ML20195B620
| ML20195B620 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 04/04/1986 |
| From: | Dewald I COMMONWEALTH EDISON CO. |
| To: | |
| References | |
| CON-#286-300 OL, NUDOCS 8605290446 | |
| Download: ML20195B620 (324) | |
Text
{{#Wiki_filter:1 ORIGINAL UNITED STATES OF AMERICA y5 y g2 p
'l NUCLEAR REGULATORY COMMISSION 7 GAY g71986p 7 3 BEFORE THE ATOMIC SAFETY & LICENSING B ARD poctrnNG& 5.1
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A SECY-I;3C - 4 / //
~ g 5 - - - - - - - - - - - - - - - - - -x 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 / 'j 13 51st Floor
\_J 14 Chicago, Illinois 15 April 4, 1986 16 Deposition of: IRVING FRANK DEWALD 17 called for examination by Counsel for Intervenors BPI, et 18 al., pursuant to notice, taken before Pamela Briggle, 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. 4 8605290446 860404 PDR ADOCK 0500 6 Ob
2 I were present on behalf of the respective parties: 2 3 APPEARANCES: 4 For the Licensee Commonwealth Edison Company: 5 MICHAEL MILLER, ESQ. 6 ELENA KEZELIS, ESQ. 7 Isham, Lincoln & Beale 8 Three First National Plaza 9 - Chicago, Illinois 60602 10 11 For the Intervenors BPI, et al.: 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. 18 Office of the Executive Legal Director 19 Nuclear Regulatory Commission 20 Washington, D.C. 20555 21 22 O
3 1 C0NTENTS rQ I \/ w- 2 3 Witness: Examination by: Page: 4 IRVING FRANK DEWALD Mr. Guild 6 5 6 *** 7 EXHIBITS Page: 8 Exhibit No. 1: 7 1 9 Intervenors' Notice of Deposition 10 addressed to Mr. DeWald, among others, 11 dated 3/4/86. 12 13 Group Exhibit No. 2: 11 ( } 14 A stack of documents from 15 Mr. DeWald's files. 16 17 Exhibit No. 3: 15 18 Mr. DeWald's Resume. 19 20 Exhibit No. 4: 44 21 17500 and 17501. 22 O
4 1 EXHIBITS (Continued] Page: 2 Exhibit No. 5: 46 3 17520 and 17521. 4 5 Exhibit No. 6: 74
-6 Weld inspection report S-17169 and 7 S-17170 with a cover sheet dated 3/12/81.
8 9 Exhibit No. 7: 153 10 A memo dated 5/12/84 from DeWald 11 to Mennecke and Quaka. 12 13 Exhibit No. 8: 184 14 A memo from Dominique to DeWald 15 dated 8/25/84. 16 17 Exhibit No. 9: 191 18 A document dated 7/6/84 signed 19 by George G. Nemeth. I 20
-21 22 O
5 1 l 1 EXHIBITS (Continued] Page:
- 2 Exhibit No. 10: 192
- 3 A document consisting of a test 4 cover sheet and a weld inspection report 4
5 reflecting an examination dated 7/3/84. 6
- 7 Exhibit No. 11
- 192 8 A document consisting of a cover l 9 sheet dated 7/31/84 and an inspection 10 report dated 7/19/84.
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6 1 PROCEEDINGS 2 Whereupon, 3 IRVING FRANK DEWALD 4 a witness called for examination and, having been first duly 5 sworn by the notary public, was examined and testified as 6 follows: , 7 EXAMINATION 8 BY MR. GUILD: J
- 9. Q Mr. DeWald, would you state your full name and your f
10 business address for the record, please?
! 11 A Irving Frank DeWald, Braidwood Nuclear Power Plant, 12 -Braceville, Illinois.
l 13 Q And by whom are you employed? ( } 14 A Comstock Engineering. 15 Q And in what capacity? 16 A QC -v Quality Control Manager. 17 Q My name is Bob Guild and I'm counsel for the i 18 Intervenors in the Braidwood licensing proceeding. I 19 Let me show you a document that's dated March 4, 20 1986. .It's Intervenor's Notice of Depositions. And it bears i 21 your name, among others. And I'll ask you, sir, if you've 22 seen that before? I 1
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7 1 A Yes. i
%/ 2 MR. GUILD: I ask that that document be marked, 3 please, as DeWald Deposition Exhibit 1.
4 [DeWald Deposition Exhibit No. 1 5 was marked for identification.] 6 MR. GUILD: Off the record. 7 [ Discussion off the record.] 8 BY MR. GUILD: j 9 Q Mr. DeWald, the document that's been marked as 10 Exhibit 1, directed to you, asks that you produce documents 11 that are described in that notice of deposition. Have you 12 brought any such documents with you today? 13 A
'( }
No, sir. Everything that I was supposed to have 14 produced is here in the files. I have no other documents. 15 Q Now you started to tell me, before we went on the 16 record, about one portion of those documents. It has a tag on 17 it -- the first page has a tag on it that says Group Exhibit { 18 3. It was a proposed exhibit to Mr. Saklak's deposition and l 19 he couldn't identify them. i 20 The first page has a Bates number of 002847 -- I i 21 left out some zeros there. And it appears to be -- it's l 22 entitled Questionnaire. Can you identify that group of O
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8 1 documents, Mr. DeWald and tell me how you came to identify
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- (b 2 them?
3 MR. MILLER: There's more than just questionnaires 4 in this stack. 5 BY MR. GUILD: 6 Q Perhaps you can identify the rest of them. So, if 7 you could, just take a moment and look through the stack. 8 [ Witness reviewing document.] 9 MR. MILLER: Up through 02881, Mr. DeWald has now 10 looked at. Could you respond to Mr. Guild's question. 11 THE WITNESS: These are responses. I asked the 12 inspectors to give me some good solid criticism as to how can ( ) 13 we better the department, good solid criticism or suggestions 14 for things that we might need and would make the people feel 15 more comfortable and so forth. 16 BY MR. GUILD: i 17 Q And when did you do that, Mr. DeWald? { 18 A I'm not positive of the time frame in which I did 19 this. 20 Q I saw a page, in one of those responses, that bore a l 21 date of -- I believe it was June of 1984. Does that sound i I 22 like the -- O V
9 1 A It could possibly be. 2 Q Why don't you take a moment and maybe you can find 3 the same page. 4 A It was around the end of June of '84. - 5 MR. MILLER: Do you want him to go through the rest 6 of these, or do you want to? 7 MR. GUILD: Let me just finish a moment on this. 8 BY MR. GUILD: 9 Q You circulated questionnaires to all of the 10 Comstock's Quality Control inspectors? 11 A Yes, sir. 12 Q And how many, approximately, were there at that 13 time? ( 14 A I would say around 46 or 47. That's a guess. 15 Q And did you receive responses from all of them? 16 A No, sir. 17 Q And are all of the responses that you received 18 contained in the documents that you've made available? 19 A Yes, sir. 20 Q All right. Now, your lawyer was asking you to look 21 to the second portion of that Group Exhibit. Can you identify 22 those documents? O
10 1 [ Witness reviewing documents.]
/)
(_,/ 2 MR. MILLER: I can actually tell you, Mr. DeWald, 3 that the documents have been through so many hands that the 4 staples and so on, and the order, don't necessarily reflect 5 the way they came from your files or anything else. 6 THE WITNESS: The best of what I can see here, this 7 is my draft of Mr. Seeders' letter that I drafted up for my 8 response to Mr. Seeders' letter. And when he was given the 9 warning by Mr. Seese. 10 BY MR. GUILD:
- 11 Q Can you read the number on the bottom of that, just 12 to identify it for the record, please?
13 A f}s/ It looks like it's 0002886. 14 Q And following pages. 15 MR. MILLER: It goes all the way to -- 16 THE WITNESS: 0002902. 17 Now these, I'm not sure where this come from. 18 MR. MILLER: That's 02885 or 2884. 19 BY MR. GUILD: , 20 Q Okay. 21 A This is the -- 00002882 and 00002883 is a letter of 22 resignation.that I got from David Parks shortly after I became O
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11 1 Quality Control Manager at Braidwood.
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2 Q Mr.' Parks was a Quality Control inspector at the 3 time? l t 4 A That's right. l 5 Q And that comprises the documents that you were , _ 6 looking at? 7 A Yes. ! 8 Q All right. i
- 9- MR. GUILD: Let's mark all except the documents that 10 you -- let's mark them all and mark them as DeWald Group
, 11 Exhibit 2 for identification. J
- 12 [DeWald Group Exhibit No. 2 was 13
) marked for identification.]
- 14 BY MR. GUILD
a ' 15 Q Mr. DeWald, how did you come to identify those 16 documents that you just now were able to recognize? How did 17 you find them? You related to me, off the record, how you i 18 located them recently. , 19 A They were back in one of the file drawers that we i 20 had went through, but it was just overlooked. 21 Q And you found it recently? 22 A I'm not sure how long ago. I think it was probably t
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l 12 1 on the second set or the third set. I'm not sure which. 2 Q of document requests? 3 A Yes. 4 Q Let me ask if you can identify another document. 5 This document begins with Bates number A-10790 and extends 6 through 10913 and it's entitled Braidwood Good News Story, 7 L.K. Comstock and Company Incorporated. This was made 8 available in discovery, Mr. DeWald. 9 I'd ask you to review that for me and tell me if you 10 can identify that? 11 [ Witness reviewing document.] 12 A It appears to be the Braidwood good news story that () 13 14 Mr. Seltmann had drafted up. Q Mr. Seltmann was responsible for authoring that 15 document? 16 A Yes, sir. 17 Q Did you review it? 18 A No, sir. 19 Q Have you seen it since? 20 A I've read it since, yes. 21 Q And when did you read it? When did you first see 22 it? O
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13 1 A After he had published it, I had read it. I mean, I
- 2 didn't review it prior to his publishing it.
~ 3 Q Okay. And can you recall approximately when 4 Mr. Seltmann wrote it? 5 A Not the actual date, I can't, no. 6 Q Within the last year? 7 A Possibly. 8 Q When you reviewed the document, Mr. DeWald, did , 9 you identify any factual errors in Mr. Seltmann's work? 10 A No, sir. I didn't review it specifically for that. J 11 Q Did any come to your attention, when you did review 12 it?
; 13 A No.
14 Q Do you know what the circumstances were of the 15 document's production? 16 A This was a function that Mr. Seltmann was handling, . 17 being it was a QA function and I really didn't get involved in all the particular statistics that took place when he put this 18 19 together. l 20 Q I understand, but do you know the circumstances 21 under which Mr. Seltmann undertook to compile those statistics 22 and draft the document? i i O 6 v __ _ , _ _ . , _ _ . _ _ . _ - . . ._ _ _ . _ _ _ , __ _ . . _ , . _ - - . . _ _ _ _ _ _ , . - , , _ ~ , , , . _ ,
). 14 ,
- 1 A I believe he was requested to draft up a good news 2 story from day one up until present.
3 Q Requested by whom?
- 4. A Edison, 5 Q Do you know who, in particular, from Edison?
l 6 A No, sir, I don't.
- j. 7 Q Did you participate in a meeting with project
! 8 management, at which Edison requested'that contractor 4 9 management put together such good news stories? 10 A I may have, but at this present time it doesn't ring 11 bells, as to the time or the place. 12 Q Okay. How did it come to your attention that Edison 4 13 had requested such a -- (} 14 A Through conversations with seltmann, that I knew of.
- 15 MR. GUILD
- Off the record.
16 [ Discussion off the' record.] [ 17 BY MR. GUILD: 4 . l 18 Q Mr. DeWald, I want to show you a document that l j' 19 appears to be your resume and ask if you can identify it as I ! 20- such? It was contained in an Edison document that accompanied j 21 the identification of you as a perspective witness in the QA i 22 hearings.
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15 1 A Yes, sir. It's my resume. (
'N 2 MR. GUILD: Mark that as Exhibit 3, please.
3 [DeWald Deposition Exhibit No. 3 was 4 marked for identification.] 5 BY MR. GUILD: 6 Q Mr. DeWald, is this an accurate and up to date 7 reflection of our background experience? 8 A Yes, sir. 9 Q Do you understand that you have been identified as a 10 witness to testify in the Quality Ascurance hearings in the 11 Braidwood licensing case? 12 A Yes, sir. [J'T 13 14 Q And what subjects are you informed that you are to testify on? , 15 A Contention 2 and 11-d, I believe. 16 Q Contention 2 -- by contention 2, do you mean the 17 issue involving alleged harassment and intimidation of 18 Comstock inspectors? 19 A Yes, sir.
'20 Q And what do you understand the subject of ll-d to 21 be?
22 A That would be the Comstock QC inspectors inspected O
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16 1 items in final inspection and allowed the deficiencies they
\-- 2 found to be corrected during the final inspection.
3 Q Have you prepared testimony on those subjects? 4 A Yes, sir. 5 Q Can you describe for me how you went about preparing 6 testimony? 7 A Through all the documentation and so forth that I 8 had in the files, and through recall and memory. 9 Q And that's what you relied on, as sources of 10 information? 11 A Yes. 12 Q What did you actually do, to go about preparing [)
%s 13 testimony? What have you done, so far, to prepare testimony?
14 Have you written testimony? 15 A I've written it, yes. 16 Q Did you have an outline or questions to go by? 17 A Questionnaire. 18 Q Pardon me? 19 A Questions. 20 Q And where did you get the questions from? 21 A From the lawyers.
- 22 Q Mr. Miller here?
i.
s. 17 1 A Mr. Miller here and Elena. 2 Q Ms. Kezelis? 3 .A Yes. 4 Q Have you seen a company document filed in this case 5 that describes the testimony that you were going to provide? ! 6 It's technically called Applicant's response to general 1 7 interrogatories by Intervenors? It's a list of witnesses and . 8 subjects of testimony in the case. 9 A I believe I have. I'm not sure which one you're -- 10 Q I'd show it to you, but I don't happen to have one 11 in front of me. I have an excerpt from it and pages six and 12 seven of it -- with my hen scratching it -- mention your 13 name. 14 And again, it is only an excerpt from that document, , 15 but at the bottom of the page you're mentioned, in substance, 16 and going on to the next page, with respect to the harassment i 17 issue. 18 Have you seen that description before? 19 [ Witness reviewing document.] 20 A I don't believe I've seen this exact copy. 21 Q I'm sure you-haven't seen that one, because that's i 22 the one I just ran off the machine this morning. But have you 1 t i
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18 1 seen that document, with those words on it? Or a document x ( 2 with those words on it, describing your testimony on the 3 harassment issue? 4 A I really don't recall seeing the exact -- that 5 particular exact -- I've seen a lot of other documents, that 6 relates to the contentions, the discovery. It's hard to pick 7 out exact documents. 8 Q The document, again, reads -- on page six, in part 9 -
"Mr. DeWald will testify regarding the L.K. Comstock 10 Quality Control organization at Braidwood." And have you 11 prepared testimony on that subject?
12 A I don't believe I have, on that particular one. m 13 Q Have they told you that you're going to testify on 14 that subject, so far? 15 A The only two I was aware of was 11-d and possibly 16 the contention 2. 17 Q This, again, is a description of what you expect you 18 to say on contention 2 now. Have they told you that ycu're l 19 supposed to testify regarding the Comstock QC organization at ( 20 Braidwood? 21 A I don't recall that. 22 Q The second subject is the expansion of its QC O
19 1 organization. It's activities which took place in late '83 (~ 2 and 1984. 3 A I'm aware of that. 4 Q Are you aware $ hat you're supposed to testify on 5 that subject? 6 A Yes. 7 Q Have you prepared testimony on that subject? 8 A I believe it's in part of contention 2. 9 Q It's part of what you've put together already? 10 A Yes. I'm pretty sure, 11 Q The next, reading further, " Sources of grievances 12 among Comstock QC inspectors and Comstock management responses /% 13 to those grievances." And have you addressed those subjects b 14 in your prepared testimony? 15 A I believe I have. 16 Q "The union organizing effort which took place in 17 1984 and 1985 and its effect on management's relationships 18 with Quality Control inspectors." Have you -- are you aware 19 that you are to testify on that subject? 20 A Yes, sir. 21 Q And have you prepared testimony on that subject? 22 A Part of the contention 2. O
t [ 20 4 1 Q "The transfer of employment responsibilities for QC 2 inspectors from Comstock to BESTCo, B-e-s-t-c-o, in July 3 1985." Have you prepared testimony on that subject? ^ 4 A Yes. 5 Q "In addition, Mr. DeWald will testify regarding his f 6 interaction with Mr. Seeders and Mr. Puckett and the basis on ~ 7 which Mr. Seeders' improper calibration inspections have been j 8 corrected." Have you prepared testimony on those subjects? 9 A Yes. 10 Q I'll ask you some questions, following your resume, 1 11 Mr. DeWald, with respect to your background and experience. 12 Looking at your resume, on page 2, it appears to reflect that f v 13 you were employed first at Braidwood, beginning in November ] 14 1980, by the L.K. Comstock Engineering Company, is that 15 correct? 16 .A Yes, sir. 17 Q In what capacity did you start work with Comstock at
- 18 Braidwood?
l 19 A Level II inspector. i 20 Q And in what areas did you perform inspection work? l 21 A Welding. 22 Q Anything else? Y O
21 1 A Configuration. And'I was certified in conduit, but s 2 I don't believe -- offhand, I can't remember whether I did any 3 inspections in that group. 4 Q Did you happen to have the certifications? J($ 5 A Not at that time. 6 Q You had certifications in welding and configuration 7 as well? 8 A Yes. 9 Q And how long did you perform inspection activities 10 as a Level II inspector for Comstock at Braidwood? 11 A Until October 1981, I believe, was when I went to 12 D.C. Cook. [d'\ 13 Q That's what your resume reflects. It reflects, 14 though, that your last position at -- it reflects your 15 position at Braidwood as supervisor of Quality Control. 16 A At that time, it was a mediocre-type -- or an in 17 between-type position. I would actually supervise the 18 individuals and also do inspections, i l 19 Q Were you in the scope of a lead inspector? 20 A It's similar, yes, at that time. l 21 Q To what you have as lead inspectors today? 22 A Right. O 4
22 1 Q Do you recall approximately how many inspectors 2 Comstock had working for them during that period of time? 3 A I think when I first got there, there was probably 4 four or five. That would be including myself. I 5 Q And how many of those were weld inspectors? 6 A I think, offhand, three of them. 7 Q Including yourself? 8 A Including myself. 9 Q You and two others, probably? 10 A Right. 11 Q And at the time you left, to go to D.C. Cook, can 12 you recall approximately how many inspectors you had? 13 A I think there were approximately 14 or 17. Again, 14 I'm not sure of the figure. 15 Q Can you recall approximately, of that number, how 16 many were weld inspectors? 17 A Approximately six, I would think. But then, that 18 might not be accurate either. 19 Q Then again, you were one of the six, if that was the 20 correct number? 21 A Yes. 22 Q Was L.K. Comstock's scope of work at Braidwood, at l O
"I 23 1 the time, essentially the same as it is today? O)
's. 2 A No, there was a lesser requirement.
3 Q Can you generally describe to me what Comstock's 4 scope of work was during the time you were there, first as a 5 level II? 6 A The weld was 300 percent and the other areas, we 7 only had to do 35 percent. 8 Q This is inspection? 9 A Yes, that's of safety related items. 10 Q And was the weld inspection a final visual? 11 A Yes.
- 12 Q Was there any other weld inspection, aside from the 13 final visual?
( } 14 A No other, than just visual weld, was all. 15 Q Was there any in-process weld inspections? 16 A Oh, yes. Yes, we done fitups and stuff like this, 17 but that's all part of visual. 18 Q When you say other areas were 35 percent, what other i l 19 areas are you referring to? l 20 A Configurations, equipment, junction boxes, conduit, l 21 cable pan, conduit hangers, pan hangers. 22 Q Welding on those? O i
24 1 A No, welding was always 100 percent. 35 percent of () \s / 2 configurations, conduit inspection, junction box, equipment, 3 cable pan. 4 Q When you say cable pan, is that a configuration 5 inspection, or dimensional inspection? 6 A It would be a dimensional, configuration-type 7 inspection. 8 Q But the weld inspection was 100 percent? 9 A Yes, sir. 10 Q Had there been a time, before you arrived at 11 Comstock, where there was less than 100 percent visual weld 12 inspection? 13 A Not to my knowledge. ( } 14 Q You don't recall whether there was ever a sampling 15 inspection done? 16 A No, sir. 17 Q When I asked the question about Comstock's scope of 18 work, essentially they were the electrical contractor at the 19 time, as they are today? 20 A Yes, sir. 21 Q So they have the same scope of work, in that 22 respect? O
25 1 A Yes, sir. 2 Q Can you recall what other welding inspectors, if 3 any, you supervised in your -- when you were at Braidwood the 4 first time? 5 A Could you -- 6 Q By name, can you recall the names of any other weld 7 inspectors? 8 A Rick Martin was there. 9 Q Rick Martin? 10 A Richard Martin. Joseph Hii, Michael Kast, Steven 11 Lobue -- that's L-o-b-u-e -- Charles Tyler. And I think 12 that's about the end of them. We were recruiting some more, gh 13 but the names don't come.
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14 Q Okay. Any of those inspectors presently performing 15 weld inspection at Braidwood? I 16 A Could you read the names back? 17 Q Sure. Martin, Hii, Kast, Lobue and Tyler. 18 A None. 19 Q Any of them presently working as Quality Control 20 inspectors at Braidwood? 21 A Martin. Joseph Hii is one of my supervisors. 22 Excuse me, what are the other two? O U
26 1 Q Kast, Lobue, and Tyler. A k~s) 2 A They're not here. 3 Q Do you recall participating in the training of any 4 of those weld inspectors? l 5 A Yes, sir. 6 Q Can you tell me who? 7 A I trained Rick Martin, or participated in. Chuck 8 Tyler. I believe those are the only two. 9 Q Now can you tell me in what respect you participated 10 in Mr. Martin and Mr. Tyler's training? 11 A I'd take the drawings to the field with us and have 12 them identify the joint or the detail or the configuration so () 13 14 that they could get used to the drawings, versus what's installed, so they could pick out the deficiencies and so 15 forth. 16 Q Okay. 17 A I made them work directly with the drawings from the 18 drawing to the item, and so on, so they could relate back and 19 forth. 20 Q Is this, in substance, what's now referred to as on 21 the job training? 22 A Sure. " O V e
27 1 'Q Do you know whether or not your training of (<m (m- 2 Mr. Martin and Mr. Tyler has been documented? 3 A I'm not sure, it may have been on form 101. 4 Q That's the training record? 5 A Yes.
,6 Q And out of the program today, there would be a 7 requirement that on the job training for an inspector be 8 documented on that form?
9 A Yes, sir. It totals out 40 hours. 10 Q And it would indicate who the certified level II 11 inspector was, that was responsible for that on the job 12 training? f') 13 A Yes, sir. v 14 Q Level II and level III inspector? 15 A Yes. 16 Q And you're just not certain whether or not, at the 17 time Mr. Martin and Mr. Tyler were trained, that you used 18 those forms? 19 A I'm sure there was forms filled out. They're not 20 the same type of form that we use presently. They're a 21 different form. And I'm sure when the personnel records were 22 copied, that there were forms in there. I'm sure there was O V
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,e 1 forms^ 'in there.
p % 2 Q Okay. And even -- at that time, would that form 3 have indicated your responsibility for the on the job
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4 ' training? '
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. ,. 5 A -It would have indicated thati I gave him the
\6 training. It would have no specifics, as to what was given, 7 other;hta visual welding or weld procedure, whatever the
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8 number migOb be. , y - ' s - '9 Q Did you, yourself, Mr. DeWald, perform visual 10 inspection of welds during that time?
' !L1 A 'Yes,. sir.
12 Q Anf did you document your visual weld inspections on s Os 13 a weld inspaction- record?
,14
A Yes, sir. w
., 15 _Q Can yod recall the identification of that weld
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16 record, at- the time, duririg the time you did level II 17 insp'ections?j A# What was it', e number or -- 8 18 'y The form, number, you mean? 19 . Q' Yes. .
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A, I believe it was still 19 then.
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e - .., 21 Q Form 197
- 22. . A Yen, sir.
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29 1 Q Can you describe generally how you recorded the + (-~
\ 2 results of your visual weld inspections, when you performed 3 level II weld inspection work?
4 A You check your accept / reject criteria on the form 5 19. 6 Q On the checklist? 7 A Yes, sir. 8 Q Do I understand correctly, there's a list of columns 9 accept, reject, and not applicable -- N/A? 10 A Yes, sir. 11 Q And for each of the weld inspection criteria, there 12 are three blocks and you check either accept, reject or not 13 applicable? 14 A Yes, sir. 15 Q And is it correct that the checking of the box 16 acceptable indicates that 311 the welds that are documented on 17 that inspection report were acceptable to that criteria? 18 A Yes, sir. 19 Q If it was a fitup, checking accept indicates that 20 there was acceptable fitup for all those welds? 21 A Yes, sir. 22 Q Does one of the boxes say lack of fusion?
30 1 A Yes, sir. 2 Q And if you check accept, it indicates that all of 3 the welds documented on that inspection report were acceptable { 4 for fusion? 5 A- Yes, sir. 6 Q The same thing for the other attributes? 7 A The same thing for the remainder. 8 Q And how was it indicated which welds were the 9 subject of that inspection? 10 A Which welds? 11 Q Yes, how did you document what welds were being 12 inspected? 13 A I'm really not sure what you're asking. ( } 14 Q Well, the inspection report -- the form 19 15 checklist, applied to more than one weld? 16 A Yes. 17 Q one or more welds, shall we say. And how did the 18 form 19 identify which weld you were inspecting? 19 A It would be by the component, which at that 20 particular time we had a PTL sheet that we used like a cover 21 sheet. 22 Q The component and the component was identified on a () ss 4
31 1 cover sheet? A kss 2 A We used a PTL cover sheet, in some cases, that was 3 sent to PTL. J 4 Q First of all, was there a component identification 5 on the form 19? 6 A In some cases. 7 Q Were there some cases -- were there other cases in 8 which there was not a component ID on the form 19? 9 A Yes, and then they used the PTL cover sheet, which 10 would cover those. 11 Q Can you describe what the PTL cover sheet is? 12 A It's a request that's sent to PTL with the component 13 ( numbers, the drawing, and so forth, for them to do their 10 14 percent overview. 15 Q And who was responsible for filling out the PTL 16 cover sheet? 17 A The inspector. 18 Q The same inspector that did the visual inspection? 19 A Yes. 20 Q So in the case of inspections that you performed, 21 you would fill out the form 19 checklist and either indicate 22 the components that were the subject of your inspection on the 1 v 4
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32 1 form 19, or on the PTL cover sheet? k-s 2 A Yes, sir. 3 Q Did you ever use a so-called grid system for 4 identifying the subject of your inspection? 5 A I don't really recall it would be -- it's not 6 actually a grid system. I guess maybe it would be. It would 7 be to the drawing from line N to P, L to Q, which would cover 8 that particular section on the drawing. 9 Q Not the term grid system is not one I invented. 10 It's a term that I've heard others use. I can't recall who, 11 to tell you the truth, offhand, but other Comstock inspectors 12 or -- I think Jim Gieseker from Edison was the first source of 13 that term. [/ w
}
14 A I guess you could call it grid. 15 Q Grid in the sense that, using coordinates -- they 16 are identified on drawing. You describe the areas that were 17 inspected with reference to those grid coordinates? 18 A Exactly. 19 Q And the reference is designed to indicate that you 20 inspected welds on components that were located within those 21 grid coordinates? 22- A Yes, sir. 4 0
33 1 Q And what were the source of the coordinates that you ((_/) 2 used, if you used such a system? 3 A The drawing. 4 Q Whose drawing? 5 A It would be the IE drawing. Sargent & Lundy's, the 6 construction drawing. 7 Q Okay. And what's an IE drawing? 8 A Electrical installation. 9 Q And would this be the same drawing that had been 10 used by the persons who had performed the installation 11 activities? 12 A Yes, sir. () 13 14 MR. GUILD: Mr. Miller, the company was asked to identify certain weld inspection records that reflected 15 inspections performed by Mr. DeWald. And I believe the 16 response was that all of Mr. DeWald weld records had been 17 identified and brought together. I wonder if I could ask if 18 we could take a break and try to put our hands on those I 19 documents. l 20 MR. MILLER: Sure. My recollection is that Elena 21 sent them directly to you. The original request was for a 22 weld record that reflected, I think, 1,000 weld inspections in O V l l
34 1 one day. A k,_, 2 MR. GUILD: Right. 3 MR. MILLER: We were unable to identify any such 4 record with Mr. DeWald's signature. And finally, I think we 5 just bundled all of his up and shipped them over to you. 6 MR. GUILD: Off the record. 7 [ Discussion off the record.] 8 MR. MILLER: Let the record reflect that in the 9 conference room in which this deposition was held, the 10 inspection records of Mr. DeWald are currently being made 11 available to Mr. Guild and staff. 12 Those inspection records which indicate that 100 or 13 more inspections were aggregated on a single sheet with one (~J] 14 date, bear the identification numbers S-15241 to S-17825. 15 Those inspection reports, which indicate 100 or less 16 inspections aggregated on a report with a single date are 17 identified by the numbers S-17826 to S-20714. 18 BY MR. GUILD: 19 Q Mr. DeWald, for this purpose, I want to simply 20 understand a little more detail of your last series of 21 answers, explaining how weld inspections were documented at 22 the time when you were performing level II inspections. I'm
r-35 1 just pulling the top inspection report from the documents that G _s) 2 were identified. 3 This is in the first group and those are the ones 4 described as single reports reflecting 100 or more welds or
- 5 components -- I don't know which, to tell you the truth -- on 6 a single report. This is S-17500.
7 Let me show it to you and could you just explain to 8 me what that document represents, please? r 9 A Okay, this is the date that I filled the document 10 out. 11 Q You're saying this, which? 12 A Which is the date reflected up here. I'\ 13 Q At the top of the cover page? i 14 A Right. 15 Q And that's the date you put on the document, right? 16 A Yes. I may have done this in maybe two days. 17 Q Can you tell, from the document, what days you 18 performed the inspection work? 19 A It would have to be prior to 4-30. Or it could be 20 on 4-30. 21 Q So it could have been all done on that one day, or 22 it could have been done on preceding days?
( 36 1 A Yes. 2 Q But your practice, are you telling me, was to put 3 the date on the cover page, reflecting the date on which you 4 filled the form out? 5 A Yes, sir. This might be two days compilation of 6 Work here. 7 Q Did you have any other documentation reflecting your 8 inspection results over that period of time, other than the 9 inspection report and cover sheet? 10 A We used to carry a little notebook in the field with 11 us. It was a little thing and once we got done or filled it, 12 we usually threw it away.
}
13 Q Did you usually throw it away? 14 A Yes, sir. 15 Q So you might have recorded your inspection results 16 initially on a personal notebook or record? 17 A Yes, sir.
-18 Q And then transferred that information to the 19 inspection report?
20 A Yes. 21 Q And have you maintained any other records f 22 documenting the results of your inspection work?
37 1 A No, sir. 2 Q Except for the inspection reports and cover sheets? 3 A That's it. 4 Q Was there any Comstock procedure that expressly 5 provided that an inspector should document the inspection , 6 results in a notebook or other record and then transfer them , .7 onto the inspection report? 8 A No, sir. 9 Q Did the inspection procedures speak to that question 10 at all? 11 A No. 12 Q Did the inspection procedures, at the time, tell you
'N 13 when you filled out the inspection report?
('J
\.
14 A No, it didn't. i 15 Q Did it, in essence, just say date and sign? 16 A Date and sign. 17 Q And didn't specify what that date referred to? 18 A No. 19 Q Now with that example in mind, can you tell me what 20 other information -- aside from the date -- appears in this 21 report? 22 A Okay, it gives you whether it's a conduit hanger or O
38 1 aux steel. The drawing number, which is applicable to these; (h (s / 2 the total of welds, which is accumulation of all the welds on 3 all of these. 4 Q And in this cover sheet, it has a number of total 5 welds? 6 A Right.
- 7 Q And what is that number on the sheet?
4 8 A Right here. 9 Q What's it say? 10 A 230. 11 Q Now, the sheet you're looking at, this is the cover 12 to PTL, asking for overinspection? 4 13 A This was the one we sent to PTL, to do their 10 [V) 14 ' percent overinspection on. , 15 Q That's what you're referring to? This is not a form 16 197 The form 19 is attached, right? 17 A This is a form 19, yes. 18 Q And the cover page that you're looking at is the 19 memo addressed to PTL? 20 A Yes, sir. 21 Q Okay. I'm sorry, that helps. 22 Now the information you've just described appears in O
39 1 the middle of the page and it's really not under any O
\,,,) 2 particular box or blank.
3 A It gives PIL the direction on where to do and where i 4 4 to locate it. 5 Q And then, under the next open space on the page, 6 there is a series of columns and information. And can you 7 tell me what that is? 8 A L to 13, L to Q is the coordinates on which these 9 hangers -- CC-56 and so on -- could be located. 10 Q And those are grid references? 11 A They were actually the grid reference to which these 12 are close to or actually on. 13 Q And then, there's another column similarly? 3 14 A Which is the same as the first column. 15 Q Different information? 16 A Different -- this is 10 to 11, L to Q. And it gives l 17 the hanger numbers, which is relative. 18 Q Another set of hangers, different grid reference? 19 A Yes. 20 Q And the third column, what's that? 21 A Which would relate to the grid reference. 22 Q Are those component identification numbers?
%d 4
40 1 A They're hanger numbers, yes. 2 Q Hanger numbers. 3 CC-56-AS, can you tell me what those numbers 4 represent? 5 A Aux steel. 6 Q What's the CC indicate? 7 A Conduit hanger. 8 Q How about-CP? 9 A That's a conduit hanger. 10 Q What's the difference between the two? 11 A That's the difference in the detail. 12 Q A P and a C, detail? 13 A It's in the details in the drawing. Different [ 14 conduit hangers are labeled differently because you have so 15 many conduit hangers on a drawing. You may have cps, WHs, WS. 16 Q What do those different letters stand for? 17 A one would be wall strap, wall hanger. 18 Q Different kinds of hangers? 19 A Different types. 20 Q What's a CC? 21 A It's a conduit hanger. 22 Q A hanger? O
41 1 A A cantilever type. 2 Q A cantilever hanger? Okay, what's a CP? 3 A I don't recall that particular one. 4 Q~ How did you determine how many welds there were when 5 you placed the date that appears, 4-30 in this case, how would 6 you identify the number of weld? 7 A Counting those as you do the components. 8 Q And you'd record, as you did the inspection, in your 9 notes? 10 A Yes. 11 Q And transfer the total onto your form? 12 A Yes, sir. 13 Q Now, attached to this particular cover sheet there
)
14 is a document, Bates number S-17501 and it's a form 19. It 15 doesn't appear to have any revision date. Origination date 16 5-26-80. Does that appear to be the original revision of form 17 19? 18 A That's the -- I believe it's the original procedure 19 date of when that procedure was initiated. 20 Q So this is the original version of form 19? 21 A Yes. 22 Q Now you signed this form 19 -- let me ask you this. O f
42 1 The form 19 describes the subject of the inspection under the l (Q_s 2 drawing / details block, at the top? Is that where you describe 3 what you inspected? 4 A That's where you would put your drawing numbers. 5 Q To indicate what the subject of the inspection was? 6 What you looked at? 7 A What components were, yes. 8 Q Now here you've written a number and then, under the 9 rev block next to it, you have a star. And what does that 10 description indicate? 11 A Down below, in the remarks section, you see it says GAS-l J4C:> 12 attached -QA-le-one. But I can't recall exactly what it would 13 be now. That's quite a time. ( } 14 Q What's a QAS-2 or l? 15 A QAS-1 is a general form that normally we would write 16 the procedures on and we use that to attach, at times, general 17 notes or something for clarification to the checklist. 18 Q Well, in this instance, for this particular record, 19 do you need the attached QAS-2 form, in order to know what the 20 subject of your inspection was? What components you 21 inspected? 22 Why do you refer to that, can you tell me? O
43 1 A I can't really tell you, now, just by looking at 7-) (_) 2 this. If I saw the QAS-1 I possibly could. 3 Q It doesn't appear to be in the next document. Are 4 those separate filed? Or are they -- 5 A It should have been filed with it. 6 Q That remains somewhat of a mystery, but at the 7 bottom of the page there is two signature blocks. One says QC 8 inspector and appears to bear your signature? 9 A Right. 10 Q And the other signature says level II inspector and 11 appears to have the name David Thomas by it. Were you a level 12 II at the time? 13 (') x/ A Yes, sir. 14 Q What's the significance then of having you sign as 15 the person who performed the inspection and then somebody else 16 sign -- in this case, Mr. Thomas -- as a level II inspector? 17 A He reviewed that sheet for the accuracy or the 18 completeness of the form. 19 Q Did he -- Mr. Thomas -- indicate by that signature 20 that he had gone out and visually inspected all the wolds 21 himself? 22 A No, sir, n k ) v
44
.1 Q He had just seen the paperwork?
2 A Yes, sir, i 3 Q And after the fact? 4 A Yes, sir. 5 Q And his review is indicated on 5-1-81, your date and 6 signature is 4-30-81. 7 A Yes, sir. 8 Q Was there any procedure that specified when the j 9 level II inspector would perform whatever review work he 4 3 10 performed? i 11 A No. 12 Q It had to happen after you filled out the form? 13 A Yes. ; 14 Q But no specified time.thereafter? 15 A Right. , i j 16 MR. GUILD: Let's mark 17500 and 17501 as the next i 17 exhibit. i 18 (DeWald Deposition Exhibit No. 4 was 19 marked for identification.) 20 MR. GUILD: Off the record. )- 21 (Discussion off the record.) 22 i !O 4
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45 1 BY MR. GUILD: !m\ (_,/ 2 Q Another inspection report. It's S-17520 and the 3 following page. It appears to reflect the inspection of 492 4 welds. Just take a moment and review that. 5 [ Witness reviewing document.] 6 Now, I just happened to pull from the first folder 7 of many, another document which indicates the performance of 8 weld inspection documenting the inspection of 492 welds. And 9 as I was saying, off the record, Mr. DeWald, I saw multiple 10 copies of that same inspection report. Can you describe how 11 it would happen that copies would be made like that? 12 A The stamp on the side says ID and drawing number, if ['} v 13 you'll notice. There's HO33. HO33 is one of the components 14 identified here. So there would be a copy of each one of 15 these components identified for the vault filing system, for 16 packaging. 17 Q After the fact of these inspections, that were done 18 fairly early on, you went back and reformatted the records and 19 had to reproduce this inspection report for packages for each 20 of the components listed on the inspection? 21 A Yes, sir. 22 MR. GUILD: Let's mark this and that is 17520 and o
l 46 l 1 521, and that's Exhibit 5. k-m 2 (DeWald Deposition Exhibit No. 5 was 3 marked for identification.] 4 BY MR. GUILD: 5 Q Mr. DeWald this, again, appears to reflect another 6 grid coordinate reference, does it not? 7 A Yes, sir. 8 Q And it appears to be a drawing and on that drawing 9 you documented inspections of components from coordinates Q to 10 V and 11.2 to 15? 11 A Yes, sir. 12 Q And that establishes a rectangular area in which 13 these components were located? ( ) 14 A Right. , 15 Q The components here have an H number. What's an H? , 16 A That is a cable pan hanger. 17 Q And in a parenthetical after the component, there's 18 an AS. Can you tell me -- . 19 A That would be the auxiliary steel that the hanger is l l 20 attached to. 21 Q What's auxiliary steel? 22 A It would be another piece of member that might be 'I !O
47 1 put in between two beams, that the one leg of the hanger has 2 to be attached to. 3 Q There's an indication -- and this is again a PTL 4 cover sheet -- welders and number 6-58-120. 5 A Those are the welders that done it, welder number 6, 6 welder 58 and welder 120. 7 Q Those three welders did all of the welding on the 8 components listed on the cover sheet? 9 A One -- either -- they could have done one of each of 10 those components. 11 Q Do you know which welder did which component? 12 A Not offhand, I don't. 13 Q Can you tell from this inspection report? 14 A No, sir. 15 Q Is there any other documentation that would indicate 16 which welder did which component? 17 A There would be the installation report. 18 Q The record that was made when the welder did the 19 installation? ' 20 A Right. 21 Q And would there be a welder stamp or mark on the 22 weld? O
48 1 A There would be the welder's'name. 2 Q On the weld itself? Was there a stamp used? 3 A There was a stamp used on the veld. 4 Q So looking at the weld or the component, you would 5 see a welder's unique stamp? 6 A Yes, sir. 7 Q Or you'd see a number, in any event? 8 A Yes. 9 Q It may not be the welder's unique number, but it's 10 a number. 11 A It would be his unique number. 12 Q There may have been more than one welder with that () 13 14 number, at different points in time, during the job? A Early, early, early, there's very possibly that 15 there was a number that had been duplicated. 16 Q The attached page is the form 19. Again, it 17 indicates, by use of the checklist, that all of the welds -- 18 the 492 that are described by the grid reference -- were 19 acceptable? ! 20 A Yes, sir. 21 Q The last box is weld as a result of repair per ICR 22 or NCR number. And that's N/A correct? il
49 1 A Yes, sir. 2 Q There was no NCR or ICR -- 3 A Right. 4 Q -- that resulted in that weld. It looks like 5 someone erroneously marked the accept box originally. 6 A That's my initial. I had checked the wrong box. 7 Q You checked the wrong box and you initialed your own 8 correction? 9 A Right. 10 Q Approved by Mr. Kast, as the level II inspector? 11 A Yes, sir. 12 Q Same date on which you dated the form? 13 A Yes, sir. 14 Q can you tell from this form when you performed the 15 inspection of the 492 welds that are documented on that 16 report? 17 A I would say it would be a series of days, two, 18 three, or four days. 19 Q Two or three or four days preceding the 3-24-81 20 date? 21 A Yes, sir. 22 Q And as you indicated before, you may have had a O
50 1 personal notebook or record of the inspection results, as you (_/ 2 were performing them? 3 A Yes, sir. 4 Q And you don't have those documents anymore? 5 A No. 6 Q The two documents that we just really pulled out at 7 random, are they exemplary of the documentation system that 8 was used for visual weld inspections at that time? Are these 9 typical? 10 A That's typically the way that it was filled out at 11 that time. 12 Q Now the two that we happened to pull out here, the ( } 13 second indicates 492 welds on a single date. Do you know 14 whether or not you ever documented any more than 492 welds on 15 a single inspection report? 16 A Offhand, no, I don't. 17 Q Do you know whether you ever documented as many as 18 1,000 welds on a single inspection report? 19 A l'm sure I didn't. 20 Q Did not? 21 A Yes, sir. 1 22 Q Why are you sure you did not? O
51 1 A Because I didn't let them go that far before I 2 documented down what I had inspected. 3 Q Why not, Mr. DeWald? 4 A Because I like to keep the inspection reports up as 5 close as I could, once I completed an area. 6 Q How often did you complete inspection reports, 7 documenting the inspection work that you had done? 8 A As soon as I finished an area. 9 Q Well, the number of welds that happened to be 10 contained in a particular area varied from area to area, did 11 it not? 12 A Depending on the amount of activity that was in that 13 area, the amount of welders that was working in that 14 particular area. 15 Q Was there any set procedure that defined the limits 16 of an area that would be subject to a single inspection 17 report? 18 A procedure, no. 19 Q Was there a practice that established the limits of 20 an area that would be subject to a single inspection report? 21 A No. 22 Q How was it determined then, what particular area you O V
- l 52 i <
1 would be responsible for going out and inspecting at that I 2 time?
; 3 A Usually on elevations. I took care of 439, I think i 4 426. There was a couple of other elevations which had various 5 welders and different crews working in there.
6 Q So particular weld inspectors would generally be 7 assigned to particular areas of the plant and they are 8 described by elevations, correct? 9 A Well, as you're indicating, we didn't have anybody 10 really assigned to it. I worked with the welders in 439, 426. 11 Q It was an informal assignment of inspectors to cover i 12 particular crews? Is that right? 13 A ( ) We didn't really have particular crews. We just
- 14 took the elevation. Whatever crew was working on it, we worked 15 with those to inspect it.
16 Q By elevation, you mean an area of the plant? i 17 A Right, a level in the plant. T I ! 18 Q And so then that helps understand a little bit, but a I 19 was there any practice that defined what particular area you 20 were going to inspect and document on a single inspection 21 report? 4 22 A Other than what I got right there. ; i
< ()
4 i I
53 1 Q You went out and did the work. Once the work was 2 completed, you defined what you had just gotten done 3 inspecting and documented it? - L 4 A Documented it on the inspection report. d 5 Q Now, I'm trying again, to get back to the point that 6 you were making, and that is I asked you why you wouldn't do 7 as many as 1,000 on a particular report. I understood you to
- 8 say because you didn't want to get behind, in effect.
9 A As I completed an area, I'd like to -- as soon as I 10 was done -- it might took me two days to work in there with 11 these welders to complete it -- I would make that inspection 12 report out. It might have been three days. ! 'T 13 Q That's what I'm trying to figure out. When you say [Q t 14 completed an area, how did you define the area that you were j 15 going to complete? When did you decide I'm done, and I better 16 go back and record all this stuff? 17 A Once I got caught up to them. In other words, they 18 started on drawing 3051-H, just to take a hypothetical 19 drawing. They would start at that and of the drawing and they i 20 would be working this way. 21 Q Okay. 22 A And I would start and work until I caught up to . O L I
s l 54 1 them, then I'd go to another crew and work until I caught up 2 until them. l 3 Q' So when you caught up with crew 1, in your example, 4 you'd stop and write up the documents for the inspection 5 report? i l 6 A Yes. ' l 7 Q In essence, do I understand you to say that as your 8 work responsibilities permitted, when you were done doing the 9 inspection work, you turned to the documentation for that work 10 and finished that? 11 A Basically. j 12 Q And there wasn't any procedure or guidance that l 13 dictated when an inspector completed the inspection 14 documentation for a particular inspections? 15 A No. 16 Q Did the level II inspector who, under the procedure, 17 reviewed your inspection report for completeness and clarity j 18 -- is that the words you used? - 19 A Right. l 20 Q Did that level II inspector review your personal 21 notes that were the basis for your inspection report? 22 A No. O i
55 1 Q Was there any procedure or policy that provided that 2 the level II would review your personal notes that were the 3 basis for your inspection report? 4 A No. 5 Q Mr. DeWald, has the Comstock policy or practice or 6 procedure changed since the days l'1 which the inspections were 7 performed by you, that are referred to in Exhibits 4 and 5, to 8 provide any guidance on when the inspection report is to be 9 completed or how you define the area of inspection? 10 A Yes, sir. 11 Q Can you tell me when those changes took place? 12 A Shortly after I got there as the QC Manager, in '83, 13 August. 14 Q And what kind of changes were implemented then? 15 A You do the inspection checklist at the time of the 16 inspection. 17 Q That's a practice that's now -- that changed at that 18 point? 19 A Yes, it's in effect right now. 20 Q And was there a procedure change that provided for 21 that change in practice? 22 A I believe the procedures imply that -- I'm not -- O
- 56
;~ %
< $' 3 risht now, I can't remember exactly what the procedure says,
\. . 2, but I bAlleve that'it implies that the inspection report is to 3 be c'ampleted at the time of the inspection.
4 Q Do you know whether the procedure implied, to that 5 : sffect, at the time you performed the inspections that are
~
6 documented in -- 7 A I don't believe it did. 8 Q So there was a change in the procedure? 9 A ,Yes, sir. .-, 10 Q han you tell me what"the change in the procedure 11 was? The subatttnce of the change? i' 12 A I can't really remember, unless I looked at the o , procedure. ( { 13 14 Q You might want to try to pull it out. It would
/ ~,
s , 15 help. Just my recollection, of reading the current procedure, 4 16 says only date and sign. 17 A It's a policy that the inspection report is to be 18 filled out at the time of inspection. 19 Q Is it possible, Mr. DeWald, that the Comstock 20 l] inspection procedure has always been more or less general in 21 this respect and said date and sign back then and says date 22 .and sign now, but there's been a change in policy? - 4. . l) J I
1 57 1 A That's possible. t
~-
2 Q Do you know whether the change in policy is 3 reflected in any kind of documentation, a memo or a guidance , 4 in writing? 5 A I can't recall whether I issued a memo or not on l 6 that. . 7 Q Is it your belief that the practice has changed? 8 A I know it has changed. ! -9 Q And how do you know that? 10 A Because I review and to see when these inspection 11 reports-come in, when the inspection was done, when it was , 12 called for. 13 Q ( ) And from the face of inspection reports -- from form 14 19s now, you can tell that instead of documenting 492 welds,
- .15 they document four welds on one component, that sort of thing?
16 A Yes, sir, as many as -- whatever the component 17 entails. 18 Q They document one component? 19 A One component. 20 Q And that's the practice now, is to have one 21 inspection report per component? 22 A Yes, sir. ] O
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. . - _ . _ . _~ - -- - _ - - .. . - - _
58 1 Q Have you rev'ewed the deposition transcript of the 2 deposition of a QC inspector named Dan Holley? I 3 A No, sir. 4 Q Have you discussed Mr. Holley's deposition with 5 anyone? 6 A No, sir. 7 Q Mr. Holley was asked, generally, whether he was ! 8 familiar with any instance in which you had performed more 9 than 1,000 welds in one day. And in substance, Mr. Holley 10 said yes. He was asked how he knew and he said I, on occasion 11 would review inspection reports in the vault, in the course of 12 performing configuration inspections at a later date, and
} } 13 would come across your inspection reports -- presumably of the 14 sort that we're looking at today.
15 In substance, Mr. Holley said yes, I've laid hands 16 on some of Irv DeWald's old inspection reports and my belief 17 is they documented more than 1,000 in a day. And he gave us a l 18 drawing reference. 19 Do you know why Mr. Holley would have been under the 20 belief that you performed more than 1,000 welds in one day?- 21 MR. MILLER: Object to the form of the question. Go 22 ahead. 1 O
59 1 THE WITNESS: No, I don't. 7 2 BY MR. GUILD: 3 Q Have you ever said, to Mr. Holley or to any other 4 inspector, words to the effect that you had done more than 5 1,000 welds in one day? 6 A No, sir. 7 Q Had you ever said words to the effect to Mr. Holley 8 or another inspector that you had documented 1,000 or more 9 welds on a single inspection report? 10 A No, sir. 11 Q Do you know whether or not there's a common belief 12 on the job, Mr. DeWald, among QC inspectors to the effect that
/
)
13 Irv DeWald has done more than 1,000 weld inspections in one 14 day? 15 MR MILLER: Object to the form of the question, but 16 go ahead. 17 THE WITNESS: I don't know about the belief. " 18 BY MR. GUILD: 19 Q Have you ever heard rumors to that effect? 20 A I hear rumors. I hear a lot of rumors. 21 Q I would just submit to you, Mr. DeWald, that at 22 least in terms of the inspectors who have testified so far in
~%
60 i 1 this proceeding, in deposition, they have said to the effect 2 that there is a common belief on the part of inspectors that 3 Irv DeWald did more than a 1,000 welds in one day. 4 And have you heard rumors to that effect? 5 A Through hearsay, I might say. Not -- just since 6 this ILB hearings and so forth have been going on, but not 7 prior to that. 8 Q That's what a rumor is, it's just hearsay. 4 9 A A rumor is hearsay. 10 Q But recognizing that hearsay has rumor and rumor has 11 hearsay, that's still the point of my question. You are aware 12 of rumors to that effect? 13 A ( I've been made aware of it as far as -- like I say, 14 through the contentions and so forth. 15 Q And how were you made aware of that? How did that 16 come to your attention, that rumor? 17 A I don't recall, offhand, where I heard it, but it 18 got back. 19 Q Did you hear it from one of the lawyers for Edison? 20 A It may have been. Like I say, I don't remember who 21 I heard it from. 22 Q Did you ever hear it on the job, from an inspector?
/G k
61 1 A No. 2 Q From anybody else in Comatock supervision? 3 A I may have heard it from Bob Seltmann or something. 4 He's the licensing coordinator, so -- or was the licensing 5 coordinator. 6 Q Okay. He's not doing that anymore? 7 A No. 8 Q Who's doing that? 9 A Clarence Hart. 10 Q Clarence? 11 A Hart. 12 Q H-a-r-t? () 13 14 A Yes. Q You earlier said that you didn't document more than 15 1,000 welds on a single inspection report and I think you 16 explained why, by saying you wouldn't let it get that far 17 behind, in substance. What, exactly, was the standard that 18 you were using when you were doing inspection work? How far 19 behind did you let it get before you said I got to stop and 20 write this up? 21 A Just a few days. 22 Q We've got one inspection report that shows 492 O
62 1 welds. Do you have a recollection of how many welds was the h x/ 2 maximum number of welds that you documented on an inspection
- 3 report? If it wasn't 1,000, how many less than 1,000 was it?
4 A I can't really say. I don't know. 5 Q At least 492, right? 6 A At least that. 7 Q Somewhere between 492 and 1,000? 8 MR. MILLER: Object to the form of the question. I 9 think the witness has already answered the question. 10 BY MR. GUILD: ' 11 Q I'm trying to refresh you recall. I know it's a 12 long time ago, Mr. DeWald, so I'm trying the best I can to see ( } 13 if we can probe what memory is understandably not precise on 14 this point. But you know it wasn't 1,000 and you said why you 15 believe it's not 1,000. We know it's at least 492. 16 Is it a fair inference that it's somewhere between 17 492 and 1,000? 18 A I don't really know. 19 Q So 492 may well be the maximum number that you 20 documented on a single report? i 21- A Possible. Like I say, I don't really know. 22 Q Do you know what the maximum number of welds O
63 1 inspected by you was, in a single day, Mr. DeWald? 2 A No, sir, I sure don't. 3 Q Let's look at Exhibit 5 as the only example that's 4 available to us on this. The inspection that was written up 5 on March 24th, 1981. It documents total welds, 492. Now do 6 you know how many days work -- inspection work is documented 7 in that report? 8 A It could be two, three, or four days. I'm not sure. 9 Q Can you tell me what the maximum is? Could it be 10 more than four? 11 A It's hard for me to say. I don't recall. 12 Q Given your knowledge of your practice, limits on how 13 far behind you allowed yourself to get with inspection reports b(^N 14 -- and I think you said a couple of days -- could it have been 15 more than four days? 16 A It's possible. . 17 Q How many more than four days, possibly? 18 A Maybe another day. 19 Q Five days? 20 A Possible. 21 Q Could it have been more than five days? 22 A That's hard to say. O
64 1 Q It could have been more than five days? i 2 A I don't think so. 3 Q Let's just take -- is five days a reasonable outside 4 limit for the number of days worth of work would have been on 5 a single document? i 6 A I feel possibly yes, due to the conditions that were 7 out there at the plant at the time. 8 Q Can you just tell me what you mean by that? 9 Conditions? 10 A You didn't have items to crawl over. You didn't 11 have items -- you could move a ladder from one end to the 12 other of the room with no obutacles in the way. Everything 13 was accessible. 14 Q So things were accessible. Why is that condition 15 relevant to the question of how many days were the maximum 16 number of days on this report? 17 A The easier it is to get to the weld, it's a whole 18 lot easier to inspect it. 19 Q You could do more weld inspections at that time than 20 you could today? 21 A That's right. 22 Q If it's a maximum of five days work reflected in O
65 1 this inspection report, five divided into 492 roughly reflects
} 2 slightly less than 100 welds per day. Do you believe that 100 3 welds per day was the average number of welds that you 4 inspected, as reflected in this inspection report?
5 MR. MILLER: I'm going to object to the form of the 6 question. You've asked Mr. DeWald generally about what the
- 7 outside limit was. And now we're back to the specific ,
8 inspection report, as to which he has said he has no specific 9 recollection. 10 THE WITNESS: I couldn't say. It would vary from 11 day to day. 12 BY MR. GUILD: 13 Q What I want to try to establish is, within the ( 14 limits of your recollection, what was the character of your 15 weld inspection work at the time, and I just want you to tell 16 me what you know. And if you don't know or don't recall, just 17 be truthful. 18 A The character of my work? 19 Q Yes, yes. How many welds you were doing in a day is 20 what I'm trying to focus on here. And that's the nature of my 21 last question, was if there's a total of 492 and at the 22 outside it would have been five days work, simple division i 1-
- _ _ _ , . , . , , - _ . _ , , , , --.7,.-. _. _-. _
66 1 suggests that is slightly less than 100 welds per day. [D
\m ,/ 2 Now if it was one days work, it's 492 welds in one 3 day. If it's two days work, it's 250 approximately welds in a 4 day. I'm just trying to -- using those numbers, Mr. DeWald, 5 trying to understand, during that period of time, how many 6 welds per day you were inspecting.
7 A I could probably get about 15 hangers a day, 8 depending on how many welds was on the hangers. 9 Q How many welds were on hangers? What's the range of 10 welds per hanger? 11 A It would range from two to 12 or probably more. 12 Q Two to 12 is the range of welds per hanger,
'/ 13 approximately?
U' 14 A It could be more, it could be less. 15 Q It can't be much less than two. 16 A It can't be less than two, probably. 17 Q Id could be more than 12, though? 18 A Sure, depending on the configuration. 19 Q What's the typical number of welds per hanger that 20 you were looking at at the time of this inspection report? i-l 21 MR. MILLER: Would it be useful? 22 BY MR. GUILD: g i /
\/
i a l
, - - - - w 9 ^^ ' ~ '
I 67 l Q Please, take your time and look at the documents, if '( 2 they help. 3 A' Well, I can't really give you a typical, if I don't 4 know the attachments that are on those hangers, right at the 5 present. 6 Q Can you tell from looking at the numbers, the 7 description? ' 8 A Every hanger has the possibility of different 9 detail, attachment detail. And I can't really say that 10 particular one has two and that particular one has four. ' 11 Q Can you tell, looking at those details and given 12 your knowledge and experience, Mr. DeWald, whether any of () 13 14 those hangers have as many as 12 welds per hanger? A The aux steel may have as many -- would probably 15 have 12 welds. 16 Q Can you tell from looking at those component 17 descriptions, whether any of them have more than 12 welds per
- 18. hanger?
19 A No. 20 Q In you opinion, Mr. DeWald, how many welds could a 21 level-II inspector have reasonably performed during a days 22 period of time under the conditions that existed at the time O
68 1 of the March 24, '81 inspection? 2 A That would depend on the area in which he was 3 working, whether it was congested or uncongested. 4 Q Okay. Let's take the specific components in an area 5 that's identified in your Exhibit 5. Using that as an 6 example, those components, that area as an example, how many 7 welds of that sort could an inspector reasonably have 8 inspected in one day? 9 A I don't think you can go by the number of welds. 10 You have to go by the number of components and I would 11 probably say 10 to 15 components. 12 Q Of that character? Of the character reflected in [} 13 those areas on Exhibit 5, your inspection? Right? 14 A In both these. 15 Q 10 to 15. Now, were these components installed in 16 the plant? These were not inspections performed in the fab 17 shop, for example, were they? 18 A No. 19 Q These were hangers that were installed in the field? 20 A Yes. 21 Q If, in your opinion, 10 to 15 hangers per day was a 22 reasonable measure of inspection work at the time -- and under O
, 69 1 the conditions reflected in Exhibit 5 -- at a low range,
~h) x_ 2 Mr. DeWald, that appears to reflect -- if there were two welds 3 per hanger -- 20 welds. At the high range, if there were 12 4 welds per hanger and 15 hangers, 180 welds. Now, is it your 5 opinion, Mr. DeWald, that a range of 20 to 180 welds per day of the components described in Exhibit 5 represents a 6
7 reasonable weld inspection performance? 8 A That would depend on the individual, too. 9 Q How about for you? 10 A I feel I could do that. 11 Q You feel like you could have done 180 welds in one 12 day, of the sort that are described in Exhibit 57 13 A If I worked a full eight hour day, yes. ( } 14 Q Now, given the conditions that exist today in the 15 field, for the inspection of similar components, but given 16 today's conditions -- and I gather that your testimony is that 17 today conditions are much more congested and therefore more 18 difficult to inspect, correct? 19 A Yes. 20 Q Given today's conditions, but of components similar 21 to those described in Exhibit 5, in your opinion, Mr. DeWald, 22 how many welds could be reasonably performed -- inspected in
70 1 one day? q h 2 A About half. 3 Q Half as many as back then? 4 A Or maybe less. 5 Q In your supervision of QC inspectors at Comstock, in 6 your capacity as Quality Control Manager, Mr. DeWald, have you 7 used any measures of weld inspection productivity or 8 inspection rates for any purpose, such as for planning and 9 scheduling. purposes? 10 A I have made schedules and such up, taking a period 11 of time and seeing what the inspections -- how many 12 inspections were performed, so I could get an end date or 13 establish a completion date. 14 Q And when you've done that,'what measures of 15 productivity or inspection rates have you used for weld 16 inspection? 17 A I think it's five to seven or five to ten. I forget 18 just what it is. 19 Q Is that welds or hangers? 20 A' Number of components. 21 Q So that would be a hanger? 22 A Yes. O
71 1 Q Okay. Per day, correct? O A
\ms/ 2 Yes, this is just an estimate.
3 Q And for what purpose would you use such an estimate, 4 Mr. DeWald? 5 A For an area of completion of something of that 6 nature. 7 Q Did you ever use such measures to apply to 8 productivity levels of work actually performed by inspectors? 9 MR. MILLER: Object to the form of the question, but 10 go ahead, if you understand it. 11 THE WITNESS: I don't really understand what you're 12 getting at. 13 BY MR. GUILD:
)
14 Q If you use it as an estimate for completing -- and I 15 assume that's future oriented, you want to figure out how long 16 it's going to take you to get a job done, given today and 17 looking into the future, correct? 18 A [ Witness nodding affirmatively.] 19 Q You have to answer yes or not? 20 A Yes. 21 Q The other side of the coin, or what I'm directing 22 you to now is have you ever used any such measures to evaluate O
72 1 actual inspection productivity by inspectors? (
\ss/ 2 A I believe I have.
3 Q And can you tell me how you've done that, what 4 circumstances? 5 A I think it was the warnings in particular, was 6 Mr. Stout. 7 Q Hershel Stout? 8 A Yes, sir. 9 Q And do you recall using -- measuring Mr. Stout's 10 productivity? 11 A Against his time that he had worked on the job. 12 Q And for what purpose did you do that? j } 13 A Due to his absenteeism, to try and get him 14 straightened out. 15 Q Is Mr. Stout the inspector for whom you calculated 16 that he's performed 1.5 inspections per day? 17 A Yes, sir. 18 'Q And that was an average figure? s 19 A His average. 20 Q His average figure, given his absenteeism? 21 A It was to the number of days and hours he had 22 worked, versus against somebody else that was doing the same
l 73 4 1 thing that he was doing.
- 2 Q That's my question. Did you include in the 3 measurement of Mr. Stout's average just the days and hours he i
4 worked? 5 A Yes. 6 Q Not days that he was absent? 7 A Correct. 8 Q Have you used such measures, measures of inspections 9 per day, either formally or informally with any other
- 10 inspectors?
11 A Not to my recollection.- 12 Q Do you know whether any of your supervisors have 1 l 13 used such measures, either informally or formally for other [ } I 14 inspectors? j 15 A Again, not to my recollection. 1
- 16 Q Did you ever hear of Mr. Saklak, for example, say to 17 you words to the effect that inspector X is only making three i
18 a day or two a day, words to that effect? f 19 A Mr. Stout was the only one he brought to my i 20 attention. 21 MR. BERRY: If you're passing onto a different 22 subject or a different line of questioning, perhaps this would i
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74 1 be a good time to take a five minute break. 2 MR. GUILD: Sure. 3 [Short recess.] 4 MR. GUILD: Let's mark another weld inspection 5 report. This is S-17169 and 170 and it appears to be form 19 6 with a cover sheet dated 3-12-81. ! 7 [DeWald Deposition Exhibit No. 6 was 8 marked for identification.] 9 BY MR. GUILD: { 10 Q Mr. DeWald, another inspection report. Was that 11 inspection performed by you? 12 A It's got my signature on it, 13 Q Does that appear to indicate that it was your i-( }
'14 inspection?
15 A Yes, sir. 16 Q How many welds does that reflect? 17 A 551. 18 Q Does it also reflect the grid coordinate references? 19 A Yes, sir. 20 Q It reflects that the components all are described 21 with the letter "H." What is an "H"? 22 A It's a hanger. O
75 1 Q And that the welders were 99, 11 and 566. Can you 2 tell which welders did which components? 3 A No, sir. 4 Q Do you know whether there are any instances in which 5 you inspected more than 551 welds per inspection report? 6 A I don't know. 7 Q Mr. DeWald, you left Comstock at Braidwood and went , 8 to D.C. Cook as the quality control manager? 9 A Yes, sir. 10 Q Is that the position that you took when you went to 11 D.C. Cook? 12 A Yes, sir. (~') 13 Q Who was the Comstock QC manager at Braidwood at the (./ 14 time you left? 15 A Robert Brown. 16 Q And did you replace Mr. Brown when you came back as 17 QC manager in August of '83? 18 A No, sir, Mr. Corcoran. 19 Q What is his first name? 20 A ( Thomas, I believe. 21 Q What happened to Mr. Brown? 22 A He was transferred to Perry nuclear power plant. L . - - . _ __
76 1 Q And in what capacity did Mr. Brown work for Perry; 2 do you know? 3 A I don't know. 4 Q Did he work as a QQ manager there? 5 A No. I don't know what capacity he was in. 6 Q Do you know whether Mr. Brown was replaced because 7 of deficient work performance? 8 A I don't know why Mr. Brown was replaced. I never 9 inquired. 10 Q You never inquired, and no one ever told you? 11 A No, sir. 12 Q Had you ever heard that Commonwealth Edison had had 13 him replaced? 14 A I had heard that. Again, it's hearsay. 15 Q Do you recall who you heard that from? 16 A No, not offhand. 17 Q Was Mr. Corcoran on the job when you came on as QC 18 manager? 19 A Yes, sir. 20 Q And what position did you come back in? What 21 position did you come back to Braidwood in when you returned 22 from D.C. Cook? I l _ _
77 1 A QC manager. s 2 Q And Mr. Corcoran wasn't QC manager then. You 3 replaced him. 4 A I replaced him. 5 Q And what job did Mr. Corcoran get? 6 A He took the QC engineer's job. 7 Q Can you describe the circumstances in which you 8 replaced Mr. Corcoran as the QC manager? 9 A Such as? 10 Q How did you learn that you were going to come to 11 Braidwood as QC manager? 12 A Oh, I was called and asked: Do you want to go down 13 there? I said: I'll go to work anyplace. ( } 14 Q And who called and asked you? 15 A The corporate manager, Mr. Marino. 16 Q Mr. Bob Marino?
-17 A Yes.
18 Q And what did Mr. Marino say to you, in substance, 19 about the reasons why Mr. Corcoran was being replaced? 20 A I don't know exactly the actual conversation. It 21- was more or less he was dissatisfied with Mr. Corcoran's 22 performance. O
78 1 Q He, Mr. Marino?
'd 2 A Yes.
3 Q Did you understand from Mr. Marino whether Edison 4 had a hand in replacing Mr. Corcoran? 5 A Not at that particular time, but I found out later 6 that possibly they was also dissatisfied. 7 Q And how did you find that out? 8 A Through casual conversation with various people. 9 Q Can you recall who? 10 A No. 11 Q Did you ever speak with anybody in Edison management 12 about the circumstances under which you replaced Mr. Corcoran? I~' V) 13 A The exact circumstances, no. 14 Q Well, generally, the subject at all of 15 Mr. Corcoran's work performance? 16 A No , I never talked other than, like I say, casual 17 talk where they would say, well, that was one of 18 Mr. Corcoran's memos or something, but I never went over and 19 inquired. 20 Q Well, whether you inquired or not, did anybody with 21 Edison ever sit down with you, Mr. DeWald, and say we've 22 identified deficient work performance by your predecessor,
79 1 Mr. Corcoran, and here are the problems, and in substance, 2 you,-Mr..DeWald, need to take corrective action for these 3 problems? 4 A Not in a meeting of that specific substance. In 5 various meetings that I had right after I got on the site, it 6 was brought out that they were dissatisfied with Mr. Corcoran. 7 Q And can you identify those meetings? 8 A No, I can't. 9 Q Did they involve Edison people? 10- A Oh, yes. Probably at the time, I talked a lot with 11 Mr. Cosaro.
' 12 - Q Mr. Cosaro was the construction superintendent?
13 A I think that was his title. 14 Q Project construction manager? 15 A Something like that. 16 Q The senior Edison person. 17 What work performance deficiencies did Mr. Cosaro or 18 others identify of Mr. Corcoran, your predecessor? 19 A His methods, I believe, some of his memos and so 20 forth, personal actions, I guess. 21 Q Could you be a little more specific? What do you 22 mean by his methods? O
I 80 1 A He really wasn't construction orientated. He was n k ,) s 2 quality orientated, from what I could gather. Again, this is 3 just my opinion of what I understand. He didn't understand 4 construction. He came basically from an industrial-type 5 environment. 6 Q Do you know what kind of industrial background he 7 had? 8 A No, sir, I sure don't. 9 Q Were there concerns or complaints expressed to you 10 that Mr. Corcoran was slowing the job down, in effect? 11 A Not that he was slowing the job down. There were 12 things he wasn't getting done. 13 Q He wasn't getting his QC inspection work done in a (} 14 timely fashion? 15 A Basically, yes. 16 Q To meet the needs of the production side? 17 A To keep up with or possibly meet schedules or so 18 forth. 19 Q Did you ever have conversation on that subject with 20 Mr. Wallace, the project manager? 21 A Not that I recall, not with Mr. Wallace. 22 Q Mr. Wallace was there at the site when you came on ,O
~ l 81 1 in August of '83, was he not?
^N 2 A I think he was.
3 Q He was the assistant manager of projects or -- he 4 was there at the same time Mr. Cosaro was there? 5 A I believe he was. Like I say, I'm not sure. I know 6 when I got there I really didn't have that much dealings with 7 Mr. Wallace. 8 Q Now, when you say memos, do you have something in , 9 mind in particular? , 10 A Not anything in particular. 11 Q Just the form of his writing? 12 A The form of his writing and the way he expressed O
'J 13 himself.
14 Q Okay. There were inadequacies in the way he did 15 that? 16 A Some of the memos were vague and they were hard to 17 understand. 18 Q Okay. What did you understand from Mr. Cosaro or 19 others by way of actions that you were expected to take to 20 correct these deficiencies? 21 A Basically to go in there and find out where I was 22 at, what number of inspections that existed, where was the O
. . - -. ._ _ = --
82 1 different projects that was in place, where was they, and try 2 to figure out an estimated completion date on these things. 3 Q Did you do that work when you came on? 4 A Yes, sir. 5 Q And did you identify any backlog in inspection 6 activity? 7 A Yes, sir. 8 Q And did you identify any backlog in other projects 9 that were under your area of supervision, aside from 10 inspection activity? 11 A Did document review. 12 Q And that was backlogged as well? 13 A Yes. 14 Q And can you describe generally the extent of the 15 backlog on inspection activity at the time you came on? 16 A When I got there, I saw numerous installation 17 reports laying around, and I didn't really know how many had 18 been inspected. They had been sent up. So I took a hand 19 count of what we had and came up with what I thought was the 20 total number by the pieces of installation reports that I had. 21 Q Just the pieces of paper? 22 A They were installation reports, and I counted these
83 1 up. There could have been multiple items on an installation /^ km ,\ 2 report and so on. This is what I based my total number 3 on. The document review which was supposed to be at that time 4 completed the 30th of September, I found that I had numerous 5 documents there that had not yet been reviewed, so I had to 6 take a complete hand count of all this to find out exactly 7 where I was there. These were the two major projects that I 8 really undertook when I got there. 9 Q And what was the inspection backlog that you 10 identified? . 11 A I can't off-hand remember the exact number, but I 12 think it was around 14,000. ( } 13 Q And were these just items that -- were they 14 backlogged any particular amount of time? Was there a measure 15 of time you used? 16 A Some of them would have been a year old or so. 17 Q That's on the outside? A year old? I mean no more 18 than a year old, or that's the outer limit of -- 19 A Well, that's -- the majority of it, probably a year 20 old, or less. It depended. 21 Q I'm not being very precise in answering the 22 question. I apologize. But I have heard measures used of A V
p- - y ..
~. _
x-84 1 more recent vintage of 36 days as a standard for backlogging.
's 2 'A No, what we call a 30-day is that the inspection be s
3 done in a timely manner.
- 4. Q 'And after that it's backlogged?
- i. 'J 3 y 5 A After that we consider it not really backlogged but
' Jg 6 those are the ones we give the emphasis on in order to get the 4
7 ,
,lnspections current.
S' Q Now, when you use the count of 14,000, was that over 19 30 days or just gil uncompleted installations? 10 A AlU uncompleted installations, which would be a wide 11 range. 4 12 Q Sono lesc.than 30 days but some over a year? t I~h 13 'A Yes.s N 14 Q And}is'thhtthehighestnumberofbacklogged
~
+ 15 inspections since you took over? Have there been 14,000 16 4 backlogged inspections?.
17 A No.
~
18 Q How far backlogged was the document review when you 19 came on? m 1-20 A Again, I can't reme'mber,the exact'-- I'm going to , 21 say but I'm not sure whether this'is right. I think it was 22 something like -- the number 50,000 in the documents is what
- c
, ar' mm*
gd 4 y- , n , , , - - - , . -
85 1 rings a bell, but I'm not sure if it's the exact amount. 2 Q Was it in the tens of thousands of documents that 3 had yet to be reviewed, more than 10,000? 4 A I would say it was between 50 and 10. I don't 5 remember the exact number. I did document it on a document 6 somewhere. 7 Q What kind of document? 8 A I issued a report -- I think it was in September, or 9 it might have been in October -- of what I thought I had 10 existing. 11 Q September or October 19837 12 A Yes. [~' 13 And do you remember who you reported that to? V) Q 14 A I don't remember whether I sent it to Marino or 15 Edison or to Frank Rolan, the project manager. I'm not sure 16 just who I addressed it to. 17 Q Would you have copied it to the others? 18 A Yes. 19 Q Who were you reporting to at CECO, Mr. Cosaro? 20 A At the time it would probably have been Carl 21 Mennecke. 22 Q Who is Mr. Mennecke? O
86 1 A I'm not sure what his title was, but he was kind of 2 right underneath.Mr. Cosaro for the electrical portion of the
-3 job.
4 MR. GUILD: Mr. Miller, we would ask that if you
- 5 could identify this document, that it be made available.
6 MR. MILLER: I'm reasonably confident that one was
.7 been made available in the first document, but I will take a 8 look.
9 THE WITNESS: Do you think you know which one it is? 10 MR. MILLER: I believe I have seen it. 11 MR. GUILD: I don't recall seeing it, but that 12 doesn't mean it hasn't been in the file someplace. 4 13 [ Discussion.off the record.] l 14 BY MR. GUILD: 15 Q Following the same line of inquiry, Mr. DeWald, + . i 16 when, if at all, did the inspection backlog get eliminated? 17 A Again, I'm guessing, but I think it was either June, 18 July or August of '84, and-some of the areas could have went 19- past that. I'm not sure of the exact timeframe. We cleaned
~20 up a little bit here, a little bit here and a little bit here.
21 Q Have you been backlogged in inspections since the 22 summer of '847 i 4 o
87 1 A We have been pretty well within the timely 30 days. 2 Q Up until today? 3 A Yes. 4 Q And when did you, if you did, eliminate the backlog 5 in the document review work?
- 6. A That was stopped and restarted and we finished our 7 second go-round on the corrections, I believe it was, in 8' January sometime.
9 Q January of '867 10 A Yes. 11 Q -And is the document review complete, then? 12 A No. We should clean up the corrections
/ 13 approximately the end of April.
V) 14 Q 1986? 15 A Yes. 16 Q Do you recall an Edison project goals meeting in 17 January of 1985? l 18 A Yes, sir. l 19 Q Do you recall discussing the subject of meeting 20 Edison's goals with Mr. Richard Saklak? ( 21 A Yes. 22 Q Do you recall Mr. Saklak preparing a document I O r l
88 1 think he referred to as a matrix, indicating tasks and 2 . relationship between tasks and Edison target dates?
- 3 A He created something similar to a matrix.
4 Q And did you make a presentation to Edison on that 5 subject? 6 A Not on his particular subject, but on the goals. 7 Q On meeting Edison's goals? 8 A Yes. 9 Q And can you describe generally what the nature of 10 the goals were and the nature of what you presented on that 11 subject? 12 A Oh, boy. I discussed the certifications and how the i 13 cross-certifications was going. That was one of them. ( ) 14 Discussed the progress in the inspections and how we was 15 keeping up with the 30 days, and what the numbers were at the 16 time when I gave the report. As to the exact context, I can't l 17 really unless I had it in front of me. 18 Q Can you identify a little more particularly the 19 document that Mr. Saklak put together? 20 A It was similar to a hub, and he had -- I don't 21 remember just how it was or how he had it labeled. A lot of 22 little runners coming off of it with various other small 3
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. . - _ , , . , _ , - _ , - . , ..-._._v.-_. . . _ _ . _ , . . _ _ . _
89 1 special projects that we were doing at the time, too, and how O k) s- 2 they were interrelated with getting some of these other Edison 3 goals cleaned up. 4 Q okay. Do you recall in substance whether Mr. Saklak 5 took a position that, given the tasks and the resources, that 6 it was difficult or impossible to meet those tasks, to 7 accomplish those tasks in the time set out with those 8 resources? 9 A He may have said something like that. I don't recall 10 his exact response to it. 11 Q Well, did you pass on any such observation to the 12 Edison people? 13 A ( I believe I did, but I don't really remember right 14 at present who exactly I did it to. 15 Q And do you recall what Edison's response was? 16 A Off-hand I can't recall what that was. 17 Q Do you recall whether or not Edison made available 18 additional resources or time to accomplish the task? 19 A Well, we were authorized to bring in more people, I 20 think, through that. 21 Q Did they give you any more time? 22 A I think since then some of the goals have been O
. . . .. _ . ~ -- - .-. I 90 ! 1 extended a little bit on some of the various items. l
) 2 MR. GUILD: I don't recall exactly what the status ;
3 of this_ thing was, but we had asked Mr. Saklak to identify 4 this document more particularly, and I think he tried, made a 5 stab at it, and I think we asked at the time that we try to 6 put our hands on it or identify it for inspection, and as best 7 I recall, that's where things stand, but if there is any way 8 we can identify, I think it is, two things: first, whatever
.9 the Edison goals document is, and then whatever Mr. Saklak and 10 Mr. DeWald put together in response to it.
11 BY MR. GUILD: 12 Q. Do you know whether at any point in time, 13 Mr. DeWald, Comstock's QC inspection or electrical
)
14 construction contract with Edison at Braidwood was in 15 jeopardy? 16 A There was rumor, but I had never been officially 17 told that. 18 Q When were such rumors circulated? 19 A Probably at the beginning of 1985, somewhere in that 20 neighborhood. 21 Q Somewhere after this goals meeting? 22 A I believe so. O
1 91 1 Q And do you know where you heard of those rumors? x_, 2 , A Off-hand I don't recall who was saying it or 3 where. Like I say, it was like a rumor. 4 Q And did you discuss the rumor with, say, Mr. Rolan, 5 Mr. Marino, any of your people, your management people? 6 A I may have discussed it with Rolan. I may have 7 mentioned it to Mr. Marino. 8 Q Did you ever speak to anybody with Edison about the 9 subject? 10 A Not that I recall. 11 Q If your backlog was brought up in the summer of '84 12 or thereabouts, you were current, essentially, on inspection
/T 13 activity. What, if any, cause would Edison have for V
14 questioning the comstock contract? 15 A I think at the time it was a matter of getting 16 conduit installed and getting cable pulled. I think that was 17 the main substance. 18 Q So it was production activity and not QC activity? 19 A Yes, sir. 20 Q And were there goals set in that goals meeting for 21 conduit installation and cable pulling? 22 A Oh, yes. O
92 1 Q And was Mr. Saklak's matrix in any part reflective N_ / 2 of inspection personnel shortcomings in order to meet goals 3 associated with conduit and cable? That may not be real clear 4 A I don't really know how to answer because I'm not 5 quite clear. 6 Q I guess what I'm asking is was Edison astting goals 7 in the area of conduit and cable that you identified the need 8 for more inspection resources in order to meet? 9 A Yes, we did identify more people that would be 10 needed. 11 Q In those two areas? 12 A Yes. 13 Q And do you know how many more people you got? ( 14 A I really don't know exactly how many. We've built 15 over -- since I've been here we've been from, I think it was 16 43 when I got here until now there's approximately 145 total 17 QC people. 18 Q Okay. Did you add inspectors in the areas of 19 conduit and cable pulling in the January '85 period or ! 20 thereafter? 21 A We cross-trained people to cover these particular 22 areas from the existing people. O
93 ', 1 Q And brought in some new people generally? i 2 A, Yes. 3 MR. GUILD: Do you want to break now? 4 4 MR. MILLER: Yes, t i
- 5. [Whereupon, at 12:40 p.m., the deposition was i:
6 recessed, to reconvene at 1:45 p.m., this same day.) I- 7 . 8 1 9 10 i f ! 12 13 , 14-l 15 ,' 16 F
- i. 17 i-5 18
. 19 I 20 21 { 22 i 4 l 4, 4 i
'- . - . _ . .-_m... . _ _ _ _ _ _ _ _ _ . . , , _ _ . . _ _ . . . _ _ . _ _ , , . . _ _ . _ , , _ _ _ . ...m_,._,- . . . , _ . - . , _ .
94 1 AFTERNOON SESSION
\ 2 [2:00 p.m.]
3 BY MR. GUILD: 4 Q Mr. DeWald, returning to the subject of documents 5 while it's fresh. The intervenors had sought production of a 6 number of document from -- they were believed to be in the 7 possession of Comstock. And one class of documents were 8 documents described by one or more inspectors that were 9 believed to have been compiled by Mr. Saklak when he was a 10 supervisor. And they were described colorfully as the Pearl 11 Harbor files. 12 Have you ever heard that term used? 13 A I've heard of that term. ( I have never seen that 14 document or that pile of documents. 15 Q Okay. Where had you heard of that term? 16 A From Mr. Saklak himself. 17 Q Okay. At the time he was employed at Comstock? 18 A Yes. 19 Q And how did Mr. Saklak use the term? 20 A I got his temper up and he then informed me he had a 21 Pearl Harbor file. 22 Q Okay. And how was he referring -- what did he say O v i i 1
- - - . , ,e n, , - . - , + -,-,--,,---7 . - . , , - - - -- - , 4 m. _r, -
mg,g - . -~~-- ,,.
95 3 1 when he referred to it?
\_,) 2 A I don't recall just the exact conversation, but he 3 did reference he had a Pearl Harbor file for various items.
4 .And he never give me any type of information of what these i 5 items were for, e 6 Q So what was the context of the statement by 7 Mr. Saklak? 8 A I don't recall what it was all about at that 9 particular time. The only thing I can recall, whenever 10 somebody mentions his Pearl Harbor file, I know it was -- he 11 is one of the persons that told me, and it was when I had kind 12 of raised his temper a little bit. fT 13 Q Okay. Did he lead you to believe at the time that V 14 he was keeping documentation that was in some fashion relevant 15 to whatever you were arguing about, or what he was arguing 16 with you about? 17 A I don't recall, it may have been . Like I say, I 18 don't recall the specific conversation. 19 Q Other of the inspectors who referred to it used it 20 in the context as follows. They'd say, well, you know, some 21 issue would come up in which they were talking with Mr. Saklak
- 22 about and Mr. Saklak would say, well, you know, I've got a
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96 1 memo about that and it's going in my Pearl Harbor file, or 2 words to that effect. 3 A I don't know anything about his conversations with 4 the other inspectors. 5 Q Well, was it in a similar kind of context that he 6 made the reference to Pearl Harbor file when he talked with 7 you? 8 A It may have been. I really don't remember. 9 Q In his deposition Mr. Saklak said that when he was 10 terminated he left the site without personally taking any of 11 his documents or belongings with him. Is that correct, to 12 your knowledge? 13 A He had some papers and so forth in his desk when he 14 left. I didn't take -- go through the desk. And I don't 15 recall who did go through the desk or what happened to it. 16 Q Well, the first point though is, that Mr. Saklak i 17 worked -- he worked a Friday and left work on Friday, and as I 18 understand, was contacted over that weekend and told not to 19 come in Saturday, and to await further word from -- contact 20 from Comstock management? 21 A I told him on Friday not to come in on Saturday. 22 Our regional manager, Tom Paserba came in on Saturday and then s l'
97 1 called him that Saturday and told him that he was suspended
- O s ,/ 2 until such time as we got back to him.
3 Q Mr. Saklak left work on Friday, and at the timo he 4 left work Friday did he understand that he was being 5 terminated? 6 A We told him -- 7 MS. KEZELIS: Objection, as to what Mr. Saklak 8 understood or didn't understand. Mr. DeWald is perfectly 9 competent to testify to what he did or did not say to 10 Mr. Saklak. 11 BY MR. GUILD: 12 Q What do you think Mr. Saklak understood when he left 13 the job on Friday, Mr. DeWald?
}
14 MS. KEZELIS: Same objection. 15 THE WITNESS: I really don't know what Mr. Saklak 16 thought. I told him that he wasn't to come in on Saturday, 17 that we was going to investigate the situation. 18 BY MR. GUILD: 19 Q Did you give him any reason to believe that he was 20 terminated on Friday? 21 A I possibly could have, because I told him that this 22 type of actions would not be tolerated, and it was going to be O U
98 1 looked into very heavily. 2 Q What did you mean by this type of actions? 3 A His statement of threat to Mr. Snyder. 4 Q So Saklak left the site on a Friday after you said 5 whatever you said to him. And you recall saying don't come in 6 on Saturday, correct? 7 A Yes. 8 Q Did Saklak take with him his files, papers or 9 personal belongings at that time? 10 A I really don't know. I didn't follow the individual 11 out. 12 Q Well, did you tell him to clean out his desh? 13 A No, sir, I sure didn't. ( ) 14 Q Do you know whether anyone else told him to clean 15 out his desk? 16 A No , sir, I sure don't. 17 Q You do know that subsequently someone vent through 18 his desk and provided Mr. Saklak with some perr.onal items, for 19 example? 20 A I think maybe Mr. Seltmann or Mr. Simile had taken 21 his personal items to his home. I'm not sure. 22 Q okay. Mr. Saklak stated in his dr. position that -- O
99 1 it may have been his insurance policy or health insurance 2 policy, or documents of that sort. Not Comstock quality 3 documents, but documents that related to Mr. Saklak 4 personally,_that those were provided to him at a later date. 5 Is that consistent with your understanding? 6 A Could be, yes. 7 Q Okay. Now Mr. Saklak also stated with reference to 8 the so-called Pearl Harbor file that they consisted of one or 9 two file drawers that were contained in a cabinet that was 10 associated with his work place, with his desk. He said, for 11 example, that the cabinet followed him a couple of places 12 around the job where he moved his desk from place to place. 13 Are you aware that Mr. Saklak maintained such a file 14 cabinet? 15 A I knew he had a personal cabinet where he may have 16 kept a copy of this or that. But I didn't know if that was 17 his Pearl Harbor file or not. 18 Q Well, what happened to the file cabinet that you 19 just referred to that was Mr. Saklak's personal cabinet that 20 maintained copies of this or that as you stated? 21 A I'm not sure what happened to it. I didn't go 22 through it myself. O
100 1 Q Do you know whether those files have been preserved? O 2 A (_ ,/ That I don't know either. 3 Q Do you know who would know? 4 A Maybe Mr. Seltmann would know. 5 Q Intervenors filed a motion with the Atomic Safety 6 and Licensing Board -- strike that. 7 Intervenors made a request in this proceeding to 8 Commonwealth Edison Company, the applicant, for production of 9 the so-called Pearl Harbor files. And it was described as all 10 documents reflecting adverse, derogatory, or other information 11 regarding Comstock QC inspectors maintained by Mr. Saklak, in 12 effect; the so-called Pearl Harbor file. [ 13 Do you have any knowledge of any efforts to identify 14 those documents in response to intervenors request? 15 A No, I don't. 16 Q Did anyone contact you from Commonwealth Edison 17 Company and ask you whether you knew of such documents? 18 A No. 19 MS. KEZELIS: Well, let me state for the record, 20 Mr. Guild, that I believe I contacted Comstock myself and 21 asked either Mr. DeWald or Mr. Seltmann -- I don't recall 22 which now -- whether there were any Saklak files at Comstock. - 1 O 1
101 1 And'I was told-that there weren't any, b
\ ,/ 2 So it wasn't Commonwealth Edison that necessarily 3 contacted Comstock, but rather Isham, Lincoln & Beale. And 4 that was in response to the request that served on us. And I 5 think my response to your request indicated that there were no 6 'such documents in the applicant's possession.
7 MR. GUILD: Yes, it did. And I guess I would ask 8 that if counsel could make a little more diligent search now, 9 . in light of Mr. Saklak's identification of what those files lo are, and in light of Mr. DeWald's confirmation that at least 11 he heard Mr. Saklak refer to such files. 12 MS. KEZELIS: I don't think there's any need to 13 argue about it during the course of Mr. DeWald's deposition. V() 14 MR. GUILD: No need to argue about it. It's just, I 15 don't think there's been a diligent search for them, and I'd 16 ask that they be identified. 17 MS. KEZELIS: Well, I object to your
; 18 characterization of my search, Mr. Guild.
- 19 MR. GUILD: Counsel, do you intend to look into it
- 20 any more, or shall I file motion? What would you prefer? I'm i-21 just renewing a request. If all you made was a phone call and i
i 22 the answer was, there are no files from Mr. Saklak, I stand by O i +.
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102 l l 1 my characterization. That's not a diligent search. l 2 Would you like me to file a motion? Is that the 3 position that applicants take? 4 MS. KEZELIS: I'll talk to Mr. Miller, but I suspect 5 that we will suggest that you file a motion. 6 MR. GUILD: Because as you also know, I've got a 7 subpoena issued by the chairman to Mr. Saklak. Mr. Saklak 8 says he doesn't have the file. And I'd just certainly like to 9 get the files. 10 MS. KEZELIS: Well, if there are any such files, 11 they are not in Comstock's possession. I don't know if any 12 such files exist anymore, Mr. Guild.
-13 MS. KEZELIS:
( ) Ms. Kazelis, you're testifying, and 14 all you said to me so far now is that you made a phone call to 15 an unidentified person, Mr. DeWald or Mr. Seltmann, and asked 16 them if they had any files of Mr. Saklak. Now I suspect that 17 that may not have captured what Mr. Saklak described as his 18 Pearl Harbor file. 19 MS. KEZELIS Mr Guild, I differ with you. I think 20 the applicants production of documents has been 21 extraordinary. And I think we have been very diligent. 22 MR. GUILD: Let's focus on this point, Ms. Kazelis.
103 1 Really, there's no need to be hyperbolic about the point. p '\s- 2 Are you going to take any other action to look for 3 these files? That's all I need to ask. You don't need to 4 yell at me about it, or crab at me about it. Just answer the 5 question, please. 6 MS. KEZELIS: Bob, let's be gentlemanly about this. 7 MR. GUILD: I've been doing fine all day today, 8 Ms. Kezelis. There's no reason for you to start crabbing at 9 me and getting my back up. Just is a simple point really. If 10 the answer is, sit on it and rotate, I'll do that and I'll 11 take it up with the licensing board. Okay, just tell me. 12 MS. KEZELIS: Bob, I will make additional efforts to [ \ 13 see -- \J' 14 MR. GUILD: Thank you very much. 15 MS. KEZELIS: -- what I can do. 16 MR. GUILD: Off the record. 17 [ Discussion off the record.) 18 MS. KEZELIS: My representation today to you, 19 Mr. Guild, as it was in my response to you in your request 20 some time ago, we are unaware of any such documents that would 21 constitute the so-called Pearl Harbor file in existence today. 22 MR. GUILD: Ms. Kezelin, would you describe the O
104 1 extent of Edison's efforts to identify such files, please, for 2 the record. 3 MS. KEZELIS: I believe my efforts included, but 4 were not limited to -- and I cannot specifically recall each 5 individual effort that I made or others made. But I spoke to 6 Mr. DeWald, and I believe I may have also spoken to 7 Mr. Seltmann. I don't recall with whom else I spoke regarding 8 the Pearl Harbor file. I just don't recall right now, Bob. 9 MR. GUILD: Thank you. 10 BY MR. GUILD: 11 Q In light of this discourse, Mr. DeWald, do you 12 recall being contacted by anybody with respect to the 13- so-called Pearl Harbor file?. 14 A I don't recall. I could have. I don't recall. 15 Q Were you contacted with respect to the request for 16 documentation of weld inspections that you performed, the 17 1,000 welds a day question? 18 A No, sir, I had nothing to do with that pile. 19 Q No one asked you to identify any such documents? 20 A No, sir. 21 Q Okay, thank you. 22 Mr. DeWald, your resume, which is Exhibit 3, O
105 1 reflects that in your position of quality control manager of
) 2 Comstock at Braidwood, that you are a certified Level III 3 inspector to the ANSI N-45.2.6 standard, correct?
4 A Yes, sir. 5 Q And when did you become certified as a Level III 6 inspector? 7 A I think it was December of '83. You mean as a Level 8 III. 9 Q And can you recall the areas in which you were 10 certified as a Level III in December of '83? 11 A I think it was configurations, conduit, 12 terminations, CEAs, welding. Let's see, how many have I 13 named? [ 14 Q How about calibrations? 15 A Calibrations. 16 Q How about receipt inspections? 17 A Yes. 18 Q Any others come to mind? 19 A I'm trying to think. I was certified in all the 20 areas. 21 Q All the areas in which there was Level II inspection 22 work being performed? O
l 106 1 A Yes. / \ (s_) 2 Q And were you certified at about the same time in all 3 those areas? 4 A At different times I took the same tests and so 5 forth that the Level II did. 6 Q Okay. Well, if you say about December '83 is 7 when you were certified, about December '83 for all the 8 areas? 9 A Yes. By the end of December, I think it was, that I 10 was certified for all the areas. 11 Q I see. And do you recall when you obtained your 12 first Level III certification? / 13 A When I was at D.C. Cook. V} 14 Q No, before -- I mean, at Braidwood, to the Braidwood 15 program? 16 A I don't know the exact date of when it was, but I 17 think it was December something. 18 Q So your recollection is that in each of these areas, 19 during the course of the month of December, you attained Level 20 III certification? 21 A During that, yes. 22 Q okay. Did you take and pass a practical examination O
4 107
! 1 in those areas as a Level III?
2 A Yes, sir. 3 Q And did the practical examination involve actual 't 4 field inspection work in each of those areas? 5 A Yes. [ 6 Q In December of '83? i 7 A Yes. i $ 8 Q Okay. Did you do a field inspection of welds, a l i 9 visual inspection of welds as part of your practical exam for i 3 10 your Level III certification?
! 11 A Yes, sir.
12 Q In December '837 () 13 14 A Q Yes, sir. Do you recall who evaluated your practical, weld j 15 practical?
. 16 A Offhand, no. . 17 Q Is that documented?
I
- 18 A It should be.
i' 19 Q Okay. Do you recall whether or not your field 20 practical in welding involved review of a field installation i 21 that contained rejectable conditions? l 22 A It did. i !O 1
108 1 Q And did you identify those rejectable conditions? 2 A Yes, sir. 3 Q Have you had to subsequently recertify in any of 4 those areas, Mr. DeWald? 5 A Yes, sir, to update to Rev. C. 6 Q Okay. And in which areas did you have to racertify 7 to update to Rev. C? 8 A I had to update in all of the disciplines. 9 Q Okay. In which areas did it require any additional 10 examination to update to Rev. C? 11 A I think welding was one, equipment. I'm not sure 12 which others it was. / 13 Q Okay, let's take welding. For example, can you 14 recall what you had to do to update to Rev. C in your Level 15 III certification in the welding area? 16 A I took another practical. I missed one aspect. So 17 therefore, I had to do -- I done a full 40 hours OJT, and took 18 another practical on that. Went through the same type 19 training that the Level II does for that again. 20 Q Why did you have to do another practical in the 21 welding area to update to Rev. C? 22 A I think, if my memory serves me correct, there was n v
109 1 something with the other practical that didn't meet the bs/ 2 standards of Rev. C. I don't know exactly just what it was. 3 Q Is it correct that all inspectors had to update to 4 Rev. C of the QC inspector qualification procedure at 5 Comstock? 6 A Yes, sir. 7 Q And yet additional work was only required where the 8 original certification package reflected differences from the 9 Rev. C requirements? 10 A correct. 11 Q If I'm being clear in that question. 12 A Yes. 4 13 Q All right. You only had to do things to the extent
}
14 that your original certification did not meet the Rev. C 15 standards? 16 A Correct. 17 Q Otherwise it was simply a matter of updating the 18 paperwork, in effect? 19 A Yes. 20 Q Now in doing so, you updated your practical exam 21 requirement in the welding area. And can you recall when you 22 took the first practical to update? O
110 1 A I don't know what month it was, no. / s/
) 2 s Q okay. Would it have been in late '84, or early '85?
3 A I really couldn't tell you. 4 Q How long after the effectiveness of Rev. C did you 5 requalify? 6 A That I'm not sure of either. I know there was a 7 time frame in there where I didn't have time to go out and do 8 this because of various other things. But I couldn't tell you 9 the exact time frame of when Rev. C come into effect until 10 when I started to get mine done. 11 Q Well, I was just thinking perhaps that would refresh 12 your recollection, if you did it near the effective date of 13 Rev. C. Can you recall whether it was during 1985 that you ( 14 updated to Rev. Comstock? 15 A I've been updating from when I started, and I'm just 16 finishing up now on some of the update. , 17 Q All right. Are you finishing up in the welding area 18 now? 19 A I'm done with the welding area. 20 Q When did you finish the welding area? 21 A Like I say, I don't know the month. But that is 22 finished, and it's already been approved by Ceco. O
111 1 Q Okay. Was it a long time ago? Was it six months, a 2 year ago, or more recently than that? 3 A I really can't answer that either. 4 Q All right. 5 Describe the first practical exam you did in welding 6 as part of your Rev. C update. 7 A The first practical was like a mock exam that we had 8 in the training department that they had made up especially 9 for me. And I missed one or two aspects of it. 10 Q This was a coupon? 11 A No, it was like a joint detail put together. 12 Q And when you say it was put together especially for 13 you, what do you mean by that? 14 A We use in various training aspects, if we don't have 15 a rejectable item right at that particular time, we have a 16 mock inspection that we can take and use to give the inspector 17 the practical exam, which would be similar to the actual field 18 condition. 19 Q Right. 20 A And this is what they made this one up for. I had 21 never looked at it or laid eyes on it until the day they was 22 ready for me to take the practical exam. O
-. ~ - . . . ., . . . - - - ..
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-, 112
1 Q Well, did they use a mock-up for you that was in
. - 2 some fashion different from a mock-up they'd use for a ,fu q 3 certifying any other inspector? .
- 4 A Somewhat, yes,
- i. ~,
, 5 Q And in what respects was it different?
~
6 A It was a piece of tube steel with a clip on one end 7M and another configuration on the other end. 8 Q .And in what respects was that different from the
~
9 mock inspection that they would administer to any other 10 inspector? 11 A Most of the -- the way it was different is this was oy 12 the first'one that they had'rade up for this particular thing. i( } 13 Q Well, did they make'up such mock details to qualify 14 other inspectors? '
'15 A This is what it was made up to use for, but they 16 used it on me instead'of the other inspectors.- -
! 17 Q You were the first one, is that what'you're telling s
, 18 me?
X. I 19 - A Yes. 20 Q Okay. And what aspects of the practical did you
, , <j
= 21 - miss?
4 22-
- A A couple pieces of undercut, I think.
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113 1 Q Okay. Undercut is a rejectable condition? 2 A Yes, subjective. 3 Q Who was it who evaluated your practical exam? 4 A I believe it was Daryl Landers. 5 Q And who is Mr. Landers? 6 A He's one of the supervisors, and he's a qualified 7 'AWS certified inspector. 8 Q Level II? 9 A Yes. 10 Q And he's a welding inspector supervisor? 11 A Yes. 12 Q And was it Mr. Landers conclusion that you had [') 13 missed the aspects involving undercut on this mock-up?
%)
14 A Yes, it was. 15 Q Did you agree with his conclusion? 16 A After we talked, yes. 17 Q Why did you miss the rejectable conditions? 18 A Overlooked them. 19 Q Were there any other aspects of the practical that 20 you missed? 21 A Offhand, I don't think so. 22 Q So did they score you on the practical? O
114 1 A They rejected it. . 2 Q And what score did you get on the practical? 3 A There's no -- if you reject it, it's failed. 4 Q You either pass or fail? 5 A It's either pass or fail. 6 Q And you don't get 100 percent score? 7 A No. If you pass it, you get 100 percent. 8 Q All right. And anything short of passing it is a 9 fail? 10 A Is a fail. 11 Q Okay. And as a result of failing the weld 12 practical, what did you have to do? 13 A I went through the complete one-eight-40 practical. 14 Q What does that mean? 15 A I got one hour lecture, eight hour , 16 lecture / demonstration, 40 hours OJT, and a repractical. 17 Q Okay. Now had you done that before you took the 18 first practical, requalification? 19 A No. 20 Q Who did you do the 40 hours OJT with? 21 A Various Level II inspectors. 22 Q Can you recall who? O
115 1 A I think Ed Pishney was one. 2 Q How do you spell his last name? 3 A P-i-s-h-n-e-y, I believe. 4 Q And is he a Level II weld inspector? 5 A Yes. 6 Q All right. Anyone else? 7 A I think another whose name was Mr. Gubelman. 8 Q A Level II weld inspector? 9 A Yes. 10 Q Okay, can you recall any others? 11 A Offhand, I can't. 12 Q And you have to bear with me. I missed your ( 13 detailing what was the requalification training. Four hours, 14 one hour? 15 A one hour lecture, eight hours lecture / demonstration, 16 and 40 hours in the field OJT. 17 Q All right. Who provided the one hour lecture? 18 A I don't recall who did that. 19 Q How about the four hours lecture -- eight hours 20 lecture /OJT? 21 A I don't recall who give that to me either. 22 Q All right. Lecture / demonstration. You don't recall 1 l A V
116 1 the eight hour lecture / demonstration? 2 A No, I don't. 3 Q And how much -- how long after the first practical 4 exam did you take the retest? 5 A I can't -- I don't even know the time span. It 6 wasn't exactly right after. It could have been a week or so 7 after. 8 Q Okay. 9 A When time permitted. 10 Q All right. And did you review the same mock 11 inspection? - 12 A No, this was actual field condition in the field. 13 Q You went out and looked at something in the field? ( } 14 A Yes. I don't recall which one it was or what type 15 it was. 16 Q Okay. And did it have any rejectable conditions on 17 it? 18 A Yes, sir. 19 Q And did you identify those properly? 20 A Yes, sir. 21 Q And did you pass the second practical? 22 A Yes, sir. O
117 1 Q Who evaluated your second practical? O2 A Mr. Landers. I think it was Mr. Landers. 3 Q Okay. In your first practical exam, Mr. DeWald, on 4 requalification, did you identify the condition -- did you 5 identify the detail as having any rejectable conditions? 6 A That I can't remember, because it's been three or 7 four years -- three years anyway. 8 Q Well, you think it's been three years since you did 9 this? 10 A Well, December of '83. 11 Q No, no. Back to -- I'm sorry, I should have been 12 clear. On the first requalification practical test, the one () 13 14 where you failed to identify the aspects, did you identify any rejectable conditions? 15 A Yes. But I missed a couple of them. 16 Q And you completed an inspection report for the 17 conditions that you identified? 18 A Yes, I sure did. 19 Q Was the requirement of the practical exam that you I 20 identify all rejectable conditions? l 21 A Yes, sir. 22 Q And is that stated explicitly in the QC l
118 1 qualification test procedures? s_ 2 A I'm not quite sure how it's stated, but it states 3 that you'll identify the rejectable items. 4 Q Okay. So your recollection is that you identified 5 some rejectable itema, but not all of them? 6 A Not completely all of them. 7 Q Okay. Now what other areas did you have to do any 8 further work in to requalify to Rev. C, aside from welding? 9 A I think configurations was one of them. I think 10 equipment was another. 11 Q How about calibrations? 12 A I'm not positive. I may have done calibrations fT Q 13 also. 14 Q Okay. What was the most recent area in which you 15 requalified? 16 A I really don't remember. 17 Q Okay. Can you recall how long ago it was you 18 finished your requalification? 19 A I got one back here not -- it was probably last l 20 week. And I don't remember just which one it was. 21 Q Did you take a practical exam last week? 22 A No , this is one where the book itself was updated to O
119 1 Rev. C.
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2 Q Just the paper was updated? 3 A Paper, yes. I think. 4 Q Okay. Did you perform Level II inspection work in 5 any other areas at Braidwood other than welding? 6 A Configurations, I believe, was the only area. 7 Q Okay. Welding and configurations? 8 A Yes, sir. 9 Q Okay. Did you ever perform any calibration or
- 10 receipt inspections as a Level II, or a Level III? By that I 11 mean, did you ever personally approve any inspection reports 12 in-the areas of calibrations or receiving?
1 [ 13 A I may have released an MRR on a Saturday because 14 CECO had just approved the release of it. I may have signed 15 that release in order to release the material to go out to the 16 construction forces. 17 Q That would be a receipt inspection? 18 A Well, it's not a receipt inspection. It's releasing
- 19 that inspection that had already been previously done it, 20 because'they didn't have any receipt inspector there. All I 21 did -- it was a formality. Now the inspection has been 22 accepted, and the MRR was just released from CECO QA. And all O
b
- --,-,,,-----v ,,v- -- ,< --
120 1 I did was pull the hold tag off and release that to the field. 2 Q Okay. That would be a function normally performed 3 by a receipt inspector, Level II? 4 A Yes. 5 Q How about in the area of calibrations? + 6 A Not to my knowledge. 7 Q Did you ever supervise the area of calibrations , 8 work? 9 A I would imagine I supervise it now, as far as being 10 over the whole group. 11 Q Right. And in that capacity, since you've been -- 12 you've supervised calibrations from the beginning? 13 A Yes, sir. (} 14 Q Since you've been the quality control manager. All 15 right. 16 Have other supervisors been certified as Level II or 17 Level III in the area of calibrations who have performed 18 supervisory responsibilities over calibrations? 19 A Yes, sir. 20 Q And who would that have been? L 21 A Joe Hii is one of them. 22 Q Okay. Mr. Hii is certified in calibrations? !O
121 1 A Yes, sir, I believe he is. , O- 2 Q As a Level II? l l 3 A Yes, sir. 4 Q And he has supervised the calibrations work? 5 A Yes, sir. 6 Q Does he supervise Mr. Snyder in the calibrations 7 area? 8 A He did, yes, sir. 9 Q And when you say did -- 10 A We've had an organizational change -- 11 Q And what's the change? 12 A -- which moved the supervisors around the different 13 areas. ( 14 Q Okay. And Mr. Snyder is still doing calibrations? 15 A Yes, sir. 16 Q And who is supervising Mr. Snyder now? 17 A It will be -- effective the 8th, it'll be Rick 18 Whitehead. 19 Q The 8th of April? 20 A Yes. 21 Q Before Mr. Hii supervised the area of calibrations, 22 was there any other supervisor who was certified in O
122 1 calibrations who supervised that area? 2 A I believe it was Rick Saklak. 3 Q Okay. Do you know whether Mr. Saklak was certified 4 in the area of calibrations? 5 A I'm not totally positive, but I think he was. 6 Q Do you recall yourself ever directly supervising the 7 calibrations area, instead of through another supervisor who 8 worked for you, but directly yourself supervising the 9- calibrations work? 10 A I may have went to the one of the inspectors and ask 11 him could you do this particular thing or check on this 12 thing. I may have done that. (h
~) 13 Q All right, but aside from on an incidental basis, 14 did you ever perform the direct supervisory work over the 15 calibrations area?
16 A No. 17 Q You remember a former calibrations inspector, John 18 Seeders? 19 A Yes, sir. 20 Q You didn't directly supervise Mr. Seeders, did you? 21 A No, sir. 22 Q How about in receipt inspection work that he -- for l
123 1 Mr. Seeders? (~ 2 A No, sir. 3 Q Who did supervise Mr. Seeders? 4 A Mr. Saklak. 5 Q Mr. Saklak supervised his calibrations work? 6 A Yes, sir. 7 Q And his receipt inspection work? 8 A Correct. 9 Q Do you know whether or not Mr. Saklak was qualified 10 to supervise Mr. Seeders in calibrations and receipt? 11 A Would you be more specific? 12 Q Yes, do you know whether Mr. Saklak was qualified to ( } 13 supervise Mr. Seeders in the areas of calibration and receipt 14 inspection? 15 A I think he was qualified. I'm not sure whether he 16 was certified, like I said. That I'm not positive of. 17 Q In your opinion, did Mr. -- in your opinion, was it i 18 necessary for Mr. Saklak to be certified in the areas of 19 calibration and receipt inspection in order to effectively 20 supervise the area of calibrations and receipt inspection? 21 A At that time that was a requirement of the 22 procedure. O O i i
124 1 Q So your answer would be yes, it was a requirement (O m/ 2 then? 3 A At that time, yes, it was a requirement. 4 Q When you say at that time, what time are you 5 referring to? 6 A In Mr. Saklak's period. The procedure has since 7 been revised. 8 Q After Mr. Saklak left? 9 A Yes, it's recently. 10 Q And in what way has the procedure been revised? 11 A The supervisors no longer need to be certified. 12 They need to have their one and eight-hour lectures. 13 Q In the area in which they supervise? ( } 14 A Yes, sir. 15 Q Do you know whether or not Mr. Saklak had the one 16 and eight-hour lectures? 17 A That I'm not sure of. 18 Q In calibrations or receipt? 19 A I'm not sure of that. 20 Q okay. Aside from the questino of whether Mr. Saklak 21 was certified in the areas of calibration and receipt 22 inspection, do you believe that he was qualified to supervise a
l l 125 , I 1 in those areas by way of his knowledge and expertise and f% k/ s 2 experience? 3 A Yes, sir. 4 Q One of the subjects of testimony that you've been 5 assigned, Mr. DeWald, is to speak to your interaction with 6 Mr. Seeders, and the basis on which Mr. Seeders improper 7 calibration inspections have been corrected. 8 Now can you tell me what is your understanding of 9 the improper calibration inspections that are attributed to 10 Mr. Seeders? 11 A Could you rephrase that? 12 Q Sure. What is your understanding of the nature of () 13 the improper calibration inspections that are attributed to 14 Mr. Seeders? 15 A Lack of proper documentation; releasing of the tools 16 to the field with lack of proper documentation; not issuing 17 ICRs, NCRs; and his documentation is all. It's hard to -- a 18 lot of his documentation is incomplete. 19 Q Okay. l- 20 A I think that about sums the whole problem up. 21 Q Okay. How was that problem or those problems as you 22 described them identified? O
126 1 A Through NCR 3419. ( \ k) 2 Q In the process of dispositioning that NCR? 3 A That's when they were all discovered. 4 Q And how was that NCR, as you understand it, 5 initiated? 6 A I believe it stems back from when -- I think it was 7 May of '84, I think. We had had a CECO audit, and we had had 8 various findings in the calibration area. And at that time, I 9 had requested that 100 percent review of the records be done 10 to assure that we had no records in there to which an ICR or 11 an NCR had not been initiated on an uncalibrated tool. 12 About, I think it was August the 17th, Mr. Seeders t (~~N 13 was given a warning by Mr. Seese, at which time I was not b 14 there. And when I returned the -- I don't remember whether it 15 was a Monday or the next day or what, but when I returned 16- Mr. Seeders handed me the letter that he had dated August 17 17th. 18 And through investigation per his letter and so 19 forth, these inconsistencies were brought to light that was in 20 the calibration program. 21 Q Does that complete your answer? 22 A Yes, sir.
127 1 Q Okay. Now to whom did you make your request that [h (m l 2 there be 100 percent review of calibration records? 3 A I'm not sure whether I made the request to 4 Mr. Saklak or Larry Phillips. 5 Q And was Mr. Phillips Mr. Seeders' lead? 6 A Yes. 7 Q Did you make it in writing? 8 A No, sir, I didn't. It was verbal. 9 Q Did you make any written documentation to anyone, 10 either Mr. Phillips, Mr. Saklak, someone with Commonwealth 11 Edison in auditing, for example, that you were going to 12 perform a 100 percent review of the calibration records for [) 13 this purpose? v 14 A I don't recall whether I documented that or not. 15 Q Okay. Mr. Seeders states that he understood the 16 request as communicated to him to be for a sample of the 17 calibration records? 18 A That's not my direction. My direction was I wanted 19 100 percent to go through the records to see if there's 20 anything in there that was out of calibration that an ICR or i 21 an NCR had not been initiated for. t 22 Q Yes. Do you -- is it possible, given your knowledge l O i
128 1 of the way this was communicated, that your request was (^') (,/
- 2 communicated, in your judgment that Mr. Seeders could have 3 misunderstood this to have been for a sampling inspection 4 instead?
5 A I don't know how the direction was given to him. 6 But I did give explicit direction that I wanted 100 percent 7 done. 8 Q Okay. To one of those two people? 9 A Yes, sir. 10 Q And did they confirm, Mr. phillips or Mr. Saklak, 11 did they confirm back to you in writing that they understood 12 this was for 100 percent review of the calibration records? () 13 14 A No, sir. Q And when next did you hear about after you made the 15 request? Hear about the subject of the review? 16 A Mr. Seltmann had asked me a few times how the review 17 was coming, and I went to Sak a couple times and asked how the 18 review was coming. And this was just prior to the warning 19 being issued. 20 Q Shortly before the warning was issued? 21 A Around in that time frame. 22 Q Okay. And what did Mr. Saklak say to you? O
129 1 A He checked on it. 3 # 2 Q That he would check on it? 3 A Yes, sir. 4 Q And did he report back to you on checking on it? 5 A I don't recall whether he did or not. 4 6 Q Okay. Do you recall anything else about it prior to 7 the point where you learned that a warning had been issued to 8 Mr. Seeders? 9 A Offhand, not right at the moment. 10 Q Okay. Were you aware of any requests by Mr. Seeders 11 for any additional resources, time, people, to perform 12 whatever review he understood was called for? 13 A Not at the time.
}
14 Q Are you aware at any time of such a request? 15 A After. 16 Q After the warning was issued? 17 A Yes, sir. 18 Q How did you become aware then? 19 A Through a memo that Mr. Seeders issued. 20 Q It was a memo that he issued before the warning that 21 you found later? 22 A After. O
130 1 Q And what was the -- can you describe the memo? - 2 A I don't know exactly what the memo said. He was 3 talking about overtime, and I don't remember just what it 4 was. And I approved the overtime. 5 Q Okay. It was a memo from Mr. Seeders requesting 6 overtime to work on this review? 7 A I'm not sure what it was about. I think it was. 8 Q All right. When you made the request to 9 Mr. Phillips or Mr. Saklak that 100 percent review of the 10 calibration records be performed, was it your belief and 11 understanding that Mr. Seeders alone would perform that 12 review? (} 13 A I didn't know who was going to do the review. The 14 only thing I asked was, I needed -- wanted that review done. 15 I didn't know if it was going to be Mr. Seeders himself, or it 16 could have been Mr. Seeders and Myra Sproull, or somebody else 17 that helped him. All I requested was that the 100 percent - 18 -review be done. 19 Q Okay. In your opinion, Mr. DeWald, was it -- how 20 long would it have taken Mr. Seeders to have performed the 100 21 percent review, if he had no other duties at all to perform? 22 A Probably a couple weeks or so.
- I l
131 1 Q okay. In your opinion, how long would it have taken
. f}
() 2 Mr. Seeders to perform the review at the same time as he was 3 also performing his normal inspection duties in calibration' . 4 and receipt inspection? 5 A I would say probably the same amount of time or a 6 little more. Because he works with those records day in and 7 day out. 8 Q Did you work with those records? 9 A I've been in them. I haven't really worked them. 10 I've looked at them and been through them. 11 Q Had you been in them in that way before Mr. Seeders 12 was transferred from that position?
/ 'l 13 A In what respect? ; b 14 Q The way you just referred to them. Had you reviewed 15 the calibration records, familiarized yourself with the 16 calibration records before Mr. Seeders was replaced in the 4
17 calibration inspection position? 18 A Not a review, per se. I mean, I went through them. 19 I've looked at them. 20 Q Did you identify any deficiencies yourself when you 21 reviewed them? 22 A Yes. O
132 1 Q This was before Mr. Seeders was removed from the h (d 2 position? 3 A Yes, there were deficiencies, and this is early '84. 4 Q And you identified them -- 5 A Or early '83, excuse me. 6 Q Early '83? Well, were those deficiencies that were 7 caused by Mr. Seeders? 8 A Some of them were. 9 Q Were those deficiencies that were caused by somebody 10 who preceded Mr. Seeders in that position? 11 A Some of those were, yes. 12 Q Okay. You brought those to Mr. Seeders attention? ( ) 13 A Not directly to Mr. Seeders. 14 Q Who did you point them out to, if anybody? 15 A Mr. Saklak, his supervisor. 16 Q Can you recall what kind of deficiencies you 17 identified in early '837 ruab0 4WZ 18 A Duplication check marks, and form 23s were not erka , 19 out correctly. 20 Q In what way weren't they made out correctly? 21 A The standards were in the wrong slot or in the wrong 22 column, versus the as-found condition on the form 23.
133
.1 Q Clerical errors?
'2 A Well, they couldn't really be counted as a clerical 3 error, as you're taking -- when I say the standard, that's the 4 device or the metho'd used to calibrate the tool and the 5 as-found condition. These two columns were reversed.
l 6 Q The right information was there, it was in the wrong 7 place on the page? 8 A Right. 9 'Q Was it an error that affected the adequacy of the i 10 document or the condition of the tool? 1 11 A lit could have if it was misinterpreted, the way.it : 12 was documented. 13 Well, did you take any corrective action? ( ) Q 14 A This was when I had -- I wanted him again, prior to, j 15 because at this time we was going through some audits that had ! l 16 identified the same type of deficiency in there. And this l- 17 was, when I say late '83. And I wanted these all corrected 18 and for him to go through them again. i j 19 Q And did you assure yourself that the deficiencies 20 had been corrected? 21 A We had QAEs at the time that went back through, and I 22 they had looked at the specific items, too, that they had b
-(
b k l- !
. .. ._ . -._. m___ ._. _. , _ . _ _ _ _ . _ . _ -. _ _ . - _ . - _ _ _ _ ...
134 I i 1 found. I'm not sure how extensive they went back through the 2 files. 1 3 Q You had what now? I missed the term. 4 A QAE.- 4 5 Q What is that?
- 6 A Wh'ich is quality assurance engineers.
f 7 Q Okay. In your opinion, did Mr. Seeders has 8 sufficient supervision in the area of calibrations and 9 receipt? ) 10 A I believe so. 11 Q In your opinion, did Mr. Seeders have sufficient 2 12 training in the area of training and receipt inspections? 13 A I believe so.
)
l 14 Q In your opinion, were the calibration and receipt 15 inspection procedures adequate for Mr. Seeders to perform 16 effectively? 17 A I believe so.
- 18 Q And to what do you attribute then deficiencies that 19 you identify in Mr. Seeders calibration work?
20 A Mr. Seeders hard-headedness, and sometimes l l l 21 unwillingness to really take and sit down and look at what the l l 22 procedure says and to do exactly as it's stated in there. I t I l
1 I i 135
- 1. Q All right. So in your judgment, the deficiencies I
Of 2 were Mr. Seeders fault? 3 A Basically. 4 Q Do you accept any responsibility yourself for those 5 deficiencies? 4 6 A I'm responsible for the whole program. 7 Q Do you think there's anything you should have done j 8 differently to have prevented the deficiencies or seen that 9 they were identified and corrected earlier? 10 A I requested for-them to be done, checked and so
- 11 forth.
12 Q So you don't think there's anything you should have ( 13 done different?
} ,
14 A I can't check every little piece of paper and every 15 item that the individuals do. Being in charge of the whole-16 group, I have to rely on the inspector and the supervisor, and
- j. 17 their integrity, to get the items done.
! 18 Q Well, do you think that it was -- the deficiencies 19 in Mr. Seeders calibration work were in part the 20 responsibility of his supervision by Mr. Saklak and 21 Mr. Phillips? 22 A Possibly a very small amount. . l f i O 4 l-1
136 1 Q Are you familiar with the circumstances under which
-2 Mr. Seeders was transferred?
3 A Yes, sir. 4 Q What's the basis for your knowledge on that subject? 5 A I believe I was the one that was instrumental in the 6 transfer. 7 -Q Okay. Can you describe the circumstances, please? 8 A Once I received the total review that Mr. Seltmann 9 had done over the complete calibration program, I evaluated 10 what he had there, and I first came to the intent of 11 terminating. Then I issued the memo for his termination on 12 August the 27th, I believe it was. 13 ( ) On August the 28th, I had a meeting with 14 Mr. Shamblin. Robert Seltmann was there. I believe Jim 15' Gieseker was there. And T- Robert Schulz the NRC inspector was 16 there. And I discussed my reasons for wanting to terminate 17 him. 18 And through the discussion of the meeting, various i 19 suggestions was brought out as to, was it necessary to I. l 20 terminate him or could he possibly have another place in the 21 company or in the group to be better suited for. And I gave 22 this a lot of consideration. i s l O i
137 1 And after the meeting I went to Frank Rolan, which (O) s_ 2 is the project -- Comstock project superintendent, and I 3 discussed a transfer down instead of firing him, and Mr. Rolan 4 agreed. 5 I then went to Mr. Seeders and had a talk with him, 6 which I believe Mr. Seltmann sat with me. And I showed him 7 the letter that I had written on August the 27th of my 8 intentions to terminate him. And I said, instead of 9 terminating, I'm going to offer that you be transferred down 10 to Comstock the construction arm. , 11 And he asked me a few times, are you giving me an 12 ultimatum. I said, I'm offering you a transfer because you no
/N 13 longer have employment with the quality control group. But b
14 you can transfer down there with the same salary, same 15 benefits, same everything, as long as you agree to it. And 16 it'll be effective on September the lat. 17 And eventually he said, well, okay. We went down 18 and talked with Frank Rolan, Joe Klena, Bob Seltmann was 19 there, and the transfer became effective. 20 Q okay. Who proposed in this meeting that a transfer 21 or other work assignment should be considered? 22 A Mr. Shamblin proposed it. I made the final
e 138 1 decision. ( 2 Q Was Mr. Shamblin. aware of Mr. Seeders August 17th 3 letter? 4 A I believe he was. 5 Q Why do you think that? 6 A Because when I received Mr. Seeders letter that was 7 dated -- I think it's August the 17th, I got in contact with 8 Frank Rolan. I had Mr. Saklak and Mr. Seltmann there. I had 9 Mr. Seese there. And I'm not sure whether the project 10 engineer was there or not. 11 But we discussed the letter. And during the 12 discussion the letter -- and when I wanted to ask for an ( 13 evaluation or an investigation as to why all this stuff was
}
14 going on, or supposedly supposed to be going on, Larry Tapella 15 from Ceco walked in and I said, here, Larry, would you take 16 this, a copy of this letter and either give it to Dan or Carl 17 Mennecke. And eventually, I believe it got over to 18 Mr. Shamblin. 19 Q Okay. Did you ever discuss the content of , 20 Mr. Seeders' letter with anyone from Edison? 21 A I believe I did. I think I documented it, but I 22 don't know what date it is. i S h
139 l' Q can you recall who it was you talked to? 2 A I think Mr. Shamblin was in there. I think Jim i ' 3 Gieseker was in there. Bob Saltman was in there. I'm not 4 sure who else. 5 Q This was a meeting before the one at which you I 6 discussed the transfer? 7 A I believe so. I think I documented something to 8 that effect. 9 Q Okay. Did you reach any conclusions about 10 Mr. Seeders allegations regarding his exchange with 11 Mr. Saklak, the specific event, the argument, if you will? 12 'A Well, there were several arguments mentioned in I 13 there. Which specific one are you talking about? 14 Q I'm talking about the one that's sort of a 15 culmination of the series of events that was alleged to have 16 occurred in the office. It involved Mr. Saklak observing 17 Mr. Seeders in conversation with someone; interrupting him and 18 chewing him out for not working, or words to that effect. And l 19 them being in the -- l 20 I surmised out of that there probably were some A 21 heated words between the two of them. t 22 Q All right. Did you reach any conclusion about E O 1
--,--.-re- - - - - - - - = - , * - - - - -
c 140 l' whether or not Mr. Seeders version of the event was correct?
. 2" A Well, I didn't -- I also interviewed -- through his t '
3 -letter, I interviewed, I think it wa six other inspectors. 4 AndI'mnotsurejustexactlywhatwasbaidinthere,butI 5 got the impression from them that possibly there was a 6 personnel clash behween the two individuals, which created the 7 heated argument also at that particular time. 8 Q Did you reach any conclusions about th5 9 appropriateness of Mr. Saklaks behavior in that instance? 10 '
- A Through that investigation that I did and talking to 11? the other people, what I surmised was maybe Mr. Saklak did 12 raise his voice, but not to the extent that it was being extra 13 ' boisterous.
( } 14 Q Did you reach any conclusions about whether 15 IIr. Saklak verbally abused or threatened or harassed 16 ! Mr. Seeders on that occasion? -
' 17 A Again, through talkirj ni h-these other people, who 18 supposedly heard it, I didr 7 fo 1 there was any intimidation 19 or harassment or verbal abuse come out of there.
20 Q Do you recall Mr. Seeders stating to the effect that 21 Mr. Saklak used words like, you know, you've got to play a . 22 little chess? Words that Mr. Seeders interpreted.in his 1 k_s) ,
~
s J V 9 ,-
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\
l 141 1 letter as being blackmail, in effect. Did you reach any 2 conclusions about whether those words, words used by 3 Mr. Saklak were threatening? 4 A Not at that point, no. 5 Q I'm not being clear in my question. Did you reach a 6 conclusion on that subject? 7 A That chess business, I don't believe went into that 8 particular argument that day, if my memory serves me correct 9 on that. 10 Q You think that was another incident? 11 A That was another incident, I believe. 12 Q Well, if.the letter is something that would be of I [ } 13 help, I could dig it out, but I'm trying to move this ahead. 14 Assuming it was a separate instance, did you 15 investigate and reach any conclusions about whether words used 16 by Mr. Saklak using the chess analogy were threatening or , 17 abusive? 18 A Yes, I don't feel they were. 19 Q Did Mr. Saklak have a reputation for being verbally
- 20 abusive, in your opinion?
21 A At times he would flare up. And I think this 22 happens in any construction environment. Tempers do get hot. a
142 1 I don't feel his personality was that he was 2 verbally abusive. He was an exceptionally well-versed person 3 and could use words very well. 4 'Q Did he have a reputation for having a short temper? 5 A Yes, sir, he did. 6 Q Did he have -- when I use the words verbally 7 abusive, I mean using threatening language, perhaps using 8 obscenities, perhaps threatening words. Did Mr. Saklak have a
.9 reputation for using such language?
10 A Occasionally he would make an outburst. And he 11 would make accusations, which he had been called on the carpet 12 for a few times. ( ) 13 Q And aside from whether a construction site generally 14 involves people who sometimes get angry and use off-color 15 language, which I assume that they do. Did Mr. Saklak have a 16 reputation for being somewhat unigme in that respect? Did he , 17 use language that was harsher, more abusive than persons i j 18 generally on the site? 19 A I don't feel so. 20 Q You think Mr. Saklak was just typical of -- l 21 Mr. Saklak's behavior was typical of persons on a construction 22 site? T O
143 1 MS. KEZELIS: I'm going to object. I think you're 2 -- I find it confusing whether you're talking about 3 Mr. Saklak's language or Mr. Saklak's personality or 4 character. And I think there are a lot of -- 5 MR. GUILD: Neither. I didn't say personality or 6 character. I said his words or his actions. 7 BY MR. GUILD: 8 Q In your opinion, was Mr. Saklak's words or actions 9 typical of persons on the site? 10 A I would say yes, as far as language. 11 Q How about his manner, his manner of dealing with 12 people, typical? ( ) 13 A He was unique. 14 Q And how was he unique? 15 A He could express himself in such a manner. He was 16 big. He would make, sometimes, facial expressions. And he 4 17 was very quick with words. And if an individual didn't listen 18 to what he was saying, it could sound as being abusive, or 19 possibly harsh. l ! 20 Q okay. i 21 [Brief recess.] 22
f 144 1 1 BY MR. GUILD: 2 Q We were talking about Mr. Saklak and his manner and 3 his reputation, Mr. DeWald. I think you used the words, if 4 you didn't listen closely to his words, they could be taken -- 5 they could sound abusive or sound harsh?
'6 A Yes, sir.
7 Q And what was it about listening to his words that 8 softened them or made them more understandable if they did?
, 9- A In the way he expressed them. Let me think of an 10 example. The way he used the word chess game. His example of 11 chess is in the course of a person's work you have to move 12 .from one spot to the other, and be able to cope with the 4 '~h 13 various situations that do come up.
l {d 14 Some of them may be adverse, you don't like to do them. Some of them may be 15 something you really enjoy doing. 16 And I think his word chess, this is exactly what he 17 ' meant. You have to go from one discipline to the other or 18 back and forth. 19 Q Such as the expression he used with Mr. Seeders? l~ 20 A Yes. L 21 Q -And you say, if you understood what he meant, that's , 22 not a threatening term? i t O
. 145 1 A Yes.
2 Q Or a figure of speech? 3 A Yes. 4 Q And is that particular figure of speech an example 5 of one that he's used -- 6 A He's used it on me several times. And I've stopped 7 and thought of exactly what he was saying. And then I come 8 'back to him, do you mean this? Well, yeah. 9 Q And you concluded that his meaning was innocent, or 10 his intention was innocent? 11 A His intention was innocent. 12 Q And it may not have struck you that way on first 13 hearing though? 14 A Well, the first hearing when I first met the 15 individual, I kind of got a little abrasive to him until I 16 understood the individual. 17 Q. Okay. Were you aware of Mr. Seeders and Mr. Saklak 18 having any prior. personality conflicts? 19 A Not until the actual warning when I came back and I 20 had the letter and I was told the warning was issued. I said, 21 what's-it all about? 22 Q You hadn't heard prior to that of Saklak and Seeders
146 1 having any run-ins before? n/
\_ 2 A Not before that. They seemed to get along pretty 3 decent.
4 Q Okay. You mentioned that you had had some prior -- 5 you'd warned Mr. Seeders before -- not Mr. Seeders. You had 6 warned Mr. Saklak before or -- I'm trying to use the word you 7 used, and I can't exactly recall it. But if it wasn't 8 warning, it was you'd noted in the past where he had had 9 altercations with people or used abusive or harsh language. 10 A Yes. 11 Q Okay. And can you identify any instances in the 12 past, prior to the Seeders incident? 13 A I'm not sure whether this is prior to the Seeders (} 14 incident, but it was with Franco Rolan, where I issued Rick a 15 written warning because of his conduct, when he was talking or 16 questioning Franco as to why he wanted to disposition an NCR 17 the way he wanted to. And I felt he should have done it in a 18 different manner. 19 Q Okay. Mr. Saklak says that he understood that 20 Franco Rolan, who is the son of Frank Rolan the project 21 manager, called his father after he and Saklak had words, and 22 that his father in some fashion influenced you to take action t f l
147 1 against Saklak. 2 A No, sir. 3 Q That wasn't the case? 4 A No, sir. 5 Q on one other -- let me clarify something here. On 6 one other occasion, prior -- I'm not sure of the date of this 7 -- an office in construction was locked. And Mr. SaklakAnd 8 another inspector decided to go through the ceiling. 9 Q Right. Climbed over the hanging ceiling? 10 A Yes. And they got the CT prints out that they 11 needed to work with. Mr. Rolan wanted Mr. Saklak fired, and I 12 told Mr. Rolan no. 13 Q This is the project manager Mr. Rolan? 14 A Yes, sir. That I would handle it the way I felt it 15 should be handled. And I gave him a verbal warning and told 16 him I won't condone any more of it. 17 Q Gave Saklak a verbal warning? 18 A Yes, sir. 19 Q But you don't recall any contact with Mr. Rolan, l 20 Sr. regarding the incident between Saklak and -- 21 A No, sir, I don't. Not on that specific instance. 22 Q -- Franco Rolan. 1 s
- , - - . . , . - .. ,~ . . - , . . . . - _ _ . - . - - - . - - , - - - - - . y- ,-
148 1 [ Discussion off the record.]
) > \
2 BY MR. GUILD: 3 Q Had anyone ever brought to your attention another 4 instance where Mr. Saklak used threatening language about an 5 inspector, words to the effect, "I ought to kill him, or he 6 ought to be killed," aside from the instance with Mr. Snyder? 7 A Not that I recall. Not that I recall. 8 Q Do you recall any such instance regarding Mr. Hii, 9 H-I-I, Saklak saying such a thing to Hii? 10 A There are two Hiis. 11 Q Oh, okay. There are two Hiis. Maybe you had better 12 tell me who the two Hiis are.
/'C ) 13 A The Hii that works for QC is the supervisor. His 14 dad works for Construction. They're both J.A. Hii.
15 Q Okay. So how about involving either of them, since 16 I'm not sure who it was. 17 A Not that I can recall, not in that particular frame 18 of speech. 19 Q Okay. You don't recall any complaints about any 20 kind of threatening language by Saklak directed toward Joe 21 Hii? 22 A Not that I recall. V L
149 1 Q. Okay. _Did you make any recommendations to Edison or 2 Comstock management on what action to take regarding the 3 Saklak/Snyder incident? 4 A I didn't make any recommendations. CECO issued a 5 letter with recommendations to me. 6 Q _Right. And you got that from them, but you didn't 7 make any recommendations to them? 8 A I didn't make those recommendations. I either 9 accepted them, or I didn't accept them. 10 Q Okay. And you accepted them. 11- A The majority of them, I accepted, yes. 12 Q Did they recommend anything that you didn't accept? 13 A It was the first one where they wanted a corporate
)
14 policy written, a corporate procedure written on how to 15 investigate, which we already had. 16 Q Okay. 17 A Corporate Policy 1.0.0, which is in the QA/QC 18 manual, which directs the hiring and firing and so on and so l 19 forth. 20 Q Okay. You didn't think it'was necessary to take any 21 further action on that recommendation? 22 A This Mr. Seltmann took care of, and he responded, I L O l I l
150 1 believe, to the effect that it's already covered in our manual 2 or something of that nature. 3 Q Okay. Let's talk about Mr. Puckett. You know 4 Worley Puckett? 5 A Yes. 6 Q What knowledge do you have of the circumstances of 7 Mr. Puckett's hiring at.Comstock? 8 A We were in a recruiting drive at the time to obtain 9 more Level II inspectors, because we had been authorized to 10 get -- I'm not sure of the number right at the moment, but we 11 decided since we needed a Level III type welding individual 12 that could take care of the procedures, handle all the welding ( ) 13 - problems, be able to identify problems, resolve problems, 14 revise the procedures, requalify procedures if they needed to 15 be, anything that was related to welding, we decided to get a 16 Level III which would be totally responsible for all that, and 17 we decided to. fill that -- use that Level III with a Level II ! 18 slot that we had vacant at the time. That's how we came about j 19 hiring the individual. 20 Q Mr. Puckett? 21 A Yes, sir. 22 Q Okay. You were a Level III weld inspector at the 1 4 O t i i w , - - - , , -,,n-- w,-- --.--.,,.,.,,.~,..-.m---,,n., ,.,--na, , , . . , - . - , , -r- ,,-,,,,..v,m,-n.._n,w,,,,-n.,-,-n. m., ,.,n,,n,, an-.m, ,
151 1 time? f'N (_ / 2 A Yes, sir. 3 Q All right. And were there any other Level IIIs at 4 the site? 5 A No, sir. 6 Q Okay. Why did you feel that you needed another 7 Level III in welding aside from yourself? 8 A With myself, dealing with the whole entire 9 operation, I did not have the time to sit down and strictly 10 deal with that particular area when I knew I had problems in 11 it, and I didn't have the time to devote directly to that. 12 Q Okay. What problems had you identified in the 13 welding area? ( } 14 A On May 5th, I think it was, or May 12th -- I think 15 it was '84 -- we had our corporate Level III welding engineer i 16 come in just prior to that, and he went through the 17 . contractual specifications versus AWS versus our procedures 18 and identified numerous inconsistencies within the contractual 19 specs versus the AWS specs and so forth. And I issued a 20 letter to -- I believe it was Karl Mennecke in CECO -- l l 21 identifying all these inconsistencies, and this was one of the 22 areas that the Level III, Mr. Puckett, was going to have to I O
152 1 take and clean up. 2 Q Okay. Can you help me identify these documents a 3 little better? Who is the corporate welding Level III? 4 A Mr. Tom Vogt. 5 Q V-O-G-T? 6 A Yes. 7 Q Okay. And were his findings documented? 8 A Yes, sir, in that letter that I wrote to 't 9 Mr. Mennecke. 10 Q Did Mr. Vogt write any kind of memo or letter 11 reflecting what he found? 12 A He helped me draft up this particular letter. () 13 14 Q Okay. So you signed a letter to Mr. Mennecke of Commonwealth Edison documenting Mr. Vogt's findings? ) 15 A Yes. j 16 Q Okay. And Mr. Vogt's work was -- you said May 5 or 17 May 12, '84? 18 A He come in prior to that and was there. I initiated 19 the letter. 20 Q Well, May 5 or May 12, one of those days? i 21 A He was in there in May, I believe, the earlier part 22 prior to me issuing the letter. O 4
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153 1 Q Okay. And when did you issue the letter? 2 A On the 12th. I believe it was the 12th. 3 MR. GUILD: Counsel, do you know offhand if that has 4 been identified? 5 MS. KEZELIS: That has been produced. If you want, 6 I can get a copy for you right now. 7 MR. GUILD: That would be great. 8 MS. KEZELIS: Let's take a couple minutes, then. 9 (Recess.] 10 BY MR. GUILD: 11 Q Mr. DeWald, we've marked as DeWald Exhibit 7 a May 12 12th '84 memo from you to Mr. Mennecke and Mr. Quaka, [JT 13 14
Subject:
-L-2790.
Braidwood Welding Program Contract Specifications 15 (DeWald Deposition Exhibit No. 7 16 was marked for identification.] 17 Is that the memo that you had reference to a moment 18 ago? 19 (Witness reviewing document.] 20 A Yes, sir. 21 Q Okay. And did you bring this memorandum to 22 Mr. Puckett's attention when he was hired?
l 154 1 A Yes, I did. 2 Q Okay. And in the context that you described 3 earlier, these were things that you wanted him to address? 1 4 A Yes, sir. 5 Q Okay. Now when did you have your first contact with 4 6 Mr. Puckett? 1 j . 7 A The day he was hired. 8 Q All right. Did you interview him? 9 A Yes, sir. 10 Q Okay. Who else interviewed him? I 11 A I believe he spoke with Tom Paserba. I believe he ! 12 spoke with Tom Vogt and Mr. Marino. 13 .Q All right. Did you review Mr. Puckett's statement
}
14 of qualifications or resume? j' 15 A Yes, sir. 16 Q Were you aware of his prior work at the Zimmer
.17 facility?
i 18 A Yes, sir. That was in his resume.
- 19 Q Okay. Did you discuss with Mr. Puckett his Zimmer 20 work in the interview?
4 21 A Yes. Not to any great extent. We asked him what he t 22 had done. He indicated that he had control over the weld , 4 4 O i i
. .--- - - - . - - .- ,_ ,. .,. ..- ,. .-,., ..-.._ ., .- ...- -...,- - ,-...-----_ -n - - _ .n.,-__ . - . . . - . - -
155 1 qualification area and the qualifications of the welders. \ ms 2 Q Did Mr. Puckett identify to you at the time of his 3 initial interview that he'd had experience with NRC regulatory 4 actions in the welding area at Zimmer? 5 A No, he didn't, not that particular specific thing. 6 Q Okay. You don't recall during the interview 7 Mr. Puckett bringing up the subject of deficiencies that had 8 been identified by the NRC in the program of Kaiser, the 9 welding program of Kaiser, at Zimmer and that experience as a 10 basis for addressing whatever deficiencies there might have 11 been in the Comstock program at Braidwood? 12 A Not at the time of the interview, he didn't. 13 Okay. /~') N./ Q Did you discuss at all the subject of his 14 Zimmer background and experience? 15 A Nothing other than really what he had done -- 16 actually done while he was there. 17 Q And what did he tell you he had done, aside from -- 18 A The welder qualifications and the weld qualification 19 and historical type data that he kept up on the welders and 20 the weld qualifications. 21 Q All right. Did he -- did you ask him who he 22 reported to at Zimmer? 1 J
156 1 A No , I didn't.
'2 Q All right. Did anyone else ask him?
3 A I don't recall whether they did or not. 4 Q Okay. Did you all interview him together? 5 A Mr.-Paserba and I interviewed him first, and then he 6 talked with Tom Vogt awhile, and then we had a little 7 conference type session, and through his resume and speaking 8 with him, we thought this was the Level III that we wanted, 9 that he would qualify as a Level III. And before he left, 10 Mr. Marino talked with him. 11 Q Okay. Had you seen anything in writing from 12 Mr. Puckett before you interviewed him? f\_/
%, 13 A No, sir.
14 Q You hadn't seen his resume before you talked to him 15 that day? 16 A I don't recall whether we got his resume before we I 17 got him or had him come in, or if we told him to bring it in 4 18 when he came in for the interview. 19 Q Okay. Well, what prior information, if any, did you 20 have about Mr. Puckett before the day you hired him? 21 Just his interview and the resume that he brought A 22 with him. 4
157 1 Q Right. But before that day, though, Mr. DeWald, had 2 you gotten any information about Mr. Puckett? Did he just 3 walk in the door off the street, or -- 4 A Oh, he had called about a job interview, if that's 5 what you mean. 6 Q Yes. What kind of contact had you had with 7 Mr. Puckett before? 8 A Oh, he had called about an interview, and we told 9 him to come to the site for an interview. 10 Q Okay. And did he talk to you when he called? 11 A I think he did. 12 Q Okay. And did you identify the Level III position 13 to him at that time? 14 A No, I didn't -- oh, excuse me -- maybe I did, or 15 maybe I didn't. I'm not sure. 16 .Q Okay. Do you know what job he was applying for at 17 the time you talked to him on the phone? 18 A That I'm not sure of. 19 Q Okay. How did, if you know -- what information did 20 Mr. Puckett have when he contacted you? 21 A What I recall, he just said that he'd been a welding 22 engineer, I believe, at Zimmer, and he had prior Naval
158 1 background, heavy into the. welding, and we figured we needed
?
I
\ 2 to talk to this individual.
3 Q Okay. Well, I guess what I'm driving at is, you , 4 told me you were doing a recruiting drive for Level IIs in the 5 welding area, right? 6 A Yes. 7 Q Okay. And did Mr. Puckett know that, as far as you 8 are aware? 9 A I believe he did, because we put it out in the 10 paper. We had it advertised. 11 Q And do you think he was aware of an ad for the 12 position?
/ 'N 13 A I think so.
O 14 Q All right. The ads did not offer a Level III ' 15 position? ' 16 A No, it just said Level II welding, and I forget what i
- 17 else was on it.
18 Q okay. So as far as you know, Mr. Puckett was 19 responding to a general ad for Level II welding inspectors. 20 A I believe so. 21 Q Okay. You had contact with him on the phone, said, i 22 "Come on in for an interview." ,- O
e l 159 1 1 A Yes. i g 2 Q And you set up a specific date? 3 A -Yes, there was a specific date. ^i i 4- Q Okay. And did you make particular arrangements to i 5 have the others available to interview him at that time? By 6 that, I mean, Mr. Paserba, Mr. Vogt,1Mr. Marino. Were they i i 7 expecting Mr. Puckett on that day when he came for an i 8 interview?
- j. ,
l 9 A They was all there. They were expecting him to be 10 there. { 11 Q Okay. You had them in attendance for the purpose of . 12 interviewing Mr. Puckett? () 13 A Well, they were there in attendance for the review 14 that -- you know, the interviews that we were doing. j-
- 15 Q Okay. They were interviewing others as well?
I l 16 A Yes, i 17 Q I see. And before you talked to Mr. Puckett'-- you 18 may have answered this already -- but before he actually came 19 in for the interview, had you and the others with comstock ! i ! 20 identified the potential for the Level III position? I t 21 A Oh, yes. ' 22 Q Okay. And you identified Mr. Puckett as a candidate I I } i a
160 1 for that position? i- 2 A Yes, sir.
- 3. Q Okay.
! 4 A After we looked at his resume.
t 5 Q So after he actually arrived onsite. '
! '6 A Yes.
j- 7 Q I see. And in the first conversation with i 8 Mr. Puckett, did you tell him that there was a Level III 9 position? i 10 A I don't recall whether we did or not. 11 Q Okay. You interviewed.Puckett. How did you first 12 raise the question of the Level III position? () 13 ~A He had the necessary background and experience, we
} 14 felt, through his resume and through talking with him, that he l 15 would fill the bill for the Level III that we were looking ; 16 for.
17 Q Okay. And is that a decision that you arrived at { 18 privately among yourselves, the Comstock people? 4 19 A Yes, sir. 4 20 Q Okay. And who arrived at that decision? 21 . A I'think it was an ultimate decision amongst the i 22 group. i i LO l J 3,--..,.--.-._._.--,_ _ _ . . _ - - . ._ ._ _,_ -, __ ___-.-
161 1 Q Okay. And again, the group was who? 5
%- 2 A Paserba, Vogt, myself, and Mr. Marino.
3 Q And Mr. Marino participated in that as well, that 4 decision? 5 A He discussed it with us, yes. 6 Q Outside of Mr. Puckett's presence? 7 A Yes. 8 Q You decided to offer him the Level III position? 9 A Yes, sir. 10 Q Okay. Did you bring him back in and do that, or did 11 you contact any -- 12 A We brought him back in an done it. (~) \_/ 13 Q Okay. And what happened when you brought him back 14 in? 15 A All right. 16 Q How did you describe the position, the Level III 17 position, that you offered him? 18 A That it was the responsibility of the whole welding 19 area of revising the procedures, taking care of the known 20 existing inconsistencies that we had at the time, and anything 21 else that he may have found while he was doing some of these 22 items, so that we could get them all resolved and get our [ v
162 1 procedures in line the way that the contract specifications 2 required. 3 Q Okay. And did you show him the May 12 meno, the 4 Exhibit 7, at that time? 5 A Not on the date that he came in, no. 6 Q Did you give him any documentation reflecting what 7 the problems were that you referred to? 8 A Not during his interview. 9 Q Did you give him anything in writing describing what 10 his duties would be as a Level III at that time? 11 A During the interview? 12 Q Yes. () 13 A No, sir. 14 Q So it was an oral description on your part of what 15 the position was. 16 A Yes, sir. 17 Q All right. He was hired on the spot? 18 A I believe he was. 19 Q Okay. 20 A To the best that I can recall. 21 Q All right. And was something in writing given to l 22 him subsequently that described those duties, the
- l
163 1 responsibility for the welding area? l L_/ 2 A No, I never did give him anything in writing. ' 3 Q Okay. Now are you familiar with the circumstances 4 of Mr. Puckett's termination? 5 A Yes, sir. 6 Q Okay. And would you describe those, please? 7 A On August -- well, prior -- let me start over here. 8 When he got there, shortly after that, Bob Schulz, 9 the NRC Resident, gave me a list of weld rod withdrawal slips 10 that the heat numbers were referencing E-6013, and the weld 11 rod withdrawal that was -- that they drew from the rod crib 12 was E-7018. () 13 I gave these dates to Mr. Puckett and asked him to 14 review these to see if he could possibly trace down the CMTRs 15 and the material receipt request numbers, so that we could 16 make these compatible and find out the exact numbers to make 17 sure these were the correct numbers, and if maybe it was a 18 clerical type error when they wrote the numbers down. 19 I'm not sure what date this was that I gave it to 20 him. I think it was in July sometime. 21 Then on August the 22nd, we had a meeting -- I 22 believe it was August 22nd -- there was a meeting with various
164 l} l S&L people, CECO people, to discuss two PQRs, Attachment,A'and 2 Attachment O's. 3 Q. What is a PQR7 4 A That's a welding procedure qualification. 5 Q I'm sorry. You gave me the two numbers that they 6 were? 7 A 14 Y Attachment,A and Attachment O. These were 8 attachments to Procedure 4.3.3, and they dealt with A-36 to 9 A-446 materials. 10 In the meantime, this is one of the deficiencies 11 that Mr. Puckett had identified as being a -- in one of his 12 letters, a stop-work type situation. () V 13 Q These were unqualified procedures? 14 A We had one procedure that was -- both procedures 15 were qualified, but the Attachment O was qualified 16 incorrectly. 17 Q Incorrectly qualified procedures. All right. 18 A And during this meeting, Jim Loudon, I believe his 19 name was, from S&L, expressed something to the effect that we 20 could still weld with this procedure, although it needed to be 21 -- we'd have Attachment H; Attachment H should have covered 22 it, and Mr. Puckett agreed, and it was shortly after that that 1 i O
165 1 Mr. Puckett issued one of his letters for a total, complete C) (_/ 2 breakdown. 1 3 In the meantime or prior to this -- I forget the 4 exact date -- Mr. Puckett had requalified Attachment O, and it 5 was qualified properly, although he had failed to resubmit 6 this back to Commonwealth Edison and S&L for final approval, 7 which would have cleared the whole situation up. 8 This was also identified in Status 2 comments that 9 came back from S&L on Procedure 4.3.3, I think it was Revision 10 C, which stated -- 11 Q Let me slow you up there. What is a Status 2 12 comment? ( } 13 A This is a comment that comes back from S&L that says 14 they're not approving these particular ones; you've got to do 15 some other extra work to it. 16 Q Okay. 17 A And Attachment o was in those Status 2 comments. 18 Q okay. And they had identified the -- 19 A The incorrect qualification. 20 Q okay. The same thing that Puckett had identified. j 21 A Yes, sir. l 22 Q Okay. I i O i _ _ - _ . _ ~ _ _ _ _ _ . _ _ . _ _ .
166 1 A The incorrect qualification was, we had qualified to
! 2 a flare bevel groove, and it should have been qualified to a 3 fillet, 4 Q All right.
5 A When the procedure was requalified, we used the same 6 samples or the same coupon's that we used to qualify the flare ! 7 bevel to qualify the fillet. We resubmitted it. It was the 1 8 PTL for the effective throat and so on. And that's when we
- 9 requalified that particular procedure.
10 Q After when Mr. Puckett requalified it? Again, after 11 him? i 12 A No. That1was what he done. l l\ 13 Q Okay. b 14 A Then the meeting on 8/22 and after it was discussed
, 15 and everything would have been all right, Mr. Puckett then ; 16 issued those two letters -- the one letter stating that we had 17 a complete breakdown, which, in fact, we did not have a 18 complete breakdown.
19 Q Words like "We are approaching a complete 20 breakdown?" 21 A Something similar to that, yes, i j 22 Q In a memo to you,'right? f 9 O
167 1 A Yes, sir. 2 And various people from other organizations then 3 started to question Mr. Puckett's knowledge of AWS, and I, 4 too, at the same time started thinking maybe I had got me a 5 wrong individual in there to act as my Level III. 6 Q ,And who were the other people from other 7 organizations that started to question -- 8 A LotADEtt M I think it was Mr. Louder. and -- 9 Q He was the Sargent & Lundy man? 10 A Yes, sir. l 11 I think Mr. Gieseker. 12 Q He's the Edison man. I
'R A E.F 13 A And I believe an S&L man by the name of Don-Rauf was 14 sitting in there.
15 Q How do you spell his last name? 16 A I'mnotsure.0 "RAEF x 17 Q R-A-I-F? RAEF .$O 18 A " A 'J-F or something like that. I'm not sure of the 19 exact spelling. 20 Q You pronounce it "rafe?" 21 A "Rafe." 22 Q And what is Mr. Rauf's area of work, if you know? O
168 1 A I'm not sure just exactly what he's title is. I 2 know he's part,of the electrical part of it. 3 Q Okay. ~ KcLnosKY -54b 4 A He works for Jim E lar.owski-5 Q Okay. Any others that,.you are aware of who 6 questioned Mr. Puckett's -- 7 A There,were several more, and I don't remember 8 exactly who was there. 9 Q . All in this same meeting on the 22nd? k.cnosty asp 9 10 'A' Yes, sir. Jim Yal2"auski- was not there. 11 Q Okay. But you are reforring to people questioning 12 Mr. Puckett's knowledge at that meeting?
l 13 A Yes. Well, kind of in that meeting.
(D At the same y 14 time, they asked him a few questions. The answers were not 15 there. And then after the maating, I had heard, "Does'he know 16 what he's doing" and so forth. 17 Q From these people? 18 A Yes. 19 Q From any others that you can recall? 20 A Not offhand. t21 Q And you, yourself. began to -- 22 I began to wonder, because things weren't just A
~
169 1 getting done. It seemed like he would go out and identify 2 something, and yet I would never get no resolution from it, or 3 I would never gat a clean-up item on it. And I was getting 4 the feeling that it was just, " Hey, I found something, and 5 I'll go on to the next item." 6 Q Okay. When you say "no clean-up" on it, what do you 7 mean by that? 8 A To provide the resolution and to straighten the item 9 out. 10 Q Okay. Did Mr. Puckett have authority to originate a 11 nonconformance report? 12 A He sure did. 13 He did?
) Q 14 A Yes, sir.
15 Q All right. He could have signed one himself, in 16 your opinion? 17 A Yes, sir. 18 Q All right. And did he have authority to issue a 19 stop-work directive? 20 A I was the only one that had the authority to issue i 21 the permanent stop-work. Any inspector out there in the plant 22 can stop the work while they're doing an inspection, if they I
i 170 1 see that it may be detrimental to the piece of equipment or 2 whatever they might be inspecting or working on. 3 Q Mr. Puckett didn't have any certifications then. 4 A None, but he still could initiate an NCR. 5 Q He could have issued an NCR? 6 A Yes, sir. 7 Q Okay. And did he understand that he had the power 8 to issue an NCR? 9 A I think he did. In the procedure, it states that 10 any QC person can or QC personnel. 11 Q Okay. Well, he wasn't certified in any -- 12 A You don't need to be certified to initiate an NCR. 13 Q Okay. I interrupted you. You were telling me that
}
14 you began to question his judgment, and others told you that 15 they had doubts. 16 A My judgment started to question him, was when I was 17 not getting any resolutions. 18 Q Okay. 19 A And the problems were not being totally resolved, 20 and this was when my -- I had very vague doubts on him then as 21 to does the individual understand the method of AWS and so 22 forth. l
- O l
l
171 1 1 Q And did you identify any of these questions or 02 doubts to Mr. Puckett? 3 A He had given me a memo a couple times. I said, 4 " Fine," especially on the stop-work, "What's your basis on it, 5 and what's your resolution," and I forget exactly what I did 6 write on it, but I did ask him, "What's the specifics," I 7 believe, and, "What is the resolution in order to get the 8 problem cleaned up?" 9 Q And did Mr. Puckett propose any resolution? 10 A I never got a proposed resolution from him. 11 Q okay. Did you ever speak to him about it? 12 A Yes. () 13 14 Q A And what did he say?
"Well, I'm working on it."
15 Q Well, wasn't the resolution to stop work and 16 requalify or rewrite the proceiures? 17 A It wasn't a stop-work condition. 18 Q Isn't that what he proposed? 19 A That's what he proposed. 20 Q And you don't believe that was the appropriate 21 resolution? 22 A No, sir. l l
172 1 Q Were you aware that Mr. Puckett proposed to 2 reorganize the weld filler material control program? 3 A He recommended to do this. He was responsible to 4 sit down and revise the procedure, which he never done. 5 Q He proposed enhancing the filler material control 6 practices, did he not? 7 A Yes, but like I said, it was his responsibility to 8 sit down and revise the procedure, contact the right person in 9 Construction, and tell them, "You're got to reeducate the rod 10 crib person to the procedure." 11 Q Did you authorize him to do that? 12 A He had full authorization. He could talk to anybody 13 in Construction that he wanted to talk to. 14 Q Did you authorize him to revise the weld rod control 15 practices? 16 A That was one of his responsibilities when I talked 17 to him when he came on. 18 Q All right. So as far as you were concerned, he had 19 the authority from you to do that? 20 A Yes, sir. , 21 Q Okay. Did you speak with Mr. Puckett about his -- 22 well, did Mr. Puckett propose to you that you requalify i' O
173 1 procedures to the AWS D.1.3 code? (m- 2 A Yes, sir, he sure did. 3 Q All right. 4 A And L-2790, which is our contract specifications, 5 gave us, as the contractor, the option of staying with AWS D.1 6 and not using D.1.3. 7 Q All right. Well, notwithstanding that, you had the 8 option to also qualify it to D.l.3, didn't you? 9 A Yes, but that would throw us into a whole different 10 perspective, because the D.1.3 is a sheetmetal qualification. 11 Q Right. And you do sheetmetal work, don't you? 12 A No, sir. () 13 14 Q Well, you do work with thin gauge cable pan material. 15 A Thin gauge, but we can still use our qualification 16 for our welders to weld on that thin gauge material. 17 Q Right. But did Mr. Puckett propose that you qualify 18 some or a? 1 of your procedures to D.1.3, to the extent that 19 you used thin gauge? 20 A He wanted to qualify our welders to D.l.3. 21 Q Right. 22 A And this we didn't have to do. O V i
. __ = - - - - . - - .__
174 1 Q All right. So you didn't give him authority to do 1 2 that. 3 A No, sir. ' 4 Q All right. He proposed it, and you rejected that 5 proposal. 6 A Yes, sir. 7 Q Okay. So what happened then, after you questioned 8 Mr. Puckett's knowledge? j 9 A On -- again, I'm not sure of the date, but I believe 10 it was the 28th -- 11 Q August now? 12 A Yes, I believe August. [ } 13 There was a meeting with Mr. Shamblin and myself, 14 and I'm not sure who else was in there. But anyway, we 15 discussed Mr. Puckett's performance and his lack of knowledge 16 of AWS, and that he wasn't really fulfilling the Level III 17 obligation that we had. And I made the decision then to 18 terminate him within the 90-day evaluation period that we had. 19 Q Okay. What did Mr. Shamblin contribute to the 2 20 discussion, if anything? ! 21 A Well, he more or less asked questions, like does he 22 know what he's doing? He'd heard from various other people 4 O 3 i
i 175 1 that Mr. Puckett really doesn't have the knowledge of AWS the 2 way he should have. 3 Q Did he say who he'd heard from? 4 A No, he didn't. 5 Q Did you have any understanding who had talked to 6 him? 7 A I had a general idea who was indicating it, because 8 of the meeting on the 22nd. 9 Q Okay. Mr. Gieseker, for one? 10 A Probably Mr. Gieseker, Jim Loudon. Jim Loudon is 11 S&L's AWS person, and I take his readings on AWS as pretty i 12 prudent, and he is a very knowledgeable individual. i I~'T 13 Then, like I say, I made the decision that he's V 14 within the 90 days, and we'd go ahead and terminate him. 15 Q Okay. And did Mr. Shamblin agree with that 16 recommendation? 17 A He said it was up to me.
- 18 Q Okay.
i 19 A He really never gave me no direction. It was my own l 20 personal doing. 21 Q All right. Who set up the meeting on the 28th with 22 Mr. Shamblin? I l I O f
- , . - . - - , ~ - , - ,w ~ . . , +
176 l
. 1 A I don't recall whether I called or Dan called me
( 2 over to talk. I'm not sure just who set the meeting up. 3 Q Okay. 4 4 MR. BERRY: Off the record. 5 [ Discussion off the record.] 6 BY MR. GUILD: 7 Q That's August 27 or 28, 19847 8 A Yes. I documented it somewhere. I know I have a 9 memo that's been submitted someplace. 10 Q Was Mr. Shamblin aware that Mr. Puckett had -
- - 11 recommended a stop-work in a number of areas?
4 12 A I'm sure he was, because I sent a letter after I got (} 13 the recommendation, that until such time as I could really 14 check into the depth of everything that was as he had 15 expressed in his letter, heading for a complete breakdown, I 16 sent a letter to the Project Manager saying -- I recommended 17 we stop work on the stainless and the A-36. 1 j 18 Q Okay. Was the Project Manager Mr. Wallace now? 19 A Mr. Rolan. ( 20 Q Oh, to your Project Manager. l 21 A Our Project Manager. l ! 22 Q Okay. And why does that make you believe that l f l l
177 1 Mr. Shamblin knew about it? (3
\s ,/ 2 A Because I'm sure Mr. Rolan called him up right away 3 and said, " Hey, Irv just threw a stop-work on me."
4 Q Okay. 5 A And I may have put CECO for a copy of that. I'm not 6 positive. 7 Q But you are basically confident that Mr. Shamblin 8 was aware of Mr. Puckett's stop-work recommendation? 9 A Yes. Oh, yes. 10 Q How would you have known that Mr. Puckett was behind 11 that? You wrote the memo to Rolan. 12 A And I attached his memos and his letter with it.
'~
/
\_/
') 13 Q Mr. Puckett's?
14 A Yes. 15 Q Okay. Was Mr. Shamblin aware of the Puckett memo to 16 you that made reference to the impending breakdown, complete l l 17 breakdown or whatever words specifically he used? 18 A That was in a letter. Yes, he was aware of that, 19 too. I attached the whole thing. j 20 Q Okay. So Shamblin had that as well, so far as you 21 know? 22 A Yes. l i
178 1 Q Did Mr. Shamblin offer his opinion at all on what p
\s 2 action to take, aside from a recommendation that he offer an 3 opinion?
4 A No. The opinion was mine, or the action was mine. 5 Q Okay. Did you discuss the pros and cons of taking 6 any particular action with Mr. Shamblin? 7 A I think we did. 8 Q Okay. 9 A But like I say, I, myself, was the one. 10 Q You made the decision. 11 A I made the decision. 12 Q All right. What did you discuss about the pros and
/~ 13 cons of terminating him?
D) 14 A Well, one of the ideas that we thought about was 15 dropping him to a Level II and making him an inspector, the 16 pros and cons of that. We figured his poor performance, the 17 way he was here, it would possibly reflect if he was an 18 ' inspector in the same way. So I determined, "I'll terminate 19 him."
- 20 Q Do you believe that Mr. Puckett was qualified to l
21 perform as a Level II weld inspector? 22 A I do. l IOa i
179 1 Q You have since hired another Level III weld 2 inspector? 3 A Yes. 4 Q Okay. Who is that? 5 A Anthony Simile. 6 Q Okay. And when did you hire Mr. Simile? 7 A He reported there -- I believe it was August the 8 28th. 9 Q Of what year?
.10 A '84.
11 Q All right. Did you know that Mr. Simile was 12 available at the time you terminated Mr. Puckett? i [ } 13 A No , sir. I called Mr. Marino and told him I needed 14 a Level III, and Mr. Simile was working at our Perry project, 15 and then he was transferred in. 16 Q Okay. You called Marino after you made the decision 17 to terminate Mr. Puckett? 18 A Yes. Well, I also discussed his termination. This 19 was all done at the same time. 20 Q So you called Marino and said you were considering 21 terminating Mr. Puckett. 22 A Yes, I did. O
180-1 Q And asked -- did you ask him if he had available 2 another Level III? 3 A. I said, "We'll need another Level III," and he said, 4 "I'll get right on it.". 5 Q Okay. Did he identify Mr. Simile to you at that 6 time? 7 A Not at that time. 8 Q Okay. And Mr. Simile had been at Perry? 9 A Yes, sir; he was at Perry. 10 Q And what has Mr. Simile's work performance been 11 like? 12 A Outstanding. [JT 13 14 Q Has Mr. Simile ever recommended a stop-work? A No, sir. 15 Q Did Mr. Simile recommend qualifying welders or weld 16 procedures to the D.l.3 code? 17 A No, sir.
- 18 Q Has Mr. Simile recommended requiring heat number 19 traceability for weld filler material?
20 A That was always on the withdrawal slip. 21 Q Well, I know heat numbers are on the withdrawal 22 slip. But traceability to a particular weld. O
181 1 A No. . 2 Q All right. Has Mr. Simile recommended 3 accountability for weld rod that's been issued and then 4 returned to the ' issue station, rod by rod accountability? 5 A -Not specifically one, two, three, four. 6 Q You don't have a system like that in place, do you? 7 A No. They return the cans at night. l 8 Q Okay. There's not a count of rods issued and rods ! 9 returned, stubs consumed? ! 10 A It's by the pound. They may issue one pound, and 714ey orto 11 they bring it back and the-weigh it and put it back. 12 Q Okay. There is a weighing system now. , 13 A Yes. 14 Q Did you testify in Mr. Puckett's Department of Labor j 15 proceeding? 16 A Didn't get the chance. 17 Q Why not? l 18 A We didn't get the chance to cross-examine. {' 19 Q You didn't have a chance to cross-examine 20 Mr. Puckett? 21 A Yes, sir. l 22 Q Do you know why? . O c
182 1 A The judges and the attorneys got together. 2 Q You're aware they settled the case with i 3 Mr. Puckett?- Comstock reached a settlement with Mr. Puckett? I 4 A Yes. 5 Q ~O kay. Did you have any contact prior to the j 6 testimony, the hearing in the Department of Labor case, did + 7 you have any contact from the Department of Labor investigator 8 that reviewed Mr. Puckett's discrimination claim? 9 A Yes, sir. 10 Q And did you tell that investigator the substance of 11 what you've told me about Mr. Puckett's performance?
- 12. A Yes, sir.
13- Q Did you provide the investigator with any documents 14 that were asked for reflecting Mr. Puckett's performance?
- 15 A He was provided everything that he asked for, yes, 16 sir.
17 Q And did you give him documents reflecting i 18 Mr. Puckett's performance? ,' 19 A He had documents that was previously provided when l 20 the Labor Relations case was in process. i 21 Q That's what I'm speaking, the investigator from the
-22 Department of Labor-had contact with you about Mr. Puckett's e
O e i 5 _ , - _ , . . , . , _ _ - _ _ _ _ , _ _ _ , _ ~ _ , _ . . . , , _ _ , _ , . _ . _ _ . . . _ . . _ _ _ _ , _ _ . . ~ . - _
. . -. . - . _ . . . .~ . . - - - . . . .. ._.. ..
183 1 claim? 2 A He visited me once at the plant. But prior to that 3 I had made a whole package up, which was transmitted to the 4 Labor Relations Board, d 5 Q Okay. When was Mr. Puckett terminated? 6 A I'm not sure of the exact date. I think it was the 7 28th. 8 Q Of August 1984? 9 A I believe. 10 Q Okay. I show you a series of documents. First, is i 11 a memo that appears to be dated 8/25/84, and it's S4344. It i 12 appears from Mr. Dominique. I think it's to you, Mr. DeWald,
/T 13 although the copy has been slightly cut off at the top. Can V
! 14 you identify that document? 15 [ Witness reviewing document.] , 16 A This is a run-down of Mr. Puckett's training. , 17 Q Is it a memo from Mr. Dominique to you? 18 A Yes. 19 Q And is it in response -- is it at your request? Was 20 it written at your request? 21 A Yes. 22 Q And what were the circumstances of your requesting 1
- O
_ ,_m. . . .- r_,, . - _ . ,
184 y 1 that document? 4 2 A This was part of the whole complete package that we ( 3 drew'up on Mr. Puckett. i 4 Q Okay. This was at the point where you made the j '5 decision to terminate him under the probationary period? 3 6 A Yes, sir. 7 Q And you were documenting the basis for that 8 decision? 9 A Yes, sir. l 10 Q' And what did you ask Mr. Dominique to do? . 11 A Just to draw me up of the training and so forth and i 12 practicals and what-not that he had. 4 ( ) 13 Q Okay. And this memo does that? 14 A Yes. I 15 MR. GUILD: Let's mark this, please. ! 16 (The document referred to as 7 17 DeWald Exhibit No. 8-
- 18 was marked for identification.)
19 BY MR. GUILD: i 20 Q Mr. Puckett performed a series of practical 21 examinations as part of his-certification process as a Level ' 22 III inspector, correct? f 1 i
- - _ _ . , _ . , . _ . . - ~ _ _ _.___-.. _.m . _ _ _ . _ _ . - - - _ _ _ , _ ___
185 1 A Yes, sir. (, / 2 Q Now in the first of those examinations Mr. Puckett 3 was determined to have failed the test, correct? 4 A I'm not sure whether that was the first one or not. 5 Q Well, I'm showing you -- I have a document in hand 6 that's dated 7/6/84 and signed by Georgo G. Nemeth. Who is 7 Mr. Nemeth? 8 A He's a Level II inspector. 9 Q All right. This is S4311. And it's a document of 10 several pages in length and appears to include the 11 documentation of the practical test first taken by 12 Mr. Puckett. Examine it, if you would, please. (
) 13 [ Witness reviewing document.]
14 A Okay, this -- yes, he failed this one. 15 Q And why did he fail that test? 16 A There are two types of connections out there, as 17 Mr. Nemeth explains here. DV120s were installed and a DV2. 18 The DV2 was incorrectly listed as DV120 on his practical 19 exam. 20 Also, he indicated there were no welder stamps, 21 welder ID stamps on the particular item. And this was 22 incorrect as all eight field welds, as he has written here,
186 1 were stamped with a welder ID stamp, which did not constitute (D s-) 2 a deficiency or a rejectable item. 3 Q Mr. Puckett identified a failure to have a welder ID 4 stamp for one or more welds? 5 A Yes, sir. 6 Q And another inspector found those stamps? 7 A Yes, sir. 8 Q And that represents in part the reason why 9 Mr. Puckett failed the exam? 10 A Yes, sir. I examined those welds myself. 11 Q And you found the stamps? 12 A Yes, sir. () 13 14 Q stamps? Do you know why Mr. Puckett didn't see the weld 15 A No, I don't, unless he didn't look at it. 16 Q Okay. They were visible to you. 17 A Yes, sir. 18 Q All right. " Field welder stamps were visible and 19 found by certified Level II welding inspector verifying 20 Puckett-found deficiencies." Do you know who that Level II 21 inspector was? 22 A I don't know who wrote that. That looks like a O
187 1 sticky was put on top of the paper. I don't know whose
,3
)
,/ 2 handwriting that is. It could be mine, but I'm not sure.
3 Q- And then it has written by it, "Who?" At least on 4 the copy I have. 5 A Yes, I didn't write "Who?" on there. G Q Okay. Is that your handwriting? 7 A It could be my handwriting, yes. It looks like it. 8 Q You weren't a certified Level II inspector, were 9 you? 10 A Well, what I'm saying, " Details incorrectly listed. 11 Welder ID stamps were visible and found by a certified Level 12 II welding inspector verifying Puckett-found deficiencies." 13 [~h Q Who is the certified Level II inspector? 14 A George Nemeth. 15 Q Nemeth found the weld stamps? 16 A Yes, sir. 17 Q And you are just writing that note summarizing what > 18 the results are? j 19 A Yes, I believe I did. 20 Q I see. That's not a part of the original record? i 21 A No, it can't be. 22 Q Okay. l l l l
188 1 A After a rejection like that, I always write a
~(~\
(,) 2 note or two on the bottom. 3 Q Okay. That's your practice? 4 A Yes. 5 Q on a sticky like this? 6 A Not on a sticky. I don't know where that sticky 7 came from unless I was doing that through the review that I 8 was doing when I packaged up that material for -- 9 Q For the lawyers? 10 A Yes. 11 Q And what's the note on here? Is that your 12 handwriting? "Through the mistakes made, 20 additional hours
/~ 13 was required to comply with 4.1.3"?
O) 14 A Yes, sir. That was in-the procedure at the time. 15 Q And that's your note? 16 A Yes, sir. 17 Q That's remedial training, in fact? 18 A Yes. 19 Q Now, where was the detail incorrectly listed on the 20 form, Mr. DeWald? Looking at Form 19. Is that right, the 21 Form 19? i 22 A The Form 19 and in the details inspected. i l io l
189 1 Q In the details inspected, he lists a detail. a f' f
\m- 2 A DV120.
3 Q Okay. And that's what Mr. Puckett says he ' 4 inspected. 5 A Yes. 6 Q Well, was there a DV120? 7 A There as one DV120. 8 Q How do you know that wasn't what he inspected? P 9 A There was also a DV2 on that. 10 Q Well, isn't it Mr. Puckett's position that he 11 inspected the DV120 and found a rejectable condition, that 12 was, the absence of a welder identification stamp? ( ) 13 A The DV120 and the DV2 encompass the attachments for 14 that particular hanger. 15 Q All right. But he rejected the hanger on the basis 16 of the absence of the welder identification stamps on the 17 DV120, did he not? 18 A Yes, he did, but in fact the welder stamps were on 19 the DV120. 20 Q Well, isn't that the point of Mr. Puckett's 21 inspection report, that he got to the point of identifying a i 22 rejectable condition on the DV120, documented that rejectable ( V) i
- --,-n- c- . . . . , , , . . . ---- - ,---,- ,- ,, ,, ~ a r.
190 1 condition, and therefore the component itself was rejectable 2 and required rework? 3 A He lists four of eight welds. That means he also 4 inspected the other connection. 5 Q That's the way you take it? 6 A Yes. You don't stop halfway in the inspection. You 7 complete the entire inspection. This indicates also that he 8 stopped halfway here, also. 9 Q All right. He stopped after he found a rejectable 10 condition. 11 A Which he thought was rejectable but at the time it i 12 was not rejectable because the welder stamps were, in fact, in [~ \ 13 place, b 14 Q And is there a provision in the weld inspection 15 procedure that says that you go forward and identify -- that t 16 says you complete inspection of all aspects of a component j 17 even after you have identified a rejectable condition? 18 A There is nothing in the procedures that states 19 that. That is the practice. Instead of doing half of an 20 inspection, you do the whole inspection. 21 Q And that is what you were doing when you did your 22 last qualification test, your welding requalification test, O
191 1 when you identified only part of the discrepancies? (3 k/ 2 A I did a whole inspection. I just overlooked a 3 couple items. 4 Q Do you know whether or not Mr. Puckett did a whole 5 inspection and overlooked deficiencies or whether or not he 6 simply identified the first rejectable condition in his 7 opinion and rejected the item? 8 A The thing wasn't rejectable. 9 Q That is the conclusion by the Level II. 10 A That is my conclusion as I went out and personally 11 looked at it. The stamps were there and it was not 12 rejectable. [Gl 13 Q My only point to you, Mr. Dewald, is do you know 14 whether or not Mr. Puckett took the position that the item was 15 rejectable and therefore that that was all the inspection he 16 was required to perform? 17 A I don't personally know what position he took, but 18 the direction was you inspect the whole item, not half the 19 item. . 20 MR. GUILD: We will mark this as Exhibit 9. 21 [DeWald Deposition Exhibit No. 9 22 was marked for identification.] O
192 1 MS. KEZELIS: Off the record.
. s_/
'~] 2 [Off the record.]
3 BY MR. GUILD: 4 Q Mr. DeWald, let me show you two documents. The 5 first is identified as Exhibit 10. It has a Bates number 6 of S4307. It's a test cover sheet and attached weld 7 inspection report reflecting an examination dated July 3, 1984 8 for Mr. Puckett. The second, Exhibit 11, has a cover sheet 9 signed by Mr. Robert Hunter, July 31, 1984, and attaching 10 several pages, including an inspection report dated 7/19/84 11 and signed by Mr. Puckett, and the second exhibit is numbered 12 S4271 and following pages. 13 [DeWald Deposition Exhibits No. 10 and 11 ( } 14 were marked for identification.] 15 BY MR. GUILD: 16 Q Now, these appear to be two other practical tests 17 that Mr. Puckett took. If you look at Exhibit 10 first, that 18 reflects a practical exam taken and passed on the 3rd of July, 19 1984 by Mr. Puckett; correct? 20 A It was passed but it did not meet the Rev. C 21 criteria of having rejectable items in it. 22 Q All right. He correctly inspected a component that
193 1 was acceptable. 2 A Yes, sir. 3 Q And he correctly completed the inspection report 4 reflecting that item. 5 A Yes, sir. 6 Q And the Level II who reviewed his work, Mr. Hunter, 7 noted that he scored 100 percent on that exam. 8 A Yes, sir, but it was not acceptable per the 9 procedure 4.1.3, Rev. C, where you had to have known 10 rejectable items. 11 Q Who reached that conclusion? Who reviewed it and 12 reached the conclusion that it was not an acceptable 13 examination? (} 14 A I did. 15 Q 'You did. Is that your note? 16 A Yes, it is. It doesn't meet Rev. C. 17 Q So the document came to you after Mr. Puckett 18 completed the inspection, Mr. Hunter approved, evaluated 19 the inspection and grade it 100 percent, and you reviewed it 20 at that point. 21 A Yes, sir. 22 Q And that's when you put the note on it that appears O .
. - , y -- - ,. -- .-- - -
194 f
'l on the document?
l 2 A Yes, sir. 3 Q So it was your direction that Mr. Puckett retest a 4 second time. 5 A Yes. , a i 6 Q And that second test' led to the inspection that is 7 identified as Exhibit 11, where Mr. Nemeth failed Mr. Puckett 8 for the reasons we have discussed; correct? ) 9 A I believe. It would be within the time frame, yes. I 10 Q Well, look at the dates, if you would like, to 11 confirm that. 4 12 A okay, you're right. 13 okay.
-( } Q So he took one test and got 100 percent, and l 14 you determined that it was not an effective test to Rnv. C.
15 A Right.
- 16 Q He ratested and failed by Mr. Nemeth's review and 17 your review.
~
18 A Yes, sir. 19 Q Andthbnhetestedathirdtimeandhepassed. 20 A Without rejectable items again. 21 Q All right. Now, what were the circumstances of the i 22 test that was administered the third time? O l l
195 1 A I don't know why the test was given for 2 nonrejectable iters. Mr. Puckett knew that it had to have 3 rejectable items to meet the Rev. C procedures. Without ' 4 rejectable items, it does not meet our criteria as specified 5 in 4.1.3 in Rev. C, and I could not qualify the individual 6 based on doing the inspection without finding any rejectable 7 items. 8 Q So who wrote this, as it says in the margin? 9 A I did. 10 Q That's Mr. DeWald's handwriting. 11 A Yes, sir. 12 Q And you said "No reject items, although passing," () 13 14 and you dated that 7/31/84. A Yes, sir. 15 Q Now, is it the trainee's responsibility to go out 16 and set up a test with known rejectable items in it? 17 A No, sir, it is not. It's the training department's 18 and the applicable supervisor. 19 Q So in this case, the whole name of the game is for 20 the trainee to identify rejectable items that are present in a 21 piece of work; correct? I don't mean the name of the game, 22 but the purpose of the evaluation and the examination; O V
196 1 correct? O x/ 2 A! The, purpose of the evaluation and examination is
-3 thatthetrkineedoesknowarejectableitemandatthesame 4 time can disseminate between an item iliat is fully acceptable.
-5 Q Well, i no way, shape or form could any traihee, 6 incI;uding Mr. Puckett, go out, find a component with a known 7 rejectable item in it and then test himself to that component, 8 could he?
9 'A No, sir. 10 Q Someone else hag to set the test up. 11 A He should have, and I don't know whethcrr he did or 12 not at this point iri time, contact the welding supervisor. He
/ '\ 13 was actually the supervisor. We had a lead in there at' that U
14- time. Contact that Level II lead and say, hey, I ..need' 15 a rejectable item to do my practical. Evidhntly, he d d~not 16 THL .th do this, because -he- time he done it other than -- it was all 17 acceptab).e' items. 18 Q Well, do you know whether Mr. Hunter, the Level II 19 inspector, was familiar with the Comstock qualification l 20 procedure? 21 A I'm quite sure he was familiar with the procedure. 22 Q Then do you expect Mr. Hunter understood that when s I (._,/ 1
l 197 1 he administered this test to Mr. Puckett, that the test, in G k_,) 2 order to qualify him, had to include a rejectable condition? 3 A Yes, sir, I'm sure of it. 4 Q Why did Mr. Hunter, then, the certified Level II, 5 administer another test that didn't have any rejectable 6 conditions in it? 7 A I can't answer Mr. Hunter's intentions. 8 Q All right. 9 After the third test, the 7/31/84 test where 10 Mr. Hunter documents that he got 100 percent, you determined 11 there were no rejectable items again. 12 A Through his evaluation. 13 Q Right. Did you send Mr. Puckett back to test again? [U~') 14 A Yes. I indicated he needed another test. 15 Q And how did you indicate that? 16 A The Training Department, once they got that in, they 17 looked at it and said no rejectable items, they had to have 18 another test. 19 Q Did they do that? 20 A Yes, they did, and at the time we didn't have any 21 rejectable ones other than some coupons that laid around. 22 Q Did Mr. Puckett say "I'm not going to retest," or O V
198 1 did you just not provide another opportunity for him to O2 retest? 3 A He didn't say he wasn't going to retest, no. 4 Q Did you provide another opportunity for him to 5 retest if you thought he needed to?
- 6 A I didn't specifically go out and look for one, but 7 as soon as we found one, we would have given it to him.
8 Q But you didn't by the time he terminated. 9 A No, sir. 10 Q Did you document any direction for Mr. Puckett to 11 test a fourth time? 12 A I didn't document it, no. 13 Q Was it necessary to take a fourth test for ( } 14 Mr. Puckett to be certified as a Level III quality control 15 inspector? 16 A Yes, sir. 17 Q Were there any other steps that Mr. Puckett had not 18 completed that he needed to certify as a Level III? 19 A As far as his training? 20 Q Yes, as far as training and testing. 21 A No. 22 Q So passing the practical weld test was the last step O
199 1 that Mr. Puckett had to do to qualify?
.(3 v' 2 A Yes.
3 MR. GUILD: Off the record.
-4 (Discussion off the record.]
i 5 BY MR. GUILD: 6 Q Mr. Dewald, your testimony is indicated by Edison to 7 be also on the subjects of the sources of grievances among 8 Comstock QC inspectors and Comstock management responses to 9 those grievances, the union organizing effort which took place 10 in 1984 and 1985 and its effect on management's relationships 11 with quality control inspectors, and the transfer of 12 employment responsibility for QC inspectors from Comstock to
/T 13 BESTCo in July 1985.
L/ e 14 That's a long mouthful, but I'll let you look at 15 that summary if that would help, and I would like for you to 16 address those subjects, please. Let's take them in turn. 17 I can ask you a series of direct questions, but can 18 you -- 19 A That would probably be better. I don't know exactly 20 where you are at. 21 Q Okay. It is a big subject. Let's just start at the 22 top. bv
200 1 What, in your opinion, are the sources of grievances _) k'O 2 among Comstock QC inspectors? 3 A What specific timeframe are you talking about? 4 Q I really can't tell. Just what sources of grievances 5 are you going to testify to in the proceeding? That's what 6 I'm picking up on. 7 A Well, in '83 when I got there, there was a dispute 8 over the pay scale. Some inspectors were making quite a bit 9 less than other inspectors. The pay scale was the main 10 source, I feel. Again, this is my opinion, that this is the 11 reason for the union organization, because of the variances. 12 I think the pay scale runs from $7 to approximately $13. 13 Q At the time you started in '83? (/) r-14 A Yes, sir. 15 Q For new inspectors or for inspectors based on 16 experience? 17 A This was the pay scale range when I got there.
' 18 Q Okay. For all Level II's?
19 A All Level II's. In September of '83, CECO l 20 authorized me to give them a raise. Then there was a group I 21 came down from corporate. I believe Mr. Marino was part of 22 it.
/"N V
201 1 Q From Comstock corporate. 2 A From Comstock. Mr. Gardner was part of it. 3 Q Gardner? K gL J4Lb 4 A Yes. .He's from Comstock. I think Mr. Dan eeut was 5 there. He was from Comstock. 6 MS. KEZELIS: I'm sorry. I didn't catch that name. KAHL JATS 7 THE WITNESS: 4Mn6L . 8 MS. KEZELIS: Do you know how to spell it? g.g. g _ L 49Cd) 9 THE WITNESS: I know it's not spelled-C-:-1-4.
- g. A - H - L _SCEh 10 Again, I'm just guessing at the spelling. -0 a u-1, I believe, 11 is the way he spelled it.
12 BY MR. GUILD: () 13 14 A Q And when did this happen, this meeting? This happened about the middle of October. Or 15 excuse me, the middle of September. 16 Q '83? 17 A Yes. And at that time, all the QC Department was 18' given a raise, some a little more than others and so on. This 19 ranged from the clerks all the way up to the Level II QC 20 inspector. And there was another raise, which was the yearly, 21 like a cost of living raise was given then on 4/1/84. 22 MS. KEZELIS: I'm sorry. What date was that?
- O 1
i
202 1 THE WITNESS: It's not 4/1. Excuse me. 1/1/84. s_/ 2 January. ~ 3 BY MR. GUILD: J 4 Q January 1, 1984, cost of living. t 4 5 A That was like a cost of living raise, and this was 6 an across-the-board raise to the various people. Some got-l 7 more than others. There was one didn't get any. His name was 8 Brad Robbins. He didn't get a raise due to his poor 9 attendance. I think for the year of '83 he had a total of 166 1 10 hours no pay that he had been off. And 4/1/84, the standard i 11 for a Level II inspector was then brought to $12 an hour, with F 12 a 50 cent hourly raise for each additional certification they i 13 got after the first initial one. ( 14 At the time, I wasn't totally geared up to take and 15 pull all these people in and start doing a massive training 16 effort to accommodate giving anybody a new certification 17 whenever they wanted it to get their additional 50 cents an 18 hour, and through the slowness of the process -- also at this 19 time I didn't have a training coordinator. If we had an area i 20 of high necessity, we would then program some people to go l l 21 into training there, at the same time get the first initial t 22 certification on-the new inspectors so that we could get them i O i h i
i 203 1 out in the field and doing inspections. 2 This created a lot of unrest because everybody 3 wanted to make the dollar right now and didn't want to set 4 around and wait for it. 5 Q Let me interrupt you. When did you get a training 6 coordinator? 7 A I believe Mr. Whitehead came in on, I think it was, 8 the 1st of June. 9 Q Of which year? 10 A '84. On June 25th or 26th, Mr. Whitehead was in an 11 accident which laid him up for almost a year or a little over 12 a year, and then I didn't get another training coordinator ( } 13 until, I think it was, the 15th or so of September. 14 Q Of what year? 15 A '84. 16 Q And that was Mr. Dominique? 17 A Yes, sir. 18 Q So the absence of training and the absence of the
- 19 ability to cross-certify was causing dissatisfaction among the 20 inspectors?
i 21 A Yes, sir, quite a lot. 22 Q All right. i O m -
204 m i 1 A And during this time period there was a lot of small 2 group' meetings in the corner over here or a corner over here,
.3 of which unionization talk was taking place. And during this
- 4 time also, the inspectors would make wisecracks, quick, sharp 5 response to the supervisor if they asked him a question, to
~6 see if they could goad the supervisor into exploding, and making this another issue as to we're being harassed or we're
~
7 8 being intimidated, and also to make the people that didn't 9 want to unionize to say, well, if we have a union, then the 10 supervisor cannot do this, it would be a more controlled-type 11 atmosphere. 12 Eventually this led to the unionization vote, which ( }
.13 I believe was on the 27th of November in '84.
e 14 Q And what was the union vote result, if you know?. tjo FOR. 15' A I believe it was 4+, and 30 against. ! 16 Q Thirty? f
'17 A Yes.
18 Q Ultimately there was bargaining and you reached a 19 contract with the QC inspectors? 20 A The vote wasn't ratified until, I think it was, ! 21 April. . 22 Q I didn't mean ratified. 1 1 !O f _ . . _ . - . . . . . . _ . _ _ . . . . . _ . . . . _ _ _,._.____..__..___....,__._,_,_..,._.._,_..-..,_._...m_ _ . . , _
205 ' i l 1 A It wasn't sanctioned. I'm not sure whether it was I b
\m / 2 the Labor Relations Board that has to ratify the vote or not, 3 but it wasn't ratified and become official until about April.
4 Q Of '85. 5 A Yes. 6 Q And did Comstock challenge the vote? 7 A Yes. The vote was challenged by both Comstock and 8 by Mr. Dominique. 9 Q What position did Mr. Dominique have to challenge? 10 A He was a Level II inspector. He challenged that 11 there was verbal harassment and intimidation by the 12 unionization people in trying to persuade him to go with the ( 13 union as well as the other individuals that didn't want the 14 union at the time. 15 Q These are unfair labor practice charges? 16 A Yes. 17 Q By Comstock and by Mr. Dominique? i 18 A Yes. l 19 Q And that ultimately was resolved in favor of the 20 union and against the company by the NLRB? 21 A Yes. 22 Q In April of '85? 1 i ( ud
---.n..----,,,-,.---._.,g ,..,. . , . _, -. . . - , , , , . - - , - - - - , - - , , , - - . - - , - - - - , , . ,
206 4 1 A In that timeframe. I'm not sure the exact date it i 2 was ratified. j 3 Q Ultimately, a contract was entered into. That's the 4 BESTCo relationship -- 5 A Comstock went into the negotiations and they were 6 kind of stalemated, and I'm not sure exactly why, I didn't get l 7 involved in these. During this time, there was an awful lot 8 of unrest with the inspectors. They slowed down. You could 9 obviously watch them. You could see them standing around not 10 being busy. 11 Q When you are saying "during this time," which time 12 are you referring to? a 13 A Between the time of the vote and when the w 14 negotiations were going on after the ratification. 15 Q Can you give me a day or a month? 16 A Probably from November of '84 and after April of 17 '85. 3, 18 Q Okay. Just to kind of put a timeframe in here, 19 ultimately a contract was entered into, the restructuring took 20 place involving BESTCo formally employing the inspectors. 21 That was July of '85, is that right? 22 A In July sometime. Edison had made a contract with O 4 4
207 1 BESTCo. On July 23rd, Mr. Marino came in, Mr. Paserba came in, 2 and we were instructed to lay off all the inspectors, the QC 3 clerks, the document reviewers, and the QA engineers. The 4 only people left in the Comstock organization then were the 5 two QC secretaries and the supervisors and the management 6 people. 7 Q In the Comstock QC organization. 8 A Yes. 9 Q And the QC inspectors were employed by BESTCo? 10 A They were then on the 24th, when they came in the 11' morning of the 24th, they went through the BESTCo trailer and 12 were rehired and we put them back to work. 13 ( Q And you still supervised the quality control 14 inspectors? 15 A I supervised the quality control area. We 16 supervised the inspectors as far as inspections and the 17 quality control portion. BESTCo does the hiring, the firing, 18 they take care of the personal problems, they monitor the 19 absenteeism, they do everything except for managing the 20 quality control area.
- 21 Q All right. You have functional authority over the 22 quality control work that the inspectors perform?
lO
208 1 A Yes. 2 (Off the record.] 3 BY MR. GUILD: 4 Q Has Comstock employed union labor at Braidwood in 5- other than the QC positions? 6 A The craft are union labor. 7 Q Has Comstock employed union QC inspectors at other 8 sites? 9 A I'm not sure. They may have. 10 Q All right. You're not aware of that happening? 8
- j. 11 A I'm not aware of it.
- 12 Q Do you know whether or not there are other union
() 13 14 labor on the Braidwood site, aside from the Comstock labor? A The fitters are all labor. Pullman, I believe, are j 15 labor. All the craft personnel are labor. 16 Q All right. Are there any other unionized quality 17 control inspectors on the site at Braidwood? 18 A Comstock was first. PTL was second. I think 19 Pullman is. Newberg's are because we transferred some of our r l 20 inspectors over to Newberg. 21 Q Are the other QC inspectors represented by the same i 22 local union? l
. - ~ _ _ _ . ._- _ _
209 1 A Yes, sir. 2 Q And do you know what local union that is? ' 3 A 306. 4 Q 306 of what? What international? 5 A I believe it's the Pipefitters and Plumbers 6 International out of Washington, D.C. 7 Q And it's a quality control local? 8 A It's kind of an affiliation of the pipefitter's 9 union. 10 Q Right. And the local is specifically for quality 11 control inspectors? 12 A I think their local -- and again, I'm not positive
/~ 13 U) -- but I think it's out of Omaha, Nebraska. Since I don't 14 deal with that, I don't really get involved with the union 15 business much anymore.
1 16 Q Okay. And when you say that Comstock was first and 17 the othe.rs followed, there were unionization drives among 18 quality control inspectors at these other contractors? f i 19 A Yes, sir. l 20 Q All right. And do you know whether those led to 21 reccgnition, elections and contracts? 22 A Yes, sir. l l i O f
j 210 1 Q There are now unionized QC inspectors at these other 2 contractors? 3 A Yes, sir. 4 Q All right, now that takes us up to March of 1985. 5 How did you first learn of the complaints by inspectors to -- 6 were you aware of the complaints by the Comstock QC inspectors 7 prior to the point where they went to the NRC? 8 A The total group? 9 Q No, I guess -- let me see if I can be clear. You 10 became aware that a number of Comstock inspectors went to the 11 NRC March 20th, '85? 12 A Yes, through the grapevine. ( ) 13 Q Well, you learned later more directly, did you not? 14 A After the Rick Saklak incident. 15 Q March 28th. 16 A March 28th. I learned about the incident on the 17 29th. Okay, after -- as soon as I learned about it, I wanted 18 to talk to Rick Saklak and Rick Snyder. 19 While I was doing -- or talking, you might say, to 20 Rick Snyder and so forth, I got a phone call from Mr. Shamblin 21 and said he wanted to meet with me. And I forget what time it 22 was, but just a few minutes later. And I went over, and then O
211 1 he made me aware of the second group and the initial six that im I
) 2 's-/ went over.
3 Q Did he know the names -- did he identify the names 4 of anybody that went over? 5 A No, sir. 6 MR. GUILD: Off the record. 7 [Off the record.] 8 BY MR. GUILD: 9 Q Did you subsequently learn of the specifics of the 10 inspectors complaints to the NRC? 11 A I haven't really seen any documents as to what, 12 other than after the fact. I've seen them since, but I still f') N_- 13 don't know the names. 14 Q Okay. At the time -- well, when did you first learn 15 of the details of their complaints, and how did you learn of 16 those? 17 A It was quite a bit of time afterwards that I knew 18 what the complaints were. 19 Q Well, did you get anything from Edison identifying 20 the complaints, with or without names, what the details were? 21 A No, they was just talked about until after I got 22 involved with the hearings and so forth. ( v)
212 1 Q Well, let's see. Did you ever see a listing of the 2 complaints since you became involved in the hearings? 3 A Without the names, yes. 4 Q Did you see copies of the March 29th and April 5th i 5 NRC memo with the names blanked out? 6 A It may have been. I'm not sure what the thing was. 7 Q Let me see if I can show you one. You recall 8 something with names blanked out? 9 A Yes. I've looked at so many documents, I'm not sure -) ' 10 what I did look at. 11 Q All right, here are three documents, and we'll see 12 if you've seen these before. There's an April 5th memo --
) 13 working backwards. It's an NRC memo, and it's from Weil to
-)
14 Norelius, subject, allegations re Comstock quality assurance 15 program, et cetera. And it has names blanked out in it, but 16 details -- what I'll represent to be the NRC's documentation i 17 of complaints made to it. 18 A That may have been. I seen a document with lines l 19 drawn through the various names. 4 20 Q All right. Can you look at this a moment and see if 21 that's something you've seen before? 22 (Witness reviewing document.] f O
213 1 A I think I seen this portion of it. , 2 Q Okay, you're looking at a page -- it looks like 3? 3 A Yes. 4 Q And you think you've seen that part before? 5 A Yes, sir. 6 Q All right.. Now there are two March 29th memos 7 written the same day at different times in the day 8 apparently. One is from McGregor and Schulz to Warnick and 9 Weil, and has the first -- third paragraph down says inspector 10 X. And let me ask you if you've seen that. It doesn't have 11 any names in it of inspectors. They're just identified by 12- letters. 13 (Witness reviewing document.) ( } 14 A Some of these excerpts in here are familiar. I 15 think 2 remember reading something about it. As to whether 16 l'?.'s the same particular document, I'm not sure. 17 Q All right. And let me show you the third one. And 18 it's a March 29th, '85 memo, McGregor and Schulz again to 19 Warnick and Williams. The subject, telephone conference call 20 with Commonwealth Edison, et cetera. ! 21 (Witness reviewing document.) 22 A I don't believe I've seen this one. O
214 1 Q Now can you identify the circumstances in which you 2 saw the excerpts from the other two documents? 3 A It could have been in a meeting with the lawyers. 4 Q Your best recollection is that if you saw it, it's 5 been no earlier than in preparation for these hearings? 6 A Yes. 7 Q And you don't recall seeing these in the spring of 8 '85? 9 A No, I sure don't. 10 Q Ckay. Do you know whether or not the complaints 11 that were made by Comstock inspectors to the NRC.on the 29th 12 of March, whether the substance of any of those complaints 13 have been previously made to you or to other Comstock 14 supervision? 15 A No, I don't believe. 16 Q Okay.
.17 A At that particular time the inspectors avoided me 18 like the plague, even though I had an open-door policy, that 19 ycu could come in and talk to me any time, express what you-20 wanted to. If you wanted to yell and scream, fine and dandy.
21 Q Do you know whether or not any of the complaints 22 made by the inspectors to the NRC on March 29th had previously O
l r u
- ~ 215 I
b 1 been made to Commonwealth Edison, say through the Quality ; 2 First program * ! I ! 3 A They may have. They did do some investigation.
; 4 Q You were aware later that Quality First did an 5 investigation?
4 6 A Yes, sir, because they come over and ask me i i 7 questions. They asked various other people questions. 8 Q Did they do that in April of 1985? 9 A (Pause.) 10 Q Previous testimony reflects that an investigation , 11 was conducted after the meeting with the NRC in April of 1985 12 by Quality First. 13 A I believe it was after. I know there was various [V)' ] 14 Quality First investigations. It could have been after April. l 15 Q Okay. Do you remember who talked to you about that 16 subject? 17 A No, I don't. 18 Q Was it somebody from Edison? 19 A It was one of the Quality First individuals.
- 20 Q Mr. Preston, Ray Preston?
21 A It may have been Ray Preston. I did talk to him on ? l 22 one or two occasions. And I talked to one of his other staff, i I l
216 1 which I don't recall his name. 2 Q Did you ever talk to Mr. Shamblin about the 3 complaints? 4 A He addressed complaints also. But as far as reading 5 the context, I didn't read the context. 6 Q Well, I'm just not understanding what you're 7 saying. When did you discuss the matter with Mr. Shamblin? 8 A After these people went to the NRC and I knew about 9 it, which would have been the meeting after the Snyder/Saklak 10 incident, they requested that I get all the group together. 11 And I think it was -- again, I'm not sure of the date, but I 12 think it was -- again, I'm not positive on the date, but it ( ) 13 was shortly after that he requested a meeting of all QC 14 inspectors in the conference room in the service building. 15 And there they expressed that they were going to do 16 an investigation of all the allegations, and if they had any I 17 more allegations would they please come forth. If they didn't i 18 want to tell them in the meeting, would they go over to 19 Quality First and express their allegations. 20 Q Okay. And did you have any other contact with i j 21 Mr. Shamblin about the specific concerns by the inspectors? 22 A Not on the specifics. r !O
_ . _ . _ . _ = . _ .. _ _ _ 217 1 Q Okay. How about with Mr. Quaka?
,0
' (s,) 2 A No. When the concerns were addressed, it was a 3 generality type. We got these concerns, and we're going to be 4 investigating. 5 Q Okay. So at the point when you heard that the 6 inspectors went over to the NRC the 29th of March, as far as t 7 you know that was the first time those concerns had been raised? 8-9 A Yes, sir. 10 Q I'm looking at the April 5th memo. And this is the 11 summarization -- the summary of the Comstock inspectors 12 allegations by the NRC. The first states -- and I'm going to [~') 13 paraphrase -- Comstock is asserting the quantity of r
\m) 14 inspections rather than inspection quality. !
t 15 Have you ever reviewed that concern by Comstock 16 inspectors? 17 A You mean address it to the inspector? . 18 Q No, have you ever looked into that question, whether 19 or not Comstock is asserting quantity over quality. 20 A We never did. l 21 Q That's your -- you don't think you ever did assert ' r 22 quantity over qualityu, right? l U
218 1 A I know we never did. 2 Q You know you never did. All right, did you ever 3 review that question, look into the question? 4 A We explained our status reports as to how we used 5 them, what they were used for, and they were a management tool 6 to get you an estimated completion date or an idea of when you 7 could be completed with something. And this was how I feel 8 this quota business came out. 9 There was never no quota put on an individual or any 10 group of inspectors that you have to do X number in a day. i 11 Q Okay. Who did you explain this to? 12 A The whole group of inspectors. T 13 At what time? ( Q 14 A It was during a meeting. I think -- I used to have
- 15 group meetings when the group wasn't so huge, because I really 16 don't have a big assembly group or an area. And this question 17 did come about. That's when I said -- and Mr. Seese explained
- 18 how he used these, and that they were management tools, and 19 they were not quotas being placed on anybody.
20 Q Okay. And these were documents that projected work 21 on the basis of average rates of inspection per day? 22 A As to how we established maybe an end date or an
219 1 estimated completion date on something. O (ms/ 2 Q Can you recall when you made this explanation, or 3 Mr. Seese made this explanation, approximately? 4 A I think it was shortly after this particular item 4 5 came out where we was -- the accusation was that we was 6 putting quotas on people. 7 Q So after the March 29th meeting? 8 A Yes. 9 Q Okay. Did you ever speak with the NRC on this 10 subject, Mr. Mendez, Mr. Neisler? 11 A I'm not sure. I spoke to them quite often. But I'm 12 not sure whether I spoke to them specifically on that subject. ( 13 Q Did you ever show them a status report, Neisler or 14 Mendez, or any of the other NRC people? 15 A Not I myself, I never did. They had visited ' , 16 Mr. Seese and he's the one that takes care of the statusing. 17 Q All right. Do you know whether Mr. Seese showed the 18 NRC a status report? I { 19 A I'm not sure, he may have. 2 20 Q Do you recall yourself ever discussing with the NRC 21 how you used the status report? 22 A I may have at one time or another. As to the
220
, 1 specific date, no.
O ks/ 2 Q All right. 3 MR. GUILD: Ms. Kazelis, do you know whether or not , 4 any of these status reports have been identified in discovery? 5 MS. KEZELIS: No, I do not know. I can probably J 6 make a sample one available for you. 7 MR. GUILD: That would be real helpful. 8 MS. KEZELIS: Next week. I'll try. 9 MR. GUILD: Thank you. 10 BY MR. GUILD: 1 4 11 Q Well, the second item -- I'm just going to try to 12 move through here as quickly as I can. But if I'm moving too () 13 fast, please tell me, because I want your opinion on these. 14 Rick Saklak, Comstock QC supervisor was not 15 qualified for his position. He was not certified in all the 16 inspection areas which he supervised. Was that true as of 17 April 5th, 19857 18 A I believe so, yes. , 19 Q He wasn't qualified? i 20 A He wasn't certified. I feel he was qualified to 21 supervise the people. 22 Q But he wasn't certified in a number of areas he i O
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w 221 I l' supervised?
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2 A I think there was two or three areas that he 3 supervised that he wasn't certified in. 4 Q Calibration and receipt, for example? 5 A I think he was qualified in calibrations or receipt, 6 one of the two. 7 Q Okay. Do you know what other areas he wasn't j 8 certified in that he supervised? l 9 A Offhand, I'd have to look through his cart package
.10 book.
11 Q Okay. The third item, Saklak was constantly l ? 12 intimidating / harassing the Comstock inspectors. Did you look ()/ s-13 into that question? 14 A Yes, sir. Mr. Saklak felt the same as I do. They , 15 give us eight hours a day for eight hours pay. In other l 16 words, be busy, do your work, and not stand around and shoot
- 17 the breeze. If you're busy, you're doing something, fine. If I
l 18 you're standing there shooting the breeze on generalities or k j 19 what did you do last night, that's not work. 20 Q okay. The fourth item, 93 hanger inspections i 21 containing 1100 to 1200 welds were signed off in one day by an i 22 unidentified inspector. The allegers consider this to be too i 4
222 L 1 many inspecticns for a single inspector to make in one day 2 without the qualit'y of the inspections suffering. ( 3 Did you ever look-into that question? 4 A Yes, sir. , 5 Q What did you find? t 6 A This was an inspection done, I believe, back in 1978 7 or '79 by Rick Yanketis. It was brought to my attention by 8 Dan Asmussen. 9 Q Who is the inspector now? Rick -- 10 A Yanketis. 11 Q And it was brought to your attention by whom? 12 A QC inspector Dan Asmussen. 13 Q Okay. 14 A Of which I documented a letter to Mr. Mennecke with 15 this attached to it. 16 Q With what, attached to it? < 17 A With the inspection report attached to it stating 18 Mr. Asmussen's concerns. 19 Q And what action was taken o that? 20 A Really, there was no action taken on that particular 21 item. 22 Q Was thin a grid inspection? Was this similar to the O '
223 1 --
) 2 A It was similar to what we have right here t
3 (indicating). 4 Q To the inspection reports that we've identified for 5 you? 6 A Yes, sir. 7 Q Do you know whether or not the 93 hangers, 1100 to [ 8 1200 welds were, in fact, done in one day? 9 A Just assuming -- an assumption on my part, they were 4 10 done in the same manner which we done those, only it would : 11 have been over a longer period of time. 1 g 12 Q And dated on a single day? , j IN 13 A Yes. D 14 Q Do you agree that it would have been too many { 15 inspections for a single inspector to make in one day without t 16 the quality of the inspection suffering, if they had all been 17 done on one day? If that 1100 to 1200 -- 18 A I don't feel he could have done that many. 4 ,
- 19 Q Okay. You mean, he couldn't have actually done an 20 acceptable job of inspection in one day of those number?
21 A Right. 22 Q can you identify more specifically when you sent l s 4 j
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224 1 this memo to Mr. Mennecke and when Mr. Asmussen brought'this 2 matter to you? , _j , g. 3 A I don't know'the exact month. . l 4 Q Year? -
. '. 7 5 A I'm not sure whether it,vas '84 or '85. I think it m
6 was in '85. ' 7 MR. GUILD: Ms. Keze'is, l do you know whether or not 8 the Asmussen note or Mr. DeWalf.'s memo to Mr. Mennecke has 9 been identified? - 10 MS.~KEZELIS: I don't recall ever having seen it. 11 MR. GUILD: Okay, I would request that item be 12 identified and made available fee inspection, please. () 13 14 MS. KEZELIS: 'I'm not sure -- I just don't know whether it was ever part of the pr'odu tion." s 15 BY MR. GUILD: 16 Q Did the NRC ever ask you about this' matter, '
, /'
17 Mr. DeWald?
~ . 18 A I d0n't recall if they did or not. Qua].ity First 19 investigated it.
20 Q Okay. Do you know what the results of their 21 . investigation were? - ' . , 22 A No, sir.
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225 1 Q We've reached the point where we're blanking out an 2 item here. Blank, a Comstock inspector is assigned to the 3 records vault for the sole purpose of closing nonconformance i 4 reports. Blank never goes to the field to verify the , 5 condition before closing the nonconformance reports. 6 Did you ever look into that question? 7 'A I don't know who it would be. . 8~ Q All right. Are you aware of any Comstock QA, QC 9 inspector who was assigned to the vault for that purpose? 10 A No. l 11 Q Okay. Are you aware of any QC or QA personnel who 12 closed out nonconformance reports without performing a field ( } 13 verification of the condition? 14 A No, sir. i
-15 Q Have you ever heard of an allegation or concern to 16 that effect?
17 A I heard of it, but I don't know of anybody that done 18 it. 19 Q And where did you hear of that concern?
- . 20 A This was part of one of the ones that Quality First l 21 was talking about.
22 Q All right. Do you know how that matter was 4 O
r 226 1 resolved? 2 A No , I didn't see Quality First's resolution of it. 3 Q Did they bring the matter to your attention? 4 A They talked to me on that particular one. 5 Q And did you provide them any information on the 6 matter? 7 A I didn't never have anything to provide them. I 8 didn't know who it was. 9 Q Okay. Page 2, there's a column blanked out and then 10 comments. These are apparently the NRC's documentation of 11 remarks that were made to them. 12 Rick Saklak continually violates procedures during 13 inspector certifications. ( ) Are you aware of a concern to the 14 effect of Mr. Saklak doing that? 15 A I'm not sure whether that was one of the Quality 16 First investigations or not. But I don't know -- I'm not 17 aware of any -- where Sak had violated a certification 18 requirement.
-19 Q All right. Are you aware of Quality First bringing 20 to your attention any allegation involving Saklak violating 21 procedures during inspector certifications?
22 A Offhand, I don't recall it. [
227 1 -Q Okay. The next item has the quote of Mr. Saklak 2 stating, "If beating was legal, you would be dead. You're 3 aware of Mr. Saklak using those words? 4 A Yes, sir. 5 Q That was the incident with Mr. Snyder? 6 A Yes. 7 Q And you know John Walters, who's a lead? i 8 A Yes, sir, he's one of my supervisors. 9 Q And Ken Worthington, who's a supervisor? 10 A He was a supervisor. He's now since been 11 transferred. 12 Q Where did he transfer to? 13 A D.C. Cook. d 14 Q Okay. This is a statement, again, part of it's 15 expurgated here. John Walters, so-and-so's lead, and Ken 16 Worthington, so-and-so's supervisor, told so-and-so that he 17 would lose his job if he did not hurry up and produce more 18 inspections. 19 Have you ever heard of a concern of those two , 20 gentlemen taking that action? l l 21 A I've heard of the concern, but I -- in talking with l 22 various people I could never substantiate that particular i l
228 1 allegation. 2 Q All right. Who did you talk to on the subject? 3 A John Walters himself. 4 Q And did Walters identify an inspector -- 5 A No. No, he didn't identify anybody. He said he 6 never made any such statement. 7 Q Okay. And did you talk to Worthington? 8 A I think -- I'm trying to remember. I can't remember 9 when Worthington was transferred. I don't believe I talked to 10 Worthington. 11 Q Okay. Page 3 of the April 5th memo, Saklak 12 threatened an inspector, unidentified, for not closing an 13 inspection report even though the engineering change notice 14 had not been issued for it. 15 Are you aware of a concern to that effect? 16 A No, sir. 17 Q Did you ever look into that matter? 18 A I don't believe I did that particular one. I was 19 never really given those to look into. 20 Q So you're hearing that for the first time today? 21 A Other than to look into them. If I had looked into 22 them, yes. i O
c 229 ; 1 Q Okay. And who asked you whether you looked into 2 them? 3 A- Nobody has. You're asking me today have I looked 4 into them. 5 Q Right, exactly. No one has asked you that before 6 today? 7 A No.
- 8 ., Q All right. November 5, '84, Saklak told him -- and i
9 again, the name is blanked out -- to finish an inspection even 10 though drafting errors were noted. Blank complained to 11 Comstock management about this issue but did not receive any 12 satisfaction. 13 Are.you aware of any such allegation? [ } 14 A I've heard of a couple of situations like that and
- 15 we said go ahead and finish the inspection and document it on 16 an ICR so that we can send it.through and get the correction
- 17 made.
4 18_ Q And so to the best of your recollection, complaints-19 of that -- when complaints of that sort were made, the 20 inspector was told to document the drafting errors? 21 A Sure. l 22 Q Did Quality First bring such a concern to your i O
230 i 1 attention? 2 A I don't remember if they did or not. 3 Q Blank observed a base metal reduction problem in a 4 structural weld. Blank told his lead, John Walters, and 5 Walters told blank to stay within the scope of his job and not 6 to worry about base metal reduction. Blank also told Daryl 7 Landers. Landers informed blank to keep up his production or 8 he would lose his overtime. 9 Familiar with that concern? 10 A I heard something to the effect of keep up your 11 production or you're going to lose your overtime. And this is 12 -- I give direction that I didn't want to hear such items'like () 13 this. This is not what we're here for. We're here to get the 14 job done, but we're not worried about the amount of 15 production. It's to get the inspections done in a quality 16 manner. 17 Q Okay. 18 A I don't know about the first part of it. 19 Q The base metal reduction problem in a structural 20 weld? 21 A There was one problem with an inspector with Thurman 22 Bowman, which I went out and looked at it so I could give the O
231 1 correct coordinates. And I did, and sent a letter through to 2 CECO. They sent the letter to GKN, which is Gust K. Newberg, 3 that takes care of the structural part. They, in turn, 4 answered us and said that it's their problem. And I don't 5 know what their resolution was to fix it or whatever. But 6 they accepted the responsibility for that particular thing. 7 Q Newberg did? 8 A Yes, sir. 9 Q That was a base metal reduction problem? 10 A Yes. 11 Q On something that was Newberg's work? 12 A Yes, sir. 13 MR. GUILD: Let's go off the record. 14 [ Discussion off the record.] 15 MR. GUILD: Time is late, so we're going to recess. 16 And, Mr. DeWald, it looks like we're going to have to ask you 17 to come back for a repeat engagement. 18 MS. KEZELIS: The court reporter's plane is going to 19 be leaving shortly. And, Mr. Guild, I believe you indicated l 20 you had about an hour's worth of examination left? 21 MR. GUILD: I have for Mr. DeWald, yes. i , 22 MS. KEZELIS: Okay, thank you. l i O l
i l 1 i i 232 i 1 (Whereupon, at 5:45 p.m., the taking of the , 2 deposition was adjourned, sine die.) 3
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233 1 CERTIFICATE OF DEPONENT 2 3 I, IRVIN FRANK DEWALD, do hereby certify that I have read 4 the foregoing transcript of my deposition testimony and, with 5 the exception of additions and corrections, if any, hereto, 6 find it to be a true and accurate transcription thereof. ! 7 8 J& ,) ,p p Inv i d G / 9 IRVIN-FRANK DEWALD 10 11 [.:i/~[6 12 DATE 13 *** 14 CERTIFICATE OF NOTARY PUBLIC 15 Sworn and. subscribed to before me, this the )[ 16 day of Lk , 19 . U 17 18 19
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k/ h'. hf O D 20 NOTARY "UBLIC IN AND FOR a 21 My commission expires: LV '
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234 1 CERTIFICATE OF NOTARY PUBLIC 20 2 3 I, PAMELA BRIGGLE, the officer before whom the foregoing 4 deposition was taken, do hereby certify that the witness whose 5 testimony appears in the foregoing deposition was duly sworn 6 by me; that the testimony of said witness was taken by me and 7 thereafter reduced to typewriting by me or under my direction; 8 that said deposition is a true record of the testimony given 9 by the witness; that I am neither counsel for, related to, nor 10 employed by any of the parties to the action in which this , 11 deposition was taken; and further, that I am not a relative or 12 employee of any attorney or counsel employed by the parties 13 hereto, nor financially or otherwise interested in the outcome 14 of the action. 15 4 16 T n.i/,, En,,/s 17 PAMELA BRIGGLE l 18 Notary Public in and for the 19 District of Columbia 2 c j 21 My Commission expires: May 14, 1990. 22 i { lO 1 I
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Please provide a positive, constru:tive answer as to w't.at way car. the Quality 7rc1:a:r. be it*.:::ved. S FAIR ArvD Cs9tv 6 E t m Paset o
;. ::.!o: .s::::. :u s .tz:.an 1HIS AREA E A c H m e R N i ^l G Lo r T H TH C .Su fc e v ,so t A s o
A SHoRT .SES,5 t o N on E E Y tN G S O A Su c H FOR- YH AT DA't AN D psnemo
*fo A n 't TH A T EA C H Ins 9Cc 7~c2 HA.S BEElv ISSu ED sucu l D HEL P t ovs ACTS n R E ulTIES .
Ira Fo e rn ED OF TH E. DA y ,S
- 2. ;ocren ation TH L Fottn,S 'THA T 1 HAVE TOL43C, s/v sn y ev,oetvr rnA r rnE PAR 1 s c.u t A e aa e n s Aa e. rtea ot e . rrs PE c P L E. su M o WK o TE. TH E /1 N E J E. R., H A V E To u.5 E# ~TH E S rtou te bECcNSu t 7,ED BCld F. A PAU CCbL< R E.15 $EjvT~ fG CE hs R A M
- 3. : raining 4. E T C E PE A 50 tJ A L o tv C MA N DL t- 7// a s 7fp,y, EA C H s ' I T H
_T NST E A D O F A t L. /7) A N A (s t /1E N'T CE7T I N G ' / M CO L E D , JEE'l
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. 4.
1:::hing cenLittens ~1~M C't v.'E R C TE RR e 6L E. BE FcR E TH E F
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- 5. s .S.nsp'e: f A
- G' D ' *G G TH E Ai~/n o.s P H Ett oEg,gg icn Practices v) H9 f A h5 I N T u.s OR K SHOMl 9 0E posa c_ .pg-g
'Tt4 E. t u s PEc 70 R s D o S ca ero otJ,
- 6. Working Relations TH E. Iw SPEC ro /2,,5 A A E -rd E dACr< Ocm' E c f=
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- 8. If you had one item to change right away how and what do you suggest to o ,p, y improve Lt1 gg33 S u p g g_ v ,3, , ,, , gg g g g p p ,
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CUESTIONAIPI - PLEASE PRINT
. Please provide a positive, constructive answer as to what way can the Quality y Program be improved.
- 1. Information Distribution - $ e , n,5 4, gg gjg gdg
- 2. Documentation - 74 erg g,, ,4 l'
Y4L s'ngs .
- 3. Training ~ (Jery ( o g fy,ln e, t
- 4. Workiag conditions Jo-5D O
O
- 5. Inspection Practices - g rt y W o n f C a.s c s c A#
l
- 6. Working Relations - &<}see n irts pt.de e,s O R -- W e R Mo.nq med Y he r t is a. Iof a4 Inis+ru.s+. a.n<l very /NWe ConVl dens.t
- 7. salary - senefits fer fG.s s u p ede r ik or by f // ke everya,fe e/.re.
if could b < b <t+e e, B < ns 1.s $s o.e e rgJ good. po pnbhms . p 8. If yo had one item to change right away how and what do you sug' gest to improve it? $94 4 f Y a.c.h.e d S h e t.'f- (oe Svy1 fe OM / j
-v.b' CO3844
This is an open. Ittfer te m a n. q ,. m e n.f . The f,r3+
+h.ing 1 w c o ld Te k , l o sa.y a ikc in +he pa.si h.s.s breded me a nd my hm aly pec++y g ook as far a. b ene(<{s anz Con c ,en e d, sa fary w&e 'lhis h scens/hrny +hid nchody h SJilie/ u.t 4 , bef zv iny &n;/7 are nct rea//y ye//my a6ou+
i /A The +ki ng s + hd conc < cr1 me m os 1 are ). .Inspe cicq b orn -o JF - 30in e dspeden are Cldinyihis is r>of only cv phpse.a/ sfra.in , 6v f a menM ne a.s well. % ha.d h ef4er Oa.J'e /-h 5 ffry Serie vs /y becruse e.J as jthsfec}er 1 See if 12 ore +ha.n ye v people do. TA ece are pa op/c Joo b ny fo r se .ss,one / de/p /o help fdem fiy ute o 0+ +h A e affifucle Sha.n3 es . L. E. c . m a.nry em e.nf sa.ys one fh erig a.n d -f h e feeple
~
a c e o..s s 'l-h e Sfre ef Sa y Some/hing else . lok. O c We-htl set /s !t- C a n. Ina.ke ye ople no/ frust ma.naf ernenk. .zv some/irir es (ceJs /n%< w< ha. s, a. gon +o ovr head.,vst usai}ia 7 /o 7" c " U-rhh a c~ ba.cl siteJion an/ you ea.n. h.ea.e(if oFf if yoo r zu.tl y i s a. J f or GuiYe a fca.) idsp<ehe.1 he./iaie yo u cou/J '<re feu ado A -f4eser ., fkJ a/f yo u wan/ fo clo a w,l/e pccpfe vp a nd w < ree nehuhy n1ert. + A r n P c c e.s of sneaf Yoo should Fske a long ka.ed look' a.f the cuay. yo u ha-sedle peop/e. O 00002845
1 O The .5u..nJ //em g oe 1 a./,,,3 wM. who.t h. s be at
.saiel abu+ overhae . 2 -h e nom be rs a.r < co rnn% ch ou , I,k s v> < o. e s h l d , -f h e n. Why not sket cH for mor< +% n cv w < a. k . 'i~h e re c.c < msp< ufons -h4d can gd -Mein wark chne 51 V4/J a.nd ca.n n af help m oiker a.r ea.s b e c.a. us e of carIcTa'e d s nr , al.is as :Ker a.s 5ds.
are concernscl, if ~ you pd N W^"/(cy we neecl your help con you come in fal you w:u peekbly get as m o d. kale ns sqh 7 "yo w will be hora .Gf e, al.ie , people l o e k' c} 4 kd u a. %ed a.nc it , ca.n., a. net it & ca.us e e a 7-ense s'ik}sn , %v might suf- 'r a 1. < il- kt peop/e a.re s as+ aksy h /ea.oe a.n c) a he y,fM-+4e canes wy ww., a,nd .cfor and --i,e flow cao011 %d se.f wih. CECD , h1y y ou.s u Raf good '! co wrL% tu p sf n. umber of people who left m S4 n, Shef he AsiJe Fron above i%.s your bfest threa+ +o
+Gjob us boraJe W ERE~ is M o nM .
The r <. a r <- pop)< ujo.i+kg -For a recuoy 40 go :k -the MR L . , wt if +h.ey h ve nohin.y conc.cdes +h.sf c.a.n. ca. us e troable . Tki.> c o ulcl be c 3oos job , but we ha.0< do B u wock toy S ec Ms gwa it a fry 2~ bd ;+ Co.n. sfilf be done, ba 9 ma.n o.,9 e m e nt o_s toe.4 ( o +k msp<dw.s ko v e h fry. 0 / hm k you For fa.YSy %e
+o eea.A %is , si,ysed a.coi&sel but conc <rnd .in.spechqfn'00002sas
l QUEST 23NAIRI - PLEASE PRINT O Please provide a positive, constructive answer as to what way can the Quality Program be improved.
- 1. Information Distribution - /ee ei.ay pieemei M
- f e A** 1. e afs.
% lesas <ee e /~eys Ike h a + ,In }~wo U L*' *- pr*\=\* in band c* ^ d ' * * * \ N lN ss. te fgs a clas.3 or mene o,,, +f e sul,,e} sL,,lJ be Lateg }, g, Ca r ,, a U e r-taspec4*s of Ike netelo lies or noOec44ew of S I7,d, to,,, lo c ueid fakre
- c. . Ca ..t .
*\*n $ )
- 2. Do:umentation . 4 k 13 c.kn *S aM We 5 i@ AtV" 8"' kb 2.c 4-ios er- d, rec /s, . f>r., 3 ,, .e s ,le he .elre. l e a.al co n d ci-plA ../
Adad & be Her legderen f Le vu4,,(t c rea.
- 3. Training ,Tle.ld noi be cc @.cge.d wt h pro duc.k ge- . Should fuke as
/c ne a 3 d b do3 [or O tseg, Margesftc.h'C 3kes!c/ be Me Gha nce kg t% hv Grcs3 'Yruen-. Qk.e v \d b,e opn. sted will.lgNe /eadyheq,p 6/cr
- gy"I' o 'IL W 1r#< jy).C ae, pep,te
- 4. worxing coneizions - less fired. A k M can he
,m t3 p .,s.e g+. Tre.Jyeyte Irke L u ...,1, W .c % .s e,+L % oape krs pe+
' W4o A.eg escis\ up. Ge+ a se ho ud e nem -atwe, o ver4 i.e for Fame uLe wa n.+ +o wor k. s t.
- 5. Inspection practices =
hk.C GEculd O Ot M***G Ar 9VC'ry pas be hof S k sc.me 80ne+ d r $trto,-l- L wa y . Every cer+,C,.c4 a ver cl,,gg 1, e , N. cog ve r kt co n .e.k,.,g o r. mem
- 6. Working Relations
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4- k.,,V
- 1. Salary - Benefits - Skoulol .,Me. /acrec.34, g a d a.eoisry.*12 sk..A.I be w sk,.% p,co i, g43 ,
n.7, owe, Aa.uo by cert w ci,. ,,,,# ,,,g, % j, m,,f g p,7. g,j ,g ,, jg,,j ,_, , Qg,,,,1 y Perry cor k. Illou ve"ec
- s. If u he one it*= t ch*"S* **S h * ""*Y * ""*ta"""a.it ' * "se' " *1.cA<.at i t i-l
[, na molE m ey ar~y "rv ne.oe r ,k.ap, socco?. <
I COESTIONAIRE - PLEASE PRIt Please provide a positive, constructive answer as to what way can the Quality Program be improved.
- 1. Infomation Distribution
- 2. Documentation J
S N & h { hy&at/" j f @? N # 9>& pdW ude ath &awA *madAk
- 4. Working Conditi:ns op ?
O w YFh WAVkt21,/2 oddy ang j,92 O""'"A as 5 Inspection e
- 6. Working Relations l
- 7. Salary - Benefits 8.
w w y n m ,asy D 2"' If you had one item to change right away how and shat do you gest to
. improve it?
0000?S50 b wx
~ ---
i QUESTIONAIRE - PI. EASE PRINT 1 Please provide a positive, constructive answer as to what way can the Quality Prograr. be improved.
- 1. Information Distribution }g ge7, CommwedicATies es peer. memo disTeil.wTeord SHovId bE Y. Y gg e,,;7 wt,kc N f Lb Tc, ATTP@ C.LAs4 E E - g 7;,J(s.s -Te g,u ssu 6, g f S5 '**I A Ts*( To sekth.LL s'aTo %e a as;L 3 s.;,se.t. pscg7;$ 6s. LELJ To Edl 4E YO*E'*
Nf 4 seJTk.dwc.Tich E edTe, i.s tpCcf. sus agg dg(,,.g7(y foo sgegy To AteW f # El AA81Dm
*da T m L A e. ia ev T - u s ci ig op, ,, L ,5 ...
4 0 Documentation ' Litt.L 3 cask.EsiD sn T~ A.c sw.us.A-be Asis- TC $' ell ouT f'fR. WDC d ANE
%s+ 'TC g W lit ou AemA ns'a e,a EsEms os A yE<Atss osN4L. L ett asnua.R .T F'fEmG A'
W) p C'"3 TAa TL~j ftAsesTsk, f s p e l w * , K - p*, i g .T'n est osscw ptTruT pr<ple u,Ho lp(#*p'
'6*dT'
- w A 4y'IawaWL D4 wGs d#ie Lr 41.t. c%f e. s u4pE c7oes And trop
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$"'Agt 7 g,g Nut. Leos c4' ye.g. g.c. y,py l 4. Working Conditions Q 7 " R - ( s d w a h a s , - Yo o a.a,14 su summ en. , To o u c T oou w.a Tre Tec, cme t'y - net g e,od yes t ta T;.44 - eg4 p ed s usp re Tees -desgs r, s,twa.4.l. pao pl Act *E WEiTL ( Tetfif. ec mms uTs ag.c pT plA sa', bwL L A.H 8 T) .
T p!<ft t. =g; upt.t,R eatt7 m'c us.A A ic ' pgs!Jn %gy o 4 t ti;mt a s so,c.T Tred Af o M ET' wI'If '# N '
- d6*'* I M d '
- 5. Ins.NetYokP iYes9 * ' # "f *
>oAE e,, pkAs,iir, pvTo)C{oA.L.'Tj e4d AWci G w n a 7. Tg ft S T e4 E. Zy mb.
l Oc t. Ti4E. $ so G .C . - Tusis,T og Ess,wa.J., weg.r ma aa. H P TaenT impEc.Tse.s Lille pet #c.ss =o'A.LS rnAN L TfYI'[ #8 l 4CI EdI-s j
- 6. Working Relations bvT Ts. m & /- S was.,l d Ac1 P' r^c R ALE- k a'h 8 Ts ops 4 dowAs
- 7. Salarv - Benefits '
L #'I**L'lh l'#"$ - eer e ca u L e.)A o.sfaiR % P"P E li'#"*K m $* T C ' * ' Th ' * 'T g gca uva fle. kvad Ac.k(5,- P*5 ssgems.s y,, 4m 3 s.n.'r_ 4 24 pass . r to 4 cit.
- 8. If you had one item to change right away how and what do you suggest to
'"F' "" it?
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QUESTIONAIRE - PLEASE PRINT . p Please provide a positive, constructive answer as to what way can the Quality Program be improved.
- 1. Information Distribution NO $49 4ee'e'd?"'~~d-0k
- 2. Documentation pu (*swe.s 7'- A-O1
- 3. Training / :r* * ~ * ' < l* u 72< ~ e.-
v s.. , /06 ...o' ' ra4 '*.r-*"r~ e.,,,a n . u - < or-74* r.<.er/'".e*
- e. *r- *.sx,,'.'
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4. er e',e se.* , &s ._ f u Working Conditions ne. A>e.,c. v 4'c_ ,o. e.a_ f, ,,,ys,,,, g,,,, ,,.r. ,, ff., e ,
,,4 2 4/f. 'D * ~4 L- ft *f e .* 4x.c aE ytsye e fa of ,a t on .s .e h. W < t. L (s s, . n .'.a, '~n'c /<re~'r x.a.a -//so,6 a.r.e ,
*~ 5. Inspection Practices /h<p #7 M
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- 6. norking Relations .* sJo < > l b & Fe* x st.Je
- kc - d e -*.c ~<.-
- f. d . 4'"' N'}
- 47. 's 0v s 2. H o n fxop:<,, fis.se.< .1 4.o~p /* rove A n< < .
s,0e,a c..; s a,y . , r ,per ~ r , /,a ,ps., r: sga g ,; , ~ ,y ,,,, ,,. fxasa , ,e .u
~ f.a . e r p.e s.a f * * ', e
/4 * /d a s D. 's to o o u rese f~ec< c .~ .'.v7 s m cs 7 ,, y,,<<
- 7. salary - Benefits 4,,n. s u ,< s- 7.dE 5 e. '#4> . [*e ~,,+"7 Y"' Q , , , , ,
,d',nu r f ,y.o e ,, f.ee a e's /4 *s/Me< s *$*s Nes s ,,4 o suu .a sua 7 t'd s. y -e-
,2, r a"=w see
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- 8. If you had one item to' change right away how and what do you sug t to improve it? DI,)(T*'gg >
~~
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- 1. When changes are made, they should be thought through thoroughly
- as to the future consequences.
- 2. Management should learn more about Employee relations and comunica tion.
- 3. Clerks jobs should be re-evaluated and they should be paid accordingly.
- 4. Clerks jobs should be more defined.
1 5 i s 4 i i j l l 4 l a Ie , i i } i I jD000'?S53
m
'J 4
, O'JESTIO!UiIRE - PLEASE PRINT s pT Please provide a positive, constructive answer as to what way can the Quality
[ Program be ireproved.
- 1. Information Distribution
- 2. Dorumentation
- 3. Training I T4 md Aav.*ng o ,ves man 7/ o y'" , 7%+ 3 o t" h *. g c_ e r_ t *m u3e )cith
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-f** be a doc:fGr- * $
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- 4. Working Conditions n
- 5. Inspection Practices
{ l
- 6. Norking Relations on A A),s ta f et H T wenT 6 VCa* THM Mf To n' C 7F SAj'-
'beco nt//wtuh's Hew w*"LD you ff E L & evR 6 Po r{ A m e m o c srint c e r-Tc Tin US To TAL x 70 A curnisv Atevp 4 x,vor via ant s ,9,gt,T c a s &:'
AHb WE 6er 70LD 7C Dgf 7ttC e6'Cs irt, isJ 4 vi Rf Root FAs nicn,
- 7. Salary - Benefits 00 ffA N00A /S sve'r $d I'V.M TQ M@iN AivD isu irry' 6 pin ien is W+'to pgR Heug usuosx, ggc 7 7,g.
YCu Pregaay Reat s zt uit AAY 7WE L~ ts r Raio Cv d . z ,v s r e e r m 6 11 7 HIS S /IE - 0000 ss.1 l 8. If you had one item to change right away how and what do you suggest to l] PH RArsz., fcA E vityoovt, rc AMiiv Bario 2, v> pie \ iOimprove it?A LANjQgj(On 7 nE SR/112 YVf L Ss91 Aff.Art.7HI5 wts LO 6elit) 4 ABCv7 A !!?t<c & mff E
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+,h,e Z ha ct a va cia on proii d ln ocp f 6v7 hou ta c.a asaL e,y
" s *"T' e m nedplans por i k< on s ve ek we ceee *o c6o "r
$Or>4 C L/Q C. fi o n bWn QT h om t t'eL over~ n $
t-o m ss en u ffVOi.se ca>cc'O Joe sy}ce-t i I > 200 000?S55 22 QA5 3
e 0 0 WESTICNAIPI - PLEASE Ph!';T '= , '
- s Please provide a positive, constructive answer as to what way can the Quality Frogram be improved.
- 1. :nformation Distribution 86 kl
/J/^'S
- 2. Documentation
- 3. Training
- 4. Working Conditions
- O i
j .
- 5. Inspection Practices l
l l
- 6. Working Relations l
l l 7. Salary - Benefits . l -
- 8. If you had one item to change right away how and what do you suggest to s improve it?
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't . 24 August, 1983 i g . Comstock Engineering, Inc. Braidwood Nuclear Power Plant R. R. #1, Box 83A-2 Braceville, 11. 60407 ATIN: 1. F. DeWald Mr. DeWald: Please be advised that I am tendering my resignation as a Quality Control Lead Inspector for Comstock Engineering, Inc. ef f ective 1 September,1983. I am accepting an off er which was extended last year to attend Renssalaer Polytechnic Institute in Troy, N.Y., and will begin classes on that date. This decision was based on my desire to continue in the construction industry on a management level. Based on observations and conversations with executives of this and other companies, I f eel that this goal of managerial employment and future advancement can best be achieved through the obtaining of university degrees in the areas of Mechanical Engineering and Business Management. I had originally planned to delay this move for at least another year; however, the continuing attempts at harassment in recent months have made the working environment on this site unsuitable at the present time. I apologize for giving only one week's notice of my intent, but this v' decision has only been recently reached and a longer notice period is not possible. My employment for Comstock Engineering has been generally a satisf actory and rewarding experience and I look forward to any opportunities for future employment with the Company. Very truly yours,
Y he David A. Parks, Quality Control Lead Inspector Level II cc: R. Marino, Corp. QA/QC Manager W. Cardner, Regional QA/QC Manager file O
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Comstock Engineering, Inc. Braidwood Nucl, ear Power Plant R. R. #1, Box 83A-2 Braceville. 11. 60407 ATTN: I. F. DeWald Mr. DeWald: Please be advised that I am tendering my resignation as a Quality Control Inspector for Comstock Engineering, Inc. effective 1 September, 1983. I am accepting an offer which was extended last year to attend Renssalaer Polytechnic Institute in Troy, N.Y., and will begin classes on that date. This decision was based on my desiretto continue in the construction industry on a management level. Based on observations and conversations with executives of this and other companies, I feel that this goal of O- managerial employment, and future advancement can best be achieved through the obtaining of University degrees in the areas of Mechanical Engineering and Business Management. - I apologize for giving only one week's notice of sh intent, but this
- decision has only been recently reachcd and a longer \ notice period is not possible.
My employment for Comstock Engineering has been generally a satisfactory and rewarding experience and I look forward to any opportunities for future employment with the Company. Very truly yours, b David A. Parks Quality Cchtrol Lead Inspector Level II
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cc: R. Marino, Corp. QA/QC Hanager W. Cardner, Regional QA/QC Manager file e O - mtz, QggMW
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. . ~:L%, March 4, 1986
/ )
i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of: )
)
COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-456
) 50-457 (Braidwood Nuclear Station, )
Units 1 and 2) ) INTERVENORS' NOTICE OF DEPOSITIONS Pursuant to 10 CFR S2.740(a), Intervenors Bridget Rorem, et al. hereby gives notice that they shall take the
) depositions of J. O'Connor; T. Maiman: L. DelGeorge; J. Gieseker; C. Groth; D. Shamblin; M. Gorski; 1. Dewald; R. Seltman; L. Seese and R. Saklak, who are agents or employees of Apolicant Commonwealth Edison Company The depositions shall commence on Monday, March 24, 1986, at 10:00 A.M., and shall continue thereafter until completed, at the offices of Isham, Lincoln & Beale, Three First National Plaza, Chicago, Illinois; or at such time and place as the parties may agree.
The depositions shall be taken before a certified court reporter, and shall relate to the witnesses' knowledge of the subject of quality assurance for the Braidwood Nuclear Station, the matters identified in Intervenors' Amended Quality Assurance Contention, including the Quality Control 3 W4.ld b X. N !
! 9-9-FL
x ~r
, )'~
.' .gyGl .;
,(t-/-' Inspector Harassment and Intimidation Contention, and the witnesses testimony in this proceeding.
The deponents shall bring with them all documents in their possession or subject to their control which pertain to the subj ects of the deposition. Submitted by, 1 \ l k (%k
)
Rkbert bbild One of the Attorneys for Intervenors Rorem, et al. O a Douglass W. Cassel, Jr. i Robert Guild i Timothy W. Wrip,ht, III j 109 North
Dearborn,
#1300 4- Chicago, IL 60602 (312) 641-5570 G
l O
b COMSTOC A
- j 1 P Y BR AIDWOOD NUCLEAR POWER PLANT R.R. # 1, P.O. Box 83A2
, ace #904 Bracevdle. IL 60407 Comstock Engineering,Inc. / A COMSToCr GAOup COVPANY RESUfG IRVING F. DEWALD CLASSIFICATION: Quality Control Manager Braidwood Nuclear Power Plant Braidwood, IL PERSONAL: Date of Birth: June 16, 1939 Health: Excellent Height: 5'11" Weight: 155 lbs.
Status: Married, three children Bloomsburgh High School O EDUCATION: Vocational Automotive Skagit Valley College (High School Diploma) 320 Hour Prep Program
- Bechtel Power Corporation Certified Welder Pl-A-LH/B .187 Unlimited United States Navy Quality Control Courses: QA Inspector for Hydraulic, Flight Control and Fuel Systems, Engine and Structural Components of all EA-6B Aircraft. EA-6B Structural Organization Aircraft Maintenance course. Quality Control Inspection for Hydraulic, Flight Control, Structural and Rotor Systems of UH/2/A/B Helicopter.
F8U/1 Aircraft Maintenance Course for Hydraulic and Flight Control System. United States Navy Management Training Courses: Aviation Maintenance Officers course, Phase h (Management Administration). EA-6B Maintenance Supervisors Familiarization course. Supervision and Management Training Course. Instructor Training Course, Certified Naval Instructor, jh i Ex.,tf 4-s-g ATLANTA e CHICAGO + NEW YOA + PITTSBURGH + SAN FRANCISCO
ek W. . . . . VING F. DEWALD Page 2 ' EXPERIENCE: h August 1983 Comstock Engineering, Inc.
# to Present Braidwood Nuclear Power Plant, Braidwood, IL Quality Control Manager Responsible for the i=plementation of the LKC Quality Control program by directing the inspection program, personnel assignments, planning, scheduling, certifying Quality Control inspectors for all required areas of in-spection. Certified ANSI Nh5.2.6 Level III Inspector, and qualififed auditor for ANSI Nh5.2.23.
- October 1981 L. K. Comstock Engineering Company, Inc.
to July 1983 D. C. Cook Nuclear Power Plant, Bridg=an, Michigan Quality Control Manager Responsible for the Quality Control program implementation and revisions, personnel assignments, planning, inspection, auditing, reviewing and updating records. Directing training of inspection, engineering, and craft personnel in all areas of the site Quality Control Manual. Qualified Level III Inspector per ANSI Nk5 2.6 and Auditor per ANSI Nh5 2.23. m i November 1980 E K. Comstock Engineering Comnany, Inc. ( N to October 1981 Braidwood nuclear Power Plant, Braidwood, Illinois Supervisor Quality Control Responsible for assisting the Quality Control Manager in personnel assignments, planning, inspection, auditing,
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reviewing and updating records, and maintaining the Quality Control Manual. Directed the training of inspection, ! engineering, and craft personnel in the areas of veld qualifications, structural supports, and electrical inspec-tions. During this period of time, qualified as a Level III Inspector per ANSI Nk5 2.6 and as an Auditor per ANSI Nh5.2.23. March 1979 K-Fab Inc. l November 1980 Berwick, Pennsylvania Welder Fabricator Responsible for layout, cutting, burning and velding various components in accordance with approved drawing. Performed visual veld inspections on finished configurations. ( September 1978 Bechtel Power Corocration to March 1979 Susquehanna Steam & Electric Power Generating Station Berwick, Pennsylvania Pipetitter Welder Responsible for velding piping supports to Class Q and Non Class Q structures in accordance with AWS .187 Unlimited.
f IRVING F. DEWALD Page 3 EXPERIENCE: [ June 1976 to Columbia Aircraft Services Septe=ber 1978 Bloomsburg, Pennsylvania Aircraft and Engine Overhauler Performed periodic aircraft and engine inspection / overhaul in accordance with the Civil Aeronautics Administration requirements. February 1957 United States Navy Department (Retired) to May 1976 1976 Maintenance / Material Control Supervisor (night shift) Quality Assurance inspector for hydraulics, airframes, and flight control systems. Certifying aircraft for safe flight in accordance with Naval Weapons Instruction h790.2. 1975 Maintenance / Material control Supervisor (night shift) Aircraft Division Chief Petty Officer Beach Detachment. Chief Petty Officer Quality Assurance Inspector for all squadron aircraft in areas of flight safety, maintenance procedures of all phases of maintenance safety. V 1974 Quality Assurance Representative (night shift) Maintenance Control Chief Petty Officer supervising and inspecting all phases of inspections in accordance with Naval Weapons Instruction h790.2.
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1973 Quality Assurance Representative for the NAS Cubi Point Beach Detachment (night shift) Maintenance Control Chief Petty Officer. Performing safety of flight and security in accord-ance with Naval Weapon Instruction h790.2. 1972 Instructor and Unit Instructional Supervisor of the Aviation Mechanical Hydraulics "A" Course. Observing instructors, screen course changes, council trainees with academic and personal problems. 1971 Instructor and Unit Supervisor of the Aviation Mechanical Hydraulics "A" Course. Instructing approved course of , instruction, initiate requests for changes or additions to l the course of study. l 1970 Instructor in the Aviation Mechanical Hydraulics "A" Cource instructing approved unit course of instruction. Council trainees with academic and personal problems. l l t i
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32 FIT-UP COMPONDTTS IS CORRECT. [y] O I 3.3 UNIER CUT IS WIWIN MDTDiUM REQUIR9e7TS. l ll 3 . 11 CRACKS /DISCOIITINUITIES DO lOf APPEAR IN JOD7f OR PARENT VETAL. / [__Jl 35 SURFACE POROSITY IS WIEIN MINIMUM ACCEPTABE LIMITS. . f'i2]l ll 3.6 SLAG OR ODER INCWSIONS ID NOT APPEAR Di FINISHED WELD. I v1RI 3.7 TrlOROUGH FUSION DGSTS BEIVEEN WELD METAL AND BASE METAL. Ql ll 3.8 FIL1ET SIZE / THROAT, GECMETRY OR PEOFIIE CO?EORM 'IO PROCEDURE [ d]RI q REQUIRBOTTS AND DRAVING DETAILS.
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QC DJSPECIOR S00i?bO1 0 . TITLE OR8G. OAT E REv.DATE PAGE PR EPA m E D APPROvCD REvl5EO RR 05/26/80 . ForTn 15 RAB PROCEDURE . ,, n... .
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; REQUIREGITS AND DRAWDIG DETAILS.
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3.10 V.UD AIO SURROUNDDIG SURFACES HAVE BEB1 THOROUGHLY CIEA.?ED l vil l[ OF SLAG, SPATTER, FwX, A?O OXIDIZED PADIT, ETC. . 3 11 WELDER AND ESPECTOR IDDEMCATION ARE DTDICATED BY ASSIGfED QI l[ SYMBOLS STATEED ? EAR UHE WELD JODIT. 3 12 WELD IS A RESULT OF A REPAB PER ICR, NCR # ,J/.M j l IQ RD4 ARKS: SIG: v&erL DATE J .:1v- 7/ SIG!ED /.
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i,, ' - The attached SMW and Stud Welding Inspection Checklist for the' locations listed below is being forwarded to you for your inspection of the installations. - - Wus ~$7M44.- u 3W6 .50 E - / - Jo.:cs N () - tf, /s. 7 - t 7 7 0 m e. useas (g.arl} Initial Inspection (% Reinspection ( ) f0;LHV/ 14oto I Ho P3 W E LD E.et.S , hob 3 Ros1P Ro @
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- vg' Memorandum b C. Mennecke/T. Ouaka Office: Braidwood pro w I'. DeWald Sso;ect Braidwood Welding Procram Due; S-12-34 Contract Specifications L-2790 Control No. 84-05-12,12 - . ._-
Recently, a review of the L. K. Co= stock.& Co. , Inc. welding program at the Braidwood Nuclear Power Plant was conducted to evaluate the existing program to assure co=pliance to the contract requir ements. This review was also to eva-luate the concerns identified by S & L who indicated our QC Inspectors were being over-critical and were marking discontinuities which S & L f elt were acceptable. Several meetings were held between Mr. T. Vogt, Comstock Engineering, Inc., Corporate Welding Engineer and Kr. Stu Klevens and both parties were in agreement that Comstock Procedure 4.8.3, Revision E, dated 1/30/84 was open to individual interpretation in regard to overlap, undercut, are strikes, lack of fusion, tack welds, base metal reduction and spatter. The procedure, therefore, allowed the Comstock Level II Inspector to make evaluations and interpretations which could be construed as over-inspection. , Based on the above review, the Welding Inspection Procedure 4.8.3 was revised clarifying all areas in wh'ich an Inspector could evaluate or interpret to cause en over-inspection of an item. Also discovered during the review of the Comstock Braidwood Welding Program were various ite=s pertaining to being in compliance to the contract requirements. Based on the review, the following observations and recom=endations are being for-l warded for clarification and possible resolution via change to Contract Specifica-tion 1-27.90: Iack:round Prio; to Amend =ent 30 to S & L Specification L-2790, all welding was to be l in accordance with S & L Form 1701. Paragraphs 1.2.2 and 1.2.3 of Form 1701 required all welding procedures and welding perfor=ance tests to be conducted in accordance aith AWS D1.1-75. In addition, the following S & L Standards also require welding to be in accordance with AUS D1.1: 1 l l STD-EB-115.0 Paragraph 2.7 STD-EB-7 02BB Paragraph 2.4 A=endnent 30 issued to S & L Specification L-2790 7/14/83, added welding in accordance with AUS D1.3. Although AUS Dl.3 was added. Pararra:h 1.31.19.2 does not specifically define the i:ees/compenen:s er =$:ehials i V :o be welded in acccrdance with AUS D1.3. Several :ues:1:ns were raised i lA M h6.K.A'7 53 ._ j q94 39 000CGMD
Memo to C. Mennecke/T. Quaka Page 2 N Control No. 84-05-12-12
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concerning welding in accordance with Specification L-2790, ref erence Mr. L. J. Tapella, (CICo), memo to Mr. T. A. Kosik (S & L) dated March 23, 1934 which addressed Commonwealth Edison's interpretation of the S & L/AUS Visual Weld Acceptance Criteria. Mr. T. A. Kosik responded April 4,1984 and concurred with the interpretation as stated in the March 23,1984 memo. In accordance with S & L Standard Form 1701, Paragraph 1.1.1, states in part. "All welding shall conform to the require =ents of this standard unless otherwise indicated in the Project Specification or on the design drawings". Concern 1: Several important items have been addressed via letters between Comstock, CECO and S & L concerning welding repairements and procedure requirements, but these important items have not been incorporated into S ,& L Specification L-2790. t Recommendation: Request S & L Specification L-2790 he revised to include the following to support the criteria specified in Comstock Procedure 4.8.3, Rev. T. dated 5/10/84. Ref erence S & L L-2790 Paragraph 401.18 Welding Procedures may be qualified to either ASME B & PV Code, Section IZ, or AWS D1.1 requirements. Job type materials such as unistrut and cable pan, which are classified as commercially purchased mate-rial may be used to perform qualifications using AUS D1.1 as a guideline. Qualification established using ec==ercially purchased caterials qualifies all types of joints and positiens to be used in construction provided the fi _ ler metal strength requirements are as specified in the original procedure qualificati:n test. Commercially purchased materials and structural materials
, may be grouped together under one (1) Weld Procedure Speci-fication (UPS) provided essential velding parameters re=ain the same.
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Memo to C. Mennecke/T. Quaka Page 3 () Control No. 84-05-12-12 S & L Soecification L-2790 .
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A. Undercut requirements of AWS D1.1 is waived for Specification L.-2790, and shall conform to the f ollowing requirements
,regardless of the direction of primary stress in relation to the veld undercut.
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B. Undercut equal to or less than 3/16"-in length and not- over
'1/16" in depth is acceptable provided spacing between two dis-continuities is not less than 3 inches.' -
- C. Undercut over 3/16" in length shall not exceed 1/32" in depth.
D. Undercut in cable pan and unistrut shall be 1Laited as follows: s Unistrut - .012 inch maximum Cable Pan -
.008 inch maximum E. Undercut defined in C and D shall have no length restrictions.
T. Arc strikes exceeding 1/32" in depth on material thickness up to and including 5/8" and are strikes 1/16" in depth on mate-rial thickness greater than 5/8" shall be: (} Cround to ' sound metal; Repair welded if required in accordance with applicabic welding procedure.
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C. Arc strikes on mild steel are acceptable and need not be removed provided: i They do not exceed the depth requirements stated in F above. There are no cracks. No foreign material such as slag, copper or unfused electrode is located in the area of the discon-tinuity. The length of the arc strike does not exceed four (4) inches. E. Arc strikes on all other materials, within the linits specified in paragraph F shall be ground to a smooth contour and checked visually to ensure soundness. I. The visual weld quality requirements for convexity and unspecified , , .; , welds in AWS D1.1 is waived. n .
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Memo to C. Mennecke/T. Quaka i
. Page 4 Control No. 84-05-12-12 l
These recommendations are based on the infor=ation available at the time of the review. If S & L has made exceptions similar to what is described, request these changes be incorporated into the specification. Concern 2:
. Commercially purchased job type materials have been used since the beginning of the job for performing procedure qualification tests.
The thicknesses required by AWS D1.1 to perform the procedure quali-fication test were not used. S & L Specification L-2790 does not clearly define the use of job type materials for procedure qualifi-cation test in accordance with AWS D1.1-75. NOTE:- "Many items have been installed in accordance with procedures which were qualified using job type material". The above concerns expressed by the Comstock Engineering. Inc. , Corporate Welding Engineer are being forwarded to you for review and considera-tion of possible Specification changes. Very respectfully. mv I. F. DeWald Quality Control Manager IFD/j f cc: 7. Rolan .
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