ML20195B726
| ML20195B726 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 03/31/1986 |
| From: | Shamblin D COMMONWEALTH EDISON CO. |
| To: | |
| References | |
| CON-#286-296 OL, NUDOCS 8605290514 | |
| Download: ML20195B726 (237) | |
Text
{{#Wiki_filter:r QWeo + - 1 q 1 ORIGINAL UNITED STATES OF AMERICA fw {( 2 NUCLEAR REGULATORY COMMISSION NN C% e ~;% 3 BEFORE THE ATOMIC SAFETY & LICENSING BOARD #' ' ' ' (%/ , . 4 ' , 5 ------------------x 6 In the matter of: i )
- Docket Nos. 50-456 y 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
( ) 13 51st Floor
%/
14 Chicago, Illinois 15 March 31, 1986 16 Deposition of: DANIEL L. SHAMBLIN 17 called for examination by Counsel for the Intervenors BPI, et 18 al., pursuant to notice, taken before Pamela R. 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. v i B605290514 860331 PDR ADOCK 05000456 q T PDR D$O >
gr_ - . . u n . .w m . wor.om 2 1 were present on behalf of the respective parties: 2 3 APPEARANCES: 4 For the Licensee Commonwealth Edison Company: 5 MICHAEL GILL, ESQ. 6 Isham, Lincoln & Beale 7 Three First National Plaza 8 Chicago, Illinois 60602 9 10- For the Intervenors BPI, et al.: 11 ROBERT GUILD, ESQ. 12 109 North
Dearborn,
Suite 1300 13 Chicago, Illinois 60602 14 15 16 17 18 19 20 21 22 O
3 ' 1 CONTENTS 2
- 3. Witness: Examination by: Page:
4 DANIEL L. SHAMBLIN Mr. Guild 5, 72 5 6 *** 7 EXHIBITS Page: 8 Exhibit No. 1: 6 9 Notice of Deposition dated 3/4/86 10 to Mr. Shamblin, a'mong others. 11 12 Exhibit No. 2: 8 13 Mr. Shamblin's Statement of 14 Qualifications. 15 16 Exhibit No. 3: 40 17 A memo bearing Bates Number 18 3392 dated 5/7/85. 19-20 21 22
d~ 4 1 EXHIBITS [ Continued] Page: 2 Exhibit No. 4: 134 3 Revision 0, 1 and 2 of Newberg 4 Procedure Section 31, " Erection of 5 Structural Steel." 6 7 Exhibit No. 5: 144 8 NRC 806. 9 10 Exhibit No. 6: 165 11 A letter dated 4/1/85 from 12 Paserba to Shamblin. 13 14 Group Exhibit No. 7: 169 15 Three letters, one dated 5/17/85 16 and the remaining two dated 6/6/85. 17 18 19 20 1 21 22 O 4 4
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5 l 1 1 P R O C E E D.I N G S 2 Whereupon, 3 DANIEL L. SHAMBLIN
- . 4 a witness called for examination and, having been duly sworn 5 by the notary public, was examined and testified as follows
s 6 EXAMINATION 7 BY MR. GUILD: 8 Q Mr. Shamblin, would you state your full name and
, 9 your business address for the record, please?
10 A My name is Daniel L. Shamblin. My business address ! 11 is Commonwealth Edison Company, Braidwood Nuclear Power 12 Station, Braceville, Illinois. ' 1 13 Q In what capacity are you employed by Commonwealth 14 Edison? b 15 A I'm the Project Construction Superintendent. 16 Q My name is Bob Guild and I'm counsel for the 17 Intervenors on the Quality Assurance contention. 18 Let me show you a document that's March 4th, '86, 19 notice of depositions addressed to you, among other persons. 20 Have you seen_that before? i 21 A Yes. j 22 MR. GUILD: Can I ask the reporter to mark that as l 1 O
r 6 l 1 Shamblin Deposition Exhibit 1 for identification. 2 [Shamblin Deposition Exhibit No. 1 3 was marked for identification.] 4 BY MR. GUILD: 5 Q Mr. Shamblin, the notice asks you to appear for your 6 deposition and it also requests that you bring with you 7 documents as described in the notice. Have you brought any 8 such documents with you today? 9 A Yes. 10 Q Can you identify those for the record, please? 11 MR. GILL: Mr. Guild, for the record, we have 12 instructed the witness to bring with him today only the ( ) 13 documents responsive to the request which have not been 14 previously produced in discovery here. And I tendered to you 15 immediately before the deposition, and I'll identify them on 16 the record here now, a copy of Gust K. Newberg and Associates 17 procedure number 31, involving structural steel erection. And 18 it's a multiple page document. 19 The second is a memo dated March 25, 1986. The 20 subject is non-conformance report, NCR number 806, and it's a 21 multiple page document, and it's five pages. 22 We also have brought with us today, and I did not
7 1 tender copies because of the difficult nature of making copies Y 2 of them, a series of drawings which Mr. Shamblin has reviewed 3 or will be relying upon in connection with his testimony. And 4 those are available here in the room. I won't identify them, 5 for the record, at this point. 6 BY MR. GUILD: 7 Q Mr. Shamblin, the Newberg procedure 31, to which 8 subpart of the contention is that document related? 9 A 3b. 10 Q That's the modification of beams issue? 11 A Correct.
-12 Q How about the NCR 806?
13 A ( } 3b also. 14 Q And the drawings that you've brought with you. 15 A 3b also. 16 Q You've been identified by the Applicant as a witness 17 on a number of subparts of Intervenor's Quality Assurance 18 contention. And I'd like to ask you some questions about your 19 knowledge and your testimony on those subjects. 20 I show you listed for 3b and 4 subparts 8d, e, and 21 f. Is that a correct understanding? You're to testify on 22 those sections? I i I
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i 8 1 A Yes. 2 Q Are there any subjects on which you've been 3 identified as a witness? 4 A No. 5 Q I'll show you a document that appears to be a 6 statement of your background and experience, Mr. Shamblin. It 7 was appended to Applicant's witness list, in response to 8 general interrogatories submitted by Intervenors and was 9 . purported to be your statement of qualifications. Can you 10 identify that document? 11 It's not the best copy in the world. I apologize. 12 A This is my resume, which is in my training file at 13 the Braidwood Station. ( } 14 MR. GUILD: Can I ask the reporter to mark this as 15 Exhibit 2, please? 16 [Shamblin Deposition Exhibit No. 2 17 was marked for identification.) 18 BY MR. GUILD: 19 Q Now, I notice that this document bears a signature 20 on the second page that appears to be yours, is that correct? l l 21 A Yes. 22 Q It has a date of 5-11-84. Is the resume current, as l I I O l
r 9 1 of that date? 2 A You would have to add to the resume the change in 3 title to Project Construction Superintendent. 4 Q Let me focus first on the date you signed it, the 5 May 11, '84 date. Is that a current statement of your 6 qualifications as of that date, May of '84? 7 A Correct. 8 Q Has your position or duties changed since May of 9 '84? 10 A Yes. 11 Q Could you tell me what changes need to be made to 12 update the resume? ()13 A I went from the Project Field Engineering Manager to 14 the Project Construction Superintendent at Braidwood Station. 15 Q When did you get the job of Project Construction 16 Superintendent? 17 A In or around May 1984. 18 Q What are your duties in that capacity? 19 A I am responsible for the construction of the I 20 Braidwood Nuclear Power Station. 21 Q Who do you report to, in that capacity? 22 A Michael J. Wallace, the Project Manager. I i (^N
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c. 10 1 Q And who reports to you, in that capacity? 4 2 A :: have two Assistant Construction Superintendents 3 who report directly to me and reporting -- the rest of the i 4 organization is made up of five supervisors in the structural, 5 mechanical, electrical, HVAC and administrative area. 6 Q One in each of those areas? 7 A One in each of those areas, reporting up through the 8 Assistant Construction Superintendents. And there are staffs i 9 reporting to each one of those supervisory areas. 10 Q And these are all Edison people or contract people 11 working for Edison? 12 A They are either Commonwealth Edison employees or 13 contract people working for Commonwealth Edison. ( 14 Q Who are the two Assistant Construction 't 15 Superintendents and what are their respective duties, please? 16 A Mr. Marv Lohmann. f
- 17. Q Marvin?
18 A Marvin Lohmann, L-o-h-m-a-n-n, and Mr. Gerald Groth. 19 Q How about their duties? 20 A Mr. Lohmann is responsible for the general 21 construction activities in the field, assuring that the work 22 is completed. Mr. Groth is responsible for the quality O
11 1 program aspects of the work. 2 Q Do they have titles? 3 A Assistant Construction Superintendent. 4 Q All right. 5 Do they have -- what are their formal titles -- do 6 their formal titles indicate their area of responsibility, 7 aside from Assistant Construction Superintendent? 8 A No. 9 Q Is Mr. Groth employed in the Quality Assurance 10 Department of Edison? 11 A No. 12 Q He's in the Project Construction Department? 13 A Correct. ( 14 Q And that's the department you supervise? 15 A Correct. 16 Q And the same is true for Mr. Lohmann, the Project 17 Construction Department? 18 A Yes. I 19 Q Is Mr. Groth, in effect, in charge of the corrective 20 action programs within the Project Construction Department at 21 Braidwood? l j 22 A Yes. i-l i
12 1 Q And who are the five supervisors? O- 2 A The structural area supervisor is Mr. Cliff Gray. 3 Q G-r-e-y or a-y? 4 A G-r-a-y. 5 Q Okay. 6 A The mechanical supervisor is Mr. Dick Farr. 7 Q Spell his last name? 8 A F-a-r-r. 9 Q Okay. 10 A The electrical supervisor is Mr. Carl Mennecke, 11 M-e-n-n-e-c-k-e. 12 The HVAC area is Mr. Joe Dierbeck, D-i-e-r-b-e-c-k.
; 13 And the administrative area is Mr. Ray Dillon.
( 14 Q Spell his last name? i 15 A D-i-1-1-o-n. 16 Q And to whom do the supervisors report? 17 A They report up to the Assistant Project Construction 18 Superintendents. 19 Q To one or both of them? 20 A To both. 21 Q Within their respective ares of responsibility? 22 A Correct. r i d i
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13 1 Q Who held the position of Project Construction 2 Superintendent before you took that job, in May of '847 c2oto J o 3 A Mr. Richard Corsaro. C-o-s-a-r-o. (CMai o 4 Q Where is Mr. Corsaro employed now? C r.aro 5 A Mr. Corsaro is with Commonwealth Edison in the 6 Station Construction Department. (_" o s si a 7 Q Where is Mr. Corsar'o located? 8 A He would be located in our Hillside, Illinois 9 offices. 10 Q Do you know what position he holds? 11 A He is the Construction Manager for all fossil 12 stations. 13 Q In the Edison system? [ 14 A Correct. 15 Q Are you building any fossil stations? 16 A At the present time we are building no new fossil _ 17 stations. We have ongoing modification and retrofit-type work 18 underway at all our fossil stations. 19 Q Would you describe the circumstances under which you 20' took the job of Project Construction Superintendent? 21 A I was approached by Mike Wallace in or around May of 22 1984 and asked if I would like to become the Project 1 L _ _ _ _ _ . . _ __
r-14 1 Construction Superintendent at Braidwood. I had previous 2 experience as the Project Construction Superintendent at 3 LaSalle County Station. And I accepted the position. 4 Q Okay. What did Mr. Wallace say to you about your 5 duties? 6 A He said that my duties would be similar to the 7 duties I had performed at LaSalle County Station. I would be 8 responsible for completing the construction work at Braidwood. 9 Q What did Mr. Wallace say, if anything, about Cosa/ O 10 Mr. Coys6ro in the capacity of Project Construction 11 Superintendent? 12 A Mr. Corsaro was going to be moving up to a position ~ [~')
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13 of Projects Construction Manager, with reporting to 14 Mr. Maiman, I think it was, in a functional role over 15 construction at Braidwood and Byron stations. 16 Q So he was being promoted, Mr. Corsaro? 17 A That's correct. t 18 Q And did he hold that position for a period of time? 19 A Yes, he did. e 20 Q Has someone else taken that job? , 21 A No. 22 Q Who's responsible for those duties, then, the duties O
7.- l 15 1 that Mr. Corsaro undertook? I s_ 2 A The duties have been phased out. {$O3CrJO l j-3 Q Do you know when Mr. Corsaro moved to the position j
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4 he' holds now? i 5 A I think it was in the late summer or early fall 6 1984. 7 Q At the time you became Project Construction 8 Superintendent, you appear to have been holding two positions i 9 at Braidwood at the time. I show, looking again at Exhibit 2, 10 the indication, as of the date of that resume, May 11, '84, GdL 11 Project ,fuer' Engineering Manager, Braidwood Station from April 12 of '83 to the present. And BCAP Task Force Manager, Braidwood 13 ( } Station, March 884 to present. 14 Were you holding those two jobs at that time? 15 A That's correct. 16 Q Were you located at Braidwood at the time? 17 A Yes. 18 Q Did you give up the two positions that you held when 19 you became Project Construction Superintendent? 20 A Yes. , _ 21 htbl Q And who took on the first job, Project Judl , 22 Engineering Manager?
16 Yo.WL 1 A Mr. Warren B4 hie,# B-a-h-1-e.
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\u >j 2 Q How about the BCAP Program Task Force Manager?
JNtw 3 A Mr. Kino,Kaushal. 4 Q Did anyone hold the position of BCAP Task Force 5 Manager before you? 6 A No. 7 Q Was there, in fact, Braidwood Construction 8 Assessment Program at the time you were appointed the position 9 of BCAP Task Force Manager? 10 A I was requested, at the time I was appointed to 11 that position, to take the lead in developing the Braidwood 12 Construction Assessment Program. ( ) 13 Q Was it in development stage when you left the 14 position and Mr. Kaushal took over? 15 A Yes. 16 Q What had Mr. Kaushal -- what was his position at the 17 point where he became BCAP Task Force Manager? i 18 A Mr. Kaushal was a staff assistant to the Projects ( 19 Engineering Manager and he had been specifically assigned, for 20 the previous few months, to work on the Task Force developing 21 the BCAP program. 22 Q Do you know when he received that assignment? O
17 1 A I think it was in and about March, 1984. 2 Q The same time you did? 3 A Correct. 4 Q Did Mr. Kaushal work for you in that capacity? 5 A He worked as a member of the task force. His 6 specific-reporting line was to the Projects Engineering 7 Manager. 8 Q And who was that? 9 A Mr. Brent Shelton, S-h-e-1-t-o-n. 10 Q And who did Mr. Shelton report to? 11 A He reported directly to the Manager of Projects. At 12 that point in time it was Mr. Tom Maiman. 13
'( Q Mr. Maiman still holds that position?
14 A Yes. 15 Q What responsibility, if any, did you retain for the 16 BCAP program, when you became Project Construction 17 Superintendent? i
- 18 A None.
19 Q Were you a member of the BCAP Task Force, as the 20 Project Construction Superintendent? 21 A No. 22 Q In what manner then, if at all, Mr. Shamblin, did O r
18
- 1. your work interface with the Braidwood Construction Assessment 2 Program?
3 A The Task Force would submit requests for information 4 or requests for services, such as scaffolding, crane 5 operators, to the Project Construction Department and we would 6 provide the document requests or provide the service to the 7 BCAP Task Force, such as build scaffolding for them or provide 8 crane operators for equipment. 9 And then, beyond that, we would process observations 10 within the Project Construction Department, as outlined in the 11 program document. 12 Q Did you participate any further, after you became
, 13 Project Construction Superintendent, in the development of the 14 BCAP program?
15 A No. 16 Q Did you participate by way of review and comment on l 17 BCAP program proposals when they were in development? 18 A While I was a BCAP director I was developing the 19 proposals. After I was Project Construction Superintendent, I ' 20 may have commented on the document from the standpoint of i 21 logistics for providing services and information. 22 Q When you say the document, are you referring to the i O
19 1 BCAP program document? ps k) ss 2 A Yes. 3 Q Did you participate in a review and comment capacity 4 on BCAP program procedures? 5 A We commented on the -- specifically commented on the 6 BCAP program procedure, which dealt with requests for 7 information and services, to ensure that we had a smooth 8 interface with the BCAP Task Force. 9 Q Can you recall what procedure that is? 10 A I don't recall the procedure number. 11 Q Okay. 12 A Did you participate in review and comment on the 13 observation processing procedure, BCAP'06? 14 A I saw the BCAP 06 procedure after it had been
'15 written and sent through for signature by the Quality
, 16 Assurance Department and the Project Manager. I saw it at j 17 that point in time and read it and, if there was anything that l 18 would not create a smooth interface between the BCAP Task i 19 Force and the Project Construction Project, as far as 20 logistics, as far as paperwork flow, I would have inputed to i 21 the BCAP Task Force that kind of information. 22 Q Do you recall doing so, with regard to the O
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20 1 1 observation processing procedure? 2 A No, I don't think we had any comments on it. 3 Q Were you in the approval chain for BCAP procedures? 4 A. No, I wasn't. 5 Q Were you in the review chain for processing of BCAP 6 observations? 7 A I don't really understand your question, can you try 8 to -- 9 Q Yes. Under BCAP 06, in the implementation of BCAP 10 06, the observation processing procedure -- that's a 11 paraphrase of the title, I don't have the document in front of 12 me -- were you, as Project Construction Superintendent, or () 13 14 your delegate in the processing flow or chain for observations that were generated? 15 A We received the observations after they had been 16 processed through the BCAP Task Force and issued as valid 17 observations. They were sent to us, to the Project l 18 Construction Department, for incorporation on a Commonwealth ! 19 Edison Company non-conformance report. 20 Q So you only received the observations, if I'm 21 understanding your last answer correctly, after they had been l 22 identified as discrepancies? l l ; O 4,..,y..~.y- - v -v,v-v - 5e e-=------+ " - - - ' ' - ' ' - ' - - - ~ ' - " ' - ~ - ~ - ' - ' " ' ' * - ' ' ' ~ ' ' ' ~ ' ' ^- - -
m _ _ 21 1 A Correct.
,2 Q And was that after Sargent & Lundy had reviewed the 3 observations for validity?
4 A It was my understanding that we received the 5 observations in parallel.with Sargent & Lundy receiving them. 6 Q At the same time? 7 A Essentially, yes. (. 8 Q Did you make comment or provide input on the 9' question of validity of BCAP observations?:
' f 10 A If there was adclitional informati~on that was needed 11 to be provided to the BCAP Task Force which would bear on the 12 validity of the observation, we would subsequently provide
'13 d d d t~
that information to the BCAP Task Force for their validatib1T 14 Oh
,on the validity or invalidity of the observation.
15 Q Did your department ever provide comment on the 16 validity of BCAP observations that were transmitted to you? 17 A' - If we felt that the information that was provided to 18 the- BCAP Task Force, 4t .cr ;he observation was issued to us, 19 , beared on,the validity or the observation, we would request 20 that they review the validity of the observation. 21 Q And what form would such a request take, 22 Mr. Shamblin? I i l l 4
22 1 A Generally, it would be in the form of a 2 correspondence between myself and Mr. Kaushal, at which time 3 we would provide our basis for questioning the validity and, 4 also, any further documentation to the BCAP Task Force for 5 their evaluation. 6 Q Would those be controlled documents? By those, I 7 mean the correspondence in which Project Construction 8 commented or recommended with respect to the validity of an 9 observation? 10 A They would be controlled, yes. 11 Q In the form of a memo? 12 A In the form of a letter. () 13 Q How many people, total, do you supervise in your 14 capacity as Project Construction Superintendent? 15 A My department is approximately 60 people. 16 Q Are any of the persons that you identified, the i 17 assistant superintendents and supervisors, are any of them 18 contract personnel? 19 A No. l 20 Q All employed by Commonwealth Edison Company 21 directly? 22 A Yes. I
FE 23 ,. 1 Q Are any of the 60 persons in the Project 2 Construction Department contract personnel? 3 A Yes. 4 Q Can you identify them by position? 5 A They would generally be what I would call field 6 engineers, construction field engineers, or construction 7 supervisors. 8 Q And as contractor people, work in the area of 9 quality programs, areas under Mr. Groth's supervision? 10 A Some of them do. 11 Q Can you identify them by position? 12 A In the mechanical area, Mr. David Boone, that's ( ) 13 B-o-o-n-e; Mr. Dick Schofield, S-c-h-o-f-i-e-1-d; Mr. Larry 14 Strope, S-t-r-o-p-e; Mr. Ralph Vanderhyden, 15 V-a-n-d-e-r-h-y-d-e-n. 16 In the HVAC area, Mr. Ken Croft. In the electrical area, 17 Mr. Bud Schryer, S-c-h-r-y-e-r; Mr. Mike Kopp; Mr. Dan 18 Vandergrift, V-a-n-d-e-r-g-r-i-f-t; and Mr. John Wozniak, 19 W-o-2-n-i-a-k. 3 20 Q Okay. 21 A Without looking at my organizational chart, I think 22 I've covered the people. O
4 l 24 1 Q Start backwards. In the electrical area, by whom s_ / 2 are -- let's start with the positions. What's Mr. Schryer's 3 position? 4 A He would be an electrical field engineer. 5 Q And by whom is he employed? 6 A Daniel Construction Company. 7 Q Mr. Kopp? 8 A Electrical field engineer. 9 Q Employed by? 10 A Science Applications, Incorporated. 11 Q And who are they? 12 A They are a firm out of the east coast, which does a L 13 lot of work in the nuclear field and defense area. 14 Q What is Mr. Kopp's duties? 15 A He works in the electrical quality programs area, 16 specifically working with L.K. Comstock. 17 Q Does he have responsibility for any particular 18 quality program? 19 A I think he is specifically charged with the I 20 L.K. Comstock document review program. 21 Q How about Mr. Vandergrift? What's his position? 22 A He would be an electrical field engineer. . O
25 1 Q By whom is he employed? O' 2 A Daniel Construction. 3 Q And is he responsible for a particular quality 4 program? 5 A No. 6 Q Mr. Wozniak? 7 A He, again, is an electrical field engineer. 8 Q By whom is he employed? 9 A Daniel Construction. 10 Q Does he have a particular area of responsibility? 11 A No. 12 Q Mr. Boone's been identified previously. 13 How about Mr. Schofield? ( ) 14 A He is employed by Daniel Construction Company. l 15 Q In what capacity? 16 A He is a mechanical field engineer with us. 17 Q Does he have a responsibility for a particular l 18 corrective action program? 19 A T h e s e c t i o n u, corrective action program and 20 processing of the Phillips-Getschow non-conformance reports. 21 Q Is Mr. Schofield responsible for a review of past 22 Phillips-Getschow NCRs? ' l lO
26 1 A No. 2 Q Do you know who had responsibility for that program? 3 A Mr. Boone. 4 Q Mr. Schofield review processing of Phillips-Getschow 5 NCRs that are current? 6 A Correct. 7 Q How about Mr. Strope? 8 A He is specifically responsible for preventative 9 maintenance program in the construction area. 10 Q Equipment maintenance? 11 A Yes. It would be our PM program under the auspices 12 of project procedure PCD-14. f i 13 Q Does Mr. Strope have responsibility for implementing J 14 corrective actions with respect to internal cleanliness of 15 mechanical equipment? 16 A No. i 17 Q Do you know who -- does anyone, in particular, have 18 responsibility for such a program? 19 A No, it would come under Mr. Jerry Groth. 20 Q What's the scope of PCD-14? 21 A PCD-14 is our ongoing preventative maintenance 22 procedure, which is the umbrella procedure which all N i
I i 27 1 contractors then have developed their preventative maintenance
.Q \/ -2 procedure for meeting the preventative maintenance 3 requirements for equipment on an ongoing basis.
4 Q By whom is Mr. Strope employed? I 5 A Daniel Construction. 6 Q How about Mr. Vanderhyden? 7 A He is employed by Pittsburgh Testing Laboratory and 8 his specific responsibilities are limited to performing 9 surveillances of the preventative maintenance activities in 10 -the field.
- 11 Q Mr. Croft in the HVAC area.
12 A He's employed by Daniel Construction. He worked on ( ) 13 some of the HVAC corrective action programs. 14 Q Looking at your resume, in 1978, your resume 15 reflects your working as a staff assistant to Vice President 16 Lee. What was Mr. Lee's area of work? i 17 A At that point in time, Mr. Lee had a responsibility 18 for the generating station operations and construction 19 activities. , 20 Q New construction? 21 A New construction activities; yes. 22 Q Including Braidwood? O I I.-..._. __ . . _ _ - . _ _ _ . . _ _ . , . , . - . , . . _ , . _ _ . . . . _ . . _ .
r 1 28 1 A Yes. O
'N_s/ 2 Q Let's turn to the subparts of the Contention, j 3 I Mr. Shamblin, for which you have been identified as a <
4 prospective witness. I would like to ask you some questions 5 with respect to subcontentions 8.d, e, and f, first. 6 What is the scope of your testimony going to be on 7 those subparts? 8 A What do you mean by " scope?" , 9 Q What subjects are you expected to testify on. Are 10 others anticipated to speak to certain portions of the 11 testimony on those subcontentions? 12 A As it stands right now, I think I am the only one 13 who is testifying on 8.d, e, and f. ( } 14 Q Your scope covers the waterfront? 15 A Sure.
- 16 Q Do you have knowledge of the identification of the 17 items of non-compliance in subcontention 8.d, e, and f?
18 A Yes. 19 Q What is the basis for that knowledge? 20 A Personal knowledge plus reading the inspection 21 report. 22 Q Those items of aon-compliance were identified in
29 I l' Inspection Report 85-08, published April 18, 1985; is that O2 correct? 3 A Can I see the document? 4 Q Sure. 5 A (Perusing document.) 6 Q It is page-three. The Notice of Violation precedes 7 it. 8 A Yes. 9 Q In what capacity were you employed at the time of 10 that inspection? The inspection was conducted, according to 11 the cover page, February 14th through March 27, 1985. i 12 A~ I was the Project Construction Superintendent at () 13 Braidwood. l 14 Q Did you attend the exit meeting with the NRC on this ! 15 inspection? I 16 A Can I see the document? I 17 Q Sure. 18 A (Perusing document.) My name is not listed here. I f 19 generally attend most exit meetings with the NRC. Whether I 20 attended this particular one, I don't remember. ! 21 Q Did you meet with the gentlemen who performed this 22 inspection? Their names appear from the cover page to be O 1 l
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-. q 30 1 D. L. Williams, A. Dunlop, Jr., M. J. Farber, and M. A. Ring. 3 T(s l 2 A I have had a lot of interface with Mr. Farber over 3 the last year. i 4 Q Do you recall meeting with Mr. Farber on the subject 1 5 of subcontentions 8.d, e, and f? 6 A I've had conversations with him regarding the issues j 7 in 8.d, e and f in the last year. 8 Q can ysu recall when you first spoke with Mr. Farber 9 on those subjects? 10 A Probably some time last Fall. 11 Q Fall of 19857 12 A Fall of 1985; yes. ( ) 13 Q Did you speak with Mr. Farber either during the
- 14 course of the inspection that is documented in 85-08 or prior 15 to the publication of the inspection report on April 18, 1985?
l 16- A I don't believe-I spoke with Mr. Farber in or around 17 March or April, 1985. 18 Q How about the other gentlemen who are indicated as 19 participating for the NRC in this inspection? Williams, 20 Dunlop and Ring. 21 A I remember being in a meeting with Messrs. Ring, 22 Dunlop and Williams, in or around February / March, 1985. O 1 i
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31 1 Q You don't recall Mr. Farber being present? 2 A No; I don't. 3 Q Was this meeting during the course of their j 4 inspection that led to 85-08?
-5 A I believe it was. I believe the subject of the
, 6 meeting was the ECCS full-flow test, which is the subject of a 7 lot of that inspection report. 8 Q A general subject of 85-08, the inspection activity, 9 was pre-operational testing; was it not? i 10 A Yes. 11 Q The items 8.d, e, and f that relate essentially to 12 the subject of internal cleanliness or cleanliness, I~') 13 housekeeping, those items of non-compliance were identified
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14 during the course of the pre-operational testing inspection?
, 15 A Yes.
16 Q Do you know what areas of expertise the NRC 17 inspectors have who are identified as having participated in 18 85-087 19 A I believe Messrs. Ring, Dunlop and Williams' area of 20 expertise is in the area of pre-operational testing. I've had 21 contact with all three individuals in the past at the LaSalle 22 County station. O 1 o
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32 l 1 Q Do they work in NRC Region III? ' O2 A Yes. 3 Q The inspection report in question shows an approval i 4 bb by L. A. Rpyds, who is identified as the Chief of the Test 5 Program Section. Is that the section that has responsibility 6 for pre-operational testing inspections? 7 A To the best of my knowledge; yes. 8 Q Did that section perform inspections at the LaSalle 9 County station? l 10 A Yes. 11 Q On pre-operational testing? 12 A Yes. ( ) 13 Q How did the subject that is reflected in items 8.d, 14 e, and f -- I will just call that cleanliness -- first come to 15 your attenticn? 16 A I remember my Housekeeping Coordinator telling me 17 about an incident, of the NRC identifying some inadequate 18 housekeeping in the auxiliary building, that he had the area 19 cleaned up and he was issuing a memorandum to the Gust 20 K. Newberg Construction Company instructing them not to let 21 this happen again and to use this experience with their 22 housekeeping crews as a learning experience. t O
r-33 1- Q Who was your Housekeeping Coordinator?
-l
(. 2 A An individual by the name of Phillip Hoffman. 3 Q When did he bring this matter to your attention? 4 A I think around March of 1985. 5 Q The NRC Inspection Report 85-08 at page three, under 6 this subject, begins as follows, "On March 15, 1985, the 7 inspectors toured the Unit 1A positive displacement charging 8 pump room." Is that the location in which the NRC identified 9 the matter brought to your attention? 10 A Can I see it? 11 Q Sure. 12 A [ Perusing document.] ' ( } 13 Q Look at that paragraph and the following paragraph. 14 A Item one there has to do with the location of the 15 debris, where my Housekeeping Coordinator brought to my 16 attention that he was issuing the memorandum. 17 Q Did you observe the condition in the positive 18 displacement charging pump room? 19 A No. 20 Q Did your Housekeeping Coordinator, Mr. Hoffman, or 21 anyone else, bring that condition to your attention? 22 A He brought it to my attention when he informed me l
q l 34 1 the NRC had a concern about the condition in the room, that he 7-~ k/ m 2 had taken action to have it cleaned up and told me about the 3 memorandum he was issuing to the Gust K. Newberg Company. 4 Q Did Mr. Hoffman describe the condition he observed? 5 A I don't really recall any description of it. 6 Q The statement in the inspection report at page three 7 under item B.1 says "An accumulation of plastic sheeting, 8 empty cans, rags and wood scaffolding was in the room." 9 Is that an accurate description of the condition at 1 10 the time? 11 MR. GILL: Objection; foundation. Go ahead. 12 THE WITNESS: If the inspection report states that, 13 I have no knowledge to the contrary. fJ) 14 BY MR. GUILD: 15 Q Do you know what work activities were underway at 16 the time in that pump room? 17 A I don't know the specific work activities. 18 Q Do you know if there were any ongoing work 19 activities at the time? 20 A I'm sure there were; mechanical, electrical and HVAC 21 activities and possibly structural activities ongoing in that 22 area of the building at that point in time.
I 35 l l 1 Q Can you describe the location? Where is it? How ' 2 big a room is it? What is there? 3 A The positive displacement charging pump room is 4 approximately 20 feet wide, maybe 30 feet long by 30 feet 5 high. 6 Q What is located in that room? 7 A The Unit 1A positive displacement charging pump. 8 Q Essentially that piece of equipment and whatever 9 associated support equipment is required for its operation? 10 A There is a wide variety of support equipment 11 provided for its operation. A lot of it wouldn't be located 12 in that room. 13 ( Q Are there any other pieces of equipment located in 14 that room? , 15 A Not to my knowledge. 16 Q What contractors had responsibility for work in that 17 room? 18 MR. GILL: At the time this was discovered or at any 19 time? 20 THE WITNESS: At any time, there would have been 21 Gust K. Newberg, Phillips 8 b ) ; U/ /;, , by 'h > .Q, 22 L 'h.t-V\ !L:U-lO 4 l
, _ . . . . ~ . _ _ . _ - -
r.... ._ . _ , . . , _ . . - _ _ _ _ _ _ , _ _ _ , , . . , , , _ _ _ . . . _ . , . . _ _ _ _ , . . . , . _ -
36 1 BY MR GUILD: 2 Q As you go, tell me what general work they were 3 doing. 4 A They would have been responsible for the concrete 5 structure work, pouring the concrete to build the room. 6 Phillips-Getschow would have been responsible for setting of 7 the equipment, the piping of the equipment, and the support of 8 that piping and the instrumentation. L. K. Comstock would 9 have been responsible for the electrical work necessary to 10 power that equipment in that room. Pullman Sheet Metal would 11 have been responsible for any necessary HVAC work in the 12 room. Midway Industrial Corporation would have been ( ) 13 responsible for any painting work that would have to go on in 14 the room. Transco would have been responsible for any 15 penetration / ceiling in the room. I think I have covered the 16 waterfront there. 17 Q You stated earlier that Mr. Hoffman wrote a memo to 18 Newberg on the subject of cleanliness / housekeeping, as a 19 result of this incident. 20 A Correct. 21 Q Why did he pick Newberg? 22 A Newberg had responsibility for general housekeeping O
37 1 throughout the plant. 2 Q They picked up after themselves and others as well? 3 A Each craft or contractor is responsible for first 4 line picking up after themselves and then Newberg has 5 responsibility for themselves and the general housekeeping, 6 sweeping the floors, removing excess debris. They also have 7 responsibility for all, scaffolding on the job site. 8 Q Looking at the inspection report, wood scaffolding 9 is identified as one of the areas. Newberg would be 10 responsible for placing and removing the scaffolding? 11 A That is correct. 12 Q How about plastic sheeting? Who, if anyone, would 13 be responsible for placing and removing plastic sheeting? 14 A It depends on who brought it in the room in the 15 first place. 16 Q It could have been any of the contractors? - 17 A That's correct. 18 Q Did Newberg have responsibility for removing it if I 19 it is n o t appropriately in the room? 20 A Yes.
, 21 Q If it is trash?
22 A If it is trash, their clean-up crews would remove O w q w,- ,-i-w --,_---,---r-w- w. g -ew-m -- --,--e-..m- w-e - e=. -v--- - - - + --,,--.---=,-e+i-
38 1 it. ( 2 Q How about empty cans and rags? Who would be 3 responsible for using empty cans and rags and removing them? 4 A The Newberg clean-up crews would remove any cans 5 that would be in the room. I assume it would be a pop can 6 that was in the room. Rags, they would be the responsibility 7 of the Newberg clean-up crews to remove those also. 8 Q Have you ever heard of beer cans being found in the 9 plant? 10 A Yes. 11 Q Were these beer cans? 12 A I don't believe they were. ( 13 Q Are people allowed to drink beer and leave beer cans 14 around the job site? 15 A Absolutely not. 16 Q occasionally, people do drink beer on the job? 17 A We have caught people on the job site for violating 18 our drug and alcohol policy and have terminated their 19 employment. 20 Q Occasionally you find empty beer cans around? 21 A That's correct. l 22 Q Sometimes you find out who put them and I guess I O r n--.,-. . - . . - . - - - , , , . , - , .._-.....-,.,,,.,.-__,..,.n--- -
-aw. e.--,-~...-.,,.,--_,.e,,,n,--,,..,----.,e,,-.,--v,--,-. n-..,,.---.n., - , --
- _ 39 4
1 sometimes, you don't. O2 A That's correct. 3 Q Is it your recollection that Mr. Hoffman brought 4 this matter to your attention on or shortly after the March 5 15th date on which the matter was identified by NRC? 6 A I don't really recall the specific date that he 7 brought this thing to my attention. It was in and around the
; 8 date dated in the inspection report. He had brought the 9 concern to me that the NRC had this concern regarding our 10 housekeeping program and using that as an example of 11 inadequate housekeeping, and he was taking corrective actions.
12 Q The NRC's inspection report, same reference, goes on ! 13 to state the next two, on March 21, 1985, found the room in ( ) 4 14 the same condition. Why hadn't the failure to maintain proper
- 15 cleanliness been corrected by that time?
l 16 A I believe the housekeeping crews probably hadn't 17 gotten to that area. i 18 Q Do you know whether or not Mr. Hoffman took his 19 action and reported it to you between the 15th and the 21st?
- 20 A I don't know. I think there is a memo issued by 4
21 Mr. Hoffman. We could check the date on that memo. 22 Q Do you know whether that memo nas been previously l 1 I
40 1 identified under discovery? O
\s / 2 A I believe it has.
3 Q With respect to 8.f on the reference list provided 4 4 by Applicants in discovery, P. G. Hoffman letter to D. Craven, 5 dated May 7, 1985. Would that be the memo? 6 A Yes. 7 MR. GUILD: Let me take a moment to pull it out. 8 (Pause.] 9 BY MR. GUILD: 10 Q Mr. Shamblin, the document has been identified that 11 bears the Bates number 3392. It is dated May 7, 1985. It is 12 Hoffman to Newberg Company. Is that the memo you made 13 ( reference to? 14 A (Perusing document.] Yes. 15 MR. GUILD: Would you please mark this as the next 16 deposition exhibit? 17 (Shamblin Deposition Exhibit No. 3
- 18 was marked for identification.)
19 BY MR. GUILD: i 20 Q The memo in question, Exhibit No. 3, appears to 21 quote directly from the NRC's inspection report, 85-08; does , 22 it not? O
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~
41 1 A Yes. 2 Q Do you know.whether any corrective action was taken 3 at the time when the cleanliness discrepancies in the pump 4 room were identified initially, March 15, 1985? 5 A Can I see the inspection report, please? 6 Q Sure. 7 A (Perusing document.) Not to my knowledge. 8 Q Do you know whether or not the cleanliness 9 discrepancies were brought to the attention of project 10 personnel at the point when they were initially identified, on 11 March 15th? 12 A Not to my knowledge. [ ) 13 Q Do you know whether generally the NRC inspectors are 14 accompanied by representatives of the Licensee during their 15 tour? 16 A Generally they are not. 17 Q It is possible that the NRC inspectors identified 18 initially the cleanliness discrepancies and they weren't 19 brought to anyone's attention at that time? 20 A That may be a possibility. 21 Q How about on the subsequent tour that is indicated 22 on page three of the inspection report, March 21, 1985, at the C
42 1 point where the condition was found again, same pump room. Do 2 you know whether or not the discrepancy was brought to 3 the Licensee's personnel's attention at that time? 4 A I don't know if it was. 5 Q Do you know whether any corrective action was taken 6 at that time? 7 A I don't have any personal knowledge that any 8 corrective action was taken at that time. 9 Q Do you know whether corrective action had been taken 10 at the time of Mr. Hoffman's May 7, 1985 memo? 11 A I know that corrective action had already been taken 12 prior to the date of that meno. [ } 13 Q When was that action taken? 14 A Some time between the NRC exit and the date of that 15 memo. 16 Q How do you know that? 17 A Discussion with Mr. Hoffman. 18 Q When did that discussion occur? 19 A Some time between the NRC exit and the day of the 20 memo. 21 Q What did Mr. Hoffman say to you? 22 A He said he had the room cleaned up. O
r .- J 43 ]i ... 1 Q And he was going to issue a memo? 2 A Correct. l 3 Q As you earlier testified. 4 A Yes. l 5 Q You assume he cleaned the room up at the time he i 6 told you he was going to have the room cleaned up? j 7 A I assumed he had the room cleaned up, if it hadn't t 8 been cleaned up already by then due to the normal housekeeping 9 process. $ 10 Q You also assumed he wrote a meno to Newberg, as ha 11 said? 1 ! 12 A The memo speaks for itself. The memo was written 13 and dated March 7, 1985. 14 Q May. The drift of my questions is Hoffman told you t
- 15 he did two things, that he cleaned the room up and wrote a 1
l 16 meno. The room is not available to us in its condition at the l 17 time, as we sit here today, but the memo is. The memo that 18 you were told was going to be written in the 3/21/85 timeframe f 19 wasn't written until 5/7/85. I ! 20 Do you know whether or not the room was cleaned up 21 before May 7, 1985? i 22 A I don't think I specifically said the memo was going I h !O
l 44 l 1 to be written around March 21st. 2 Q I may have jumped to that conclusion. The memo was 3 not in fact written for some time after Mr. Hoffman told you 4 he was going to write one? 5 A That's correct. 6 Q Was the room in fact cleaned up then or -- 7 A The room would have been cleaned up if Mr. Hoffman 8 said he had the room cleaned up. He is a very conscientious 9 individual and gets his job done. He would have had the room 10 cleaned up, if the room hadn't already been cleaned up by the 11 normal housekeeping process. 12 Q The basis for your conclusion to that effect is what 13 Mr. Hoffman told you and your knowledge of Mr. Hoffman? 14 A No. The basis for that is what Mr. Hoffman told me, 15 knowledge of Mr. Hoffman, and also the knowledge of our 16 housekeeping program. It would have cycled through that area 17 and cleaned up the room. Also the basis would be when it was 18 identified to us by the NRC, we would have taken the necessary 19 action and had the room cleaned up. I have to assume that the 20 people who work for me, when a concern is brought to their l 21 attention, they do take the necessary actions. 22 Q Mr. Hoffman's memo states in part "This area should i
45 1 be clean and given special attention..." That is May 7, 1985. 2 A Yes. 3 Q Do you take that statement as indicating that the 4 room had already been cleaned? 5 A Yes. 6 Q Who is Mr. Clif Gray? He is a recipient of a copy 7 of the letter. 8 A He is the Structural Supervisor who would be 9 Mr. Hoffman's supervisor. 10 Q Did you make any investigation of the cause of the 11 cleanliness discrepancies that were identified by the NRC? 12 A We did not make any special investigation of the I~ 13 cause. V) We believe that this is a construction site and at any 14 given time, you may have some debris accumulated in an area. 15 The key element is an ongoing program which picks up this 16 debris and prevents it from accumulating and being detrimental 17 to any of the equipment. We believe we have a very effective 18 program in this area, and based on that, we did not believe 19 there was any need to make any special investigation. 20 Q I take it you mean you believed that your program 21 was effective at the time of the item of non-compliance? 22 A Yes. O
46 1 Q On page three of the inspection report, item B.2, 2 relates to subcontention 8.e. It identifies an item of 3 non-compliance regarding inadequate protection of permanent j 4 spool pieces associated with the residual heat removal pump 5 and containment spray pump. l 6 Are you familiar with that item of non-compliance? 7 A Yes.
; 8 Q How did you learn of the circumstances of that i
9 non-compliance? 10 A In discussion with my staff. 11 Q When did that take place? 12 A Some time after March 15, 1985. l O V 13 Q After the NRC identified the item? 14 A Yes. , 15 Q Who on your staff did you discuss the matter with? 16 A Mr. Mike GorsRf.lL(d)o o ' l 17 Q Who is Mr. Go,rsky? l 18 A He is a mechanical field engineer. He works in the 19 Mechanical Quality Programs area. 20 Q Anyone else? 21 A He would be the primary person. bbsNU 22 Q What did Mr. Gorsky say to you on the subject? O
47 1 A He advised me that we had received one of the 2 examples that the NRC used in their violation'for inadequate 3 housekeeping and equipment protection, referenced in this 4 inspection report. t 5 Q How did he know that? 6 A I'm sure he had interface with either the inspector 7 or the people working with the inspector. 8 Q The site people working with the inspector? 9 A Yes. 10 Q He may have learned about it firsthand because he 11 was there or heard it from the inspectors? OnkE 12 A You would have to ask Mr. G _e ky how he heard about O 13 14 it. dhott i Q You don't.know how Mr. Gprs learned of the matter? 15 A No; I don't. , 16 Q Were you present at the time the NRC identified the 17 non-compliance? It has been identified as subcontention 8.e. 18 A Was I present on the Braidwood site? 19 Q Were you there at the time the inspectors identified 20 the non-compliance? 21 A On the Braidwood site? 22 Q No. Were you physically present to see the NRC
c. 48 i
.1 inspectors identify the item of non-compliance?
h 2 A No. 3 Q You learned about it in the manner you just referred t 1 4 to, through others? l 5 A Yes. . Gpnlu j 6 Q Mr. Go , who you recall in particular. i 7 A Yes. j 8 Q Did you examine the conditions that the NRC I L 9 identified with respect to this item? $ 10 A No; I did not. I can visualize the condition as i 11 stated in the inspection report. l 12 Q on what basis can you do that? 13 A I'm familiar with what a suction spool looks like. h 14 Q Are you familiar with the deficit manner of covering l ! 15 that piece of material? 16 A I'm familiar with the manner in which the ends of l 17 the suction spools were covered; whether deficit, it is a l l 18 matter of discussion between us and the NRC at that point in i 19 time. I 20 Q The NRC viewed it as an item of non-compliance? { 21 A That's correct. i ) 22 Q In your judgment, was it an item of non-compliance? l I j O i l I
r- s ,- 49 l 1 A In my judgment, it shouldn't have been an item of
) 2 non-compliance.
3 Q In your judgment, did it represent a non-conformance 4 withhr6cedures,specificationsorregulatoryrequirements? 5 , A Our procedures had allowcd us to use tape as a 6 covering for ends of piping materials at that' point in time. 7 Q Did your procedure authorize the use'of tape that 8 was in the condition as described in the inspection report, 9 and that is tape that was not intact? . 10 A No. 11 Q How do you understand the condition described by the
' 12 NRC?
13 A That the ends of the pipe were taped and maybe one 14 strip of tape or so had come loose. 15 Q What kind of tape are we talking about? 16 A Similar to duct tape; a heavy duty tape. It is 17 typically used in the nuclear induatry. It is pretty sturdy 15 material. It would have been taped across the ends of the 19 flanges, across the flanges, to cover the hole opening in 20 strips. ' 21 Q How wide is this tape? s , 22 A Probably three inches wide.
t 50 1 Q How wide was the opening on the spool pieces that 2 were to be covered with the tape? l l 3 A I think we are talking somewhere of greater than ten ' 4 inch diameter piping. 5 Q It would take more than one piece of tape to cover 6 the opening? , 7 A Yes. 8 Q What procedure at the time authorized the use of 9 such tape for closing components such as this? 10 A I'm not sure of the procedure number. It would have 11 been a Phillips-Getschow Company procedure. 12 Q Did the procedure at the time expressly authorize 13 ( ) the use of tape for this application? 14 A I don't really know if it did not expressly. It 15 was a job site practice to use tape as a protective measure 16 for piping ends. 17 Q In the same fashion generally it was used in this 18 case? 19 A Yes. 20 Q Was that an acceptable practice in your opinion? 21 A Yes. 22 Q Does the applicable procedure still permit the use O
51 1 of tape for such applications? 2 A It permits the use of tape for temporary storage of 3 piping materials. 4 Q In the same fashion that was used in this case? 5 A We've defined in the procedure the term " temporary" 6 versus "non-temporary storage." In the case of a temporary 7 storage, the tape would be used essentially in the same 8 application that was used here. 9 Q Okay. And what is temporary storage as opposed to 10 non-temporary. 11 A It would be best if I used an example. If you have 12 a piece of pipe, what's commonly referred to as a spool piece, ( ) 13 which is a fabricated piece of pipe, and you are erecting this 14 spool piece, you've taken it out of the laydown area, brought 15 it into the building, you're not going to store it in the 16 building, you've got it up and are erecting it, if at the end 17 of a shift you need to -- you leave the pipe in a partially 18 erected condition, i.e. that you haven't -- when you fit two 19 pieces of pipe together, you've removed the cover on it so you 20 can fit-up the pipe, if you have to leave it, let's say the 21 pass is not in for the night at the end of the shift, you can 22 cover it over with tape to prevent any debris -- anybody from O
m 52 1 putting any debris inside the pipe. I 2 Q Okay. In that case, the tape is typically covering 3 a fairly small gap between two pieces, is it not? l 1 4 A No. The tape would be covering the opening. 5 Q Well, if two pieces of pipe -- let's say in your ! 6 example, we've got to ten-inch diameter pieces of pipe, and 7 let's say it's a welded connection, there are two going 8 together, and you fit it up, how much of a gap is there 9 between the two pieces of ten-inch pipe? , 10 A If you are at the fit-up stage. If you are not at 11 the fit-up stage, let's say you've swung it into the air and i 12 have it temporarily supported and you're about ready to fit it 13 up, you still have the pipe hanging there with a large gap, 14 you haven't got to the fit-up stage, then you would be 15 covering the whole -- the total opening. 16 Q With tape? 17 A With tape. If in the case that you've described 18 where you have completed fit-up of the pipe, you could then 19 just tape the weld joint to prevent anybody from getting any 20 debris -- I doubt that, given that small opening, anybody 21 could get anything in the pipe. 22 Q Dust and dirt could get in, couldn't it? O
53 1 A Dust and dirt can get in the pipe. That's why you i 2 have a flushing program that would flush any dust that would 3 get into the pipe. l 4 Q All right. Laying that aside, let's take your 5 example. In the case where the pipes fit up, so there's a 6 small gap, how much gap would there be if a pipe was already 7 fit up? 8 A Probably on the order of a quarter inch or so or 9 less. 10 Q In that case, would site procedure call for the use 11 of tape to temporarily seal the gap overnight or between 12 shifts? i ( ) 13 A Yes. i 14 Q Okay. And in that case, the use of duct tape or 15 comparable tape, one pass could seal that gap, correct? 16 A Yes. 17 Q All right. If in the other example that you used, 18 the pipe is there and supported in the air and you haven't fit 1 19 the second piece to it, so you've got the whole ten-inch 20 diameter opening exposed, tape, under the current procedure, 1 21 could also be used? 22 A Yes. O
54 1 Q In that case, you have to do essentially what was 4 2 done as reflected in the item of noncompliance, and that's 3 tape over the opening with several passes of tape? 4 A Yes. 5 Q And that would be acceptable? 6 A Yes. 7 Q Was the condition that's described in Inspection 8 Report 85-08, page 3, paragraph B.1, was that temporary 9 storage of the pipe as you now define it? 10 A No. 11 Q Pardon me? No? I 12 A No. The condition would be -- that is described i li V 13 there would fall under the definition of a non-temporary 14 storage. 15 Q Okay. Why is that? 16 A We have redefined the threshold for temporary versus 17 non-temporary. l 18 Q Okay. And how have you defined that threshold? 19 A The example I gave you would be a good example of 20 the threshold for terporary versus non-temporary storage. I 21 Q Okay. Is there a time element employed in defining l 22 temporary storage now? l l O l l
.,-, . . - _ . -m-..-- _ _. __ __
55 1 A In the definition we use, we use an example, and we 2 gave generally an overnight type of time period for completion 3 of one shift, and then you pick up on a shift the next day. 4 Q Okay. Well, what was significant -- what is l 5 significant in the item described on page 3 of 85-08 that 6 makes that non-temporary? 7 A The permanent spool pieces were stored next to the 8 pumps. They're to be put back in after the temporary spool 9 pieces were done being used. So it would have been in a 10 temporary -- it would have been in a storage period for 11 probably anywhere from a matter of a few days to a few weeks 12 to a month. (} 13 Q Okay. And would the length of time in which the 14 permanent pieces were removed and stored -- strike that. 15 In the item described in the NRC's inspection report 16 on this subject, how, under the present procedure, would the 17 responsible personnel have detarmined the appropriate storage 18 and equipment protection practice to employ? 19 [ Pause.] l 20 Do you understand the question? 21 A I understand the question. 22 The responsible people would have been told to O v i i
56 1 remove the permanent suction spools for the -- I believe it 2 would have been the ECCS full flow test, and would have been 3 told to put them in a storage condition for an extended time 4 period. 5 Given that, they would have put on to it the more 6 permanent type covers. 7 Q Okay. How would they know that -- the responsible 8 people -- that the removal of the permanent spool pieces was 9 for a non-temporary period of time? 10 A They would have been given instructions that we were 11 going to leave the temporary strainers in for an extended time 12 period. ( ) 13~ Q All right. What was the function of the temporary 14 spool pieces with the strainers? 15 A It's a good, conservative practice in a plant under 16 construction to put in temporary spools with strainers in them 17 on your major equipment suction. History has -- we do it all 18 the time in building our plants. It's basically there for 19 pump protection in case something would inadvertently get into i 20 the system. It would catch anything that would have 21 inadvertently gotten into the system prior to getting to the
. 22 pump impellers.
l 1 O l
57 1 It's -- my experience has shown -- we've used it at 2 all our nuclear stations and our fossil stations when building , 3 power plants. We generally like to leave the temporary 4 strainers in all the way up until generally fuel load. 5 Q So what's the purpose of the temporary strainer, 6 then? 7 A It would provide pump protection. 8 Q What is it designed to strain? 9 A Any large particles. 10 Q Okay. How large is a large particle? 11 A Oh, the size of a quarter. 12 Q Okay. Can you describe the design of the strainer? 13 Let's use the example of the strainer that's referred to in 14 the Inspection Report 85-08. 15 A Very simply, it is a screen that is welded into the 16 inside diameter of a pipe, placed at a -- oh, about a 45 17 degree angle from the vertical. The water flows across the 18 screen. If there would happen to be anything, any particles 19 in the water, they would catch on the screen, and there is an 20 access plug which allows you then to go in and -- open up and 21 go in and clean out the screen. 22 Q Okay. What were the circumstances that are O _ )
58 1 described in the inspection report regarding the use of the 2 temporary spool pieces with strainers, with screens? 3 It appears that the permanent spool pieces had 4 already been installed and were removed to place the 5 strainers. 6 A That's correct. 7 Q Okay. Now why would the permanent pieces been 8 installed and then removed? 9 A For a fit-up of the permanent pieces to make sure 10 they fit in the pipeline, and then you take them out and put 11 in the temporary strainers. 12 Q Okay. Are these bolted or welded connections? () 13 A They are bolted connections. 14 Q Okay. When you -- does the procedure provide for 15 the use of the strainers? 16 A Yes. 17 Q All right. Is there a procedure that provides for 10 the cleaning of the strainers? 19 A I don't know the answer to that question. 20 Q Okay. Is there any documentation made of the 21 existence of debris found through the use of strainers? 22 A I don't know. l O
7-59 1 Q What is the procedure that calls for the use of ( 2 strainers? Can you identify it? 3 A More than likely the test procedure would have 4 called for the temporary strainers to be in there? 5 Q Can you identify that a little more particularly, 4 6 the test procedure? 7 A I think it's -- let me see the inspection report. 8 Q Sure. 9 [ Witness reviewing document.] 10 A BWP-TEF-11 ECCS Full Flow. 11 Q Why don't you just point it out to me, if you would? 4 12 (The witness complies.] ().13 Thank you. 14 Whose procedure is that? 15 A It would be a Commonwealth Edison Company procedure. 16 Q And that's the name of a specific preoperational 17 test, the ECCS Full Flow? 18 A Yes. 19 Q Okay. And that's the test that the NRC was 20 witnessing, described in 85-08? 21 A Yes. 22 Q Were there any debris or foreign objects found i O 1
r 60 1 during the ECCS full flow test? O
\ss/ 2 A Not to my knowledge.
3 Q Do you know whether or not any debris or foreign 4 objects have been found during any of the preoperational tests 5 at Braidwood in the piping systems? 6 A I think we may have found some small particles in 7 some of the strainers. 8 Q Small particles of what? 9 A Debris. 10 Q Do you know what the source of the debris was? 11 A No. 12 Q Was any effort made to identify the source of the 13 debris? 14 A Yes. 15 Q Can you identify that? 16 A Our people, flushing people, would be responsible 17 for that as part of the normal flushing operations and would 18 take a -- would identify the source of debris and take any 19 action necessary. 20 Q Okay. Do they document the identification? l 21 A I believe they do. 22 Q Do you know how they do that? O f
I 61 1 A I believe it would be in the flushing tests. 2 Q Would that procedure, the ECCS full flow, describe 3 the means for performing the test and documenting those 4 findings? 5 A Yes. 6 Q Now you said that it's general practice to employ 7 strainars in the manner in which you've described, correct? 8 A Yes. 9 Q All right. And that it's based on past experience. 10 Can you describe that past experience which supports the use 11 of strainers in this fashion? 12 MR. GILL: I'm going to let him go ahead and answer 13 this question. ( ) But I think that we have, through much of this 14 deposition, we have strayed from the reason for the notice of 15 this deposition. I think that now we have gone way beyond on 16 this one. 17 The item that we're talking about here originally 18 was the protection of permanent spool pieces, and we're now 19 off into the underlying practices and procedures associated 20 with strainer systems, which is not the subject of the Quality 21 Assurance Contention in any respect that I'm aware of. 22 MR. GUILD: Well, I think upon some reflection, O
62 1 Mr. Gill, it would occur to you that the reason why you use e
\ 2 strainers is because you perhaps didn't seal the ends of your 3 pipes properly in the first instance. The reason you have 4 these cleanliness procedures that are at issue in this case is 5 because garbage gets into your pipe systems. The strainer may 6 find garbage, and that's exactly the point of the Contention.
7 MR. GILL: I'm going to continue with my objection 8 to it. As I say, he can go ahead and answer the question, but 9 we won't go forever on it. 10 THE WITNESS: Would you repeat the question? 11 MR. GUILD: I forgot it. 12 BY MR. GUILD: 13 Q What have you found in the past that leads you to ( } 14 believe that the use of strainers is an appropriate practice? 15 A First of all, you would have to understand that the 16 protection of the pump, the equipment, is a very serious 17 matter, and we have had at both our nuclear and fossil
- 18 stations in the past history, and I think even the industry 19 has had instances of where af4psople'of
/J2 -
foreign debris has 20 'gotten into the pump or a rotating piece of equipment through 21 the piping system. So it's a very good, conservative practice 22 to put these strainers in to protect that piece of equipment.
}
l 63
'l Q Okay.
2 A It's an expensive -- equipment is expensive, in the 3 first place, and it's expensive to repair if it becomes 4 damaged. So again, it's a good, conservative practice, we've 5 found. 6 MR. GILL: Could we go off the record for a second? 7 MR. GUILD: Sure. 8 [ Discussion off the record.) 9 BY MR. GUILD: 10 Q A couple of details. Can you tell me what the 11 screen size is on the strainers that you use? 12 A I don't really know the exact screen size that is 13 used, no. 14 Q can you give me an approximation, or can you compare 15 it to a screen? 16 A My approximation would be, let's say, a quarter-inch 17 by quarter-inch holes. 18 Q If a piece of debris or foreign material -- I think 19 you used the size of a quarter as an example -- if that were 20 not -- if that circulated through a piping system and was not 21 strained out, what would be the deleterious effect, if any? j 22 A It may or may not have an effect on the pump, O 1 I
,-3-- - - - . , , , - e,,.... - . . . . . . . - - -
64 1 getting caught in the impeller. I'd be speculating now. You
S s_) 2 can speculate a lot of different things.
3 Q Okay. Well, in terms of design, from a design or an 4 engineering standpoint, what harm, if any, does one attempt to 5 prevent through the use of strainers and cleanliness practices 6 in a piping system? 7 A We're trying to protect the equipment from getting 8 an object in it that may bind up the equipment, causing 9 internal damage to a pump. 10 - Q All right. Take the pump in question that's 11 described in the NRC's inspection report, the residual heat 12 removal pump and the containment spray pump. ( } 13 What kind of damage would be caused if a piece of 14 debris the size that you described there, a quarter-sized 15 piece of debris, got into those pumps in operation? 16 A I don't know if there would be any damage caused by 17 an object that size. 18 Q Okay. Aside from the damage to the pump, is there 19 any other potential deleterious effect of debris in a piping 20 system? 21 A I stated earlier that you could speculate a lot of 22 things. I would probably refer you to somebody more versed in A V
65 1 pump design than myself. O'- 2 Q Okay. Are you aware of any other potential hara 3 that's identified that's associated with debris in piping 4 systems? 5 A Loose parts is an issue in the nuclear industry, l' 6 that if you have loose parts in your piping system, it can get 7 to your primary system. l 4 8 Q And cause what kind of harm, if any? l f 9 A I don't know if it would cause any harm or not. 10 It's an issue that we design for in the nuclear industry, so 11 there must be some basis for why we design for that. 12 Q You are not specifically aware of what that basis ( ) 13 is? f 14 A No, I'm not. i 15 Q Now what has Edison's experience been with respect 16 to debris in piping systems? Have you identified any? 17 A We have had in the past on construction of our 18 fossil and nuclear stations situations where we had a foreign ! 19 object in the piping system. I remember we had an instance or 20 two at LaSalle County Station. l 21 Q What debris did you identify at LaSalle in the l 22 piping system? - O 1
66 1 A I don't really recall what the object Was. 2 Q Did you find any cans in the piping systems at 3 LaSalle? 4 A I'd be speculating at this point. 5 Q You just don't recall? ! 6 A I just don 8t recall. 7 Q All right. Did the debris in question cause any 8 damage or harm to the piping systems at LaSalle? 9 A I really don't recall. 10 Q Did you find debris at LaSalle hfter you involved 11 strainers? 12 A I really don't recall. 13 ( ) Q Do you know how you found the debris at LaSalle? 14 A No , I don't. 15 Q How about other Edison nuclear sites? Are you aware 16 of any other instances of debris identified in piping systems? 17 A No. 18 Q Have there been any other instances, aside from the 19 ones at LaSalle? i , 20 A Not that I can recall. ! 21 Q Okay. Can debris of smaller size, smaller than the 22 quarter that you used as an example, cause any deleterious i
67 1 effects in a piping system? 2 A I don't really know the answer to that question. I 3 think you'd have to ask a piping designer. 4 Q All right. Do you know whether or not dirt can 5 cause a deleterious effect on a piping system? 6 A Again, I would refer you to a piping designer. 7 Q Do you know whether or not your site procedures call 8 for the prevention of dirt entry into piping systems? 9 A We take measures to prevent the entry of foreign 10 objects up to and including dirt into the piping system during 11 erection. 12 Q I used the word " dirt," but I mean to include 13 abrasive particulates, dirt, dust, that sort of thing. Are 14 generally materials such as I've described designed to be 15 excluded from piping systems, kept out of piping systems? 16 A And I think I said our procedures are set up to 17 prevent the entry of those materials into the piping systems. 18 Q All right. Thank you. ( 19 When the plant is in operation, are there strainers 20 in place in the piping systems? 21 A I really don't know the answer to that question. I 22 would have to ask somebody who ws more familiar with the plant O
68 1 systems. 2 Q Is one of the purposes of the preoperational piping 3 system flush to identify and remove debris in piping systems? 4 A Yes. 5 Q Okay. And is that done through the use of 6 strainers? 7 A Yes. 8 Q As you've described already? 9 A Yes. 10 Q Okay. I've seen references -- and I'm not sure that 11 they're in this document, the NRC's inspection report -- but 12 references to reliance on system flushing as a means toward ( ) 13 identifying any cleanliness discrepancies in piping systems. 14 When the term " system flushing" is used, is that a 15 reference to the testing process that's described in 16 Inspection Report 85-087 17 A No. 18 Q Okay. That's a separate function? 19 A It's a separate function. 20 Q Okay. Can you identify a little more particularly 21 what the system flush is, then? 22 A After you erect a piping system, you put it through a
69 l- a series of -- and you're able to flow water through it, you 2 put it through a flush series. You do what's called a rough 3 flush on it, and then you do a final flush on it to a certain 4 acceptance standard, cleanliness standard, depending on what 5 the architect engineer would specify for that system. That is 6 generally all done prior to the preoperational test phase. 7 Q Okay. Is the flush that you've just described, the 8 rough and final flush, done prior to the preoperational 9 testing that is described in 85-087 10 A Yes. 11 Q Okay. The systems that were the subject of the ECCS 12 full flow testing that was observed by the NRC and documented ( } 13 in 85-08 had already been the subject of a rough and final 14 flush? 15 A I believe that is so. 16 Q Are the results of the rough and final flush
-17 documented?
18 A Yes, they are. 19 Q Do you know whether or not any debris was identified 20 in the course of the flush of piping systems at Braidwood? 21 A I do not, no%d- b
- 22. Q Who would have more particular knowledge of that?
O i
._ _ _ . _ . . _ . . _ . . ~ -
'I 70 , 1 A The start-up group. I 2 Q And who is responsible for that, for start-up? 3 A Mr. Chuck Tomashek. 4 Q can you describe what you characterize as the more 1 5 permanent piping closures that were used instead of a tape on 6 piping components? 7 A It could be a wood cover, a plastic cover, a metal 8 cover, which is placed over the end of the pipe and securely 9 fastened.
- 10 Q Okay. And those covers would be in place during the 11 pipe storage and prior to its issuance for installation?
12 A Yes. ()13 Q And who places those covers? 14 A The manufacturer of the pipe. s 15 Q. All right. So the covers are in place when you 16 receive the piping component onsite? 17 A Yes. 18 Q And how are they fastened in place? 19 A Wired, taped. Those are the two common ways that i 20 they're fastened in place. 21 Q All right. Who has responsibility for removing the 22 permanent piping closures? r O a
71 1 A The erector of the pipe. 2 Q At what point would they do that? 3 A When they're going to erect the pipe in place. 4 Q okay. Do they do that in the field, or do they do 5 that at the point where it's issued from the warehouse? ' 6 A They do it at the -- in the field at the point of 7 erection. 8 MR. GUILD: Okay. Why don't we go off the record 9 and stop at this point. 10 (Whereupon, at 12:25 o' clock, p.m., the taking of 11 the deposition was recessed, to reconvene at 1:30 o' clock, 12 p.m., this same day.) 14 15 16 17 18 19 20 21 i 22 i l O _ , -~ .,- -. - - - - - - -- ---- -
72 1 AFTERNOON SESSION G k_-) 2 (1:40 p.m.] 1 3 Whereupon, 4 DANIEL L. SHAMBLIN 5 resumed the stand and, having been previously duly sworn by 6 the Notary Public, was examined and testified further as 7- follows: 8 EXAMINATION (RESUMED) 9 BY MR. GUILD: 10 Q Mr. Shamblin, let's talk about contention Subpart 11 8.b. This item is identified on page 7 of Inspection Report 12 85-08. 13 In part, the statement of the item of noncompliance ( ) 14 reads: "The Inspector observed that there were no precautions 15 posted outside the sump area, and personnel were unaware of 16 requirements to maintain material accountability, personnel 17 accountability, or the wearing of shoe covers while in this 18 cleanliness zone." 19 Moving down further, "The Inspector noted some , 20 debris, primarily paper, in the sump and surrounding area that 21 entered the suction flow path. This observation was discussed 22 with the Licensee," et cetera. "This is an example of a f O
,- ,,n- - - - , - - - - - , - , , . , . , , - , . - , - , _ , . . _ - - - , - - - - , . . .- - - - - - - _ , _ _ _ _ _ _ _ _ -- -
73 1 violation of Criterion 13, 2 Do you have familiarity with this item of 3 . noncompliance? 4 A Can I see it? 5 Q Sure. e 6 (Witness reviewing document.) 7 A
/dhJdb \ '
Yes, I do. I didn't discuss it with the ploe -- 8 I was not the Licensee that it was discussed with, but I have 9 familiarity with the item of noncompliance, and I do know that 10 corrective actions were taken, as stated in the inspection 11 report here. 12 Q Okay. How did you become aware of the item of 13 noncompliance? (
- 14 A Discussion with the test coordinator from the 15 start-up area.
16 Q And who was that? 17 A He was Mr. Hank Zimmerman. He now works for me on 18 my staff as a Parts Material Coordinator. 19 Q Okay. What was Mr. Zimmerman's position at the time 20 you were informed of this item? { 21 A I think he was the Start-Up Group Test Coordinator. 22 I'm not positive of the title, but it was a position that ! 0
74 1 could be described by that title. 2 Q All right. And who did he work for at that time? 3 A Mr. Chuck Tomashek. 4 Q Okay. And what are his duties in his present i 5 position? ' 6 A As Parts Material Coordinator, he is responsible for 7 the expediting of parts need for completion of the job, 8 coordination of procurement of parts from Marble Hill for j-9 Byron and Braidwood Stations, transfer of parts between Byron 10 and Braidwood. That's a little list of, you know, amongst his l 11. duties. 7 12 MR. GUILD: Off the record. 13 [ Discussion off the record.] ( } 14 MR. GUILD: Back on~the record, please. 15 BY MR. GUILD: I 16 Q When did Mr. Zimmerman bring this matter to your 17 attention? 18 A We discussed this matter, oh, sometime in and around ! 19 when it happened and subsequently since then. 20 Q Okay. Before the inspection report was published? 21 A I don't really remember whether it was before the 22 inspection report was published or not. It was sometime last E i l O
r 75 1 year, last spring. 2 Q Okay. Do you know -- the inspection report, page 7, 3 states as follows: "This observation was discussed with the 4 Licensee, and corrective actions were taken." 5 Do you know with whom the NRC discussed their 6 observations? 7 A I believe it was Mr. Zimmerman. 8 Q Do you know who the NRC inspector was who made these 9 findings? 10 A I don't know specific -- one of the four individuals 11 that did make the findings. 12 Q All right. Do you know whether it's the case that 13 cleanliness controls were being either ignored or not ( 14 enforced? t 15 A I think that, contrary to what it says there, 16 cleanliness controls were being enforced in the recirculation t l 17 sump area. The issue, as I understand from the inspection l 18 report, is that there was not a requirement to have shoe
- 19 covers in the cleanliness zone area, the recirculation sump 20 cleanliness zone area.
21 Q Okay. Do you know whether it's the case, as stated l 22 at page 7 of the inspection report, that there were no I t 1O . I - - - - -- -
76 1 precautions posted outside the sump area?
- 2 A I don't know if there -- have firsthand knowledge of 3 whether there were no precautions posted outside. I do know 4 that the people were aware of the cleanliness requirements for 5 the refueling cavity cleanliness zone and the recirculation 6 sump cleanliness zone.
7 Q All right. Well, isn't it the case that the 8 inspector, the NRC inspector, acknowledged that there was a 9 posting for the refueling cavity, but found that there was no 10 posting for the reactor sump? 11 MR. GILL: You're asking what the report says? l 12 MR. GUILD: No. I'm asking what happened. And he's 13 ( ) welcome to read the report. 14- THE WITNESS: Well, I believe it's as stated here in 15 the report, that the report would be an accurate reflection of 16 the situation as it happened. 17 BY MR. GUILD: l ! 18 Q As far as you know, the report is accurate? 19 A Yes. l 20 Q All right. Is the report accurate in the respect ( 21 that it states that " personnel were unaware of requirements to 22 maintain material accountability, personnel accountability, or i O
i J : 77 1 the wearir,g of shoe covers while in this cleanliness zone?" iQ (_/ 2 i I don't -- with resp ~3ct to the shoe covers, that's 3 corr.ect. With respect to the material accountability and 4 personnel accountability, it's my. knowledge that the people 5 were aware of those two facters. r ,. g
- l 'A 6 Q. Okay. Now how did you' reach that concluel'on?
1 s. 7 A DiscussionwithMr.jjimmerman.
, -y &
8 Q Mr. Zimmerman told you tha't thpy were, in fact , 9 aware of those (actors? / - 10 A Yes. He told me thrtt the material control -- m., 11 material accountability and personnel accountability were part 12 oftheECCSfullflowtest[c:./ cleanliness program for that 13 portion of the test. . 14 Q And those aspects of'the program had been
' '15i . communicated to the personnel involved?
16 A Yes. ' l 17 Q All right. 'And hos did that happen? . ,- l 18 A Through the -- in prepara, tion for.Ihe test, the j 19 information had been communica,ted to the personnel ~ responsible
. .e l 20 .for conducting the test. ' '
i . -' L '21 Q Okay. And how was that informatio'n communicated to j>' 22 them,,1f you know? -
~ ,'e: ,
l G(-'s N h i
/
78 1 A I don't know how it was communicated to them. 2 Q Do you know whether there was training in l 3 cleanliness practices as specified in the report? ' 4 A There was a detailed -- it's my understanding there 5 is a detailed plan, cleanliness plan, drawn up for the test, i 6 and that was communicated to the personnel involved in 7 conducting the test. 8 Q Did they read it? Were they taught it in a 9 classroom? Was it on a sign? Do you know how it was 10 communicated? 11 A I don't know how it was communicated. 12 Q Was Mr. Zimmerman responsible for communicating the 13 cleanliness program to the responsible people? ~ k-14 A Either Mr. Zimmerman or one of his test engineers 15 reporting to him. Me3 SE 16 Q What are the requirements of the ANCTstandard, with [J ISI. 17 respect to cleanliness? It's 3NCI N45.2.1, 1973, entitled 18 " Cleaning of Fluid Systems and Associated Components During 19 Construction Phase of Nuclear Power Plants." 20 A In tihe case of this test, the reactor refueling 21 cavity and the reactor recirculation sump were declared a 22 higher cleanliness zone than the normal cleanliness zone that
4 79 1 would be in effect during the construction phase. The purpose
'2 of doing this is -- let me go into the test sequence here.
3 The reactor refueling cavity is like a big sump 4 where the reactor vessel sits down in. I don't know if you're t 5 familiar with the plant. 6 Q Give me a general description so that the record 7 will reflect what you're talking about. 8 A It's a big pool that's probably 100 feet long by 20 9 or 30 feet wide by 40 feet deep. The reactor sits down in the I 10 refueling cavity. The sump -- reactor recirculation sump -- 11 sits in the basement of the reactor building, containment. 12 Q Below the pressure vessel? ( } 13 A Elevation-wise, it would be -- yes, probably below 14 the pressure vessel. 15 The test sequence that is ongoing at this point in 16 time is to simulate a guillotine break and a containment spray 17 actuation. You take suction from the reactor recirculation 1 18 sump, which would be the catch point for any water draining i 19 out~of a guillotine break or containment spray actuation. 20 Avfl You pump through the ECCS, )n containment spray 21 pumps, back to the reactor vessel. The reactor vessel is 22 allowed to overflow into the reactor refueling cavity and then O
80 1 there is temporary piping to pipe the water back down to the ( t (m / 2 sump, thereby simulating the water draining back down to the 3 sump. 4 In this case here, cleanliness zones were 5 established around the reactor refueling cavity, essentially 6 covered the whole reactor refueling cavity, to prevent the 7 introduction of any foreign debris. And the same thing for 8 the reactor recirculation sump. Their cleanliness zone was 9 established around the reactor recirculation sump. It would 10 be a higher cleanliness zone than normal construction because 11 you wanted to preclude against any foreign debris entering the 12 flow path. Nf 13 ( } You also would go from -- I forget the specific 90TCE-14 designation. I think it may be a cleanliness zone 4 to a 15 cleanliness zone 3. There are specific requirements when you 16- go from a 4 to a 3 that must be met, including amongst them 17 Hbkad. personnel accountability and trail accountability. 18 Q How about the other aspects of cleanliness that are i 19 identified in the inspection report? 20 A Okay, access control and shoe coverings. l 21 Q All those are required under these circumstances? 22 A I believe that they are all required, without O
hWU 1 specifically checking the ANC[ standard. I believe they are 2 required when you go into -- I think it is a cleanliness zone 3 3. 4 Q .And required under the circumstances of the test , 5 that's described in the inspection report? 6 A It was the judgment of the people who established l 7 the cleanliness requirements in this case that shoe coverings i 8 were not a requirement of a cleanliness zone 3. They had been 9 required in the reactor refueling cavity as personal 10 protection only because people would have to go down into 11 reactor refueling cavity and there would be water, since the j 12 reactor vessel was overflowing. They may be going into the
'13 water. So the shoe coverings were placed there as a personal 14 protection safety.
15 Q To keep people's feet dry. 16 A To keep people's feet dry, right. i 17 In the area of the sump, there would be no need for l 18 personnel to go down into the sump. They would always be in a 19 dry. condition, so it was initially determined that there would 20 be no need for shoe coverings in that reactor recirculation l 21 sump area. 1 22 Q As a matter of cleanliness, why provide for shoe O l i L
82
-1 covers?
2 A In some cases, in the cleanliness zone -- let's say
! 3 a 3, you may have to keep a contaminant or something getting 4 on the area you're going into, so that would be why you would 5 be providing for shoe cover.
4 6 Q You don't want to track dirt, for one thing? 7 A Depending on the circumstances. If dirt was a 8 detrimental type of a condition, it could be chemicals, it 9 could be any type of material. The requirements are written A(J'il-i 10 broadly, in'the Apef' standard, for the different cleanliness
, 11 zones and it's up to the individuals responsible for 12 implementing the standard to interpret them to what they need i 13 for that cleanliness zone.
( )
' i 14 Q Is it Edison's position that shoe covers were not 15 required in order to meet the ANCI cleanliness standards, with 16 respect to the recirculation sump area?
i 17 A It was -- when we established the cleanliness i i 18 program for that recirculation sump area, it was our position. 19 Q That shoe covers were not required? 1 l l 20 A The shoe covers were not required. l 21 Q And that covers were not required as a matter of 22 cleanliness in the refueling cavity either? ! O
I 83 l' A That's correct.
, ( 2 Q Simply as a matter of keeping people's feet dry?
3 A That's correct. 4 Q Is it true, as described in the inspection report, 5 page 7,-that debris -- primarily paper -- was found in the 6 sump and surrounding area -- I'm paraphrasing -- and that the 7 paper entered the suction flow path? 8 A It is Edison's position in this case that we cleaned 9 out the sump and hand wiped down the sump prior to the test 10 beginning, that the paper-like debris that was noticed in the i 11 sump was purge dam material that would come out of the piping 12 in an operation such as this. ("'\ 13 Q Purge dam, two words, p-u-r-g-e? O 14 A Yes. 15 Q D-a-m? 16 A Yes. l 17 Q And what's a purge dam? i 18 A Purge dam material is a paper-like substance that is 19 used in a welding operation, a piping. When you join two 20 pieces of pipe together, you would put up this dam material 21 between -- to encompass the weld joint. And you would then 22 pipe in, like argon gas, to give it an inert atmosphere for l i l l t
84 1 the welding operation. 2 Purge dam material will eventually dissolve over 3 time with water in the system. 4 Q And the system design is such to accommodate the 5 presence of purge dam material in the piping system? 6 A Yes, it's commonly used -- the paper-type purge dam 7 material is commonly used in the nuclear industry. 8 Q How did Edison reach the position that the material 9 observed, characterized as paper debris by the NRC inspector, 10 was in fact purge dam material? 11 A It would be on visual observation by Edison , 12 personnel. () U 13 Q You didn't see it yourself? 14 A No, I did not see it myself. 15 Q Whose observation are you relying on? 16 A I'm relying on test engineer's observations. 17 Q And who are they, by name? 18 A I don't know the names of the specific test 19 engineers responsible for this test. This was information 20 that was provided to me by Mr. Zimmerman. 21 Q And has Edison communicated this position to the 22 NRC? l 1.
t 85 1 A Yes. 2 Q And what's the NRC's response? V 3 A I believe they have accepted that response. 4 Q I may have asked you earlier, do you know who the 5 NRC inspector was who observed the condition? 6 A You asked me that earlier. 7 Q You did answer that? 8 A Yes. 9 Q And it's one of the four, but you don't know which 10 one? 11 A I don't know which one. 12 Q Thank you. ( ) 13 What corrective action was taken, with respect to 14 this observation? The corrective action that's referred to on 15 page 7? 16 A Shoe covers were put in the recirculation sump area 17 and a training session was held with the test engineers 18 reinforcing the cleanliness requirements by the areas. 19 Q Who conducted the training? 20 A I believe it -- I don't really know who it would be. 21 Q Was there any posting of the cleanliness 22 requirements in the sump area? O'
- a
86 1 A I don't know. 2 Q Were there any changes made to the site procedures, 3 as corrective action for this item? 4 A No, there would be no need to. 5 Q Did the NRC withdraw this item of non-compliance? l
; 6 A No.
A053-7 Q Do you know whether a copy of the 3NC1 standard has
- 8 been identified in discovery, Mr. Shamblin?
9 A I do not know. 10 MR. GUILD: Counsel, I don't see it listed in any of 11 the reference sections. I wonder if I could ask that a copy 12 of the ANCI standard that's the subject of the item of 13 non-complian,ce be made available?
- 14 MR. GILL
- If you would give me one of your notes 15 there, I will pass it on to get it responded to. I would 16 assume that this standard is a public document.
L 17 MR. GUILD: That may be. I'm certain it is. It's 4 l 18 just a question of getting access to it for us. 19 BY MR. GUILD: l 20 Q I'm going to ask you about a couple of other items i 21 that are noted in inspection report 8508, Mr. Shamblin. 22 There's an observation on page 5, with respect to a leaking 1 !~ !O 1 1 l
1 l l 87 l I check valve in the diesel generator fuel line. It begins on 2 page 5 of the inspection report.
- 3. Take a moment and review that, if you need to. I'll 4 ask you if you're familiar with that subject.
5 (Witness reviewing document.) 6 A The only knowledge I have on this subject is we did 7 do some work on the check valve. 8 Q You replaced the damaged check valve? 9 A That's right. 10 Q Has there been any redesign of that fuel oil system? 11 A As I stated, the only knowledge I have is we did 12 replace the check valve. The Construction Department ( ) 13 personnel, with the contractors, would have replaced the check 14 valve. 15 I don't have any other knowledge, other than that, 16 on this issue. 17 Q Do you know what the cause was, of the damage to the 18 check valve? ! 19 A Like I say, I don't have any other knowledge than we 20 received a deficiency report to go out and replace the check 21 valve and my personnel did and we went out and replaced the r 22 check valve. Somebody else is undoubtedly following up on O i i
c . 88
- 1 that issue.
It's been identified as an unresolved item 8508-07, 2 Q-3 page 5 and 6 of inspection report 8508. Do you know who, at 4 Edison or at the site, is responsible for following up that 5 item? 6 A No, I don't. It is more than likely been placed in 7 our system for follow up, but I don't know who would be 8 responsible for that. t 9 Q Page 8 of the same inspection report, 8508, there's 4 10 another item relating to the pre-operational testing. It's 11 identified, page 8, as an open item. It's 8508-11. l 12 Let me ask you to take a look at that and tell me if 13 you're familiar with that? ( j 14 (Witness reviewing document.) 15 A The only knowledge I have of this subject is that 16 there are two different size impellers in the pumps. , 17 Q Do you know why there are two different size 18 impellers? 19 A No. 20 Q Do you know whether or not the correct impellers 21 were installed in the correct pump? 22 A I believe -- the answer is that I don't know, O l t
89 1 personally, that the correct impellers were installed in the 2 correct pumps. I have to, based on our program, assume that 3 the correct impellers were installed in the correct pumps.
-4 Q All right. Do you know whether this open item 5 remains open?
6 A I don't know that either. 7 Q The NRC did follow up on the cleanliness issue and 8 documented their findings in inspection report 8545 and 44, 9 published November 14, 1985, a report done by Messrs. Tongue 10 and Farber, documenting inspections from September 3 through 11 November 1 '85. Are you familiar with that inspection? 12 That's an excerpt from the report. 13 (Witness reviewing document.)
)
14 A Yes. 15 Q You are identified as one of the persons contacted 16 and as an attendee at one or more exit interviews. Were you 17 contacted by the NRC as part of this inspection?
- 18 A Yes.
19 Q And did you attend exit interviews involving this 20 inspection? , 21 A Yes, I did. 22 Q The note at the bottom of page two of the report O
90 1 states that you, among others, are indicated as attending one 2 or more exit interviews conducted on September 5, 12, 19, 3 October 10, 17, 24 and 31, '85. Did you attend each of those 4 meetings? 5 A I know I did not attend, I think it was the one on 6 the 19th. And I know that because in responding to this 7 inspection report I checked my calendar regarding that date. 8 The other dates I would have to check my calendar. 9 Q All right. Why did they have more than one exit 10 interview associated with this inspection? 11 A We have a weekly mini-exit with the NRC, as a form 12 of communication between us and the NRC. (}13 Q And the dates indicated on page 2 refer to those 14 mini-exits, weekly meetings? 15 A Yes. 16 Q Page 4 of the NRC inspection report 8545 and 44 17 identifies an item of non-compliance on the issue of 18 cleanliness. The non-compliance identified states "The NRC 19 noted that in the past year there have been at least two 20 previous violations for inadequate housekeeping and equipment 21 protection. Further, the lack of effective overall corrective 22 action to protect safety related equipment in response to NRC )
p-91 1 violations and failure to respond in a timely manner to f i 2 inspection findings is considered a violation of criterion 16 4 3 corrective action." i 4 Are you familiar with the subject of that item of 5 non-compliance? I 6 A Yes. l 7 Q Do you know whether or not the at least two previous 8 violations for inadequate housekeeping and equipment 9 protection include the items of non-compliance identified in 10 subparts 8d, e and f of the contention? 11 A I believe they do. I'm not positive of that. 12 Q In the inspection report -- this is 8545 itself -- 4 13 on page 3, under the heading Licensee Action on Previous ] 14 Inspection Findings. They speak to two inspections on the d 15 cleanliness issue. 16 The first was 8523 and 24, failure to keep debris 17 and trash out of safety related cable trays and control high j 18 strength bolting. And the second is identified as 8508-10a, l 19 b and c, inadequate protection of installed safety related 20 plant equipment. > 21 Now the latter of those two, 8508-10a, b and c are J 22 the items that have been identified as subcontentions 8d, e l O
92 1 and f, are they.not? 2 A Yes. 3 Q The first item, which was 8523 and 24, failure to 4 keep trash and debris out of safety related cable trays, et 5 cetera, is indicated as having been closed in inspection 6 report 8532 and 31. Are you familiar with that item? 7 A Somewhat familiar with the item. 8 Q At the bottom of page 3, the inspector notes "During 9 plant tours, the inspectors identified areas where equipment 10 protection was inadequate. Electrical panels in the auxiliary
- 11. electrical equipment room and the main control board in the 12 control room were left uncovered and/or open while masonry .
( ) 13 work was being conducted in the immediate vicinity. This 14 resulted in fine masonry dust settling out on the control 15 panels and internal components." Et cetera. 16 Can you describe the circumstances under which dust 17 and other contaminants were found to have intruded into the 18 control panels? 19 A The item were talking about here is dust, not other 20 contaminants. There was some masonry removal operations going 21 on in the vicinity of the auxiliary electrical equipment room 22 and the main control. room and some of the dust from this O
93 1 masonry removal operation got into the electrical panels. 2 Q How did that come to your attention? 3 A Through conversation with Mr. Tongue. 4 Q The inspector? 5 A That's correct. 6 Q At the time the original item was identified? 7 A Yes. 8 Q Did you observe the condition yourself? 9 A Yes. 10 Q And was there masonry dust inside the control 11 panels, as described? 12 A There was a very fine film of dust inside the 13 control panels. 14 Q By fine you mean not a lot of dust? 15 A Not very much at all. 16 Q A thin layer of dust? 17 A Very thin layer. 18 Q Is the presence of dust adverse to the functioning 19 of -- potentially adverse to the functioning of the control 20 panel? 21 A If not removed, it can be potentially adverse. 22 Q And how can it be adverse potentially? O
, 94 1 A I'm sure it can affect the operation of the 2 electrical equipment.
3 Q Do you know in what manner? 4 A No, I don't. ] 5 Q Are there any open switches or contacts in the ! 6 control panels in question here? 1 7 A I don't know the answer to that. 8 Q Are there any open gauges or meters? 9 A I believe all the gauges and meters are sealed in 10 the control panels. l 11 Q Do you know whether you use any open switches or j 12 contacts in safety related panels or switchboards? ( } 13 A I don't know the answer to that. 14 Q The statement is made in the inspection report
- 15 "Although there may not be an immediate problem with the
! 16 equipment, the intrusion of foreign matter can cause 17 unpredictable equipment failures in the future." i la Do you agree with that statement? 19 A There is always a possibility that that may happen. 20 Q What kind of unpredictable equipment failures can be # 21 caused, potentially, by the intrusion of foreign matter? 22 A I don't really know. You'd have to ask the O
95 4 1 inspector who wrote that phrase there. I 2 Q Do you, as the witness for Commonwealth Edison on i
; 3 this subpart, know what potential damage can be caused by the 4 intrusion of foreign material into a switchbox?
5 A Well, one can hypothesize a lot of different things, j 6 is a switch doesn't work right. 7 Q Do you know whether there's been any analysis by 8 Edison to determine what detrimental effects the intrusion of i 9 foreign material into a switchbox can causo? l i 10- A I'm sure that there has been, in the past, analyses t-11 done in the design of the plant. I have no direct knowledge 12 of that, but that would probably be one of the items that 13 would be checked in the design of the plant.
- 14 These panels do see a construction atmosphere over i
15 an extended period of time. 16 Q Are there procedures that call for protection of j 17 these installations, the panels in question for example,
- 18 junction boxes, from exposure to contaminants such as dust?
)! 19 A There would be a procedure that would have called [ 20 for attempting to minimize any dust being thrown about or F 21 spread about from the masonry removal operations. 22 The panels themselves are, again, in a construction l i i O i
4 96 1 atmosphere and it would be expected that they would see some
\m / 2 type of dust during the construction phase. The key question 3 is there an ongoing cleaning program to take care of that 4 dust. :
5 Q Well, was there any procedure at the time of item of ' 6 non-compliance that provided that the control panels were 7 covered or closed? Were to be covered or closed? 8 A I don't believe there -- there was -- yes, there 9 would be procedures that would provide temporary protection 10 would be provided around the panel if you were doing masonry 11 removal in that area. 12 Q How about if there was a door on a control box or 13 ( ) junction box? Is there a procedure that called for closing i 14 the door? 15 A No. v 16 Q Then, as I understand, there were procedures to 17 protect the equipment during the performance of the masonry 18 work, why weren't those procedures followed? . 19 A The individuals executing the work did not follow l l l 20 the procedure. 21 Q And who was responsible for the work in question?
- 22 A I would probably be the masonry contractor, l
l l i > F l
=
97 1 V.S. Wallgren.. 2 Q The initials again? 3 A V.S. Wallgren. 4 Q Can you spell the last name? 5 A W-a-1-1-g-r-e-n. 6 Q And do you know what the masonry work was that's 7' referred to in the inspection report? 8 A No, I don't. 9 Q The inspection report continues, "The inspectors 10 identified an open electrical junction box for temperature 11 element leads on centrifugal charging pump 1CV01PA, which 12 contained an accumulation of oil, such that the cable insulation was submerged in the oil."
}:13 14 Do you know what the circumstances were of that 15 junction box?
16 A The electrical conduit -- flex electrical conduit, 17 fed a thermocouple into an oil reservoir. There was a minor 18 malfunction of a seal separating the oil reservoir and the 19 thermocouple and oil leaked back through the thermocouple wire 20 into the electrical junction box. l :21 There was maybe a cup or two cups worth of oil in 4 l 22 the electrical junction box. It was very small amount.
98 1 Q Did you observe this condition? 2 A Yes, I did. 3 Q And was the cable insulation submerged in oil, as 4 the report states? 5 A Yes, it was. 6 Q Do you agree with the observation by the NRC 7 inspector that the oil accumulation constitutes a potential 8 fire hazard? 9 A No, I don't. 10 Q Why not? ta L 11 A one t,bef stated in our response to this item, the 12 item had a flash pan of over 400 degrees, plus the amount of 13 oil was a very insignificant amount of oil. 14 Q If someone dropped a match into the oil, would it 15 burn? 16 A I don't think so. 17 Q What's the function of the oil reservoir in the 18 installation in question? 19 A It's bearing oil for pump bearings. 20 Q And the thermocouple measures the temperature of the 21 bearing oil? 22 A I believe that's right, yes. O
i 99 1 Q Continuing, the same inspection report, page 3, "The 2_ inspectors also identified a number of flexible electrical 3 conduits which were damaged such that the cable supported the 4 conduit and the cable insulation was exposed to cuts and 5 gashes from the sharp edges of the conduits." 6 Are you familiar with the circumstances of that item 7 of non-compliance? 8 A Yes. It would not be unusual, in a nuclear power 9 plant, to observe conditions of flexible conduits being M 10 broken. At Braidwood we have an ongoing program which i 11 identifies these instances and puts them into our repair 12 system. As part of that repair, the cable is inspected for 13 any damage. j 14 As we near the end of construction and turn over 15 areas to the station, there is a final check made for any 16 broken flexible conduits that would be present and any repairs 17 made. ; 18 Again, as I stated, this type of instance is % dO 19 unusual for any nuclear power plant construction. 20 Q What's the program that's to identify these damaged 21 flex cables -- flex conduits? 22 A They are identified by the contractor, in his O :
100 1 walkdowns, walkdowns on preventative maintenance. He has 2 personnel assigned preventative maintenance activities. If 3 that personnel would notice a broken flexible conduit, they 1 4 would report it and put it into the system to be repaired. 5 They are also identified during the testing by test 6 engineers. Again, any broken flexible conduit would be noted 7 and put into the system for repairs. Then they would also be, 8 during the area turnover activities, there would be a final 9 check made for any broken flexible conduit and be repaired at 10 that point in time. 11 Q And the contractor in question is Comstock? 12 A The contractor in question, that does the 13 preventative maintenance activity is Comstock. 14 Q Is Comstock responsible for the installation and 15 installation inspection of the conduit and cable in question? 16 A They are responsible for the installation of conduit 17 and cable, yes. 18 Q Okay. What is the cause of the damage that is 19 identified by the NRC as cuts, gashes, cuts and gashes? 20 That's in the bottom paragraph. 21 A Well, the NRC states that the cable insulation was 22 exposed to cuts and gashes. I don't think they actually O
101 1 identified any specific cuts and gashes in the cable 2 insulation. 3 Q Oh, I see. That's the potential for damage to the 4- insulation of the wire that's inside the conduit? 5 A It's potential for damage to the insulation around 6 the wire. 7 Q That's in the conduit? 8 A That's in the conduit, yes. 9 Q Well, they identify, then, " conduits which were 10 damaged such that the cable support of the conduit and the 11 cable insulation was exposed to cuts and gashes from the sharp 12 edges of the conduit." ()13 I take that to mean that the flexible conduit had 14 sharp edges. How did that damage occur? 15 A The flexible conduit wouldn't have a sharp edge. 16 It's a rubberlike product, so it wouldn't have a sharp edge. 17 It would be analogous to this type of material here 18 (indicating). 19 Q All right. You are indicating on the base of the 20 microphone. It's a sheathing, a flexible rubber sheathing? 21 A Yes. 22 Q Is there flexible conduit that is metal-linked \ 1 )
102 1 product -- I don't know how to describe it any more clearly -- O) (_, 2 but a metal product, metal sheathing that is made out of 3 separate links that can flex within limits? 4 A There's a stainless steel type metal flexible 5 conduit, yes. 6 Q All right. And do you understand that the 7 inspectors were referring to that sort of conduit? 8 A No. In the situation present here, he is referring 9 to the rubber type flexible conduit going into the junction 10 box. 11 Q okay. What is he referring to when he says "the 12 sharp edges of the conduit?" ( ) 13 A I'm not exactly sure what he would be referring to 14 there. I did not see any sharp edges when I looked at the 15 situation. 16 Q Okay. All you saw was rubber flexible conduit? 17 A I saw where there were no sharp edges, okay. 18 Q Well, was it rubber, was it metal, or what? ) 19 A It was the rubber type material. 20 Q What was the cause of the damage to the rubber 21 flexible conduit? 22 A From what it appeared to me, somebody stepped on the i O
J 103 1 flexible conduit and broke it. 2 Q Stepped on it, or it was hit with some heavy piece 3 of equipment or tool? 4 A I think that, given the location, it would appear 5 that somebody stepped on the flexible conduit. 6 Q Is the conduit such that simply stepping on it with 7 a shoe or a work book would cause this kind of damage? 8 A Yes. 9 Q Why was the conduit in a place where somebody could 10 step on it? 11 A The conduit was designed to go int'o the junction box 12 on the side,of the pump. It would normally not be -- you 13 know, it's not in a walkway. Somebody more than likely was 14 working around the pump and stepped on t'he conduit. 15 Q They had to climb up on it? 16 A Yes, they would have had to have stepped on it, 17 climb up on it to step on it. 18 Q okay. Are there damaged flexible conduits of the i 19 metallic type that would have sharp edges? 20 A I have seen those, yes. 21 Q And how were those -- well, what kind of 22 installations would a flexible metal conduit be used? O
104 1 A We use them primarily inside the reactor O V 2 containment. 3 Q All right. In a harsh environment? 4 A The containment is declared a harsh environment, so 5 -- 6 Q Are these flexible conduits that are specified for 7 use in a harsh environment? 8 A Yes. 9 Q Okay. And have you observed damaged conduit of that 10 sort that has sharp edges? 11 A Yes. 12 Q Okay. And is that the sort of damage that could ()13 cause cuts and gashes to the cable insulation? 14 A There is a potential for that. The cable insulation a 15 is generally a pretty rigid -- a pretty durable material, but 16 I suspect, given enough force, you could cut into it with a 17 sharp edge. 18 Q Well, you cut it with a pair of wirecutters, don't 19 you? 20 A Sure. 21 MR. GUILD: Let's take a break. I 22 (Recess.] I O I i L_
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105
?u .A a 1s BY MR. GUILD:
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l h 2 Q Mr. Shamblin, page 3 and 4;of the inspection report 3 we've been discussing, and that's 8'5-45 and 44, state that the ,
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4 open junction, box and damaged flexible conduit ;was presented l 5 to Licensee niadagement' representatives during an exit meeting
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6 on September'19,,1985. < i 7 Nowthat's.themeetingthatyouyeren'tPNeuentat, 8 right? < , -
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9 A. That's correct. /y ~~
- ,;/ J 10 Q And you determined that,by reviewing,your calendar? ,
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s, s ~~ ' 11 A Yes. ' '
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13 d:- T ' representatives were who ti9re,at (he September 19 meeting? a 14 A I believe my assistadt! was there. 'There were
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15 certain representatives fyor.'the station's licensing area who 16 were also present. Beyond- that, I'd have to go back and ask.
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17 Okay. Q Who was your assist; ant?
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18 A Jerry Groth. ' g 19 Q Okay. Continuing,!"As of. October 28th, no evidence
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20 was available te jab.ow that action had been I~
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_ p ~ p/' 21 - the conditio'ns and that any.evalunt' ion had r been performed on Y 22 the accumulatfIon'"of oil;" is that.Ecorrect? * < 7 .f , _,, f (9 k
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106 1 A That is an accurate statement. 2 Q Why hadn't action been taken to correct the 3 conditions as of that date? 4 A It appears, when I looked into this inspection 5 report, that we had a situation of an isolated case where the 6 NRC identified an item, and it didn't get picked up in our 7 tracking system. We generally have a very good tracking 8 system. The NRC has been complimentary about our 9 responsiveness to them. In looking back over the 10 circumstances of this item, it appeared this was an isolated [ 11 case where an item did not get picked up. L 12 Q By " item," you mean the item involving the junction ()13 box with the oil accumulation and the flexible conduit damage? 14 A That's correct, yes. 15 Q Okay. 16 A Beyond that, the pump where the junction box was 17 located en had been taken out of service sometime prior to 18 that for repair type work. As part of the work in restoring 19 this pump, they would have picked up the oil in the junction 20 box and cleaned it up. 21 Q Well, was there a procedure that said that 22 corrective action didn't need to be taken with respect to the O
l 107 1 i 1 junction box with oil accumulation because the pump had been O2 taken out of service? 3 A The procedure would have provided for that. The 4 problem of the oil getting in the junction box would have 5 gotten corrected. The pump was undergoing a preventive 6 maintenance, overhaul type work. 7 Q Okay. Well, aside from whether or not the problem 8 would have been fixed through this means, the means you've 9 just identified, the rework on the pump, was the status of the 10 pump at all otherwise significant with respect to the failure 11 to take corrective action? 12 Did you follow that? 13 A No, I didn't. ( ) 14 Q Okay. Why wasn't corrective action taken with 15 regard to the oil in the junction box, that item? 16 MR. GILL: Objection. Asked and answered. But he 17 can answer it again. 18 THE WITNESS: It was -- when I investigated that 19 similar question with respect to this item of noncompliance, 20 when it was given to us, I determined that this was an 21 isolated instance where the item, when identified to us by the 22 NRC, did not get put into our tracking system for follow-up.
108 1 BY MR. GUILD: 2 Q Okay. And failure to put the item in the tracking s 3 system is the reason why there was no corrective action for 4 the open junction box with oil accumulated? 5 A Yes, that's what I attributed the cause of why that 6 didn't get picked up. We have a very good tracking system, l $ 7 and, as stated, it's been quite complimentary by the NRC on 8 our tracking system. We just missed one item. 9 Q All right. The point of my last series of questions 10 was as follows: To what extent did the status of the pump, as 11 subject to rework as you've described, contribute to the cause 12 of failure to take timely corrective action? 13 A The status of the pump, given that it was in (
- 14 the repairs stage, we would have, by the time we put that pump 15 back into service, have picked up that problem with the oil in 4
16 the junction box. 4 i 17 Q I heard you say that, and maybe I'm just not 18 communicating clearly. 19 You have confidence that the problem would have been 20 fixed because the pump was being repaired generally. That's 21 .the short version of what you told me. 22 A Uh-huh. O r l _ _ . _ - _ - _ _ _ . . - -- -- - -- - - . - - - - - - - - - - -
109 l 1 Q Okay. But my question to you is, does that explain 2 why the corrective action wasn't taken in a timely fashion? 3 A No. 4 Q Now with respect to the evaluation of the reason for
]
5 the oil accumulation, why wasn't that evaluation performed in 6 a timely fashion? 7 A As I stated earlier, the item of the oil leaking 8 into the junction box, when identified to us on September 9 19th, had not gotten into our tracking system. 10 Q The same answer. 11 A The same answer. 12 Q Okay. October 29, the inspection report goes on,
/ 13 page 4: "The Licensee issued an action plan." Are you
}
14 familiar with that? 15 A Yes. 16 Q Okay. And can you describe that action plan? 17 A Well, the action plan that is referenced in that 18 inspection report dealt with the work, masonry wall work, in i 19 and around the control room and the electrical panels. It was 20 essentially a series of directives by myself to my people for 21 what remedial actions to take and also what to do in the 22 future for -- reiterating what to do in the future for a O
I l i l ,i 110 1 situation such as this. 2 Q Okay. And who did you communicate that to? l 3 A I communicated that to the personnel in my 4 organization, in the electrical and mechanical areas and civil 5 areas. 6 Q Okay. 7 A It was a -- my view of what was needed to do to 8 rectify the situation and prevent the occurrence in the 9 future. 10 Q Okay. According to the NRC, page 4 again of the 11 inspection report, "The plan delineates steps for cleaning 12 electrical panels" -- I'm paraphrasing -- plan is specific ( ) 13 to those areas, should be effective for those areas -- quote, 14 now: "The action plan does not address other areas of the 15 plant, e.g. safety-related equipment areas or the turbine, i 16 auxiliary and containment buildings and is specific to 17 electrical equi Fment. It does not address other systems such 18 as mechanical, ventilation, diesel generator," et cetera. 19 Is that an accurate statement? It's that long 20 paragraph in the middle. 21 [ Witness reviewing document.] 22 A That is correct.
111 1 Q So your last answer was not correct. Your directive 2 to your people did not encompass other than the electrical 3 area. 4 A My directive to my people encompassed the electrical 5 panel area. 6 MR. GILL: Just so we're clear, I don't think that's 7 inconsistent with his prior answer. 8 MR. GUILD: Well, I heard it as such. Let me see if 9 I can figure out what I'm misunderstanding, if that's -- 10 MR. GILL: Maybe to simplify it, my understanding 11 was, that was who the plan was sent to, was those people in 12 the various areas. 13 BY MR. GUILD: 14 Q Okay. Is that right? You sent the plan that was 15 limited to the electrical area to mechanical people and people 16 involved in other disciplines besides electrical? 17 A The plant dealt with remedial actions and future 18 actions with regard to electrical panels. It was sent to 19 personnel in my mechanical, civil, and electrical areas.
.20 Q Okay. Can you identify more specifically the 21 direction? Was it a letter, a memo?
22 A It was in the form of a -- I think just titled O
112 1 " Action Plan," and it listed a number, it listed the action to O (_ ,/ 2 be taken, and it listed the responsible party. 3 Q Okay. And it was from you, and it was dated October 4 29, '85? 5 A If that's the date that's stated, I believe that's 6 the date it was. 7 MR. GUILD: Counsel, I would ask that a copy of this 8 document be made available for inspection, please. 9 MR. GILL: Add it to your list here, and I'll send 10 it through for follow-up. l 11 MR. GUILD: Thank you. 12 BY MR. GUILD: () 13 14 Q And NRC goes on: "The limited scope was discussed with Licensee management personnel at the October 31 exit." 15 Were you present at that meeting? 16 A I was present at that meeting, yes. 17 Q Okay. They stated that this was the beginning to an 18 overall program in preparation for shifting the plant to a 19 test operational status. Who is "they?" Who stated that? 20 A More than likely, it was representatives of Edison, 21 myself, or Mike Wallace at the meeting. The plan was never 22 intended to be an all-encompassing plan. It dealt I i O l i - -
113 1 specifically with one issue. 2 Q Okay. Page 3, a description of the item of 3 noncompliance, No. 85-23-01, which was closed as of the 85-45 4 inspection, it refers to a " failure to keep trash and debris 5 out of safety-related cable trays." 6 What sorts of trash and debris were identified in 7 those locations? 8 A I think -- I believe in terms of that item of 9 noncompliance, it was isolated cases of fireproofing, wood 10 type materials that was identified in the cable tray system. 11 Q Wood type materials? 12 A Yes. ( ) 13 Q Okay. What was the wood used for? 14 A More than likely scaffolding. 15 Q okay. Were any cans, any soda or beer cans, found 16 in the cable trays? 17 A Without going back and checking the specific 18 inspection report, I don't know. 19 Q Do you know whether, independent of the inspection 20 report, whether soda or beer cans have ever been identified in 21 cable trays? 22 A Oh, yes. Yes. O
114 1 Q How about beer cans? f
~
2 A Both. 3 Q " Plant tours by the inspectors" -- this is quote 4 regarding this item - " plant tours by the inspectors revealed 5 that this is still a problem and corrective action has not 6 been affective." 7 Are you aware of the basis for the NRC's conclusion ' 8 that I just read? 9 A I'm sure the NRC would have noticed other isolated 10 cases of some type of debris being in the cable pan, and in 11 their view, they felt that our corrective action may not have 12 been effective. ( } 13 Q Did they bring such findings to your attention? 14 A They would have identified them to our people. I 15 think they may have identified, in this case, some situations 16 in one of the mini-exits, and we would have followed up on ! 17- them. 18 Q Okay. Do you recall the NRC bringing such findings 19 to your attention in the exit meetings regarding this
- 20 inspection report, 85-45?
21 A Not really. I do recall -- I have had instances 22 where the NRC has found a small amount of debris in isolated b.. . . _ _
115 1 occurrences being brought to my attention, and we take care of 2 those. 1 3 Q Well, how do you take care of them? 4 A Go out and clean them up. It would not be unusual
- 5 to have isolated occurrences of debris in the cable trays.
6 The key point here is that prior to any cable pulling through 7 a cable tray, there is a walkdown done for cleanliness, and 8 anything that would be in there is removed prior to the cable i- 9 pull. 10 Q Were these all empty trays? 11 A No. 12 Q Was there debris found in trays that had cables 13 already pulled in them? ( ) 14 A Yes, i 15 Q How do you get the debris out of those at the point 1 16 where you pull cable? 17 A Just pick it up and remove it. Take it out. 18 Q Well, if you've already pulled the cable and the 19 debris is there -- 20 A It's probably laying -- the debris may just be 21 laying on top of the cable. 22 Q What program, if any, do you have to remove debris i i t i L
116 1 under those circumstances? 2 A We have a multi-phase program. We have an ongoing 3 program of continual cleaning of the cable trays, personnel 4 dedicated specifically for that, and then we have the program 5 of prior to a cable pull, the cable raceway is walked down, 6 and any debris that may be identified is removed in the cable 7 pull. 8 Q okay. Were the cable trays in which debris was i , 9 found subject to-those two phases of your program? 10 A Yes. 11 Q Why wasn't the trash and debris identified and 12 removed in the cases found by the NRC? () 13 A It would have been identified and removed. As I 14 stated, it's an ongoing program. They cover the complete 15 cable tray system over a period of time. 16 Q They just hadn't gotten to this particular debris 17 yet? 18 A More than likely in this situation, that's what 19 happened. L
-20 Q Do you know whether or not, on the contrary, that it 21' was a situation where the debris was overlooked, not i
22 withstanding the existance of a program that should have found l LO l _ _ _ _ _ _ _ . - . - - _ - _ _ ~ - - _ _ -
117 1 it? 2 A I don't know that. 3 Q What, if anything, additional did your action plan 4 for the electrical area call for that was not already being 4 5 done in the area of cleanliness? 6 A To the best of my knowledge, I don't think I called 7 for anything additional. I reinforced current activities. 8 Q Did the NRC ever make a comparative evaluation of 9 the issue of cleanliness and housekeeping at Braidwood, 10 relative to other sites? 11 A I know of no published document along that line. 12 Q All right. Have they ever done so on a 13 non-published basis, characterized to you or others, that you ( l 14 understand? I 15 A No. t 16 Q Have you made observations of relative housekeeping i 17 and cleanliness at Braidwood compared to other facilities? , 18 A My own professional observation is that the 19 housekeeping program at the Braidwood Station is a much 20 stronger housekeeping program and equipment preventive 21 maintenance program than what I implemented at LaSalle County i 22 Station. I
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118 1 Q Is the program at Braidwood more effective than the 2 LaSalle Station, in your opinion? 3 A In my professional opinion, the program at Braidwood 4 is more effective than that which was implemented at LaSalle 5 Station. 6 Q Okay. Let's talk about 3.b. 7 Well, before we do that, with respect to 8.d., e, 8 and f, have you undertaken the preparation of any testimony, 9 Mr. Shamblin? 10 A Yes. 11 Q Okay. And what have you done? 12 A I've written testimony on it. 13 Q Okay. And what have you written? 14 MR. GILL: Objection and instruct the witness not to 15 answer on the grounds of work product and attorney / client 16 privilege. 17 MR. GUILD: I'd intend to examine the witness on the 18 subjects of what testimony he has prepared on all of the 19 subparts of the Contention on which he is to provide 20 testimony. The scope of my examination would be similar and L l 21 no more detailed than the examination that your colleague, 22 Mr. Gallo, conducted of NRC witnesses with respect to their
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l l 1 119 l 1 prepared testimony. ( 2 Do you still instruct your witness not to answer the 3 questions? 4 MR. GILL: The testimony is in draft phase. The 5 final testimony will be made available, pursuant to the 6 Commission's orders, and I will stay with my instruction to 7 the witness. 8 MR. GUILD: Will you make Mr. Shamblin available for 9 deposition after you make his testimony available? 10 MR. GILL: No, I'm not going to commit to that. But 11 if there are any questions that you would like to ask him 12 about substantive matters on which his testimony will be ( } 13 given, feel free to ask them today. 14 MR. GUILD: Well, I'd like to ask all those, but I'm 15 forced to guess beyond what I've asked already, to the extent 16 that you will not allow him to answer any questions that I've 17 asked with respect to the prepared testimony, and I don't want 18 to guess. 19 BY MR. GUILD: 20 Q Let's turn to 3.b. Have you prepared testimony on 21 ~Subcontention 3.b? 22 A Yes. O
120 1 Q What testimony have you prepared on that subject? 2 MR. GILL: To the extent that you're asking the 3 witness what it is that he has written, I again will instruct 4 the witness not to answer for the same reasons. 5 MR. GUILD: Fine. 6 BY MR. GUILD: 7 Q All right. Can you identify the documents that 8 you've brought with you today, Mr. Shamblin? 9 A The first document is a Gust K. Newberg & 10 Associates, General Contractors, Section 31, " Erection of 11 Structural Steel," Revisions 0, 1, 2, 3, and 4. 12 Q Okay. And what does this document pertain to? 13 A It pertains to the erection of structural steel. ( ) 14 Q All right. And how does it relate to 3.b? 15 A It would be the procedure to which the work that was 16 -- the modification of the beam work, the modification of the 17 beams was done to. 18 Q Does that procedure specify the means by which beam j 19 modification work is to be done? 20 A Yes. 21 Q All right. Can you direct my attention to the 22 portion of the procedure that speaks to that issue? I l l 1
l 121 1 [ Witness reviewing document.] O
\/ % 2 A In Revision 0, I would direct you to Section 31-3-1 3 -- well, I may be more general, the 31-3-0, the procedure i 4 aspects of that; Revision 1, the same area 31-3-0.
5 Q Okay. Let me stop you a second. 31-3.0? 6 A Yes. 7 Q Okay. It simply says " Procedure" as one word, 8 looking at Rev. O. 9 A Okay. And then the subsequent subparagraphs that 10 follow. 11 Q Well, the rest of the entire procedure follows. 12 A Yes. (A) 13 Q What in particular deals with beam modification, ! 14 cutting holes in beams for running piping? l 15 A In particular, Section 31-3-1 would be, " Structural l 16 steel will be installed in accordance with approved plans and 17 specifications." l 18 Q Okay. Is there any other portion of Rev. O that ! 19 deals with modifying beams? 20 .A Well, in the modification of beams, you would have 21 -- you may have field connections, so Section 31-3-3 would be 22 applicable. O
4 122 1 Q 31-3.3? 2 A Point 3. You may have to do some plumbing up of 3 steel. You may have to do some field touch-up work of 4 modification of beams. 5 Q Where are you looking at? 6 A The next page. 7 Q 31-3.5? 8 A Yes. 9 Q That's painting. l l 10 A You may have to do some field touch-up painting in g 11 modification of beams. 12 The next page, which is Form 1705-R at the bottom, 13 page 4, a whole section 9-3, you may have to do installation ( )
- 14 of high-strength bolts in the modification of beams.
15 Q Anything else? r 16 A No. l 17 Q Well, that basically tells you how to install beams, 1 18 and it says you do it according to specifications. Is there i 19 anything -- 20 A It says "according to plans and specifications." 21 Q Right. Is there anything in here that speaks to 22 cutting holes in beams to run pipe, drainpipe or otherwise, ' O
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123 1 through it? ) O2 A Well, the holes in the beams would be in the 1 1 3 situation here on the drawings. 4 Q Okay. Anything other than that? By reference, 5 then, to the drawings, it addresses cutting holes in beams? 6 A Yes. 7 Q Okay. Anything explicit in Rev. O that deals with 8 cutting holes in beams? 9 A No. l 10 Q Is your answer going to be the same on all the rest 11 of the Revs generally? 12 A No. 4 ( } 13 Q Well, tell me where you start talking about cutting 14 holes -- explicitly cutting holes in beams? 15 A Rev. 1 does not. Rev. 2 starts to talk in terms of 16 preparation of what's called an SSIT package. 17 Q And where does that appear? 3.17 t 18 A 3.1. 19 Q Okay. And what is an SSIT package? 20 A Structural steel installation traveler package. 21 Q Okay. And how does that relate to cutting holes in 22 beams? l i O i
l l 124 1 A That would be a package prepared for making the 2 modification to the beam, to cut the hole, from the plans and I 3 specifications. 4 Q Okay. 5 A Okay. Then if you go over to Section 4, under 6 Section 4, " Installation," Section 4-3 deals with field 7 cutting - "will not be performed unless indicated on the 8 detail drawings and approved nonconformances or as described 9 below for connection fit-up." 10 Q Okay. How about any further provisions? 11 A The Revision 2 over underneath Section 5, " Quality 12 Control Inspection," Section 5-3, " Structural steel 13 configuration, member size, and location will be verified 14 against the vendor shop drawings and the architect's design 15 drawings -- design documents." 16 Q Okay. Anything else in Rev. 2 that deals with 17 cutting holes in beams? 18 A You have a copy back on Form 31-1, titled 19 " Structural Steel Installation Traveler," where the plan 20 drawing piecemark is listed. That would deal with cutting 21 holes in structural steel beams. 22 Q That's the specification drawing? O
125 <
\
1 A That's the drawing. 2 Q What's a piecemark? 3 A A piecemark is generally an identification piece 4 given to a structural member. 5 Q Okay. It's a number? , 6 A Yes, a number. 7 Under Section 3, " Quality Control Verification, 8 Location" would deal with holes in structural steel beams. 9 Q That's where if the procedure would call for the 10 quality control inspector to note unauthorized holes in beams 11 at the point -- 12 A The procedure would call for them to verify the 13 ( ) correct hole size and location at that point. 14 Q All right. Well, there's a hole in the beam. The 15 hole has been made in the beam, absent a drawing or 16 specification. 17 Is it your understanding of the procedure that under 18 Rev. 2, using the SSIT, the quality control inspector was 19 required to note such unauthorized hole under Part 3, i 20 " Location?" 21 A If there was a hole made in the beam that was i 22 unauthorized under the auspices of -- and Rev. 2 of this 1 O
126 1 procedure was the procedure being used at that point in time O s/ 2 -- he would note an unauthorized hole under the " Material 3 Undamaged" section. ' 4 Q Okay. I'm sorry. Rev.2 was in effect at this time? , 5 A Rev. 2 was in effect as of September 28, 1982. ' 6 Q Okay. All right, and where else in Rev. 2 does it 7 speak to the modification issue? 8 (Witness reviewing document.] 9 A Underneath the excerpt from -- it looks like the 10 AISC Steel Manual, page 5-187 under Section 7-1-3, " Cuts 11 alteration holes for other trades" would speak to the issue of 12 cutting holes in structural steel members. 13- Well, was this excerpt from the AISC Code part of ( ) Q 14 the applicable procedure? 15 A It's my understanding that this is, yes. 16 Q So in the form that we're looking at it right now, 17 as attached to the procedure, and it's provisions were 18 incorporated? 19 A Yes. 20 Q Beginning with Rev. 2? 21 A Yes. 22 Q And that revision was effective -- is that 9/28/82? O
127 1 A That's correct. 2 Q When were the beam modifications that are the 3 subject of sub-item 3.b. performed? 4 A They were performed, as best I can determine, in the 5 1978, '79 and '80 timeframe. 6 Q How did you figure that? 7 A That is when the roof and floor drain piping was 8 installed. 9 Q And that's the piping that was observed penetrating 10 the beams? 11 A Yes. 12 Q I interrupted you and you were identifying portions
-( 13 of Rev. 2 that addressed the beam modification issue.
}
14 A Yes.
~
15 Q Anything else other than what you have gone through 16 so far? 17 A I don't think there is anything substantive beyond 18 Rev. 2. Rev. 3 and 4 are essentially repeats of Rev. 2. The 19 forms are a little bit different, refining them, but they are 20 essentially the same. 21 Q Let me understand this, now. What you have 22 identified are procedures that are applicable to 1
128 1 Gust K. Newberg, the contractor responsible for erecting the
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kT) 2 structural beams in question. 3 A Erecting and modifying the structural beams in 4 question, more towards terms of modification of the structural 5 beams. 6 Q Was Newberg responsible for erecting them? 7 A The initial erection would have been done by 8 American Bridge, which is the division of United States Steel, 9 underneath a separate contract, or it could have been done by 10 Midcity Architectural Iron under an initial contract for 11 erection of structural steel also. , 12 Q And when was that work done, the erection of the 13 structural steel in question? (]N
\_ ,
14 A It was in the timeframe of 1977, continuing on 15 through '78 and '79. 16 Q Have you determined whether or not any o.f the ; 17 unauthorized beam modifications were performed at the time of 18 the beams' initial installation? 19 A No, but it can be -- given the fact that the initial 20 steel erection is a very fast operation -- you probably have ; 21 seen structural steel going up on buildings -- you generally ' 22 don't do cutting of holes and modifying at that point in time. ,
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129 1 Q Your belief is that the holes were cut later, after 2 the beams were already in place? 3 A That's correct. 4 Q After the beam installation contractors were 5 complete with their work? 6 A Either they were complete or had moved on to other 7 areas of the building. ! 8 Q And then someone was coming by and running, in this 9 case, the drain lines? 10 A The drain lines were, yes, specified on the drawings 11 to be run, and that would be the plumbers and pipe fitters 12- worked to run the drain lines. 4 (} 13 Q And what contractor did that work? 14 A The plumbers and pipe fitters would be employed by 15 Phillips-Getschow Company. 16 Q And it's your belief that they were the ones that , 17 ran the drain line in question, Phillips-Getschow? 18 A The running of the drain lines would be the i 19 jurisdictional work, for the building floor drains, of the 4 20 pipe fitters union; for the roof drains, it would be of the 21 plumbers union. 22 Q Roof, r-o-o-f? l O .l
130 1 A R-o-o-f. 2 Q Okay. And they were both employed by 3 Phillips-Getschow? 4 A Yes. 5 Q What procedures, if any, applied to , 6 Phillips-Getschow for the modification of structural beams 7 that they encountered in the course of running the drain 8 lines? 9 A It would not be in Phillips-Getachow's scope of work 10 to modify structural beams. They would request that the beams be modified by Newberg. 11 12 Q So you have identified Newberg procedures that in ( ) 13 your judgment governed Newberg's work in modifying structural 14 beams; correct? 15 A Yes. 16 Q But it would have been Phillips-Getschow's 17 responsibility to have notified Newberg of the need to make 18 such a beam modification in the course of running their drain 19 lines in this case. 20 A There were on the drawings numerous designations for 21 these holes to be cut by Newberg. 22 Q Well, I guess -- how about answering the first . O
1 i 131 1 question first, and that is was it Getschow's responsibility 2 to notify Newberg of a need to make a beam modification when 3 they identified such a need? 4 A If Newberg had to go out and make a beam 5 modification, they would not have to notify Phillips-Getschow 6 Company. 7 Q I mean the other way around now. Phillips-Getschow 8 is running the drain line, and their drain line encounters a 9 structural beam. 10 A Yes. 11 Q What is their responsibility in,that event? 12 A Thay would notify the Commonwealth Edison Company () 13 station construction engineer at that point in time, who would 14 request that the Newberg iron workers cut the hole in 15 accordance with the drawing if the hole showed on the drawing, 16 or if it did not show on the drawing, to get a drawing change 17 and cut the hole then. ' 18 Q ' But in either event, they would notify an Edison 19
- engineer. , ,
l 20 A The way things were operating atsthat point in time, l i ! 21 they would notify an Edison engineer, yes. 22 Q And it would be up to the Edison engineer to I l s
i i 132 i 1 determine which route to take, whether the hole was specified 2 and therefore work should be done as specified, or whether 3 there would be need for some kind of design change. 4 A That's correct. 5 Q Did Phillips-Getschow make any modifications that 6 were identified? 7 A Based on the information I have been able to put 8 together on this instance, it would be my belief that they did 9 not, that it was the ironworkers that made the modifications 10 to these beams. The modification work is within the craft 11 jurisdictional boundaries of ironworker craft. 4 12 Q So Phillips-Getschow did not make the modifications, () 13 14 in your opinion? A It is my belief that they did not make the 4 15 modifications. i 16 Q Who were the ironworkers working for? i 17 A They were employed by Gust Newberg. i 18 Q And were they the organization that should have made 19 the modifications if they had done it according to the 20 specifications? 21 A Yes. 22 Q So basically, the right people did it; they just O
s' S , w 4 J [ - y ' J ,, 133 m' , .L 1 .- didn','y d% it according t;o procedure and specifications. 2 A T$at'is my belief, yes. 7 . t
.3 s Q Now, what is the basis fot$that conclusion, your
~
4' 4 conclusion?
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5 A First of all, the making of these type of ) 6 modifications, cutting the hole, and then the requisite
<, t.< r 7 reinforcement' work / was within the draft jurisdictional 8 boundaries,fof the ironworker craft, and Newberg employed
+ 9 iYonworkers. And generally you don't gflt a lot of crossover 10 of orie craft trying to do another craft's work. It results in 11 ,, ,som( very bad feelings between crafts. It is the subject of 12 jpar;.y jurisdictional disputes'and., squabbles amongst the labor 13 udions .7. - E 14 a And theristhe second basis is the fact that the c 15 drawings were issued to Gust Newberg for construction. In
,g16 many cases, these holes sho ed up on the drawings to be cut 17 for drain line piping.
18 Q Did you make any inquiry of the people responsible l 19 for making the modifications?
/ 20 A No.
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' ~ 21 r- Q Has anybody interviewed to determine who did the I 22 modifications?
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134 1 A No. 2 Q The basis for your conclusion is the two points that E 3 you just stated, the jurisdictional issue and the fact that 4 Newberg had the drawings? 5 A Also I would say a third basis would be that this is 6 the'way I have seen it done in the past, also, at other job 7 locations. 8 Q And where is that? 9 A LaSalle County. 10 Q You say that's the way it was done? The ironworkers 11 made the modifications? 12 A Correct. () 13 MR. GUILD: Let's mark for identification Revision 14 0, 1 and 2 of Newberg Procedure Section 31, Erection of 15 Structural Steel. 16 (Shamblin Deposition Group Exhibit 17 No. 4 was marked for identification.]
-18 BY MR. GUILD:
19 Q Now, you have brought a number of drawings with you
-20 today, Mr. Shamblin, and do any of the drawings that you 21 brought with you today indicate holes to be cut in structural 22 members to accommodate drain lines?
O
135 1 A I believe there are some in there. 2 Q Could you identify those, please? 3 A I can give you an example here. This is drawing 4 A669. This happens to be one of the three examples that the 5 NRC had in their item of noncompliance. This drain line here, 6 this is an isometric showing the auxiliary building 7 plumbing. It shows the plumbing line coming at an angle 8 there. 9 Q Can you identify that line so we can have a 10 reference? 11 A It's a 4-inch drain line. 12 Q Is there a number designation? () 13 14 A No. Drain line piping does not have that. MR. GILL: He is showing the area of D-5 on the 15 exhibit, approximately. Is that right? 16 MR. GUILD: Oh, yes. Coordinates. D-57 17 THE WITNESS: D-5, 18 BY MR. GUILD: 19 Q Approximately the middle of the drawing. 20 A Okay. The drawing for the structural steel calls.d 21 for a 6-inch opening through the web at elevation 424, 4 22 inches, in beam 6AB145.
136 1 Q How can you tell whether that is an opening for the 2 drain line that you have shown on a previous drawing? 3 A Essentially matching up coordinates of this drain 4 line. You can see this drain line is -- here is column line 5 13, here's column line Q. 6 Q Okay, 13Q. 7 A Again, here is column line Q, here is column line 8 13. 9 Q Now, the drawing you are showing me is a drawing 10 that was produced when? 11 A This drawing here was initially produced sometime 12 8/7/74. There have been numerous revisions. 13 Q Can you tell when the beam modifications, the 14 specification on this drawing was made, when it originated? 15 A In the case here, I have determined that the L 16 location was revised in approximately 1982, okay? I checked 17 subsequent revisions to the drawing and it showed a hole 18 through the beam. It was revised. based on a Byron change. i l 19 Shows that hole going through the beam there. 20 Q Again, can you track this drawing back to the point 21 at which the beam modification was likely made? l ! 22 A Yes, you can, by the revisions. l l
r 137 1 Q And have you done that? 2 A Yes, I have. 3 Q So is it your belief that there was a specification 4 on this drawing, on an effective drawing at the time the 5 modification was made calling for a hole and the point where 4 6 the hole was made?
'7 A Yes. And subsequently, when the issue was i 8 identified by the NRC, this reflects the actual as-built 9 condition.
- 10 Q You are looking at another drawing.
11 A It's the same drawing, just a later revision of it. 12 Q Now, what is the connection between the drawing you () 13 are looking at now and the NRC's identification of the item? 14 A This was one of the three that the NRC had 15 identified that the hole was not 6 inches in diameter, it IKWS 16 was 5-1/2Aby one foot. 17 Q So the NRC identified a beam modification, went to 18 the drawing, found the drawing called out a hole of a certain 19 diameter when the as-built condition reflected a hole of a 20 larger diameter. 21 A That's correct. 22 Q And subsequently the hole was -- the drawing was O
4 ) 138 1 as-built to reflect the condition of the hole in the field? . 2 A That's correct. Let me look at a couple others 3 here. . Here again is that same drawing, 1293. I just happen l 4 4 to have an even earlier revision prior to the one I showed 5 you, and it shows a 6-inch opening through the web at 424, 4 6 inches. You don't have to go all the way back, but this is, 7 again, another earlier revision. 8 Q And the size of the actual hole is a foot? 9 A It's an oblong-shaped hole one foot by 5-1/2 inches. 10 I have also looked at other drawings. There would be 11 architectural drawings which would show a plan view of the 12 floor drain piping, and they would designate in many instances ( ) 13 Size X diameter hole through steel, and then you would have to 14 go to the S drawing and also it will show it there. 15 Q At the time that the beam modifications were made 16 that were identified in Item 3B, were the modifications 17 themselves documented? , 18 A No. 19 Q Did the procedure call for documenting such i. i 20 modifications? i 21 A The procedure was silent. . 22 Q Did the erectors of the structural steel, the beams 4 O __ ., n._ _ _, _ . , , ... _ . . .-. , ,, , , _ ,. , , - . . - _ . _ - _ . . . . - . _ . , , . , , , , . _ . ,,._,,.n-,
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139 1 1 in question, work from the drawings that specified holes to 2 accommodate the drain lines? 3 A They may have worked from those same drawings, 4 yes. ihere were multiple parties who wo-ked from the S 5 drawings. 6 Q It is your belief, though, that the erectors of the 7 structural steel did not make the beam modifications? 8 A Yes. 9 Q What, then, if you.know, led Newberg to make the 10 beam modifications? 11 A They were issued out the drawings, same drawings, 12 showing the holes in them, and when they would be requested by ( ) 13 the Edison personnel to make the modification, they had the 14 correct craft to do the work and go ahead and make the 15 modification. 16 Q Was there any documentation of the Edison direction 17 to Newberg to undertake to make the modifications? 18 A Not that I khow of. 19 Q Have you looked for such documentation? 20 A No, I haven't. 21 Q Have you looked for documentation of the actual
.22 performance of the modification work?
9 O i --
140 1 A It is my understanding there is no documentation [I
\s- 2 that exists of the actual performance of the work.
3 Q And what led you to that conclusion? 4 A The NRC inspection report. 5 Q The NRC couldn't find any? 6 A That's right. 7 Q Have you looked for any? 8 A No, I haven't. 9 Q Has Edison looked for any? 10 A No. 11 Q Were the NRC findings correct with respect to the 3B 12 issue, the beam modification issue? ( ) 13 A I would have to read the inspection report. 14 MR. GUILD: Let's go off the record a second. 15 [Off the record.) 16 BY MR. GUILD: 17 Q Mr. Shamblin, I have given you the licensing file 19 from Edison's discovery responses with respect to item 3.b. 19 It should be the inspection report and the Edison response. 20 If you take a moment and review that, the question I had asked 21 was whether you agree with the NRC's findings on this issue. 22 MR. GILL: Do you have any further direction to him O
141 4 1 as to what section of the inspection report, or are we talking 2 about the entire report here? 3 MR. GUILD: I have no idea. The witness simply said 4 he needed the inspection report to be able to respond to the 5 question, and I provided him with the inspection report. 6 MR. GILL: I have an objection to it. He can go , 7 ahead and answer the question to the extent he can, but this 8 looks to me, without counting pages, to be a 20 to 25-page 9 report. I don't think the witness would be able to go through i ,10 and item by item agree or disagree with each finding in the 11 report. . 12 MR. GUILD: I'm interested in 3.b findings, and if j () 13 the witness can answer the question, I would appreciate it if 14 he would do so. l 15 THE WITNESS: On page 5 of this inspection report, 16 there is a number here at the corner, A0006548. It gives 17 three paragraphs dealing with this contention issue 3.b. Let 18 me read those three. 19 BY MR. GUILD: 20 Q I can ask you specific questions, if you like.
- 21 I'm just trying to save some time. And if you have something
- 22 that you disagree with in there, you can tell me that.
O 1 . _ , .-__ . . . - . . . _ _ - _ . - _ - . - - . - . . - . ----- - - - - - - - - - - - - -
142 1 (Witness reviewing document.] C\ (_,/ 2 A I would say there would be two aspects which I would 3 not be in full agreement with. In the third paragraph, the 4 NRC inspector states the failure to adequately control 5 modifications to beams by piping crews. It would be my belief 6 that the modifications to the beams were made by the 7 structural steel crews or the ironworker craft. 8 A second area where I would not be in full agreement 9 with the NRC deals with, in that same paragraph, the NRC says 10 "and had not established an adequate craft training program 11 with regard to nonsafety-related piping installation 12 activities resulting in field design modifications to the 13 safety-related structural steel." Since in my belief these ( 14 modifications were the result of inadequate procedure 15 implementation of the structural steel procedure on 16 safety-related structural steel, I do not believe that the 17 issue of craft training programs regarding nonsafety-related 18 piping installation activities enters into this picture. f 19 Q In your belief, it was inadequate procedural 20 implementation by whom? ( 21 A By the ironworkers employed by Gust Newberg. 22 Q Does that complete your answer? l
143 g 1 A Yes. ( 2 Q Do you agree that you had not established an 3 inspection program for structural beams that were modified . 4 during piping installation? I 5 A The procedure that would have been in effect at that 6 point in time, in my belief, did not have an adequate 7 inspection program established. . 8 Q You identified a document earlier that you brought 9 with you, NCR 806. Does that document relate to the 10 modification of beams issue? I 11 A Yes. l 12 Q And what is the scope of that document? 13 A This document -- NCR No. 806 records two instances 14 of holes in beams. The first instance was where the hole was 15 specified on the drawing and it did not exactly conform to the 16 drawing requirements. The second instance was where the hole j 17 was not specified on the drawing and it was flame cut to allow 18 the passage of drain piping. 19 Q And are those instances instances identified by the 20 NRC? ! 21 A No. l 22 Q Was the NCR before or after the NRC's inspection? I O l l i L
144 1 A After the NRC's inspection. 2 Q Was the identification of these beam modifications 3 reflected in NCR 806 prompted by the NRC's inspection 4 findings? 5 A Yes. 6 MR. GUILD: Let's mark this, please, the NCR 806. 7 [Shamblin Deposition Exhibit No. 5 8 was marked for identification.) 9 BY MR. GUILD: 10 Q Why is Mr. Kaushal the addressee of the transmittal 11 for the NCR? 12 A Mr. Kaushal is currently the project field 13 engineering manager at Braidwood. ( ) 14 Q And he is receiving this NCR in that capacity? 15 A Yes. 16 Q What is the status of the NCR in the form in which 17 it has been identified? 18 A The NCR, the nonconforming condition has been 19 identified. The cause of the nonconforming condition has been 20 identified. The action required to correct the nonconformance 21 has been identified. In this case it is to be determined by 22 the project engineering department, and the corrective action I
)
l l
145 1 taken to prevent recurrence of the nonconforming condition or 2 recommended corrective action to prevent recurrence has been , 1 3 put on a nonconformance. This essentially is in the condition i
- 4 where we are asking the Engineering Department to concur with 1
5 this information and also determine corrective action to 3 6 correct the nonconforming condition, which by our program is l l 7 their function. ! 8 Q Has the corrective action been taken yet? 4 9 A I was verbally advised that the engineering 10 disposition of this nonconformance will be to accept the 11 conditions as is. 12 Q And that disposition is simply yet to be documented l 13 on an NCR? ( }
- 14 A That's correct.
l 15 Q Now, these nonconforming conditions were only
!- 16 observed recently; correct?
- j. 17 A That's correct.
18 Q March 22, 1986? Is that the date they were found? { 19 A That's correct. L I 20 Q What led to identification of these additional i 21 instances of improper or nonconforming modifications of beams? 22 A In reviewing the NCR 740, I wanted to be sure that O
146 1 we had identified all situations, all instances of drain line, ; 2 that being roof and floor drain piping penetrating structural 3 steel beams. I requested that the technical engineers who are i 4 employed by Gust Newberg Company walk down all the drain line 5 piping in safety-related structural steel areas and note any 6 penetrations of structural steel beams. 7 They performed this activity and compared it against 8 the results recorded on NCR 740, and there were two additional 9 cases of drain line piping penetrating structural steel beams, 10 and we are asking for engineering disposition of those two 11 additional cases via this NCR. 12 Q Why were the cases identified in NCR 806 not ( ) 13 identified in the course of the disposition of NCR 740? 14 A From my review of the circumstances, the walkdown 15 underneath NCR 740 was not an all-inclusive 100 percent 16 walkdown. I wanted to have a 100 percent walkdown of all the 17 drain line piping. 18 Q What was the scope of the walkdown specified in the 19 disposition of 740? 20 A It just said drain line piping. 21 Q It sounds like 100 percent to me. 22 A It was not a 100 percent walkdown. The scope was G
147 1 for the drain line piping that Sargent & Lundy was performing 2 hanger designs on. 3 Q And there was additional piping to that? 4 A Yes. 5 Q And what did the additional piping consist of? 6 A Drain line piping. 7 Q Why was it outside the scope of the disposition of 8 740? 9 A I have not specifically determined that at this 10 point in time. 11 Q What led you to believe that there was a need for an 12 additional corrective action? 13 A When I reviewed the NCR 740, I wanted to make sure 14 we had caught all situations where drain line penetrated 15 structural steel beams. I did not get that assurance after 16 reviewing NCR 740, so I directed that a 100 percent walkdown 17 be conducted. 18 Q What was it about the disposition of 740 that led 19 you to doubt whether you had a comprehensive corrective 20 action? 21 A I did not get a warm enough feeling that we had 22 walked down all the drain line piping, that NCR 740 0
148 1 encompassed all the drain line piping in structural steel 2 areas. 3 Q Because of the specification that it included 4 Sargent & Lundy design hanger work? 5 A That was one reason. The other reason is I just did 6 not see the word "all" there, that it encompassed all the 7 drain line piping. 8 Q How many instances of nonconforming beam 9 modification were identified total in response to the NRC 10 items of noncompliance? 11 A I believe the total number of beams that were 12 identified that had holes through them were 51 beams in 13 total. That would encompass NCR 740 and NCR 806. In many of 14 the cases, the holes were specified on the drawing to be 15 there. The nonconforming condition was that they were oversize 16 or the hole -- they were flame cut and the hole had not been 17 dressed up. By dress up, I mean that the flame cut edges had 18 not been ground off. The other cases were situations where 19 the hole was cut and there was no structural drawing calling 20 for a hole to be there even though it was there to allow the 21 passage of drain line piping. 22 Q The hole was. O
149 1 A Yes. You can go back to the architectural plumbing ( 2 drawing, and by calculating the elevation of the piping and 3 the location of the piping, you can see that there needed to 4 be a hole through that beam. l i {. 5 Q But the drawing didn't specify cutting a hole? 4 6 A No, the drawing did not specify cutting a hole. I 1- 7 Q In that case, the drawing omitted the modification 4 8 that was required? 1 l 9 A Yes. i 10 Q How many instances did that occur in? 11 A I don't know the exact number. I think it was 12 somewhere around ten. ( } 13 Q Who was responsible for the drawing that omitted the 14 required modification? l 15 A The drawings would be prepared by Sargent & Lundy. 16 Q So a Sargent & Lundy specification or design , 17 document called for running the pipe through beams, but the i 18 actual working drawing didn't specify the beam modifications? 19 A That's correct. 20 Q A total of 51 beams. How many nonconforming i 21 modifications? 22 A I think the total was around 65 holes. O
150 1 Q Were the Newberg procedures for beam modifications 2 reviewed and approved by Edison and Sargent & Lundy? 3 A Yes. 4 Q Has there been any review of the unauthorized l 5 modification of structural beams to permit the passage of -
- 6 other piping or components aside from the drain systems? -
7' A The situation we have here is quite unique in the i 8 sense that drain line piping, by virtue of its location being 9 close to the ceiling and having to maintain a slope 1 10 requirement, would generally penetrate in many situations 11 structural steel beams. As the drawings show, there were many 12 cases that they were designed specifically to do that. Other () 13 piping does not generally hang close to the ceiling. You have 14 much more freedom in routing it. You can route it around i 15 structural steel beams. i 16 Q So it's your belief that the problem was isolated to i 17 the drain system? 18 A That's correct. j 19 Q Has there been a review made of the penetration of " 20 beams by other components or piping systems?
- 21 A There has been no specific review made of that. I 22 have sat with my engineers and asked them if they knew of any .
O
151 1 other instances of other components penetrating structural 2 steel beams and if there was to their knowledge any problem 3 there, and I received assurances from them that they knew of 4 no other instances of problems with components penetrating 5 structural steel beams. 6 Q Are there other structures aside from beams that the 7 drain system penetrates? 8 A The drain system may penetrate a concrete wall or a 9 masonry Wall. 10 Q And has there been a review made to determine 11 whether or not drain system penetrations of concrete or 12 masonry walls have been performed to specifications and /) NJ 13 procedures? 14 A No, and the basis for that is that there would have 15 been provided piping sleeves through the walls. Generally the 16 masonry walls were erected in a timeframe of after the drain 17 line piping was installed, such that you would build the 18 masonry wall around any drain line piping going through it 19 versus putting the drain line piping in afterwards. 20 With regard to concrete walls, there would have been 21 sleeves put in the wall, and there also has been in place a 22 site-wide procedure for core drilling of any concrete walls O
152 1 for piping-type penetrations. O (s /' 2 Q Test drilling? 3 A No. 4 Q When you say core drilling, what do you mean? 5 A By core drilling, it's a term we uce that would be 6 -- you would put, say, a three-inch hole in the wall. You use 7 a diamond bit core drill and you core through the concrete. 8 Q So in order to penetrate a concrete wall, you core 9 drill; is that what you're saying?
, 10 A You core drill a hole through it, yes.
11 Q And has there been any review made to determine 12 whether penetrations through concrete walls have been () 13 14 performed according to the specification and procedure? A There have been throughout the time period numerous 15 audits of these core drilling activities. 16 Q Any such reviews performed as part of the 17 disposition of the item of noncompliance reflected in 3.b? 18 A No. It was felt that there was no need to perform 19 this review on the basis of the ongoing existing programs for i 20 controlling core drilling activities. 21 Q Have you identified any nonconforming conditions of 22 modifying or core drilling concrete walls for drain lines? l O i
153 1 A No. O k/ s 2 Q Any other structures, aside from beams and walls, 3 that drain lines penetrate? 3 4 A No. 5 Q How about hanger members or support columns, 6 structural steel plates? 7 A The hangers would be installed generally after the 8 floor drain piping was installed, and you can always move the 9 hanger to miss a drain line. I'm sure there have been 10 instances where that has happened on the job, where the hanger 11 has had to be removed to clear drain line interference. 12 Q How about support columns or structural plate? () 13 A You generally would not -- a column is a vertical 14 member. You can route a drain line around a column and still 15 maintain slope. 16 Q Have you reviewed any other structures that drain 17 lines penetrate to identify unauthorized modifications? 18 A I think we have covered the waterfront as far as 19 identifying the structures that a drain line would penetrate 20 the beams. 21 Q Are you familiar with the subcontention of the 22 Intervenors that relates to harassment and intimidation of O
154 1 quality control inspectors? 2 A Yes. 3 Q What was your involvement, if any, in responding to 4- the March 29, 1985 concerns expressed by L.K. Comstock quality 5 control inspectors? 6 A I was a part of the Edison management group that met 7 with the NRC the afternoon of March 29, 1985 and heard from 8 the NRC the list of the L.K. Comstock QC inspectors' 9 concerns. Then I met with, after that, hearing that list, I 10 met again with part of the management team that put together 11 the short-term and long-term action plan to address those 12 concerns and was part of the team that addressed certain of ( } 13 the concerns, primarily in the management issue concerns, and 14 investigated them and put together the report dealing with 15 those concerns. 16 Q Who else was present from Edison on March 29th to 17 hear the Comstock concerns? 18 A There were Mr. Tom Maiman and Mr. Gene Fitzpatrick. 19 Q And where did you meet? Where did the Edison people 20 meet? 21 A Excuse me? 22 Q Where were the Edison people? Where did you meet O
r I
< 155 j 1 when you met with the NRC? ,
l- 2 A We met in the resident inspector's office. 3 Q And when did you do that? ) 4 A That was on the afternoon of March 29th.
- 5 Q And who else was present?
i j 6 A I believe it was Mr. Maiman, Mr. Fitzpatrick, NRC ! 7 resident inspector Lynn McGregor, Bob Schultz, and then we had 8 on the telephone in a conference call type situation members 9 of the NRC regional staff. Amongst them were, I think, 10 Mr. Cordell Williams, Mr.. Bill Forney, I think Mr. Roger I. 11 Mendez. The rest of the people escape my memory. 12 Q Do you recall Mr. Keppler or Mr. Davis 13 participating? ( 14 A I don't recall them participating. 15 Q How did you learn of the concerns by the Comstock 16 inspectors?
- 17 A It was in this meeting with the resident inspectors i
4 18 and their management by phone that we learned of the concerns. l 19, Q Let me back you up. How did you learn of the 20 existence of the concerns? How did you come to the meeting at ) 21 the resident's office? 22 A I had gotten a call from, I think it was, Gene l i i O
r 156 1 Fitzpatrick to go to this meeting. I 2 Q And who is Mr. Fitzpatrick? 3 A At that point in time he was assistant manager of 4 quality assurance. 5 Q At Braidwood? 4 6 A Yes. There was a corporate position, but he was i . 7 specifically assigned to the Braidwood project. , 8 Q What is Mr. Fitzpatrick's position now? , 1 9 A He is the Braidwood station manager. i ! 10 Q For operations? 11 A Yes. 12 Q Okay. Mr. Fitzpatrick called you, and what did he 13 have to say? ( ) 14 A He said that there was a meeting with the residents j i 15. f at approximately, I think it was, 1:30 or so to get on a ! 16 conference call with the Region; that there was a concernt r 17 that a group of Comstock inspectors had gone to the resident's [ 18 office and expressed a list _of concerns. t 19 Q And was that the first that you had heard of the l 20 action by the inspectors? I L 21 A That is right. i f 22 Q Did Mr. Fitzpatrick tell you how he learned of the i t I i t l l l 1 , (
157 1 action by the Comstock inspectors? ()
- s. 2 A He stated he had been contacted by the resident 3 inspectors.
4 Q So you went to -- did you speak with anybody cice at 5 Edison before you went to the NRC resident's office? 6 A Gene had asked me to get ahold of Tom Maiman since 7 Tom was on site that day. I think I had gotten ahold of Tom 8 Maiman and told him about the meeting for 1:30. The meeting 9 was subsequently moved up and I had to find Tom and get him 10 over there. I sent people out -- he was out in the field, and 11 I sent people out looking for him. So the only person I would 12 have spoken to prior to the meeting would have been Tom O 0 13 Maiman. 14 Q Okay. You went to the meeting, and the NRC 15 residents related what they had been told by the inspectors; 16 is that correct? 17 A That's correct. 18 Q And did they appear to be talking from memory or did 19 they have notes?
- 20 A They were talking from notes.
21 Q Have you subsequently seen any documents reflecting
- 22 the concerns of the Comstock inspectors?
i !O i 4
- ~ . - , , , , . - - . - _ , - - . . - ~ . - , - - , - -,---,-.------.-.-----,-,,,-n,
. a ~ ,e. - --
158 1 A There was a document that appeared to be an internal 2 NRC memorandum that had come to my attention sometime after 3 this whole incident. 4 Q And how did that cc=c to your attention? 5 A I think it came through one of my engineers, who had 6 gotten it from a Comstock inspector. 7 Q Did it list the names or identifying information 8 regarding Comstock inspectors? 9 A From what I can remember, the names were blanked out 10 on the document. 11 Q Are you a signatory to an affidavit of nondisclosure 12 in this proceeding? I ') 13 A Yes, I am. V 14 Q Have you received protected information subject to 15 the Licensing Board's protective order? 16 A Let me answer this way. I have not received any 17 information regarding this subcontention item since I signed 18 that document. 19 Q Have you received a copy of the unexpurgated 20 versions of the March 29th and April 5th, 1985 memos without 21 the names blanked out? 22 A No, I haven't. O
?
159 i 1 Q Can you recall the engineer who made available the (} 2 lanked-out version of the NRC memo? , , 3 L A No, I can't. 4 0 Did he provide you copies of any other documents t 5 associated with that memo? i' 6 A No.
- 7 1 Q Have you ever seen, for example, a BPI transmittal j; 8 letter or memo to Comstock inspectors?
9 NA No. . 10 ,Q BPI, Business and Professional People in the Public 4 11 Interest.
- , t 12 I ,2 A The only addiNIonal information I would have seen 13 would have been what would have been attach 3d to any public
[ )
- 14 document if you put out anything in your contention that had i
i (
- 15 your letterhead on it! I think I remember there may have been
, i 16 $ a document that had your letterhead on it. I'm not exactly 3 17 sure on that. ! 18 Q You don't recall such a document coming from your p < i j 19 engineer? , 20 A No. This came through our normal licensing 21 distribution. 22 Q What action did you take after the NRC residents l l l i s t I I i i
160 1 described the concerns that they had heard from the Comstock
,~
2 inspectors? 3 A We came back to, I think it was, Gene Fitzpatrick's 4 office, and I at that point in tima called Irv DeWald, who was 5 the L.K. Comstock QC manager, and asked Irv what he knew about 6 the specific situation. He informed me that he was aware that 7 there had been two groups of individuals who had gone over to 8 the NRC. The first group in the morning went over -- he had 9 initiated an investigation of the situation involving 10 Mr. Saklak and the QC inspector, and the second group he just 11 was aware had gone over to the NRC. 12 After finding out that information, we met with
h 13 Misters -- I met with Tom Maiman, Gene Fitzpatrick, and Tom (G
14 Quaka, who is the quality assurance supervisor on site joined 15 us, where we developed the action plan. We developed, I 16 think, a short-term and a long-term action plan. The elements 17 I don't recall exactly. I would have to refresh myself with 18 documents. 19 Amongst them were included we decided to take an 20 administrative action to relieve Mr. Saklak of his duties 21 until such time as there was a full investigation of this 1 22 matter. We also decided, I think, at that point in time to l ,- 1
, 161 1 send a communication to Comstock stating that they should
(~~) w/ 2. fully abide by their quality program. I think we decided at c- . *
' '3 '
.;,_., ,; that point in time to establish a meeting with Comstock 4 in'spectors for the following Monday. There were other points 15 to the action plan which, without seeing documents, I can't J
6 recall. ,' , 7 < Q Ok'ay. What had the NRC residents stated to you, if 5 8 anything, at the initial meeting aside from recounting what
- 9. the QC inspectors had told them?
10 A The NRC residents basically asked us if we were 11 aware of any of those issues, and I think we responded in the 12 terms that many of the issues which they were bringing up had 13 been previcusly identified in data base interviews we had ( } 14 conducted with the quality control inspectors and we were in 15 the process of doing investigations on those data base 16 interview items. 17 Q Let me interrupt you a second. The data base 18 interviews, were those the Quality First program interviews? 19 A One of the aspects of our Quality First program is 20 to conduct a series of data base interviews with all 21 management-type personnel on the site and specific union and 22 craft personnel on the site to establish a data base baseline. O
162 1 Q And that's what you are referring to? 02 A Yes. There had been a series of data base 3 interviews conducted with all contractor QC inspectors and 4 Comstock, which is one group of QC inspectors that had had 5 data base interviews conducted within the last two months. 6 Q I'm sorry, I interrupted you, but you identified 7 data base interviews as one source of prior information that 8 you received. 9 A That's correct. 10 Q And what else did you receive? 11 A The other thing we identified to the NRC that many 12 of the concerns or some of the concerns were similar to issues f\ G 13 that had been brought up the previous fall dealing in some low 14 morale problems we were having with the Comstock QC inspectors 15 which we had taken action on at that point in time, which we 16 had relayed that action to the NRC resident inspector and he 17 knew about those. 18 Q You relayed that to him when? 19 A The previous ,ald h p, 20 Q At that time? 21 A Yes. And I think it's documented in one of the 22 inspection reports, this relaying of the information to him.
163 1 We also relayed to the NRC the issue that there e 2 was a unionization movement ongoing with the QC inspectors and
- 3 that they should be aware of this unionization movement; that 4 at that moment in time, the Comstock inspector certification 5 election was in the process of being appealed by Comstock, it 6 had been in an appeal process for a considerable amount of 7 time, and that the inspectors were concerned about this and, 8 we think, were using some of their actions to put pressure on 9 the Comstock management.
10 Q And you stated that, in substance, to the resident 11 inspectors? 12 A Yes. ( ) 13 Q Were the resident inspectors previously informed of 14 the existence of a union certification drive and bargaining? 15 A I think they may have been informed. We communicate 4 16 with them quite regularly, and I think we had told them about 17 the fact that the -- well, I know we had told them that the QC 18 inspectors were organizing at Comstock. 19 Q Did the NRC residents at the March 29 meeting 20 express any surprise at your statements regarding the pendency 21 of a union drive? 22 A I don't really recall whether they did or not. O 1 i.
164 1 Q As far as you know, they had been previously 2 informed about it. 3 A I had personally spoken to the residents regarding 4 the unionization effort on the job site to make them aware 5 that it was going on. 6 Q okay. Can you recall when you did that? 7 A Back in the fall of 1984 when the union organizers 8 were appearing on the job site. 9 Q I had asked you generally what the NRC asked you in 10 the March 29 meeting. You said generally they asked had you 11 previously been aware of these concerns, and you were relating 12 an answer to that and had gone through several points of prior () 13 14 familiarity with Comstock inspector concerns. Was there anything further that you told the NRC 15 residents March 29th? 16 A I think I told the NRC that in respect to the 17 concerns that were expressed in the fall of 1984, we feel that 18 we had adequately and sufficiently addressed those concerns 19 and had taken appropriate action regarding those concerns. 20 Q I will show you a letter of April 1, 1985 from 21 Mr. Paserba to you from Comstock. Can you identify that 22 document? O V l
165 1 A This was a response letter to my letter No. 288. OV 2 Without having Letter No. 288 in front of me, I believe it is 3 responsive to the letter regarding the fact that we wish 4 Comstock to enforce their Policy Statement 1.0.0. We directed 5 them to enforce that policy statement. I don't know if 283 6 specifically requested an off-site investigation team. I would 7 have to check that out. But they have said they were going to 8 have this off-site investigation team come in starting April 9 2, 1985 to look into the matter. 10 Q You received that from Mr. Paserba? 11 A Yes. 12 MR. GUILD: Will you mark that, please, Exhibit 6. 13 (Shamblin Deposition Exhibit No. 6 fv 14 was marked for identification.] 15 BY MR. GUILD: 16 Q As part of your action plan, had you directed l 17 Comstock to enforce their Policy Statement 1.0.0? 18 A Yes. I think that is one of the action items. 19 Q And what it that policy? 20 A I believe it deals with the overall policy of 21 Comstock regarding quality assurance and their whole quality 22 program. I would have to have a copy of the statement in front 1 m l
166 i 1 of me, Policy Statement 1.0.0, to really fully explain it. 2 Q Well, this policy presumably speaks for itself, but 3 how did you understand Comstock's commitment embodied in this 4 April 1 letter when they state that: "Comstock Engineering, 5 Inc. has enforced Policy Statement 1.0.0 relative to the QC 6 inspector concerns."? What does that mean? 7 A To the best of my knowledge in terms of the
; 8 situation that was happening at that point in time -- and 9 again, without seeing the policy statement and my letter 288 10 -- it dealt with the point of any harassment of QC inspectors.
11 Q So it presumably directed personnel to refrain from 12 harassing QC inspectors. (} 13 A Again, without seeing the statement itself, in my 14 recollection of it is a very broadly-worded statement, and I 15 would really need to see the statement itself. i 16 Q Do you know whether that statement has been 17 identified in discovery? ! 18 A I don't know. 19 MR. GUILD: If I could, Mr. Gill, ask that a copy of 20 that policy. statement in relevant part be made available. 4 21 MR. GILL: I will just add it to the list. 22 BY MR. GUILD: 4
- O I
._ .. . _ - - - . . _ - . ~
167 1 Q The third item is, " Based upon the results of this 2 investigation" -- the one referred to in Item 2, the off-site 3 investigation, as you characterized it - "the future status 4 of the Comstock QA/QC personnel will be finalized." What 5 personnel did you understand Mr. Paserba of Comstock to be 6 referring to? e 2 7 A I believe he may have been referring to Mr. Saklak. 8 Q Was Mr. Saklak a QA/QC personnel? 9 A Yes, he is. 10 Q He is a QC person. 11 A He was a QC supervisor. 12 Q Right. He wasn't a QA supervisor. ()13 A No. He was a QC supervisor. 14 Q In my reading of that statement, it appears to be 15 . ambiguous and include potentially -- the reference to 16 personnel in the plural, did you understand it to extend, for 17 example, to the quality control inspectors who were the source 18 of the concerns? 19 MR. GILL: Objection. Asked and answered. I think i 20 he said his understanding was Saklak, but he can answer it 21 again. 22 THE WITNESS: Based on my recollection at this point O
168 1 in time, I would believe that was referring to Mr. Saklak. 2 BY MR. GUILD: 3 Q Okay. And not to the quality control inspectors, as 4 best you recall? 5 A It may be referring to them, but based on my 6 recollection at this point in time, I would say it was 7 referring to Mr. Saklak. 8 Q Well, is there some document that would refresh your 9 recollection of that as to how you understood the statement by 10 Mr. Paserba at the time, April 1, 1985? 11 A Probably my Letter No. 288 and the policy statement. 12 Q I will show you a package of three documents. The 13 ( ) first bears a date of May 17, 1985. It appears to be from 14 Mr. Saklak to you. The second is a letter of June 6, 1985 15 from you to Mr. Saklak. The third is a June 6, 1985 document 16 from you to Mr. Marino of Comstock. 17 A Yes. i 18 Q Can you identify those, please? 19 A The first document, dated May 17, 1905, was the 20 letter I received " Registered Mail" from Mr. Saklak. The 21 second document is a letter dated June 6, 1985, Letter 22 No. BR/PCD85-497, addressed to Mr. Richard Saklak, sent O
i 169 1 " Certified Mail," in which I was responding to his May 17, 2 1985 letter. The third letter is a letter dated June 6, 1985, , 3 Letter No. BR/PCD85-496, to Mr. R. Marino, General Manager, i 4 QA/QC Services of the L.K. Comstock Engineering, Inc., in which I was forwarding to Mr. Marino Mr. Saklak's May 17, 1985 5 6 letter for him to respond to it. 7 Q And you included a copy of your Marino letter in 8 your response to Mr. Saklak, did you not? 9 A Yes. 10 MR. GUILD: Let's mark these three letters, please, 11 Group Exhibit 7. 12 (Shamblin Deposition Group Exhibit No. 7 13 ( ) was marked for identification.] 14 BY MR. GUILD: 15 Q Mr. Saklak in his May 17 letter to you, 16 Mr. Shamblin, among other things, states, "I am writing to you 17 in hopes that you could possible shed some light on my 18 discharge with the L.K. Comstock Quality Control Department. 19 The basis of this request from you is due to the lack of 20 details I have received from L.K. Comstock management. As it 21 was put to me the day of my meeting with the L.K. Comstock 22 corporate staff" -- Mr. Saklak presumably quotes - "'It's out l O-l _ _ . - . .~. . - . . _ _ . . - .
170 1 of our hands.'" 2 What was the basis for Mr. Saklak's discharge from 3 Comstock? 4 A It was my understanding that the investige. tion that 5 was conducted had concluded that Mr. Saklak did indeed use 6 verbal abusive language against and threaten a Comstock 7 inspector. On the basis of that investigation results, myself . 8 and Gene Fitzpatrick issued a statement or -- no, we didn't 9 put it in writing, but we told Comstock three things. One was 10 that Mr. Saklak was barred from future QC inspector activities 11 at the Braidwood site and any other Commonwealth Edison 12 nuclear facility; two, he was also barred from performing any ( ) 13 other safety-related activities at the Braidwood site or any 14 other Commonwealth Edison nuclear facility; and three, that we 15 recommended that he not perform these activities at any other , 16 nuclear site. )
- 17 On that basis, Comstock did not have any work for j 18 Mr. Saklak. Since he was barred from the Braidwood site and 19 they did not have any work for him in nonsafety-related ,
20 activities, and he was barred from the Braidwood site to [ 21 perform safety-related activities, thI subsequently discharged
/
22 him. ht ; I O h w- r w-* y -,- w - r - - = m .-w -- -, --% ,. m ew ,, . . .,..e =**em-- e,-- -4 < . -~% u. e. +e--m
171 1 Q They laid him off? f'\
\ssl 2 A I don't know if they laid him off or if they fired 3 him, and I never saw any copies of his termination papers.
4 Q Did Edison take a position with Comstock one way or 5 the other whether Mr. Saklak should be laid off for lack of 6 work or terminated for cause? 7 A Excuse me. Would you repeat your question? I was 8 reading this. 9 Q Sure. Did Edison take a position with Comstock as 10 to whether Mr. Saklak should be laid off for lack of work or, 11 in the alternative, discharged for cause? 12 A No, we didn't. We, as my June 6 letter here to ( ) 13 Mr. Marino stated -- and I will read this: "Specifically, I 14 told you it was Commonwealth Edison's position that 15 Mr. Richard Saklak be removed from L.K. Comstock QA/QC 16 position at the Braidwood nuclear power station and that 17 Mr. Richard Saklak will not be employed in any other QA/QC 18 role or safety-related role for any other contractor at the 19 Braidwood nuclear power station or any other Commonwealth 20 Edison Company nuclear site. 21 "Mr. Saklak is not barred from any of our nuclear 22 sites in any other roles." What we meant there was if he
172 1 could perform a role in a nonsafety-related area. 2 Further on my letter states, "We recommend to the 3 L.K.Comstock Company, Inc. that Mr. Richard Saklak not be 4 employed at any other L.K. Comstock nuclear site in any QA/QC 5 role." 6 Q And does that letter to Mr. Marino reflect what you 7 and Mr. Fitzpatrick had orally told Comstock? 8 A Yes. 9 Q Who did you and Mr. Fitzpatrick speak to at Comstock 10 when you orally informed them of this position? 11 A I spoke to Mr. Marino. The letter, I think, 12 reflects that, the date of the conversation. ( 13 Q Did you talk to him by phone or in person?
;_ 14 A I talked to him by phone in his motel room that
! 15 night. 16 Q Had you discussed this action with any other Edison 17 person besides Mr. Fitzpatrick? 18 A I believe we had discussed it with Tom Maiman. He 19 was aware of the action that we were taking. 20 , Q And what was Mr. Maiman's contribution? Did he 21 approve the action, make any comment on it? 22 A I believe he concurred in the action. O l
173 1 Q Did he recommend any changes or modifications to () 2 your proposed action? 3 A None that I can recall. 4 Q I'm trying to see if there is a reference in this 5 correspondence. I recall.somebody referring to Edison 6 exercising its contract with respect to Mr. Saklak's' 7 termination, and I understood in context that to suggest that 8 Edison had a contractual right to call for the removal of a 9 site contractor person. Is there a contract right that 10 Edison has to that effect? 11 MR. GILL: So we are clear, I think the reference to 12 that comes from Mr. Saklak's letter, and also I would object ( ) -13 on the basis of this witness' qualification to reach a legal 14 conclusion on that, but he can go ahead and give his 15 understanding. 16 MR. GUILD: I'm not asking for a legal conclusion. 17 THE WITNESS: I think the letter that I wrote to 18 Mr. Marino reflects the fact implicitly that we were barring i 19 him from safety-related -- we were barring him from QA/QC 20 activities with Comstock and also from a safety-related role 1 21 at the Braidwood site. From a contractual standpoint, we ! 22 would do that under, I think it is, our Clause 45 of our l lO l
174 1 Exhibit C. I don't recall the specific title of that, but in 2 my view it gives us the latitude to take the action that we 3- took there as reflected in my letter to Mr. Marino and as 4 reflected in my conversation with Mr. Marino of April 2nd. 5 BY MR. GUILD: 6 Q Clause 45 of Exhibit C to what? 7 A To the contract between Commonwealth Edison and 8 L.K. Comstock. 9 Q And is there a comparable provision with other 10 contractors? 11 A Yes. Every one of our field contracts has an Exhibit 12 C. 13 - Q And has Edison exercised its rights under that 14 contractual provision to remove personnel other than 15 Mr. Saklak? 16 A Yes. , 17 Q Can you tell me the circumstances under which it has 18 done that? i 19 A We have exercised it in terms of personnel who 20 violate the drug and alcohol policy on the site. We also have 21 had instances where we have had unfit personnel on the job 22 site, and we have exercised it in terms of the unfit 1 LO t-
r 175 1 personnel. 2 Q And how do you use the term " unfit personnel"?
.3 A The person was doing damage to company property and 4 we exercised it in terms that we declared that he was unfit.
5 Q That's a particular instance that you are referring 6 to? 4 7 A That's right. i . 8 Q Have you ever exercised it under circumstances where 9 a supervisor was alleged to have harassed or verbally or 10 physically abused a person under his supervision?
-11 -
A None that I can recall. 12 Q can you give me an estimate of a number of persons 4 ( ) 13 for whom such a right has been exercised, with regard to whom? 14 A Probably less than ten. 15 Q How many people all together who have worked at the 16 Braidwood site have been subject to such a provision? 17 A Thousands. 18 Q Was the basis for exercising that provision, taking 19 the action that you did in Mr. Saklak's case, based solely on 20 the Comstock findings with respect to Mr. Saklak and
- 21 Mr. Snyder, the instance of verbal abuse?
22 A In this case, yes. 4-O l I l t 1 i
176 a' 1 Q Did Mr. Saklak's prior conduct play any role in 2 Edison's action? 3 A It definitely had a bearing on the final decision. 4 Q In what way did it have a bearing? 5 A Well, there had been some previous incidents . 6 regarding Mr. Saklak, and those were taken into account in the 7 overall evaluation of the findings of the Comstock 8 investigation team. 9 Q Did you rely, though, on the results of the Comstock 10 investigation? 11 A I had input from members of my staff, and I think 12 Gene had input from members of his staff. 13 can you tell me who you consulted on your staff? ( ) Q , 14 A I would have consulted Jim Gieseker. He would have 15 been the primary person I would have consulted. 16 Q What did Mr. Gieseker contribute on this question? 17 A Mr. Gieseker confirmed to me that the incident that 18 happened, I think it was on March 28th, did happen. 19 Q How about anything else. Anything with respect to 20 Mr. Saklak's prior conduct? 21 A He refreshed my memory that we had had a previous 22 incident with Mr. Saklak some time ago. !O l [ _ _ _ _ _ _ _ _
an 177 1 Q Do you recall what that incident was? 2 A No, I don't. 3 Q Do you recall the name John Seeders? 4 A Yes, I recall the name John Seeders. 5 Q Was it an incident involving Mr. Seeders? 6 A I don't think this was an incident involving 7 Mr. Seeders. 8 Q Were you aware of an incident between Mr. Saklak and 9 Mr. Seeders? 10 A Yes, I am aware of an incident between Mr. Saklak 11 and Seeders. 12 Q Aside from that incident, can you identify the other I'T 13 previous incident that Mr. Gieseker brought to your attention? O 14 A No, I can't. I don't have any recollection of that. 15 Q Who did Mr. Fitzpatrick consult, if you know? 16 A I think he may have consulted with Mr. Tom Quaka or 17 Mr. Ed Netzel. 18 Q Do you have any information about what 19 Mr. Fitzpatrick learned from them? 20 A No. 21 Q You earlier mentioned that you were responsible for 22 investigating management issues with respect to the Comstock
]/
178 1 inspectors' concerns; correct? D d 2 A- Yes. 3 Q Can you tell me what that involved? l 4 A Well, we took the approach to these concerns, since ; 5 many of them were items that were already delineated in the 6 Quality First data base interview folders which we had, which 7 had already been assigned to the Construction Department to l l , 8 follow up on, and there were some new items that were i 9 identified to us by the NRC, we segregated the issues or 10 concerns into management and, I think, quality, and then broke 11 them up to certain. individuals to do investigations on. 12 The quality issues were primarily investigated by 13 members of the Construction Department, the Quality Assurance ( l' 14 Department and Quality First working in concert together. The 15 management issues were primarily investigated by myself. i 16 Q And who, by name, was responsible for the quality
- 17 issues?
i 18 A It would have been Ray Preston, Tom Quaka, Ed Netzel 19 and Jim Gieseker. l l 20 Q And did you complete the investigation of those l-21 issues? 22 A Yes. O l l L_ -- - - - - - - - -
l 179 1 Q And when did you do that? 2 A I think we had completed them prior to April 15, 3 1985. 4 Q And what findings did you make on those issues? 5 A I don't really recall a lot of the details of the 6 findings or the conclusions. They are all in the folder that 7 encompasses all the information. In general, most of the 8 management issues were unsubstantiated, or those that were 9 substantiated were known already and there were actions either 10 under way to correct them, if needed, or they were issues that , 11 were not going to be corrected because they were not of 12 significant enough concern to require correction. ( 13 Q You earlier stated that a number of the issues had 14 been identified in the fall of 1984 and corrective action was 15 taken with respect to issues at that time; correct? 16 A Yes. 17 Q Were there management issues identified at that 18 time? 19 A Yes. 20 Q And can you identify those? 21 A There were complaints about pay which were, I think, 22 one big area; complaints about the management in general: "I l lO
180 1 don't like my boss" type complaints. 2 Q How about "My boss is incompetent" type complaints? 3 A I don't really remember there was anything that had 4 to do with the boss being incompetent. 5 Q You didn't review any issues involving the 6 competence of Comstock management? 7 A I believe that Comstock management is fully 8 competent. 9 Q That may be your conclusion, but I guess the point 10 is did you review any issues involving the competence of 11 Comstock management? 12 A No. 13 ( ) Q In the fall of '84 or spring of '85? 14 A Without looking at the record on the investigation 15 in the spring of '85, I don't believe we had anything in there 16 on competency of the management, but I have to again look at 17 the record. 18 Q Do you recall in the spring of '85 having looked 19 into the issue of Comstock management's competence? 20 A No. 21 Q Have you observed the work performance of Comstock's 22 quality control manager, Mr. DeWald?
- O
-y- . . _ . - . , .
181
- L A Yes.
2 Q Do you have an opinion as to the quality of 3 Mr. DeWald's work performance? 4 A My opinion would be that Irv is a very competent and 5 conscientious Qc manager. 6 Q Have you identified any weaknesses in Mr. DeWald's 7 work performance? 8 A No. 9 Q Did you investigate any concerns with respect to 10 production pressure on Comstock inspectors characterized by 11 them generally as sacrificing quality for quantity? i 12 A I think those would have been classified as , ( ) 13 quality-related concerns and those would have been done by the 14 team that did the quality-related aspects. ' I i 15 Q Did you investigate any of those issues yourself? 16 A Probably the only investigation I would have done : 17 would have been in conversation with Comstock management
. 18 regarding their work scheduling practices. l 4
19 Q And did you have such discussions? l ! 20 A I believe I had some discussions with them. 21 Q In the spring of '85? 22' A Yes. b
?
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, - _._.,_.r, . _ _ . _ . , _ _ _ _ _ - _ _ _ . _ . _ _ _ . . , _ . _ _ _ _ . . _ , _ _ _ _ _ , . - _ _ _ . . - _ _ , _ _ , . _ , _ _ _ _ - . . , _ . . _ _ _ _ , _ _ , _ _ _ . _ , _ . , _
182 1 Q And what were those discussions? (
\ 2 A I asked them how they scheduled people.
3 Q Who were you speaking to? 4 A Mainly Mr. DeWald. 5 Q And what did Mr. DeWald say on that subject? 6 A He told me that he did not sacrifice quality for 7 production. 8 Q Did you ask Mr. DeWald whether he employed goals, 9 quotas or production measures for his quality control 10 inspectors? 11 A No, I didn't ask him that question. 12 Q Did you discuss that issue, either at your ( ) 13 initiative or Mr. DeWald's? 14 A I don't think I discussed that question with him at 15 my initiatigui and I don't remember him relaying any 16 information regarding that. I do remember some information 17 coming out on that as part of the team that was investigating 18 the aspect of the production pressure over quality. 19 Q And who did that? 20 A That was the team that was investigating the 21 quality-related aspects. 22 Q Did it ever come to your attention, Mr. Shamblin, O
183 1 that Comstock employed measures of inspector productivity such 2 as, for example, five hanger inspections per day? 3 A I think it came out as part of the investigation L 4 that was conducted regarding these concerns that there were 5 some of that. kind of productivity-related measures employed. 14-6 h my view'would not be unusual to measure personnel's i 7 performance, whether they be production or quality control 8 related personnel. You have to have something to judge a 9 person on at a time of evaluation, but you have to take into 10 account also the specifics of the situation. 11 I mean say a person has to do five things in a given 12 period of time, but it's how hard or how easy. If your . 13 measure is five average things and he has to do hard things i 14 all the time, you have to take that into account when you 15 measure against that five. That's assuming, let's say, he 16 only did two. Those two hard things may be equivalent to the 17 five average. On the same line, if he completes ten but they i , 18 are ten easy things, that had to be taken into account where 19 maybe ten easy things could be done in the time it took to do 20 two average things. That always has to be taken into account 21 in any type of productivity measurement of any individual. 22 Q Did you conduct any investigation to determine O l__ _ _ _ _ -- -
E 184 1 whether or not Comstock was appropriately employing production
) 2 measures in scheduling the work of its quality control 3 inspectors?
4 MR. GILL: Is this him personally, now, or Edison? 5 BY MR. GUILD: 6 Q Did you understand the question? 7 A I didn't conduct anything like that. 8 Q Are you aware of Edison doing that, or Comstock 9 doing that? 10 A I think there may have been as part of their overall 11 work planning sequence, they would plan the work, and that may 12 have been an aspect of it. I'm not positive on that. 13 Q My question, I guess, is whether or nct Commonwealth (~)') 14 Edison reached any determination as to whether Comstock 4 15 appropriately employed such production measures in scheduling 16 its quality control inspector work. 17 MR. GILL: Mr. Shamblin, if you know the answer to 18 that question, go ahead and answer it, but don't speculate or 19 guess at it. 20 THE WITNESS: I don't know the direct answer to that 21 question. I would have to look in the Quality First file of 1 22 the investigation-because that was an aspect of the concerns, O V f P
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F i 185 1 and I would have to refresh my memory regarding our results (/) x_ 2 regarding that particular item. 3 BY MR. GUILD: 4 Q You don't have any personal knowledge at this time? 5 A No, I don't. 6 Q Do you recall a meeting in January of 1985 with 7 Comstock management at which 1985 production and schedule 8 goals were presented by Edison management to Comstock? 9 A No, I don't. i 10 Q Do you recall a meeting of such sort at any time? 11 A Yes. I think we had a meeting between Commonwealth 12 Edison and Comstock at which time Comstock presented their 13 goals for 1986 to Commonwealth Edison. ( ) 14 Q Okay. So you recall an '86 meeting. 15 A I'm sorry, '85 meeting. 16 Q okay. So you recall the presentation being the 17 other way around, Comstock presenting to Edison? 18 A Yes. 19 Q Do you recall those goals being presented in the i 20 context of scheduling milestones or deadlines that were 21 provided to Comstock by Edison?
- 22 A The overall project milestones would have been l
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186 1 provided by Edison to Comstock for them to work with and it 2 would have been up to them to schedule the specific goals, 3 whether they be installation rates, manpower required, et 4 cetera, to meet those overall goals. 5 Q And they were in this instance? < 6 A They gave to us what they felt would be their 7 production rates and their manpower levels necessary to make 8 those production rates. 9 Q Do you recall Comstock management ever expressing 10 concerns, reservations about the ability to meet Edison 11 schedule requirements and milestones given their resources? 12 A There were some reservations expressed. There
, 13 generally always is at goals-type meetings with contractors 14 regarding the ability to meet a goal with the given resources, 15 and we authorized them to go out and get any additional 16 resources they needed to meet their goals.
17 Q You did that for Comstock? 18 A We have done it for Comstock. We have done it for 19 other contractors also. 20 Q In the January '85 timeframe, do you recall Comstock 21 expressing reservations about the ability to meet the Edison 22 schedule milestones?
187 1 A Yes. 2 Q And did you authorize more personnel or resources at 3 that time? 4 A Yes, we did. We authorized them to obtain 5 additional craft manpower plus additional QA/QC personnel 6 necessary to meet the project milestones. 7 Q Did you authorize Comstock to obtain the additional 8 quality control / quality assurance personnel that they sought? 9 A Yes. 10 Q Has Comstock ever been behind in meeting inspection 11 schedules? To put it another way, has there ever been a 12 significant inspection backlog at Comstock? ( 13 A Yes, there was.
}
14 Q And when was that? 15 A That was in the summer of 1984. There was a large 16 inspection backlog just after I took over as construction 17 superintendent. This was identified to me by our Quality 18 Assurance Department. 19 Q Can you recall the magnitude of the backlog? 20 A It was on the order, I think, of 10,000 inspection 21 items. That's a gross number. 22 Q These are items of work that were complete and ready i lO
= q - - - + - - -a
l 188 1 for QC inspection but for which the inspection had not yet
\_) 2 been performed?
3 A Yes. 4 Q How did this backlog compare to the performance of 5 other site contractors, if there was a basis for comparison? 6 A It would be tough, a basis of comparison, but I 7 would say qualitatively it was larger than normal. 8 (Off the record.] 9 BY MR. GUILD: 10 Q Was L.K. Comstock ever at any risk of losing their 11 contract as a consequence of their backlog of inspections? 12 A No. [ 13 [Off the record.] 14 BY MR. GUILD: 15 Q Comstock personnel seemed to perceive at some point 16 in time that they were vulnerable to losing their contract i 17 with Edison. Is there any basis for such a perception? 18 A At what time? 19 Q I don't know and I can't say, but are you aware of l 20 there being any basis at any time for a perception that the 21 Comstock people were at risk of losing their contract? 22 MR. GILL: I object to the form of the question. I l
189 1 What I'm concerned about is the question is confusing. I don't 2 know if you are asking him whether or not those folks had a 3 basis for perceiving it, in which cass I don't think he is 4 qualified to answer it. If you are asking whether or not they 5 were actually in danger, then the question is misleading. 6 BY MR. GUILD: 7 Q Can you answer the question? 8 A The only specific instance I can think of would be i 9 just recently where we have brought on another electrical 10 contractor to perform a certain scope of work in the Unit 2 11 electrical containment. In the Unit 2 containment and steam 12 tunnel as part of our Unit 2 completion, we have established a () 13 14 contract with Gust K. Newberg, Electrical Division, that W aq. worked wi*h-us specifically at one point in the Comstock scope 15 of work. That action happened in mid-November of last year. 16 As part of that effort to get up and going, we did transfer 17 some of the Comstock QC inspectors, or the Bestco inspectors 18 to Newberg with the -- there were five individuals -- with the 19 provision that when they were done with Newberg Electrical, 20 they could go back to Comstock. 21 The concern was expressed to me regarding the 22 possible loss of the contract by the business manager of Local O
190 1 Union 306, who had been getting it from his members, and I r 2 relayed to him that it is our intention that Gust Newberg will 3 complete the Unit 2 containment and steam tunnel raceway work 4 and that is all. 5 Q That is not co-extensive with the scope of work that 6 Comstock has for Unit 17 7 A Comstock will complete the Unit 2 cable pulling and 8 termination and all other electrical work. 9 Q So in other words, when Comstock finishes Unit 1, 10 there is still work for them at Unit 2? 11 A That's right. 12 Q Now, back in time prior to the Newberg contract for ( ) 13 Unit 2, any basis for Comstock personnel perceiving that their 14 contract was at risk? 15 A No. , 16 Q Let's talk about John Seeders briefly. What 17 involvement, if any, did you have with respect to Mr. Seeders' 18 concerns regarding harassment, particularly as they relate to , 19 Mr. Saklak? 20 A I remember seeing a letter that John Seeders has 21 authored. I really forget who ha had authored it to, but I 22 saw the letter, and I had gave the letter to Jim Gieseker who O
191 1 works for me to look into the matter, the allegations O
\s- 2 contained within the letter. Jim and, I think, another 3 engineer who worked for me by the name of -- yes, I know 4 another engineer who worked for me, Larry Tapella, sat down 5 and had discussions with Mr. Seeders regarding his letter and 6 his concerns that he did have.
7 Q Did you ever meet with Mr. Saklak or Mr. Seeders? 8 A No. 9 Q Did you ever meet with the NRC with respect to 10 Mr. Saklak and Mr. Seeders? 11 A I had conversations with Bob Schultz, the resident 12 inspector, regarding the letter. I don't recall any of the () 13 substance of those conversations other than we were looking 14 into the concerns expressed in that letter and we would advise 15 him. 16 Q Did you ever speak directly with Mr. Saklak? 17 A No, I did not speak directly with him in regard to 18 this letter. l 19 Q Have you ever met Mr. Saklak? l 20 A Yes, I have. 21 Q And on what occasions did you meet Mr. Saklak? 22 A I have met him at the job site, at times he was over n s_-
i 192 1 to our office. I also met him at a picnic that I attended. He 2 was there with his -- I think he had just gotten married, and l 3 I ran into him there. 4 Q Did you ever discuss with Mr. Saklak his work 5 performance or his conduct as a supervisor? 6 A No. 7 Q So just chance encounters on the job and then 8 perhaps this one social encounter?
+
9 A That's correct. 10 Q Did you ever discuss Mr. Saklak's work performance 11 or supervisory conduct with any other Edison person? 12 MR. GILL: Was that before the March 29th meeting? () 13 14 MR. GUILD: Yes, before the March meeting. THE WITNESS: I had conversations with Jim Gieseker . 15 prior to the March 29th incident regarding Mr. Saklak, and my 16 conversations were along the line of Jim was briefing me up on
, 17 some of the, I think, instances that had happened with 18 Mr. Saklak, and one of the things I had asked was do we need 19 to have additional supervisory help, is he trying to handle 20 too much by himself? And if we do need to have that, then 21 let's go out and have Comstock get additional supervisory 22 help; that there would be no -- I always feel that a O
193 1 supervisor can find himself getting overloaded and he needs to
) 2 spread the load around a little bit, and in this case I 3 believe that my judgment was that this may be a situation we 4 h' ave developing here and let's get some additional supervisory 5 help, let's see if we can spread the load around and relieve i 6 some of the supervisory burden Mr. Saklak has going at that 7 time.
8 Q This was fall of '847 9 A This was fall of '84.
- 10 Q And was that action taken?
11 A I believe it was. I believe that Comstock hired 12 additional supervisory personnel. We were also in conjunction ( ) 13 building up the forces of the Comstock organization, bringing 14 in additional inspectors to cover the workload, so it was 15 taken in conjunction with those actions also. 16 Q Did you identify any other instances aside from 17 Mr. Seeders' encounter with Mr. Saklak and the March encounter 18 with Mr. Snyder where Mr. Saklak threatened or abused an 19 inspector, verbally or otherwise? 20 A I think I referred earlier to another instance, but 21 I don't recall the specifics of it. I remember Jim Gieseker 22 telling me about an incident, but I think he told it to me in
-~. -_
194 1 terms of he was briefing me on the March 29th incident also. 2 Q Did you understand it was'something that happened 3 between the John Seeders incident and the March incident? 4 A I understood it to be something that happened 5 between the John Seeders incident and March 29th. 6 MR. GUILD: Let me take a minute and look at my 7 notes. I think that's it. 8 [Off the record.] 9 BY MR. GUILD: 10 Q Mr. Shamblin, can you identify the drawings that you 11 discussed with respect to Subcontention 3.b? 12 A Yes. They were drawing A669, Revision U; drawings 13 S1293, Revisions AY, CK and AW.
)
14 MR. GUILD: Mr. Gill, if we could get copies of 15 those drawings made available? 16 MR. GILL: I will add those to the list to be 17 responded to.
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18 MR. GUILD: Thank you very much. 19 Mr. Shamblin, I appreciate your cooperation. That's 20 all the questions I have, sir. 21 MR. GILL: No questions. Let me just before we 22 quit, Mr. Guild, to make sure we have it covered, give you the l O
195 1 list that we have been running here in the deposition and make 2 sure that's all that I'm supposed to respond to as far as
! 3 documents to be produced.
4 MR. GUILD: Yes, that is it. Thank you. 1 1 5 (Whereupon, at 5:45 p.m. the taking of the i 6 deposition was concluded.] 7 8 9
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10 ) 11 12 . O' 14 15 16 17 l 18 19 l 20 21 22 l O . i
, 196 1 CERTIFICATE OF DEPONENT 2 3 I, DANIEL L. SHAMBLIN, 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 . 9 DANIEL L. SHAMBLIN 10 11 4 20!OL 12 DATE 13 *** 14 CERTIFICATE OF NOTARY PUBLIC 15 Sworn and subscribed to before me, this the 2b 16 day of g//L , 19 . U 17 18 1'-
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/ b NOTARY PUBLIC IN D FO 21 My commission expires: b ' '
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I 197 l 1 CERTIFICATE OF NOTARY PUBLIC (], (_ 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 16 dl24t/ k 4( SW(/ 17 PAMELA BRIGGLE 18 Notary Public in and for the 19 District of Columbia 20 21 My Commission expires: May 14, 1990. 22 O v
J , March 4, 1986 N UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE Tile 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; G. Groth; D. Shamblin; M. Gorski; I. Dewald; R. Seltman; L. Seese and R. Saklak, who are agents or employees of Applicant 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 a M6 16 ,y g 65(, 4Y( c 36&c
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. brY Inspector liarassment 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, ( ~f'
)%A Rkbertbbild One of the Attorneys for Intervenors Rorem, et al, i
Douglass W. Cassel, Jr. Robert Guild Timothy W. Wright, III 109 North
Dearborn,
#1300 Chicago, IL 60602 (312) 641-5570
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,yd j DANIEL L. SHAMBLIN Project Field Engineering Manager (4/10/83) Employee #747-790 418 W. llaven Avenue Payroll 40776 New Lenox, Illinois 60451 S.S.n 367-48-4481 Telephone: (815) 405-7236 i
Personal Data: Date of Birth October 8, 1950 lleight Weight 5' 10" 195 Marital Status Married, Boneta J. Children Hannah Marie, Martha Katherine, Aaron Mathew i Company Data: Service Date: July 3, 1972 Training Program: Tech Center - Transmission 7/72 to 9/72 Will County - Station Construction 9/72 to 10/72 1st National - Station Mechanical Engr. 10/72 to 12/72 i (~ Station Construction Department 's- Pield Engineer - Zion Station Pield Engineer - 12/72 to 11/73 LaSalle Station 11/73 to 02/78 Office Vice President Leo Staff Assistant - General Office 02/78 to 08/78 Office Manaaer of Projects Project Coordinator, LaSalle County Station - G.O. 8/78 to 8/80 staff Assistant to Project Manager - 0,0. 8/80 to 5/02 Site Project Construction Superintendent, LaSalle County Station 5/82 to 4/83 , Project Field Engineering Managor, Draidwood Nuclear Station, 4/83 to Present Draidwood Construction Assessment Program Task Force Manager, Draidwood Nuclear Station, 3/84 to Present L~) f' e 5hembl;,, b X. 42 c 33186
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. "' Job IIistory: City of Grand Rapids Engineering Dept.: Summer 1969, 1970 Owen-Ames-Kimball Construction Co.: Summer 1971 Johnson Controls Co.: Summer 1971 Michigan Tech University: School Years 1969-1972 Education: B.S. Civil Engineering: Michigan Technological University '
Itoughton, Michigan - 6/72 Masters in Business Administration: University of Chicago Chicago, Illinois - 6/82 Societies: American Society of Civil Engineers - member i Knights of Columbus - member Doy Scouts of America - member Registrations: Professional Engineer - Illinois l d i llobbies: Water skiing, Swin: ming l f Parents Wife's Parents ' Donald & Barbara Shamblin Joseph & Lovina Hoffman ( lle Fairbanks N.B. RR #1 Grand Rapids, Michigan 49931 Blwell, Michigan (616) 454-7155 (51~l) 833-7393 U [ S s hm.wt sp. ( l l 1 U l _ _ _ _ _ _ _ _ _ _ - _ - _ - - _ - - - - - - - - - - - n
N (3 \._,/ May 7, 1985 G. K. Newberg Braidwood Nuclear Power Station Braceville, IL 60LO7 Attention: Mr. Dave Craven Project Manager
Subject:
Braidwood Station - Units 1 & 2 NRC Noncompliance h56/85-008-10A
Dear Mr. Craven,
It has been brought to my attention that the 1A positive displacement charging pump room has an NRC Noncor:.pliance concerning housekeeping written against it. The Noncompliance states, " empty cans in the room cooler, plastic sheeting strewn about the area, partially eaten food items, accumulation of flacmable material and a layer of dust on all equipment in the room." The Noncompliance was written in the time period of March 15 i to March 21. This area should be cleaned and given special attention so as a re-occurrence of this discrepancy does not occur. Appropriate field personnel should be informed of this problem. Housekeeping Coordinator Braidwood Station e PGH/dl ec: Daniel L. Shamblin Clif Gray 85-180E o 3 ham}/in 58 X $3 C0lN'3T r {N3/ /% 59
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,- GUST K. NEWBERG & ASSOCIATES GENERAL CONTRACTORS INC.
Braidsood Station Section _31 eture Work Approved & ,- d. Quality Osutrol Procedure Revision 0 , (4 Date 3-8-77 ! ERECTIm OF STRU STEEL I l 31-1.0 - SECTIm SCOPE l 31-1.1 - This procedum implements he GMA li Assuranc = Manual Section VII, II, I & IIII or con of he emotion of structural steel in Cate ry I a tun. Reference S& Specification Fom 1705-R and Fo 1790-E. 31-2.0 - O M ERAL 31-2.1 - The purpose of this proc um is to insu that structural steel is erected in acco ce w th the lans and specifications. 31-3.0 - PROCEDURE 31 Stmetural a 1 will installed in accordance with the approved plans and spe ifications. 31-3 2 - Steel members s identified in accordance with shipping lists that will von to 05A. Emotion and joint connection detail drawings shall be fumished to GMA by the owner. asceiving inspection will be by the owner. 31-3 3 - Field connections shall be as follows, unless indicated: 31-3 31 - Connections of new steel to existing embedded plates shall be welded. Welding control shall conform to requimments of OMA Quality Control Procedum Section 26. Inspection services will be fumished by P.T.L.. 31-3.3.2 - All other connections shall be bolted witb high j stmngth bolts. Assembly of high strength bolted i joints shall confom to the mquirements of S & L StandaM Specification Fom 1705-L article 9.3 and 9.h. (see attached) Inspection services for bolted work will be furnished by P.T.L. 31-3,h - PLUMBING UP Steelwork shall be set accurately to the established lines and g0 grades, and shall be plumed and leveled such that the deviations for all completed work do not exceed the requirements of the AISC l l h, h code of StandaM Practice, with the further restriction that for l g ggg elevator hoistways the deviation shall not exceed la mgardless of height. (1)
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will not injure the material. e s ym. Any material unduly injured, in the opinion of the Consulting CJ Engineers 54stl be replaced by Contractor at his own expense. Q,; . 9.2 Column Base Plates: Column base plates shall be set and leveled by Contractor, but will be grouted by others. 9.3 Assembly of High Strength Bolted Joints: 9.3.1 Installation of Bolts: 9.3.1.1 Install A325 bolts using a hardened washer under bolt head or under nut, whichever element is used in tightening. Install A490 bolts, using washers under bolt head and under nut. Use beveled washers, where required. 9.3.1.2 Fair-up holes in each connection with enough pins to maintain dimensions and plumbness of structure. These pins shall remain in place until all bolts in balance of holes have been tightened. 9.3.1.3 Install enough fit-up bolts and bring them to a snug-tight condition to insure that connected parts are properly fitted and brought into full contact with each other. Pennanent high V strength bolts may be used for fit-up. 9.3.1.4 Install high strength bolts in remaining holes and spin nut on each of these bolts to a sn tight condition with impact wrench, then continue tightening to produce torque specified following (under " Inspection of Bolting") or at least an additional one-half turn, which-ever is greater. Mark chuck of wrench to permit visual observation of its rotation. 9.3.1.5 Then replace pins, and temporary fit-up bolts (if temporary fit-up bolts are used), wit strength bolts and tighten these bolts as specified in Step 9.3.1.4. 9.3.1.6 If permanent high strength bolts are used for fit-up bolts, check tightness of each fit-up bolt with impact wrench by tightening one-quarter turn. If these bolts do not appear to be tight, make them snug and tighten as specified in Step 9.3.1.4. 9.3 2 Inspection of Bolting: Services of an independent testing laboratory will be furnished by Purchaser to conduct field inspection of bolting work in accordance with following k'
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SARGENT .O LUN3Y ENDINCERO C HICAGO specifications unless otherwise indicated: 9.3.2.1 ! Eachdari three bolts of each required diameter will be tested in a tension device such the !kidmore Wilhelm calibrator. 9.3.2.2 Bolts will be tightened to the tension indicated in the AISC Specification. 9.3.2.3 The inspector, by means of a calibrated torque wrench, will determine the torque on each tightened bolt by attempting to tighten the nut a very small amount and will average the readings on these bolts. Ile will add 50 ft. Ibs. to this amount to establish a torque-tension relationship for each bolt diameter, and this ratio is the norm by which he will check bolts for that day. 9.3.2.4 In each connection on the structure approximately 10% of the bolts will be tested, but never less than two. 9.3.2.5 in testing, the inspector will place his wrench on the nut, read the wrench dial, while attempting to tighten the nut a very small amount and will compare this reading with the required torque established in Step 9.3.2.3. 9.3.2.6 If the inspector discovers one or more bolts which are under-torqued, all bolts in the con nection shall be tightened with an impact wrench by the erector and will be checked again by the inspector. '
- 9.3.2.7 Contractor shall furnish necessary labor to assist the inspector, and shall furnish all necessary staging for inspection access. Contractor shall also furnish the tension device, such as the Skidmore-Wilhelm calibrator. The device furnished shall be as approved by the Consulting Engineers, and shall bear a certification as to the accuracy of the device.
Such certification shall be dated not more than 30 days prior to the first actual use of the tension device for inspection of the WORK. 9.4 Columns and Beams: ' Install heads of high strength bolts as follows: 9.4.1 On outside faces of column flanges. 9.4.2 On top side of top flanges of beams.
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- 3. , ,, Bevision 1 f Date 5/17/77 ERECTION OF STHDCTURAL STEEL 31-1.0 - SECTIm SCOPE 31-1.1 - This pIncedure implements the ENA Quality Assurance Manual, Sections VII, II, I & IIII for control of the erection of structural steel in Category I stacture. Beforence S & L Specification Fom 1705-R and Fom 1790-E.
31-2.0 - GM ERAL 31-2.1 - The purpose of this procedure is to inburn that structural steel is erected in accortlance with the plans and specificaticas. 31-3 0 - PHOCEDURE 31-3.1 - Structural steel win be installed.in accordance with the approved plans and specifications. 31-3 2 - Steel members shall be identified in accordance with the shipping lists that will given to GMA. Erection and joint connection detail drawings shan be furnished to 01DIA by owner. Beceiving inspection will be by the owner. 31-3 3 - Field connections shall be as fonows, unissa indicated: 31-3.3.1 - Welded connections win be in accordaises with detailed drawings.14:1 ding control shall conform to requirements of SNA Quality Control Proceduzw Section # 26.
- 31-3 2 - Amesmb37 of bolted joints shall conform to the requirements of 3 & L S+amlarsi Specifications Pbra 1705-R articles 9 31.1, 9.3.1.2, 9 31.3, 9 31.5u9 3.1.6 and 9.h. (Attached)
- 31-3 3 ,!asta11mti th A -325 and ASTM 1490 selts sha be ofb high styvng/t tha o the nut method per the requi ta f, J C/Spoe i tien for Structural Joints us AS A ~ L25/ ort A490 Bolts , dated Febzsary h 3 1976 i tolm 50 (Attached)
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and shall be plumbed and leveled such that the j for all completed work do not emoeed the requirummate cf the AISC code of Standard Praction, with the ! further restriction that for elevator hoistueys the deviation ! shall not exceed l' regardless of height. ! 31-3.5 - TOUCH UP PAINTING l Fuznished by aumer. I O P
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N/ 9 3. . ~o f' HISI STEBOTH BOLTED JOINTS 9 3.1 ion of Bolts: 3, 9 3.1.14b A325 bolta using.a hardened washer under bolt head or tader nut, whichever element is used in tightening. Install Ah90 bolts using washers under bolt head and under nut. Use beveled washers where required. 9 3.1.2 - Fair up holes in each connection with enough pins to maintain dimensions and plumbness of structure. These pins shall remain in phce until all bolts in balance of holes havu been tightened. 9 3.1.3 - Install enough fit-up bolts and bring them to a snug-tight condition to insure that connected parts am properly fitted and brought into full contact with each other. Permanent high strength bolts may be used for fit-up. 9 3.1.5 - Then mplace pins and temporary fit-up bolts (if temporary fit-up bolts am used) with high strength bolts and tighten theso bolts as specified in Step 50. i 9 3.1.6 - If permanent high strength bolts am used for fit-up bolts, check tightness of each fit-up bolt with impact wrench by tightening one-quarter tum. If these bolts do not appear to be tight, make them snug and tighten as specified in Step 5C. 9.h - COLUMIS AND BEUS: Install heads of high strength bolts as follows: 9.h.1 - On outside faces of column fhnges. 9.h.2 - On top side of top flanges of beams. AISC Specification for Structural Joints Article 50 Turn-of-Nut Tightening When the tum4feut method is used to provide the bolt tension, them shall fint be enough bolts brought to a " snug tight" condition to insam that the parts of the joints are brought into good contact _1siWesch other. Snug tight is defined as the tightness attained by rflow impacts of an impact wrench or the full effort of a man an ottiinary spud wrench. Following this initial operation, shall be placed in any remaining holes in the connection and brought to snug tightness. All bolts in the connection shall then be tightened additionally by the applicable amount of nut rotation specified in Table h, with tightening pzugressing systematically from the most rigid part of the joint to its fzwe edges. During this operation there shall be no rotation of the part not turned by the ' wrench. O (3)
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;p f ;g Nf[.GameRAt. CONTRACTORS INC.
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x, ) O - p [ . k Nut Hotation from Snug Tight Condition Bolt Imagth Disposition of enter Faces of Bolted Parts (as measund from underside of head to Both faces nomal One face nomal Both faces extame end of point) to bolt axis to bolt axis and sloped not other face sloped more than 1:20 not more than 1:20 frca normal to (bevel washer not bolt axis used) (beveled washers not used) Up to and including h diameters 1/3 tum 1/2 tum 2/3 tum Over h diameters but not exceeding 8 - diameters 1/2 tum 2/3 tum $/6 tum over 8 diameters but not exceeding 12
- g diameters 2/3 tum 5/6 tum 1 tum V
a Nut rotation is mlative to bolt agartiless of the element (nut or bolt)being tuned. For bolts installed by 1/2 tum and Issa, the 0 tolemnce should be plus or minus 30 , for bolts igstalled by 2/3 tum and mom, the tolerance should be plus or minus h5'. (h)
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a .'O .*iit <n m f* .- Sect, ion 31 ! r, k' W rk t Approved -. (4! D Jtm
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F ! i ? 53 Ed$Tf Y O C T.H 0w u L STEEL q 5 $)I* u? >
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t g '7 i i 31:111 - This pr0cedu o iminments thefd.'!:A Quality /.csurnnec Manual, "S~M"iTidi'Vil> l a.r .CCategorf le EII forIcentrol of thIb-er~ ti of y ctructural ctcel in structure. 'cla%c. Specification Forri 1706-R and Fern 17$0-2 itc:,Gr.Ls H ffC- y 31-2.0 - CM'E:U.L -
- Leei '/ ~9>927 7f 31-2.1 -is The
- orectr.d purpc*:e
$n accordance of this procccurc with ti.e p1sns t.r. $ stMtcut:actural to incure,d steci crociff sti~cs 31-3.0 - PROC M.g
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31-3.1 - Structural steel trill bc installed in accordanec trith the approved plans and cpocificM,icns. ~
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- 35-3 2 - lH.cel re- d.~rn cla11 he identif3cd in accc rd .nce uith th'. chipping licts thi vill citcn to GO A. froct.icn red joint cev:cetion detail
., drsuinen d. 31 be furniched to GM:A by cr:wr. P.ccciv nc inspect,1on vill be b.r t he cin cr.
. 31-3 3 - Fielti ecr.ncetiens shall be as folle.m, unkca indicated:
31-3 3.1 - h'elded ccanuctie::s 1:311 te in accenia:.:o 1:ith detailed dr:ar;nce. L1dir.c c(ntrol W.l'. t afo;<, % reo.uircr: cuts of GR:A Cur.lity Control Procedurc Section i 26 31-3 2 - Arse.rbly of belted joints chall c:.nfom to the requi.mments of. S !.: L Standard Specifienticus Tom 1703-R nrticlec 9 3 1.1, 9 3 1.2, 9.3.13, 9 3.1.7, 9 3 1.6 ar.J 9.!:. (Attached) 31-3 3 - Install tLicn of hich strength AOL't A ~27 and ASTM A-h90 holta shall to based oa tLo tura of the nut r.sthod par the requiremnts of AISC Specification fcr Stivatural
. o3nts un$u; ASTM A-325 or ASTM A-L90 Polt;: , dated Fed: :::/ h,1976, Article $C. (Attached)
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. Gts: at.u. CosTn'acToits Isc.
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31-3,h - PDTc3M:G UP. - Stecluor:: shall be set accuratoly to the cctablichad lines and credes, and clull be plu: icd and leveled such that the - deviations for cil ec=pleted work do not exceed the
- requin..cnts of the !.ISC code of St:ndard Practico, irith the further restriction that for cleinter hoiatunya t!.e deviation shall not, execed 1" regardless of 1.ciC ht. .
, 31-3.'l - TOUCfi UP PALTIUG Damiched by o,cnor.
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'P-i Braidwood Station Section
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31 Units 1 & 2 , General Structures ibrk f/ f) Quality Control Procedure Approved J4 //AN,yyy g v ' p Ruision 2 V Date 9-28-82 ERIrTION OF STRUCTURAL STEEL 1.0 SmrICN SCDPE 1.1 This procedure implements the GKN Quality Assurance Manual, Sections VII, IX, X, aM XIII for control of the installation of structural steel in Category I stn2ctures. 2.0 GENERAL 2.1 The purpose of this procedure is to insure that structural steel is erected in accordance with the plans aM specifications. For the C purpose of this procedure, " structural steel" includes field fab-ricated itens, block wall steel, gallery steel, structural manbers, jet deflectors, pipe restraints, aM other such itws as defined under S & L Specification 2722. 3.0 PROCEDURE f- 3.1
$4 Upon identification of structural steel to be erected, the Project fy :
E ! g (] Engineer . will initiate the Structural Steel Installation Traveler (S.S.I.T.), Form 31-1 (attached), by cmpleting the general informa-
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5 e 3 2 r by tion requirements. Accmpanying the S.S.I.T. will te the following:
-d o l ! d T m$ 3, is 3 gg 5 $ 3.1.1. C) A coupleted Storage Release Requisition, Fonn 41D (attached) .
b i 50 [S5 L;;Z 7 _ j e3F:y3-f 3.1.2. A Bolting Inspection Request, Form 31-3, noting the applic ahle g i 3 d 3l fp S.S.I.T. number (attached) .
.- -2 3 5g yhh 3.1.3 A Weld Inspection Request, Form 31-2, noting the applicable a y, 3 j .Syg 7 .
S.S.I.T. number (attached) .
~3 w "h 55 A 2 " '$ O-< 3.1.4 A Concrete Expansion Anchor Inspection Request, Form 34-2, noting the applicable S.S.I.T. number (attached) .
3.2 The Project Engineer will transmit the S.S.I.T. package to the Quality Assurarce Supervisor who will cmplete the following: 3.2.1 Verify Comenwealth Edison's MRR acceptability by noting acceptance under rmarks on Form 41D. 3.2.2 Assign Fo ms 31-2, 31-3, and 34-2 the apprep:-iate number ard log same, a 3.3 TheQualityAssuranceSupervisorwillthenissuetheS.S.I.T. package to the GKN Iromorker SuperinteMent who will then take fran storage the material to be installed. For field fabricated A itens, all heat numbers will be listed on the S.S.I.T. detail V ' sheet or drawing by the Iromorker For . O/ 1
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. .. Braidwood Station Sect _on , 31
^
al tures Work Approved /Mzryyf4 Quality Control Procedure V ' ~
,7 Revision 2 U Date 9-28-82 ERE TION OF STRUCIURAL STEEL 1.0 SECTION SCOPE 1.1 This procalure implenents the GKN Quality Assurance Manual, Sections VII, IX, X, and XIII for control of the installation of structural steel in Category I structures.
2.0 GENERAL 2.1 The purpose of this procedure is to insure that structural steel is erected in accordance with the plans and specifications. For the purpose of this procedure, " structural steel" includes field fab-ricated itens, block wall steel, gallery steel, structural msnbers, jet deflectors, pipe restraints, and other such itens as defined under S & L Specification 2722. 3.0 PROCEDURE 3.1 Upon identification of structural steel to be erected, the Project Engineer will initiate the Structural Steel Installation Traveler (S.S.I.T.), Fom 31-1 (attached), by cmpleting the general infortna-
] tion requirenents. Amrnmnying the S.S.I.T. will be the following: %/
3.1.1. A cmpleted Storage Release Requisition, Fonn 41D (attached) . 3.1.2. A Bolting Inspection Request, Fom 31-3, noting the applicable S.S.I.T. rarnber (attached) . 3.1.3 A Weld Inspection Request, Form 31-2, noting the applicable S.S.I.T. ntznber (attached) . 3.1.4 A Concrete Expansion Anchor Inspection Request, Form 34-2, noting the applicable S.S.I.T. number (attached) . 3.2 The Project Engineer will transmit the S.S.I.T. package to the Quality Assurance Supervisor who will canplete the followirg: 3.2.1 Verify Ccmnonwealth Edison's MRR acceptability by noting acceptance under renarks on Form 41D. 3.2.2 Assign Forms 31-2, 31-3, and 34-2 the appropriate number and log same. 3.3 The Quality Assurance Supervisor will then issue the S.S.I.T. package to the GKN Ironwrker Superintendent who will then take frun storage the material to be installed. For field fabricated itens, all heat numbers will be listed on the S.S.I. de il' bW sheet or drawing by the Ironworker Forenan.
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3.4 The Ironworker Superinterrirnt will be responsible for reauestig timely inspections frm the appropriate organizations; PIL for welding, CEA's, and bolting; GKN Quality Control for configuration ard cmpletion of work. O 3.5 A GKN Quality Control inspector will verify on the S.S.I.T., con-figuration, cmpleteness of the installation, and that all required docments are cmplete per form 31-1. GKN Quality Assurance will maintain a log of S.S.I.T. 's docmentirg the issuance and cmpletion of structural steel installation. All S.S.I.T.'s will be filed as a final quality record. 4.0 INS'IALIATION 4.1 All welding required for the ermtion of structural steel will be in accordance with approved shop drawings or the architect's design drawings. Weldig will conform to the requirments of GKN Pro-cedures 25 and 26. 4.2 Field fabricated itms will be fabricated frm Sargent and Lundy drawings or sketches issual by the Project Engineer and verified by Q.C. on Form 31-1. 4.3 Field cutting will not be performed unless indicated on the erection or detail drawings, or approved non-conformance reports, or as des-cribed below for connection fit-up. Prior to the performance of any cuttirg, coping, or trimim, the Project Engineer will be , notified and will determine if the cuttire, copiry or triming is necessary to bring the mmber into cmpliance with the shop draw-O irgs or will not exceed tolerances as follows: b 4.3.1 Increasing the length of a cope by " and the depth of a cope by \" mre than the dimension shown on shop detail drawirgs. 4.3.2 Trinming edges or ends of the connection such that the result-irg edge distance still meets the minimum requirments of the followirg Table 4.0 All arc gauges and flme cut edges will be ground free of notches and burnt edges. Minimum Edge Distance for Punched, Reamed or Drilled Holes Rivet or Bolt (Inches) Diameter At Rolled Edges of (Inches) At Sheared Plates, Shapes, or Ears Edges or Gas Cut Edges ** 1/2 7/8 3/4 5/8 1 1/8 7/8 3/4 1 1/4 1 7/8 1 1/2* 1 1/8 1 1 3/4* 1 1/4 1 1/8 2 1 1/2 1 1/4 2 1/4 1 5/8 Over 1 1/4 1 3/4 x diameter 1 1/4 x diameter
- There maybe lk" at the ends of beam connection angles.
** All alqe distances in this column may be reduced 1/8" when the hole is at a point where stress does not exceal 25% of the maximum allowed stress in the elment.
Table 4.0
4.4 Misfits which cannot be corra:ted by the metMds in paragraph 4.3 will be brought to the attention of the Project Ergineer. If the misfit is due to fabrication error and the menber can l be reworked per the detail drawirg, wrk may proceed. For O V other instances, the Project Ergineer will contact Sargent and Lundy for disposition by BCN or EUR. i l 4.5 Assenbly of bolted joints will conform to the requirenents of S & L Standard Specifications Form 1705 and design documents. 4.6 Reamirq of bolt holes is permissible. Holes may be reamed to
" oversize" or to a short slotted hole so lorg as minimum edge distance is not violatd (see 4.3).
4.6.1 Oversize holes are defined as up to 3/16" larger than bolts 7/8" and less in diameter, " larger than bolts 1" in diameter, and 5/16" larger than bolts 1-1/8" and greater in diameter.
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4.6.2 Short slottM Mles are 1/16" wider than the bolt diameter and have a lergth which does not exceed the oversize diameter above by more than 1/16". 4.6.3 Hardenal washers will be installed over oversize and short slotted holes in the outer ply. 4.7 The burnirg of bolt holes to full size will not be permitted. However, pilot holes may be burnal " urriersize and then reamed. Drilliry of bolt holes is also permittal. O (,/ 4.8 Installation of high strength ASm A-325 and ASE A-490 bolts will be based on the turn-of-the-nut method; installation of ASE A-307 bolts based on the " snug tight" condition; and installation of AS'IM A-540 and AS'IM A-542 bolts will be treated as ASIM A-490. 4.8.1 Snug tight is defined as the tightness attained by a few impacts of an impact wrench or the full effort of a man using an ordinary spud wrench, unless otherwise defined on an applicable design document. 4.8.2 Turn-of-the-nut method is defined as the amount of nut rotation past snug tight. See Table 4.1. o e. .on os outer rues of moned p.,ts ! (,, gll",37,,,,, on. ene norm.no but sah t-- cop ne l i undeeside of head to estreme end of poent) Soth faces normal to belt aars g"',o",$",h',',%,*, o '",','Q*o bcit sa 8 1:20 (bevel washer not (bevel washers not p-used) used) Up to and including 4 diameters 1/3 turn 1/2 turn 2/3 turn l Over 4 diameters but I not exceeding 8 diameters I/2 turn 2/3 turn 5/6 turn Over 8 diameters but not enceeding 12 diameter $6 2/3 turn 5/6 turn 1 turn
. Nut rotation et redetEe to bolt, regardless of the element (nut or bolt) bema turned. For
( beats enstalled by % turn and less, the tc6erance should be plus or manus 305 ror boats on statted by % turn and more, the tolerance should be plus or manusp i a No resemeth work has been perfor.med d by theTherece Cesence to estatesan tMe turn-of nut procedure l when by ciuan ence m.nedboat.eengths.us . eed.s.i.d.e meeers. bee sene.en desie.re. senue iins the.roeused. rosa. tion must be deter-the ctu conditions. Table 4.1
4.9 Steelwork will be sent accurately to the established lines and grades and will be plmbed and leveled such that the deviations for all ompleted work do not exceed the requirments of the AISC Code of Standard Practice, Iten 7.11 Frme 'Iblerences
/7 (attached) .
() 5.0 GKN QUALITY CONIPOL INSPECTION 5.1 The Quality Control Inspector will docment on the S.S.I.T. configuration and cmpleteness of the installed piece of structural steel. Checks of welds, bolting, and CEA's will be by others (PTL) . 1 5.2 The checks for plumbness, alignment, elevation, and plan will be made frm lines and grades established by the GKN Field Engineers. The O.C. Inspector will verify these on Form 31-1. 5.3 The structural steel configuration, nunbers size, and location will be verified against the vendor shop drawings and the Architect's design documents. 5.4 The O.C. Inspector will verify all welding required by the vendor ard Architect's drawings have been cmpleted and entered on Form 31-1. 5.5 The O.C. Inspector will verify on Form 31-1 that the specified piece mark with all applicable mill certifications has been in-stalled. 5.6 The O.C. Inspector will inspect bolted connections for proper (q) location, number, size, and grade of bolts and note the same on Form 31-1. 5.7 The O.C. Inspector will advise GKN Production of any unacceptable work discovered during an inspection. If it can be reworked, the Inspector will note the unacceptable iten in the cmments under Q.C. Verification-and then reverify an acceptable installation. , 5.8 The Q.A. records clerk will review all inspection reports and verify acceptability.
FORM #34-2 Rev. 1 CONCRETE EXPANSION ANCHOR INSTALLATION REQUEST Request No. Date Requested S.S.I.T. TO: Pittsburg Testing Laboratory Braidwood Station FROM: Gust K. Newberg Construction Please arrange to torque test the concrete expansion anchors in the locations listed below: O Quantity of expansion anchors in this area Initial Inspection ( ) Reinspection ( ) 0.C. Inspector Comments:
FOT 31-3 BOLTING INSPECTION REQUEST o Request No. Date Requested S.S.I.T. TO: Pittsburgh Testing Laboratory Braidwood Station From: Gust K. Newberg Construction Please arrange to inspect bolts in the locations listed i below: Bolt No. Condition Initial Inspection ( ) Reinspection ( ) Comments: O Q.C. Inspector
Forr 11-2
.. Rev. 1 WELD INSPECTION REQUEST Request No. i
[ } Date Requested S.S.I.T. To: Pittsburgh Testing Laboratory Braidwood Station From: Gust K. Newberg Construction Please arrange to inspect welds in the locations listed below: Weld Identification: O Initial Inspection ( ) Reinspection ( ) i Comments: 4 j Q.C. Inspector f'>T l l
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. - . _ . . . _ , . _ _ _ . . . , _ , _ _ _ . - ~ _ _ _ _ _. _ . _ _ _ . _ - _ _ _ _ _ _ _ . _ _ . _ _ . -
GUST K. NEWHERG & ASSOCIATES FDRM hlD - Rev.1 GENEltAl. CONTi4 ACToltS INC.
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/ STO3 AGE RELIASE REQUISITIQi POUR N O./8. S . I .T. SHEET OF MATERIAL CATEGORI I II REQUESTING CRAFT FORC!Mi DATE DELIVERY REQUIRED DELIVERY IDCATIQi MATERIAL SUPPLIER No. Pcs. !! ark / Heat Size or Description Load Issue Substitute Number Number Checkoff (Inspection ! Required) ' I i 1 I
. l l
p . N._/ , i I i l ISSUED BY: I.W. FOREMAll/ DELIVERY DATE: l l RElfARXS
!!0TE ANY DA" AGED MATERIAL REQUIRD;G REPAIR AND DISPECTIQl:
SUBSTITICNS APPROVED BY: CSCo DATE VERIFIED BY: Q.C. INSPECTOR DATE REPAIR INSPECTIQ;S MADE AT PODIT OF PIACEMc2;T DISTRIBUTIQ;: Q.C. 9
Form 31-1 Page 1 of 2 REPvdT NO. REV. STRUCTURAL STEEL INSTALLATION TRAVELER \ I. GENERAL INFORMATION A. Location
- 1. Building / Elevation:
- 2. N-S E-W Locations: I B. Sargent & Lundy Information
- 1. Plan Drawing / Piece Mark
- 2. Authorization; FCR ECN DWG/REV
- 3. Connection Det./ Drawing:
- 4. Size / Weight:
- 5. Schedule Drawing:
C. Supplier Information ( l. Supplier:
- 2. Supplier Piece Mark / Heat No. .
- 3. Supplier Shop Drawing:
- 4. Field Fabrication Detail Sheet: ,
D. Special Rigging Required: Yes No E. Special Applications: F. Comment,:: Date Issued Issued By O
Form 31-3 Page 2 of 2 II. FIEID VERIFICATION _ Date Installed: Welder (s) I.D.: Welds proper size - length: Yes No Bolts per boltire detail: Yes No GKN Ironworker Supt. III. CUALITY COtIIBOL VERIFICATION ACC N/A DEF CObMENTS hkinber size (s) Piece Mark Mill Certs Incation -- o Welding Detail (s) Boltin3 Detail (s) Material Undamaged CEro. MRR Acceptance Welder I.D. Date Inspected: Inspector: Dolting Inspection Report Malding Inspection Report CEA Inspection Report
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\j Steel Buildings and Bndges e 5 - 185 7.11 Frame Tolerances 7.11.1 Overall Dimensions Some variati<,n is to he expected in the finished overall dimensions of strue.
tural ateel framen. Such variations are deemed to he within the limits of good practice when they do not exceed the cumulative effect of rolling tolerances, fabricating tolerances and erection tolerances. 7.11.2 Working Points and Working Lines Erection tolerances are defined relative to member working points and working lines as follows: (a) For members other than horizontal members, the member work point is the actual center of the member at each end of the shipping piece. (b) For horizontal members, the working point is the actual center line of the top flange or top surface at each end. (c) Other working points may be substituted for ease of reference. pro. viding they are based upon these definitions. (d) The member working line is a straight line connecting the member working points. 7.11.3 Position and Alignment [)
' The tolerances on position and alignment of member working points and working lines are as follows:
7.11.3.1 Columns Individual column shipping pieces are considered plumb if the deviation ofIhe working line from a plumb line does not exceed 1:500, subject to the following limitations: (a) The member working points of column shipping pieces adjacent to elevator shafts may be displaced no more than I inch from the established column line in the first 20 stories; above this level, the displacement may be increased %2 inch for each additional story up to a maximum of 2 inches. ib) The member working pointa of exterior column shipping pieces may be displaced from the established column line no more than I inch toward nor 2 inches away from the building line in the first 20 stories; above the 20th story, the displacement may be increased
%e inch for each additional story, but may not exceed a total dis.
placement of 2 inches toward nor3 inches away from the building line. (c) The member working pointa of exterior column shipping pieces at any splice level for multi tier buildings and at the tops of col. umns for single tier buildings may not fall outside a horizontal en$ elope, parallel to the building line,1 % inches wide for buildings up to 300 feet in length.The width of the envelope may be increased
)
D stret nuildine and Heide,n . s Isi 7.11 1 Acceptance of Position and Alignment Prior to placing or applying any other materials, the owner is responsible for determining that the location of the structural steelis acceptable for plumbness, level and alignment within tolerances. The erector is given timely notice of ac. cept.mce by the owner or a listing of specific items to be corrected in order to obtain acceptance. Such notice in rendered immediately upon completion of any part of t he work and prior to the start of work by other trades that may be supported, attached or applied to the structural steelwork. 7.12 Correction of Errors '. Normal erection operations include the correction of minor misfits by mod. erate amounts of reaming, chipping or cutting, and the drawing of elements into line through the use of drift pins. Errors which cannot he corrected by the foregoing means or which require major changes in member configuration are reported immediately to the owner and fabricator by the erector, to enable whoever is re. sponsible either to correct the error or to approve the most efficient and economic methad of correction to be used by others. 7.1:1 Cuts Alterations and IIoles for Other Trades Neit her the fabricator uur ihe erector will cut, drill or at herwise atter his work, or the work of other trades, to accommodate other trades, unless such work is clearly specified in the contract documents. Whenever such work is specified, the owner is responsible for furnishing complete information as to materials, size, b v h> cation and number of alterations. 7.18 Ilandling and Storage The erector takes reasonable care in the proper handling and storage of steel during erection operations to avoid accumulation of unnecessary dirt and foreign matter. The erettor is not responsible for removal from the steel of dust, dirt or other foreign matter which accumulates during ihe erection period as the result of esposure to the elements. 7.1.1 Field Painting The crector does not paint field bolt heads and nuts, field rivet heads and fiehl wehls, nor touch up abrasions of the shop coat, nor perform any other field painting. 7.87 Final Cleaning Up Upon completion of erection and before final acceptance, the erector remoses all of his falsework, rubbish and temporary buildings.
c' . 1 lu e AISC Code of Standard Practice .O f V by %-inch for each additional 100 feet in length, but may not exceed 3 inches. (d) The member working points of exterior column shipping pieces may be displaced from the established column line,in a direction parallel to the building line, no more than 2 inches in the first 20 stories; above the 20th story, the displacement may be increased
%einch for each additional story, but may not exceed a total dis. ,
placement of 3 inches parallel to the building line. 7.11.3.2 Members Connecting to Columns (a) The horizontal alignment of members connecting to columns is considered acceptable if any error in alignment is caused solely by the variation in column alignment within permissible limits. (b) The elevation of members connecting to columns is considered acceptable if the distance from the member working point to the upper milled splice line of the column does not deviate more than plus hinch or minus binch from the distance specified on the drawings. 7.11.3.3 Other Members Members not covered above are considered plumb, level and aligned if the displacement of the individual member does not exceed 1:500 from a straight line struck between the support points of the member. [v 7.11.3.4 Adjustable items The alignment of lintels, wall supports, curb angles, mullions, and similar supporting members for the use of other trades, requiring limits closer than the foregoing tolerances, cannot be assured unless the owner's plans call for adjustable connections of these members to the supporting structural frame. When adjustable connections are specified, the owner's plans must provide for the total adjustment required to accommodate the tolerances on the steel frame for the proper alignment of these supports for other trades. The tol. erances on position and alignment of such adjustable items are as follows: (a) Adjustable items are considered to be properly located in their s ertical punition when their location is within Vinch of the location established from the upper milled splice line of the nearest column to the support location as specified on the drawings. th) Adjustable items are considered to be properly located in their horizontal position when their location is within Sinch of the proper h> cation relative to the established finish line at cny par-ticular lbor. 7.11.8 Responsibility for Clearances in the design of steel structures. the owner is responsible for providing clearances arid adjustments of material furnished by other trades to accommodate all of the foregoing tolerances of the structural steel frame. O
L SQI-03 Attachment 6.5 DATE N#M 2[, /Y[d TO: Mr. N. N. Kaushal
SUBJECT:
Non-Conformance Reports Braidwood Station S & L Specification # [-27228 NCR # In accoj/44 dance with Quality Assurance Procedure #15-1, copies of are being transmitted for review, information and resolution, if needed. , o a a njg pg, T. E. Quaka '
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.4 Q. A. Superint dent Braidwood Station TEQ (0012F) cc: T. E. Quaka D. Elias G. C. Jones D. L. Shamblin' l E. L. Martin (excluding observations for BCAP NCRs)
Q. A. File 52.1 contractor, if applicable (
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d of b~ 3G-23 Revision 0 12-22-82 O CONSTRUCTION DEFICIENCY EVALUATION l Part 1 DESCRIPTION , Describe The Deficiency (Attach references) Yo\e su 8eAM ]A0520k) F62 DR% G594 TS PUWt %T A,uo ThnA caoPsw v o Ow c, R vou >baw - 1lo l-e in BEAM TA6 ?// DMS mbt AP00AL bG D&& CWG Part 2 EVALUATION O 2A Safety Impact Yts NO Does this deficiency, whether or not safety related, affect safe operation of the facility. 28 Significance
'YES NO Is a breakdown in QA Program apparent which requires $100,000 in resources to re-establish assurance of program?
Are expenditures of $100,000 necessary to rework structures, systems, components into compliance with approved design? ( l Are expenditures of $100,000 necessary to repair structures, systems., components into compliance with approved design? O \ Is approved final design inadequate to assure compliance with SAR and construction permit? I
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During Installation / Testing is it apparent that a structure, system, ; _ component supplied by others can not meet the required performance ' specifications and should be reported (10CFR21) other users? (i.e. Potential Industry Deficiency) Does Inadequate Management review / corrective action exist which ignores significant adverse trends? Do pre-operational or start-up test results determine a system that does not meet safety analysis report or technical specification requirements? part 3 REPORTABILITY OF 50.55e NOTIFICATICII If the answer to Part 2A is Yes and any answer in Part 2R is Yes, this deficiency shall be reported to Nuclear Regulatory Cosuaission Region III Headquarters. Items not reportable Items reported to date NRC Regi II Evaluated / - ~ _ _ _ _ _ ,
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- R. R. ** 1, P.O. Bo a 83 A2 Braceville. IL 60407 (815)458 2801 Comstoc< Engineering.Inc.
A CouSTCCW GROUP CovpaNe April 1, 1985 Commonwealth Edison Co. Braidwood Station R. R. 1, Box 81 Braceville, IL 60407 Attn: D. L. Shamblin Proj. Construction Superintendent
SUBJECT:
BR-PCD #288 Letter
Dear Mr. Shamblin:
Pursuant to the above referenced letter dated 3/29/85, listed below are the planned actions to be taken by Cemstock Engineering, Inc. relative to the above subject. I. Comstock Engineering, Inc. has enforced Policy ( ,) Statement 1.0.0 relative to the QC inspector concerns. v II. Comstock Engineering, Inc. will be performing an investigation of the concerns. The Comstock investi-gation team will consist of R. E. Marino, General Manager QA/QC Services Comstock Engineering, Inc.; T.N. Trumble, Corporate Adminis*. ration Manager Comstock Engineering, Inc. This investigation shall commence on 4/2/85. III. Based upon the results of this investigation, the future status of the Comstock QA/QC personnel will be finalized. If you have any questions or require any additional information, please contact me. Sincere 1y, A;'~ T. E. Paserba w/ QA/QC Services Manager Chicago Office TEP/sem cc: R. E. Marino p T. N. Trumble ; 3( g ;q ( j F. Rolan
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Y ,. # , 8 C/ May 17, 1985 Richard Saklak 2307 Lexington Dr. #306 Mt. Prospect, 11. 60056 312-981-0621 Dan Schamblin Commonwealth Edison Braidwood Nuclear Power Plant R.R. #1 Braceville, 11. 60407
Dear Dan,
I am writing to you in hopes that you could possible shed some light on my discharge with the L.K. Comstock Quality Control Department. The basis of this request from you is due to the lack of details I have received from L.K. Comstock Management. As it was put to me the day of my meeting with the L.K. Comstock Corporate Staff, "It's out of our hands." Allegedly Commonwealth Edison invoked a contractural s., agreement that allows Ceco to execute the right to hire or discharge
!'~ ') a given individual.
From the day (3-29-85) some 27 field inspectors reported harrassment and intimidation to the day (4-23-85) I was discharged, the opportunity to account for my actions to the NRC, Ceco or Quality First personnel was not granted. This bothered me particularly in that this situation was not handled the same way the John Seeders incident was handled and for that matter all parties involved in that case were still employed. After retracing my activities leading up to my discharge I have failed to see that this was the straw that broke the camels back. I also do not understand when reviewed in its entirety , and not just a one line quote from a half hour conversation that this incedent was so malign the penalty was ultimately dese rved. Recently I had applied for a conduit inspector position at the Bryon Station of which there were openings. Af ter perf orming the usual background checks my application was submitted to,the Ceco Q.A. Department and rejected without comment. Dan, as you and the other personnel in your department know I am not the kind of person who j ust gives up or quits when confronted with a problem. After working in the Nuclear Electrical Business for six (6) years I wasn't expecting to drop out of sight and start a new career from scratch. I would appreciate hearing from you at your convenience. [~) espr e t f ully ,
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Richard hr-Saklak
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6 - Bra.dwood Station RR 1. Box 81 /^7 C/ O .Comm:nwealth Edisen Co. Braceville. IL 60407 Telephone 815/458 2801 By certified Mail - June 6, 1985 BR/PCD 85-497 Mr. Richard Saklak 2307 Lexington Drive #306 Mt. Prospect, IL 60056
Dear Mr. Saklak,
I am responding to your May 17, 1985 letter. Commonwealth Edison Ccapany has forwarded this letter to Mr. Robert Marino, L. K. Comstock Engineering, Inc. A copy of our letter to Mr. Marino is enclosed for your information. We believe that since L. K. Comstock Engineering, Inc. was your Employer, that the reasons for your discharge are better provided by them. Very truly yours, _bdL.%LJL D. L. Shamblin Proj. Construction Superintendent Braidwood Station DLS/kje O G 20 5 C0003032 3
e 7 . . Commonwealth Edison Co. Bra dwood Station
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g R R 1. Box 81 I i Braceville, IL 60407 V Tetephone 815/458 2801 June 6, 1985 BR/PCD 85-496 L. K. Comstock Engineering, Inc. 920 Fort Duquesne Blvd. Pittsburgh, Pennsylvania 15222 Attention: Mr. R. Marino General Manager Q.A./Q.C. Services
Subject:
Braidwood Station - Units 1 & 2 Electrical Erection Work Sargent & Lundy Specification L-2790A
Reference:
May 17, 1985 letter, Richard Saklak (former L. K. Comstock Quality Control Supervisor) to Dan Shamblin (Commonwealth Edison Company Project construction Superintendent) (v
Dear Mr. Marino,
I am forwarding to you a letter from Mr. Richard Saklak which I received by certified mail on May 22, 1985. This letter requests that some light be shed on Mr. Saklak's discharge from the L. K. Comstock Quality control Departmant. The basis of Mr. Saklak's request is apparently due to the lack of details he received from L. K. Comstock management upon his discharge. A detailed explanation for the basis of Mr. Saklak's discharge is best handled by L. K. Comstock Engineering, Inc. It was my understanding this was done during your meeting with Mr. Saklak of April 3, 1985. During our phone conversation on April 2, 1985, I informed you of Com m nwealth Edison Company's position relative to future employment of Mr. Richard Saklak at the Braidwood Nuclear Power Station and any other Commonwealth Edison Company Nuclear sites. Specifically, I told you that it was Commonwealth Edison company's position that Mr. Richard Saklak be removed from a L. K. Comstock Q.A./Q.C. position at the Braidwood Nuclear Power Station and that Mr. Richard Saklak will not be employed in any other Q.A./Q.C. role or safety related role for any other Contractor at the Braidwood Nuclear Power Station or any other Commonwealth Edison Company Nuclear Site. Mr. Saklak is not barred from any of our Nuclear Sites in any other roles. Ve recommended to the L. K. Comstock and Company, Inc. that Mr. Richard Saklak not be employed at any other L. K. Comstock Nuclear Site in any Q.A./Q.C. role. K C 9 c o g g g y;,3
BR/PCD 85-496 Page 2 of 2 V We intend to respond to Mr. Saklak stating we have forwarded his May 17, 1985 letter onto you for your action. We will enclose a copy of this letter in our response to Mr. Saklak. We trust you will resolve this matter. Very truly yours,
\ d L. % J3' D. L. Shamblin Proj. Construction Superintendent Braidwood Station DLS/kje/1926a 0
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