewhere in that neighborhood. But he was 13 suspended from the job.
( }
14_ Q Do you recall whether or not commonwealth Edison or 15 anyone else from Comstock ever stated at that time, the April 16 1 meeting, what the cause or basis was for the action taken 17 against Mr. Saklak? In other words, why he was being 18 terminated or why he had been suspended?
19 A Because of his actions and that intimidation and 20 harrassment would not be --
21 Q That may be the answer, but my question to you is: l 22 did they ever tell the Comstock inspectors why Saklak had been i
. - - . - . _ , - - - - _ _ . , . - ~ . . . .
390 1 removed from the job at that meeting?
f 2 A I believe it came out in that meeting.
3 Q And what did they say in that meeting about the 4 reason why Mr. Saklak was removed?
5 A Because of the incident. They mentioned the May 6 28th incident. I think it was the 28th incident with Rick 7 Saklak and Mr. Snyder. Oh, March.
8 Q Okay. Well after Mr. Saklak was terminated finally, 9 are you aware that Mr. Saklak wrote the company and asked why 10 he had been terminated? Asked for the reason for his 11 termination.
12 A Mr. Shamblin mentioned that he had written a letter
(~~) 13 to -- I don't know whether it was Shamblin or CECO. I
%)
14 remember there was a letter written. I don't know what 15 Mr. Shamblin's reply was.
16 Q Mr. Saklak's subsequent deposition testimony is to 17 the effect that he has never been told why he was terminated 18 in precise words. No one ever said, you know, Mr. Saklak, 19 you're being terminated because of this reason. Now, that's 20 what Mr. Saklak says. My question again is: do you recall 21 Whether or not Edison or Comstock specifically stated in this 22 meeting why action had been taken against Mr. Saklak?
391 1 A I believe it was.
6 AKLA K $4@b m
I believe it was. Mr. Saklas.
2 wasn't in that meeting.
3 Q Right. So everybody else heard why he had been 4 terminated or been suspended but Mr. Saklak, apparently.
5 A Well I don't know about that either because I wasn't 6 in on his termination; that took place in another place.
7 MR. GUILD: That's all I have. Thanks very much.
8 MS. KEZELIS: That's it.
9 [Whereupon, at 2:30 p.m., the deposition of 10 Mr. DeWald was concluded.]
11 12 14 15 16 17 18 19 20 21 22 t
O
A 392 1 CERTIFICATE OF DEPONENT 2
l-3 I, IRVING FRANK DEWALD, do hereby certify that I have 4 read the foregoing transcript of my deposition testimony and, 5 with the exception of additions and corrections, if any, 6 hereto, find it to be.a true and accurate transcription
- 7 thereof.
)
8 I
9
/
A. k I i
10 7'
IRVING FRANK DEWALD
! 11 12 k $D O
14
"^'"
15 CERTIFICATE OF NOTARY PUBLIC i- 16 Sworn and subscribed to before me, this the h 17 day of bl4 ,
19k.
0 18 '
l 19 20 -
- 't h '
- 21 0 NOTARY PUBLIC IN AND FOR 22 My commission expires
- Al&4bp D !/
l fo6/ze .
!O
,---.-...---,.-.-.,...-,.--..w--.--------,..--...,-...--,--r-,-.,---- - - , - - - - - , , . , , - - . . , ~ . - . . , , , . . - _ - - . - .
l 393
- 1 CERTIFICATE OF NOTARY PUBLIC 2
l l> 3 I, SUZANNE B. YOUNG, the officer before whom the i.
4 foregoing deposition was taken do hereby certify that the i ;
5 witness whose testimony appears in the foregoing deposition !
i 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 3
8 under my direction; that said deposition is a true record of 9 the testimony given by the witness; that I am neither counsel t
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
)
j 12 am not a relative or employee of any attorney or counsel e j
( 13 employed by the parties hereto, nor financially or otherwise I i 14 interested in the outcome of the action.
15 ,
16 h ,
i 17 {}
SUZANNE B. YOUNG i* '(/ .-
18 Notary Public in and for the I
19 District of Columbia
. 20 l
l 21 My Commission expires December 14, 1989.
- 22 4
i f
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- b. !
O i Comstock Engineering, Inc. :
U Memorandum To: C. Mennecke/T. Quaka Of fice: Braidwood From. I. DeWald
Subject:
W. O. Puckett - Invel III Welding Date: 5-21-84 Control No. 84-05-21-04 -
Mr. Puckett's resume is being submitted for your review and approval for the position of Level III Welding Inspector. He will be handling the welding aspects of the job such as, welder qualifications, training, field problems with inspectors and craft, and procedures.
Mr. Puckett's qualifications qualify him as a Level III through his background and experience.
Please reply as soon as possible on your review and approval.
Very respectfully, i
V A M I. F. DeWald Quality Control Manager IFD/jf cc F. Rolan QC File QC Manager File O
B'.! 00012537
Le felid 46 I
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, a,= l l
i
/, Comstock Engineering, Inc.
' (~') Memorandum I
'G l To: T. Paserba Office: Braidwood Fr:m: R. Seltmann
Subject:
Yearly Site Evaluations of Level III's Date: 1/17/86 -
Control No. 86-01-17-03
., ;i P. lease forward and have Mr. R. Marino sign and return the attached yearly evaluations for the site Level III evaluations for L. Seese and
"; y - I. DeWald.
This signature requirement is per the Site Procedure k.1.3 Rev. E paragraph 3.7.2.1.
Very respectfully, 31 R. Seltmann f^')
'v' Quality Assurance Manager BS/cm Attachments .
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Comstocx Engineering.inc.
a CousioCm Omour CowraNv PIRFORMANCf [ VALUATION FORM NEW HIRL [] ((
YES NO
[MPLOY(( NANC Irving DeWald TITLE Ouality Control Wnacar CER11FICAT10N (ARLA) All Areas LEVEL OF CAPABILITY TTI
~ '
- _~CER11FICAT10N DAl[ 12-15-8h LA$7DAYWORKEDINAREA 12-15-85
[ VALUATION: Within the past year, Irv has continued to be actively involved in directing the LKC Quality Control progra= as prescribed by the LKC QA/QC program Manual Section h.1.2. He is involved with reviews and certification of Quality Control personnel in addition to co==unicating with construction any findings and initiating, recom=ending or providing solutions to problems.
) -
In addition, Irv is currently certified as a Levef III in all areas of the Braidwood Site Quality Control Inspection progra=.
~
Based on the above, Irv has continued to exhibit the capabilities expected of an individual assigned to his position.
[VALUAT[0 BY: -
'I DATE -?>/' 85' s MANAGER e DA'TC / 7!A ;
General Manager - QA/QC Services Date AT ME C 00 )12'J 11 Ah4NTA
- CMICAGO + NEW YOh * - PJTsegAGH
- SAN FR ANCISCO
BRAIDV00D k.1.3
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/ \ . ... , , p u BestevWr. it 60407 d (B15) 4 58 7801 Comstoc < Engincering. loc.
A Cowb10Cm Omour CouraNv PERFORMANtt EVAtVATION FORM NEW HIRE [] ["I YES NO EMPLOY (( NAMC Larry Seese TITLE Asst. Quality Control Manage All Areas LEVEL OF CAPABILITY III CER11 FICA 110N (AREA)
^ .. ! CER11FICATION DATE 12-15-8h LAST DAY WORKED IN AREA 12-15-85 EVALUATION:
Within the past year Larry has continued to function as the Assistant Quality Control Manager whereby he has assu=ed the duties of the Quality Control Manager when required. In addition, he has provided status reports as delineated in the 1KC QA/QC program Manual Section L.1.2.
- Larry is currently, certified as a Level III in all areas of the Braidwood v
- Site Quality Control Inspection program.
Based on the above, Larry has continued to exhibit the capabilities expected of an individual assigned to his position.
EVALUATED BY: Wi+L DATE /c // V/M 7 !86 th r'N MANAGER ,
DATE /
ATTACHMENT C General Manager - QA/QC Services Date g, g77j)jg4
~
C9 coar2912 AttaN1 A . CHfCAGO
- NEW YOAA
- PIT TSBU AGH e St.N F AtJCSCO J
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LK.Comstock & Com]any.Inc.
A CCMSTOCr. Group C3MPANY ,
January 03, 1985 e
~
, CECO Control No. C85-01-03 Braidwood Station Bracev111e, Illinois 60407 Attention: T. Quaka
. Subj ect : L. K. Comstock Company, Inc. -
A.V.0. Review s
Dear Mr Quaka:
,u The Ettachment is the A.V.O. review program we are proposing.
9e would like your approval or. comments before we proceed.
We are now Yorking on the drawing review prc/ gram. This program p will cover all drawings previeus to April '1984.
If you have comments or questions please call me.
b . Very truly yours, c
s V p
oseph J.
3\a%
r na Project Engineer JJKleo cc: D. Shstblin C. Mennecke F. Rolan B. Seltmann-I. DeWald D. Bradfute I
A s
0 s
v C9 000r2s43 nn me OA OnY QiAS O 3 Arctill I C to en An71 #01Cn ACO 99 AO
- , LXC NCR #1996
/
ff NCR DISPOSITION SUPPLEMENT So/Nure t at items removed and/or reinstalled by LKC craf t personnel per AV0' , have
. /s )1 necessary documentation and inspection work performed, the following special in,tructions shall be incorporated as a supplement to the disposition of LKC NCR #1996:
1.0 LXC Engineering shall sort all field work AV0's generated prior to 3-29-84 3
(origin date of Rework Procedure 4.3.24) by drawing.
2.0 Engineering personnel shall prepare AVO Review Drawing Status Sheets (Attachment A) for each Category I conduit base drawing and each Category I cable pan base drawing (i.e. Containment, Auxiliary, and Fuel Handling Buildings, Aux. Feedwater and Steam Tunnels and Unit I and II Valve Rooms).
2.1 The status sheets shall h3ve a listing of the AV0's affecting items shown on the subject drawing. If an AVO is written against more than one base
- _ drawing, it shall be listed on status sheets for all of the affected
- d rawings . In the event no AV0's were written against a drawing, the word "None" shall be written in the "AVO #" column of the Drawing Status Sheet.
2.2' Engineering personnel shall identify the dates the AV0's were written and closed and shall perform the research required to ascertain which items could have been altered by the AVO. These items shall be listed on the Drawing Status Sheets. The initiator of the AVO should be contacted where feasible to aid in the determination of the affected items. (For purposes of this supplement, an item or component is defined as any conduit, wireway, cable pan, hanger, instrument, junction box, equipment or hardware installed or modified by LKC.) For any dates not available N/A shall be entered in O. the appropriate column.
2.3 The present physical installation status of all items affected by an AVO shall be determined by field surveillance and all items shall be listed in -
the appropriate installation status column of the Drawing Status Sheet.
2.4 If the rework of an item or component is not complete to the current drawings and an NCR or Rework has not already been written, the personnel
' performing the review will determine if an installation report has been l turned in. If a Rework or NCR has already been written,. the number shall be recorded in the appropriate column. '
2.4.1 If an installation report has not been submitted, a Rework Report shall be generated per Procedure 4.3.24 and the Rework number referenced adjacent to the item ID number on the status sheet.
2.4.2 If an installation report has been submitted, an ICR shall be generated per Procedure 4.11.2 and the number recorded adjacent to the item ID number on the status sheet.
2.5 If an item that was altered by an AVO has been completed and is per current
, drawings it shall be listed in the " Items Reinstalled" column on the status i sheet. .
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.WCR #1996 1CRDisposit;fnSupplemente 1
Pag 2 Two g
'O 2.6 If an item affected by an AVO has been deleted or is shown as abandoned in place on current drawings it shall De noted as such in the item deleted / abandoned column.
2.7 When problems arise involving the identification or disposition of an item referenced by an AVO, the Project Engineer or his designee will review the problems and resolve the status of the AVO.
3.0jUponcompletionofresearchanddocumentationofallitemsaffectedbythe AV0's listed on a Drawing Status Sheet, th'e Engineering personnel performing the research shall sign and date the status sheet and forward it to the QC
- -Department for verification.
4.0 Upon receipt of status sheets from Engineering, the QC Department shall assign appropriate personnel to verify that all necessary inspections have been performed and documentation is on file for the items listed in the reinstalled or deleted / abandoned columns.
4.1 The name of the inspector and the date the inspection was performed shall be referenced adjacent to each item in the spaces provided.
3 4.2 If an item is listed as installed but no installation or inspection report is on file, QC shall notify LKC Engineering and hold the Drawing Status Sheet until an Installation Report is forwarded from Engineering. The ;
inspections shall be performed and referenced per Step 4.1 on the status !
sheet. ,
1 4.3 If an item is listed as installed without an Installation Report on file, but with a QC Inspectiori Report, reinspection is only required when the Inspection Report is dated prior to the AVO.
5.0 When verification of all items is completed, the responsible QC personnel !
shall signify such by signing and' dating the status sheet in the space provided. '
6.0 A copy of the completed status sheet shall be sent to Engineering for i logging and filing purposes and the original shall be filed per Procedure 4.13.1.
7.0 LKC Engineering shall keep a log of the Drawing Status Sheets for each drawing. The log shall show when research on a sheet is complete, when a sheet is sent to QC for verification, and when it has been returned complete.
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RECEIVER: WRITE REPLY, DETACH STUB, KEEP PINK COPY, RETURN WHITE COPY TO SENDER.
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PROPOSED ,
FORMALIZED PLAN AND SCHEDULE- l ks .
Item 1 -
Incomplete Installation Inspections as of 8-31-83 and manhour '
l requirements to complete inspections: I No. Time Required / Man Hours Area Inspections @ Inspection Reouired .
- 1. Hangers
.A. Configurations . -36M 122 I .@ 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> /10 inspections 2942
<B. Welding
- 4defd /pg3 @ 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> /10 inspections 3594
- 2. Conduit *
. M- @ 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> /7 inspections 328 Cable Pan .oe a 9327 7__m _@ 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> /8 inspections 2327
- 4. Terminations 438- b@ 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> /12 inspections 292
- 5. Junction Boxes (([.y ,
4es (A3 @ 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> /8 inspections 423
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- 6. E_quipment 4675 % * @) 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> /5 inspections 3000 ca .vo.<, , t.u -> n&g E)
- 7. Rework Requests MSK O @ 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> /,4 inspections 1716 O Total No. Inspections 14,377-Total No. of manhours required ~to co=plete inspections -14 d22-W e*
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!"! Memorandum To; C. Mennecke Office: Braidwood Frcm: I. DeWald
Subject:
D. Asmussen Letter Dated 12/14/84 Date: 01/02/85 Control No. 85-01-02-02 In reviewing Mr. D. Asmussen's letter in which he has expressed his concern of past inspection practices while perform-ing the phase II portior. of the document review program. You are being forwarded a copy for your review to keep you aware of the situation.
The particular area of concern is for the number of welds inspected and accepted by one (1) individual inspector in one (1) day. The total number of welds (1166) being inspected in a single day does appear to be a considerable number for one (1) individual to accomplish. Although at the time of the inspection, V 5/8/79 there were only a small number of Comstock Q.C. personnel on the Braidwood Site. The inspections written on the one check sheet could possibly be..a total for several days' work. The individual is no longer on site, so it is hard to establish the documentation methods at that time.
The other questionable item brought out by Mr. Asmussen is zero (0) rejects. 'Ib him, this is questionable, although it is felt the individual was a competent inspector.
The re-inspection addressed in Mr. Asmussen's letter was due to a Unit Concept Inspection #QC-US-27, et which an ICR was initiated to cover. the deficiency addressed in the QC-US-27 inspection report.
In reference to the above concerns, the direction given to Mr. Worthington to inform Mr. Asmussen was if there is a question concerning the documentation as to the validity of the inspection.
"Re-inspect the subject item or items to ensure a good valid inspection."
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C. M:nnecks Paga 2 Control No. 85-01-02-02 If any further concerns develop or are addressed through Mr. Asmussen's letter, this office will keep you informed. If you have any further questions, please contact my office,
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Attachments cca F. Rolan K. Worthington L. Seese J. Gieseker D. Shamblin T. Quaka T. Paserba R. Seltmann D. Asmussen QC Mgr File QC File
L K. COMSTOCK & COMPANY, INC. F '
PRI RfTY
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L. N EMSItXX & COPANY, INC.
KR INFORMAT ON XY o -
DGE: g 77 10: L. Smetana FKH: Mike William Pittsburgh Testing laboratory L. K. Comstock & Coupany, Inc.
Braidwood Station Braidwood Station
'Ihe attached SMAW and Stud Welding Inspection Checklist for the locations listed below is being forwarded to you for your inspection of the installations.
Initial Inspection ( Reinspecticn ( )
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MANUAL SHEILDED METAL ARC-WELDING AND STU WEL, 1 INSPECTION K I l l V AREA /;fo x. B/,/r.
__ LOCATION /fue . /d //- 44 Q ELEVATION #-d 6 '
DRAWING NO.: So 8'/- // # / ho e fe v- 10Be S Tee 2.
INSPECTION OF V orr. WEtDS ra1S cRI" "ee
.amuas2- THS !S A RECONST TTED REC 00
. roR Ih lT, ST&QE@0CK AL DA L W E L ENG. Q.C ni
- 1. Weld a full 360* fillet?
2.
[3 [] I At least one stud in 100 torqued to-the values on the reverse side of this form? [3 [] LT FOli MANUAL SHIELDED METAL ARC-WELDING
- 1. Welds Clean '
pf [] []
- 2. Welds free of visible cracks? LT [3 [3 3horough fusion exists between weld metal and base metal (undercut to 1/32" or free of overlap)? [/l [] [3
- 4. '
Craters filled to. full cross section of weld? ET [] [3, 5.
Wald for theprofiles weld size?within limits of the " Weld Fillet Gage" s
8 [] [3
- 6. Sum of the diameters of pi in any linear inch or 3/4" ping porosity exceed 3/8" in any 12 inches? ET [3 [3
- 7. Fillet welds in any single continuous weld do not underrun the nominal fillet size required by 1/16" '
" REJECT" Reference Inspection Correction Report #E/A D6c. 4-//-W ' .
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' / DATE ,f"- S'- M9 -
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TITLE ORIG. DATE J REV. DATE iREV. NO. JFORM -NO . g, MAW AND STUD WELDING
! NSPEOTION CHECK LIST i
3-16-77 9-6-77 -
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' HANUAL SHEILDED METAL i II ARC-WELDING AND STUD 11 Y I k*
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INSPECTION L i AREA go x. B/dr. LOCATION]f ae . /g./f. 4+ Q ELEVATION 4-d 6 '
DRAWING NO._ 3'o f'/ -R M INSPECTION OF)hnoen & fuAe. S 7 Eel Y
QTY. WELDS THIS GRID // 4 g
-% S22 RWActiEo Q A S _2.- -
FOR STUD; WELD ACCEPT REJECT N/A
- 1. Weld a full 360* fillet? [] [] I 2 At least one stud in 100 torqued to the values on the reverse side of this~ form? [3 [] E FOR MANUAL SHIELDED METAL ARC-WELDING
( 1 W [3 [3 L / Thorough fusion exists between weld metal and base metal (undercut to 1/32" or free of overlap)?
, M [] [3
- 4. Craters filled to . full cross section of weld?
R [] [] .
- 6. ' Sum of the diameters of p1 ping porosity exceed 3/8" in any linear inch or 3/4,, in any 12 inches? E [] [3
- 7. Fillet welds in any single continuous weld do not underrun the nominal fillet size required by 1/16"
[3 [3
" REJECT" Reference Inspection Correction Report #_ A//A D6c. 4-//-FY ' .
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INSPECTOR v '/ DATE g- fr- M9
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_l TITLE ORIG. DATE i REV.'DATE REV. NO. JFORM NO.
SMAW AND STUD WELDING
-lINSPEOTIONCHECKLIST 3-16-77 9-6-77 -
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'1. it. COMSTOCK & COMPANY,INC.
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' t . 3.W anc. c.cou m . ununn. .o.co,.a Order flo: Cil.3175 ' -
.'"..s.....".."..."..'.s................" " * " " " . . " . . . . . . ' . " . . . . . . . . " . . " . . " . . . . . . . . "
Client: Corrmonwealth Edison Re;. ort flo: 3 M S - Vll)
Project: Braiducod Station REP 0RT Report 0.:te: 5-9'-79 of V i t tp l I n*.nec t i t,n o f' ", t ru. t u ra l ,1.'"1.li ra:
Contractor: ). N $msh e j' page l of ll Orawing 1.'el d 1.'el d 1.'el ! Si:'e 1.'eli!
t'o. .. tio. Type I Actu.:1 I!.pecilled i Lenoth Acc Rei Rej. Cefe s .'::.te suhel&g-g n p;jj,f Q,Q '
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k H-25 e Ih /It C" x n-ar o & % _
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lYl Con forraing I J flon.Conforuir..; I j t:ot /.:.:ilic ale Acceptence Criteria: A WS QL L _.7.5_.____.. . SAFETY REl.ATED 5-Rcm rk;: Au }2}N Flo. 4iRL L.nes J 1; Q 5 1/ % } 7
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- . - . - 1Az,1utI,,./]r ' LII(I2I 5 ULe .L h Inspec' tor:_ map;- --i. vel :g . in:pectier. Cne: 5-I-7/
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Order tio: Cil-3175 .'"..'..',"..".'..".."..'".".."..."..'."..'...'"....'.'."...".".,".'......'.".."...
Client: Coir:nonwealth Edicon ge..or- ::o__f M -)/N)
Project: Draiduced Station REP 0RT Report D.:te: f-?-//
Of Vi .ual In.iirction of Stru.-ti:ral t!.1,fino Contractor: )_ k tk., s be k page .2 of l/
~
Orawing t!cid lleid '!'lil Si.'e
~
t!cli!
fio. flo. Type ,I Ai. t u.i l t '.pec t i t e il i I.engtp Ay 1:.. i Re i , r e.f..n s f: . r./
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@ Conforming [_J I on-Confor:..in.: I i ::ot t.; ,,licable Acceptance: C r i te r i.i:,dM 8, M /., / - ,ff, ,
Rmra: #s u_g. ,. / ,/ // SAFETY RELATED Inspector: M ! ..v 1:g In. i.ee tien C,.te: [-f- M
. Revicued I / w d I.evel: # -
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. c . e m,u ,2 . .. , .. . .. .. . . . . . u. o Order flo: CH.3175 ' . " . , " . . ' . " . " . . " . . ' . " . . " . . . ' " ... . * . " . . " . . " . . ' . " . . . . . " . ' . . ' . . ' . . " . . ' . ' '
Client: Cormionucalth Edison Project: Bralduced Station Repor: fo: 8(("" h REP 0RT Repcrt Date: 6 /f of Vir.ual intocction of Structural B.1dino Contractor: [ k b .,s b e k p,.g e _ J o f H
Orawing Weld Weld "cid Size Weld l'o . No. Tyne l ,k tua l 5pecil m! I L c".a t h rice Rei Rei. refects flotec
'" "'i H-du c F;Ilel % %I V x M raa D h __ 'A t 8' " x
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Acceptance Critena: N dj/,,]_--/,f I
- S,, map ,. Jg./f necon::
-- . .. ... . .... . SAFETY RELATED Inspector: $ h L. el: 77" _
1,q ectjer,cate: - g-7-y Revics.co O r /~ mite...s i :2rg__ .
O.....................[...........
v . . . .. .., . .... .. .. . . . , . . . . . . . . . . . . . . . . . . . . . . .
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- a 3k . . c .,m 3 . , . c .. . . . .o A B.C A CODL J t: . 8.uasu..aea d a s.So f.ft Order 110: Crl-3175 ...'.'.'s'"...'.'.."..'.'.'.-"..".."..'."....."....',.",.*.'.".'s".'..".."'...".."."...'...'..".,"...".."..'..'.
, Client: Co.monwealth Edison Report io:J<llI[ - h Project: Braidi;ood Staticn REP 0RT of Report D m:- 6 - P- //
V i .u.il i n*.nec t ion o f r.'.ru.. tura l 1.'. l.:inri Contractor: 1bd ,g[ack n.:q.; y. o f ll Drawin') 1.'t:I d !!cid 't lif *.itt. tie lit tio . No. Type I Ai.tu.: t I:.nec t i tut i 1.cngth /.:c R .' i Rei. Cefecte, ':c u e s e h<l w it)-l,5 g F;)lcl
% %\ f" X H-is c }4 I% 4" X
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Remaru:
- 5,, a , e /_,f//
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SAFETY RELAT_ED Inspector:
6 .':el:.. M In .i.ec tier. Ca;e: [-8-M Reviewed 4 f_ b4 L ,...e l : AC'
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i- 0 8. s .* t .sete g es.....e n.%.. .. .. . . . . . . . . . . . ... s. ...e .. . .. . .....,n. .%. ..e ...ee . . . .
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Order tio: Cll-3175 *
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Client: Comonwea1th Edison 1:e;. ort flu:_[dd- M Project: Draidwood Station REP 0RI of Repr.rt cite: 5-7-7f Vi'.u. l i n'.per t ion o r '. t.rn t ai ,i l U. l.f i mi Contractor: ). N [ g,y,[,ck,,_ _ P. . .,, . . E c t' //
Drawint) 1.'e l d lleid U..ld Si.'e l.'e l d fio . tio. Type I~A.. .u a l s '.peci s ie it i
' L..n9 t h /Mc l'.s i R.? i . ri. f. - t e. '::.t r. -
an M~ lH-77 n FJM % %, 5 v H 79' 8 Vit, $t 5 k H-79' f Yq ffi G" kl .
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i ne.na r .::
S,, foA7< J..f // . .
SAFETY REL6.TED In:pectoc: 7F f f u w a._.i.,i:.2g;.
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5-7-77 Revicued .JC I< ,, .
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. . , , . i... . i.3 l .'. "/ . 3 2- 1.; . 79
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Order tio: Cil-3175 -
.'...'.'.',.."..."..'."....."..".."..'...".."......s....- ' - . . . . . . ..."..".....".."......
Client: Cocenonwealth Edison Pro. ject: Braidstood Station ge.,crt !:c,:JM[- Y/M R E P 0 P. T P.cpert Date: 6-7-77 of Vit.uel Inwetticn of Structural !!..idir.a Contractor: 2. k [.wr slac /(,
Drawing 1,'el d page [ of fl
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/ T* >'l l nn contornino r;-] ::en.c< n ro,.mi,..: ( , ::e i.n.m.mo Acceptance: Cri ten i: AV_$j2h,_/f _ _ _
l P.ct arkt:
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SAFETY.RELATm .
Inspector: kI N @ 1.. vel: g .
In ;;.ec tier. Ca te: [- 7 ~ EN Revictied h fu -
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Order flo: Cil.3175 - - --
Client: Cocenonwealth Edi:;on ge;,crt !;o:_88[ 'Y/d/
Project: Braidt;ood Station REP 0RT Report 0:te: 6-7-77 of V i . o.il ! n* ii.sr t i r.n o f 5 ! ru. t ur.i 1 1.'..l .!i r..:
Contractor: [ N_(,pegbe,k_, _, p i .,;, . ,[_ci- H_
lir.iuing 1.'e t d !!. . l .1 '! 1 1 '. i /.. ll. . l .!
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Acceptan'.c Criter1.i: h, ((,f ,
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Inwector: M8wt.#u2-. i . v.:1: ,II-
_ in.. i.u t t or c.i te : 5-f-7P W j'4* L..v.1 : g
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auc a coot a s a . ..unw.u.a 4 4 s.sosa Order flo: CH-3175 -
.'"."..'.".."..."..'.s Client: Cncmonwealth Edicon I;el. ort fic: _Wg - t/$
Project: Draidwood Station a g, p o e i p,. par t li i t. -
of 5'-9-77 V i " u.: 1 I n *.nec t ic,n o f' S t ruc tura l 1.'..leli ner Contractor: 1 N (o ,s [,e k Page 7 of f/
Drawing b'el d t! eld !.'c i d S i .'c 1.'e l d i:n . tio . T .y e I~h . f. o . I l' p..c i i u ! I I rnei'.h #cc l' .' i Re,i . I'c f e c *. e. ::0:.,c
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75 P.c ara:
S er_page L,f..] / SAFETY RELATED in:pector: 7# ;;( # 6 i...a:E
% .c u er ta a.- 5-r-//
Reviewed t /__ [ ,* Level: g O<d............................. . . . . . . . . . . . . . . .. .. , . . . . . . . . . . . . . . . . . . . . . . . . .
sOr.'. .ai i l l'ev. 3 1I I :-14-79
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Order flo: Cil-3175 . " . ' . ' . . . " , . " . . ' . ' . . " . . '-,-
Client: Cortmonwealth Edison Report t:c,:_ M/ -/4)
Project: Braidwood Station REP 0RT - Report Date: 5' '7- /f of Vi .ual Intret tion of Struc tural 1.'..li!ing Contractor: 1 )( [w g[g/( page 7 of //
Drawing t,'e l d lleid e 1 1 r.i e L&ld i:o. tio. Type IActual ISpecititd i -
Length Acc Rei Rei. refe: s !:cte:
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SAFETY REl.ATED .
Inspector: 77/ g g j e
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_ In;;.ection Cate: 6 - /f m
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Client: Commonwealth Edison Project: Braidttood Station Report ';o:pd - YW REP 0RT Repcr Date:__ 5' 7 7 of Vitu.'l Intrecticn of Structu.r$1.1.' idino Contractor: l. k C ,w s j ,e k pa,3 jg or jj Oraving licld !! eld !.' id St.v tlrld i o. flo. Type ,I Ac tu. t I!.necii ii .i i L. n.ith Acc I:.s i n.d . c..r, cte !:e:nc
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Client: Commonwealth Edison Report t;o: f/d-Y)t/
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k ac=are: S,,mafe , 1.f // - SAFETY RELATED - - - - - Inspector: u 4 pye % vel: -77~ N, . I . Intr.cctice. Ca te: 8-I~E[ Reviewed h f e -f i Level: g - p S v...................................
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Weldej No./Q/1_i TID VI'ZPE C nt!b f h iv N40 m IIDt' EQUIP:ENT 10. 8- OS3 /$7$g G /c fg No. of Welds W Ed 8' 1DCAT10n J/% ei g/sc p ax. 4'26 ' magx, g:c. m , ,, l D.C. C I; SPEC"'ID A#7-, /,c o(/- 3 9 . 700 FL7 N/A 3.2 WELD WAS SUFFICIINILY CLEANED AS NOT 'IO IMPAIR VISCIAL INSPILTION, PER PARA. 3.2. O!I! U I I 3.3. FILLER SIZE / THROAT, GEIMEIRY OR PRCFILE CDNFOR4 'IO MINT.NUM PIOCEIURE REUIRDENTS A!O DRAhTG DEIAILS l ; p PER PARA. 3.3, 3.4, 3.5, 3.6, 3.9, 3.10, 3.11, 3.12. 3.7 CRACKS, TIE WELD HAS NO VISIBLE CRACKS PIR PARA. 3.7. d I I 3.8 'nDROUCH IUSION EXISIS BEIKE'EN WELD MEIAL A!O BASE g ; g l l !CIAL, PER PARA. 3.8, 3.16. 3.14 SURFACE PCBOSITY IS WITHIN MDGIN ACCEPIAELE LIMITS g ; p PER PARA. 3.14. .. 3.15 AFC STRIKES ARE WITHIN MINDIN RKUIREMENIS OR REPAIRED , y ; AS bW%RY. PER PARA. 3.15. 3.19 FIT-UP CCMIONENIS IS WrDIIN ALifhM REUIRDENTS . . l l PER PARA. 3.19 A!C KELD SIZES DCREASED ACCDRDDGLY. 2 c> S A 3.20 SURFACES A10 IDGES T BASE MEIAL ARE WITHIN MINIMLN g2 RE:vIRnExrS rOR NICx, GaucES, Cur IDcES, aR cmeR SURFACE Drr rewnCES. PFR PARA. 3.13, 3.20, 3.21.
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Date July 3, 1984 lQ O BRD # 12.362 TO: N L. K. Comstock F0R INF0FIMATl0N ONLV g SUP.J ECT: Response dated 06-12-84 to CECO Audit Report OA-20-84-528 i The Commonwealth Edison Company Quality Assurance Department # has reviewed your response to the subject audit and finds it acceptable, however. Finding #2 Item #3 response is acceptable but incomplete in that it does not address steps to be taken to assure that no additional deficiencies of this type exist. LKC must determine if other items are affected and address actions taken to prevent recurrence. July 20, 1984. LKC is required to respond to this by This acceptance is conditional based upon satisfactory demonstration of corrective action and preventative measures concerning the deficient items. A follow-up surveillance will be performed by Site Q.A. Personnel to close all open deficiencies. i v l - s
@ 9 %r c 8 4 Lead Auditor / .
E. T. Mazur ( 72 QL CJ t
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m E. Quaka f .w yl)y ' Q. A. Superintendent l Braidwood Station l l TEQ/ETM/mjv (0026F) do(a hubvA cc: W. J. Shewski/G. F. Marcus ' ' P" " W # Audit File - 2790A.22A/QA-20-84-528 .Cs,L,Lu noo heeo de., r w O B2 roo1ssss 5- N
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- k. . /F ISHAM, LINCOLN & BEALE COUNSELORS AT LAW THREE FIRST NATIONAL PLAZA CHICAGO. ILUNois 00602 TELIPHONE 3t2 $58 NO IDw&RD S ESMAM 18?2 1902 WASHINGTON OFFtCE ROSERT T UNCOLN. 1872 1889 TELIL 2 5288 1120 CONNECTICUT AVENUE.N W wiLUAM G BEALE, 188S 1923 $UITE 840 WASMiNGTON O C 20036 202 831 9730 April 2, 1986 Robert Guild, Esquire BPI 109 North Dearborn Street Suite 1300 Chicago, Illinois 60602
Dear Mr. Guild,
We have identified additional documents relevant to the contention items. They are included in the enclosed updated index of documents produced in response to Intervenors Third Set of Requests for Documents, Question 9. These documents are now available at Isham, Lincoln & Beale for your inspection. p) g Sin ere. V t
/
/
Phij. lip P. Steptbe PPS:lm Enclosures cc: Attached Service List
/ \
, SERVICE LIST erbert Grossman, Esq. Mr. William L. Clements Chairman Chief, Docketing and Services Administrative Law Judge United States Nuclear Regulatory Atomic Safety and Licensing Commission Board Office of the Secretary United States Nuclear Regulatory Washington, DC 20555 Commission W2shington, DC 20555 Ms. Bridget Little Rorem Dr. Richard F. Cole 117 North Linden Street Administrative Law Judge P.O. Box 208 Essex, IL 60935 Atomic Safety and Licensing Board United States Nuclear Regulatory Charles Jones, Director Commission W2.shington, DC 20555 Illinois Emergency Services and Disaster Agency 110 East Adams Springfield, IL 62705 Dr. A. Dixon Callihan Administrative Law Judge 102 Oak Lane William Little, Director Onk Ridge, TN 37830 Braidwood Project Region III 7tuart Treby, Esq. United States Nuclear Regulatory ; L;1aine I. Chan, Esq. Commission bf fice of the Executive Legal 799 Roosevelt Road Director Glen Ellyn, IL 60137 United States Nuclear Regulato'ry Commission Washington, DC 20555 Janice A. Stevens (For Addressee Only)
United States Nuclear Regulatory Commission Atomic Safety and Licensing 7920 Norfolk Avenue Board Panel Phillips Building United States Nuclear Regulatory Bethesda, MD 20014 Commission Washington, DC 20555 George L. Edgar, Esq. Atomic Safety and Licensing Thomas A. Schmutz, Esq. Appeal Board Panel Newman & Holtzinger, P.C. United States Nuclear Regulatory 1615 L Street, N.W. Commission Suite 1000 Washington, DC 20555 Washington, D.C. 20036 p-
? ~s
_ __. . _ . . _ . _ _ . . _ _ . _ _ . . . _ . . ~ _ _ _ _ . . .- . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
. _ __=
BRAIDHOOD BATES 13:45 HEDHESDAY, APRIL 2, 1986 1 INTERROGATORY C9
~$ELECTIO FCRITERIA: SUB CODE CONTAINS "C9" gt;_,, c+-t 7Litoi m g t x_
BATES 8 SOURCE DEPT / PERSON DATE TYPE TO FROM 4 ii- di
- 'A0016410 CECO ' LICENSING ' ' ' --' -~ 12/24/85 ~~ LETTER
- ~~ ~
~ ~ REED ~ - ~ ~ - - ~
LITTLE ' --
,, 7 g q, Y p Oy g(. ,
A0016418 % A0016419 CECO LICENSING - 12/27/85 LETTER REED HARRISON A0016427 A0016428 CECO PROJECT 11/11/85 MEMO MAIMAN HALLACE _A__0_0_16 4_6_5 _-- - ~ ' ~ ~ ~ - ' - ~ - - " - - - - -' ~ ~ ~ ~ ~ ~ - ^ - - ~ ~ ' ~ ~ ~ ~ - ~ - ~ ~ ~ --- MANAGER ~'- A0016466 CECO PROJECT 12/11/84 MEMD MAIMAN HALLACE A00lG516 MANAGER A0016517 CECO PROJECT 11/15/84 MEMO MAINAN HALLACE _..A0016593 ~ - ' - - ~ ~ ' - -- ~- ~ ~ - ~ ~ ~ ~~ ~~ - -
~ ~ - M A N A G E R ~ ~ ~ ~- - - --- ~
A0016594 CECO PROJECT 10/15/84 MEMO MAIMAN HALLACE A0016620 MANAGER A0016621 CECO PROJECT 09/14/84 MEMO MAIMAN HALLACE
~ ~ ' ~ ~ ' ~ ' - - - - - - - ~ - ~~ - - - - ~ ~ ~ ~ ' - -~~
A_0 0_l. G. 6_8 3__ . MA N AGER --'---- A0016684 CECO PROJECT 08/16/84 MEMO MAIMAN HALLACE A0016750 t MANAGER A0016751 CECO PROJECT 07/16/84 MEMO MAIMAN HALLACE A 0 0 lG7_7 0____. -- - ~ ~ ~ ~ ~ ~ ' - - - - - - MANAG ER - A0016771 CECO PROJECT 01/22/85 MEMO VARIOUS HALLACE A00lG801 MANAGER A0016802 CECO PROJECT MANAGER 02/12/85 MEMO VARIOUS M.J. HALLACE A0016835 LICENSING / COMPLIANCE C.H. LENTH A00lG836 CECO PROJECT MANAGER 08/20/85 MEMO VARIOUS M.J. HALLACE A0016862 LICENSING / COMPLIANCE C.H. LENTH ' A0016969-~ CECO PROJECT 08/23785~- hEMO VARIOUs HALTACE A0016982 MANAGER e e e e
~
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