ML20197B234
| ML20197B234 | |
| Person / Time | |
|---|---|
| Site: | Braidwood |
| Issue date: | 10/17/1986 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| CON-#486-1349 OL, NUDOCS 8610280280 | |
| Download: ML20197B234 (105) | |
Text
l OR G NAL UN11ED STATES b,
NUCLEAR REG ~ULATORY COMMISSION IN THE MATTER OF:
DOCKET NO:
BRAIDWOOD STATIU!1 50-456/457/0L UilITS 1 & 2 CUMi10i1 WEALTH EDISull (HEARING)
O b'
LOCATION:
CHICAGO, ILLINDIS PAGES: 14,913 - 15,019 ATE:
FRIDAY, UCTOBER 17, 1986 0
3fY 0
1 1
ace-FEDERAL REPORTERS, INC.
Oficial Reporters 444 North Capitol Street Washington, b.C. 20001 (202)347-3700 F F
[
0f)N NATIONWIDE COVERAGE
>6 1
)
14913
/
3 1
UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
3 BEFORE T'E ATOMIC SAFETY AND LICENSING BOARD 4
__________________x 5
In the Matter ~ f:
o
)
6
- Docke t No. 50-456 COMMONNEALTH EDISON COMPANY 50-457 7
(Braidwood Station, Units 1 8
and 2)
__________________x 10 Page: 14,913 - 15,019 11 United States District Court House
]{
}
12 Courtroom 1743 s_,-
Chicago, Illinois 60604 13 Friday, October 17, 1986 14
[)
15 The hearing in the above-entitled matter reconvened 16 at 8:00 A.
M.
17 B EFO RE:
[)
18 l
JUDG E HERBERT GROSSMAN, Chairman 19 Atomic Safety and Licensing Board U.
S.
Nuclear Regulatory Commission l
20 Washington, D.
C.
1
[]
21 JUDG E RICH ARD F.
COLE, Member, Atomic Safety and Licensing Board 22 U.
S.
Nuclear Regulatory Commission Washington, D.
C.
23 JUDG E A.
DIXON CALLIHAN, Member, J[
'N 24 Atomic Safety and Licensing Board U.
S.
Nuclear Regulatory Commission
( )
25 Washington, D.
C.
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Geneva, Illinois 60134
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14914 1
A PPEAR ANCES :
2 on behalf of the Applicant:
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3 MI CHA EL I. MILLER, E SQ.
PHILIP P.
STEPTOE, ESQ.
4 I sh am, Lincoln & Beale Three First National Plaz a 5
Chicago, Illinois 60602
)
6 On behalf of the Nuclear Regulatory 7
Commission Staff:
8 GREGORY AL AN B ERRY, ESQ.
ELAINE I.
CHAN, ESQ.
)
9 U.
S.
Nuclear Regulatory Commission 7335 Old Georgetown Road 10 Bethesda, Ma ryland 20014 11 On behalf of the Intervenor:
)
12 ROB ERT GUILD, ESQ.
13 14
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15 16 17 3
18 19 20
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21 22 I
23 J
24 25
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Sonntaq Reportina Service, _Ltd.
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14915
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1 EXHIBIT MARKED RECE IV ED
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2 Intervenors' Exhibit No. 172 14919 3
Applicant's Exhibit No. 153 14964 14978 4
Applicant's Exhibit No. 154 14963 Applicant's Exhibit No.155 14977 14978 6
Applicant's Exhibit No.156 14979 7
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O 14916 O
1 TESTIMONY OF O
2 THOMAS B.
THORSELL KENNETH THOMAS KOSTAL 3
4 BOARD EXAMINATION BY J UDG E G ROSSMAN:
14919 O
5 REDIRECT EXAMINATION 6
BY MR. STEPTOE:
14930 7
VOIR DIRE EXAMINATION BY MR. GUILD 15008 O
8 REDIRECT EXAMINATION (Continued) 15009 9
BY MR. STEPTOE l
l 10 0
11 12 13 lO 14 15 16 lO 17 18 l
l 19 lO 20 21 22 0
23 24 O
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1 JUDGE GROSSMAN:
The hearing is reconvened.
()
2 This is the 76th day of hearing.
3 Are there any prelimina ry matters ?
4 Mr. Steptoe.
O S
MR. STEPTOE:
Yes, Judge Grossman.
6 Overnight we have discovered a potential problem 7
with respect to Intervenors' Exhibit 170, which is a O
8 list of more-highly-stressed conduit hangers which was 9
prepared for Mr. Guild overnight, the night before last.
10 It was a reconstruction of events, o\\
O( b It appears right now that the engineer who prepared 11 N
12 it for me may not have gone f ar back enough in time to 13 get the weight of the conduits in the cales as of the
()
14 date that the list of more-highly-stressed conduit 15 hangers was sent to BCAP.
16 He went back to old cales, but he might not have
()
17 gone far enough back to get the correct numbers as of 18 January of 1985, when the list was prepared.
19 This is a reconstituted list, as we made clear in (J
20 the hearing record, and we may have made a mistake in l
21 crea ting it.
22 JUDG E GROSSMAN:
Okay.
(3
_s 23 MR. STEPTOE:
We will check that over the h
y j
24 weekend.
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JUDGE GROSSMAN:
You are going to have him go I
l D
2 over it and revise it and bring in a revised version?
3 MR. STEPTOE:
Tha t's correct.
1 4
J UDG E G ROSSMAN:
Okay.
That's fine.
l
?
5 We'll enter another designation for the revised j
6 one.
7 Any thing f ur ther ?
O 8
MR. GUILD:
Mr. Chairman, I have Intervenors' 9
Exhibit 163 reproduced -- that was the Bojan letter to 10 the Okonite Company -- and the original marked for the 1
11 Court Reporter.
l 12 J UDG E G ROSSMAN :
I'm sorry.
13 What's the number on that?
l')
14 MR. GUILD:
- 163, 15 JUDGE GROSSMAN:
163.
Okay.
Tha t's already 16 been adnitted.
O 17 MR. GUILD:
Yes, si r.
18 Mr. Chairman, I believe I had not offered 19 Intervenors' 172, th e --
D 20 J UDG E G ROSSMAN :
That's correct, you have 21 not.
l 22 MR. GUILD:
-- the memoranda regarding
' 0,,_
23 inspection point counting, and I would ask that it be S
)
24 admitted at this time.
O Sonntag_ Reporting Sertice,_Ltd.
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O 14919
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$Ok 1
JUDGE GROSSMAN:
Tha t's received.
()
2 (The document was thereupon received into 3
evidence as Intervenors' Exhibit No.
4 172.)
()
5 JUDGE GROSSMAN:
Any other preliminary 6
matters?
7 MR. GUILD:
No, sir.
C) 8 And I have no further questions for Mr. Thorsell or 9
Mr. Kostal, subj ect to the anticipated revisions and 10 corrections to their testimony that Applicant has 0
11 forewarned us of.
x_
12 JUDGE GROSSMAN:
Okay.
13 BOARD EXAMINATION
()
14 BY JUDGE GROSSMAN:
15 Q
Mr. Kostal, my exhibit, Intervenors' 167, which are the 16 response spectra, has some date on the top, but I can't
()
17 make out the year.
18 A
(WITNESS KOSTAL)
D: you have a copy of that one?
19 This is on the first page?
()
20 Q
Yes, that's correct.
21 A
(WITNESS KOSTAL)
That looks like it's dated in -- I'll 22 have to get the original on it.
It appears like about O
23 1984.
n()24 0
Well, it could be '84 or it could be '85, from the way
()
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1 mine looks.
O 2
Are you looking at the same number I'm looking at?
3 A
(WITNESS KOSTAL)
The date prepared I can't even see.
4 0
3/22/8-something and 3/27/8-something?
O s
A (WITuESS KoSTAL)
Right, right.
I 6
Q Okay.
If you could --
7 A
(WITNESS KOSTAL)
Sure.
()
8 Q
find out.
9 Let me ask you:
10 When you indicated that -- I don' t have my PSAR O()11 here.
It's in the office.
12 But I assume you have filed a response spectra in 13 the FSAR?
()
14 A
(WITNESS KOSTAL)
You would not have in the FSAR each 15 of the individual floor response spectras.
You would 16 have in the PSAR typical ones, but the -- and you would O
17 have the enveloped one at the base mat.
18 But you wouldn' t have the -- there's a book of 19 about, oh, 200, 300 of these, and those are not all O
20 included in the FSAR.
21 This happens -- well, I know there is at least 150 22 sheets, because there's 150 sheets that would have O
23 constituted this particular package, so all of those are 24 not included.
O Sonntag Repor ting Service, Ltd.
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U O
1 I can extract the examples of ones that are O
2 included in the FSAR.
3 Q
Okay.
Now, let me ask you:
4 When you said that you used in the FSAR and O
5 calculated in the FSAR, during the 1970 's, the response 6
spectra that would envelope Byron and Braidwood, did you 7
mean to indicate that you actually ran a calculation O
8 with regard to Braidwood or that you developed response 9
spectra for Byron which you knew would also envelope 10 Braidwood?
0 ;(~~
11 A
(WITNESS KOSTAL)
Okay.
What we did was we ran two LJ 12 independent analyses using time history.
Response
13 spectra is just a simply-identified version that's 0
14 applied at a floor in a building.
You actually have to 15 generate a response spectra at any given elevation.
You 16 need to have the original time history.
O 17 Using the time history and using the Byron model 18 and using the Braidwood model, we developed independent 19 analyses.
O 20 Given those two independent analyses, then we just 21 married the two together and enveloped the maximum 22 points from each of those two analyses to an enveloped O
23 response spectra for the site -- for both sites.
E xcu se 24 me.
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1 Q
Well, now, if I looked at the response spectra that you
)
2 have at Braidwood, would I see the broken line for the 3
Braidwood ?
4 A
(WITNESS KOSTAL)
Yes, sir.
)
5 What you would see is -- given the initial time 6
history, given the Braidwood model, there would be a 7
unique set of response spectra curves that are
)
8 applicable to Braidwood that would have been generated 9
for Braidwood only.
10 Those same unique spectra would have been generated
)
11 for Byron only.
12 When we add the two together, that gives you your 13 envelope spectra for the two plants, which was the J
14 basis, at the beginning of this proj ect, for the design.
15 0
And looking at those response spectra, then, I would be 16 able to see where the Braidwood response spectra are?
)
17 A
(WI TtlESS KOSTAL)
Right.
I -- tha t's correct.
18 This was just drawn up to kind of display for you 19 how the two marry at various places; but we would have a 3
20 unique spectra for Braidwood, which would literally be 21 the por tion of the spectra tha t's combined, as well as 22 dotted.
J 23 There would be just one unique curve for Braidwood.
24 The same unique curve would exist for Byron, also.
3 Sonntaq Reportina Service. Ltd.
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'\\O U 1
Q Okay.
O 2
Now, this date of 3/22/8-something, there were no
~
3 dif ferent. spectra generated at that time, were there ?
4 A
(WITNESS KOSTAL)
No, I don't know what the
()
5 clarification was at this particular time.
6 If you look at -- this is all part of the same 7
package, which has a page indicated up to 150, and the C) 8' spectras on the previous pages are all dated in 1974, 9
the approximately two other pages.
10 Q
Oh, there are dates.
Okay.
O()11 A
(WITNESS KOSTAL)
Yes, sir.
12 0
I didn't see those dates.
Well, that's fine.
13 I don't really need that last date, the n.
()
14 A
(WITNESS KOSTAL)
Okay.
15 Q
That satisfies my curiosity.
t 16 Now, let me ask you something with regard to the
()
17 example that we had of the bending radius, tha t j
18 evaluation that was made in which the bending radius of.
t 19 the conductors in the box, the bending radii -- that is,
{
'()
20 I believe, Cables 129 and 130 -- were less than the J
21 manufacturer's prescribed amounts.
22 Now, Mr. Thorsell, you are the expert on that.
1 O
23 A
(WITNESS T!!ORSELL)
Yes, si r.
p 24 0
What would have caused the bending radii to be less than
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3 sanntag nepor ting se rvi ce. Ltd.
Geneva, Illinois 60134 (312) 232-0262 4
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14924
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1 what was prescribed?
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2 A
(WITNESS THORSELL)
The size of the box.
3 Q
Okay.
4 Now, who prescribed the size of that box, Mr.
)
5 Thorsell ?
6 A
(WITNESS THORSELL)
Well, in general, the equipment 7
specifica tions are prepared by Sargent & Lundy, and
)
8 Sargent & Lundy has specific standards which address the 9
sizes of boxes for motor terminations.
10 In general, those boxes are larger than what is
)
)
11 normally provided by manuf acturers, in order to provide 12 more room for bending the cables in those boxes.
13 (Indica ting. )
l J
14 In this particular case, this was a portion of the 15 nuclear steam supply system.
16 That is provided by Westinghouse as an entire D
17 package.
The RC/PC coolers, along with the reactor and 18 the steam generators and everything else, come as one 19 package.
D 20 Westinghouse would not deviate f rom their standa rd 21 practice in providing a dif ferent size motor termination 22 box for these pa rticular f an coolers.
- ) O (In dica ting. )
23
)
24 Q
Well, I take it it's up to Sargent & Lundy, though, to q
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14925
)%s) 1 determine whether the equipment is satisfactory for the
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2 utilization of that equipment?
3 A
(WITNESS THORSELL)
Yes, sir.
4 Q
Wouldn' t'it have been possible for you to have specified
)
5 a larger junction box?
I 6
A (WITNESS THORSELL)
We could have.
7 I doubt that we would have received it in this D
8 case.
9 How ever, the box that's there, although smaller 10 than what we would have specified or would have chosen DO 11 had we had complete freedom to pick the size of the box, l
12 is adequate.
13 The bending radius that exists in the field is D
14 acceptable.
It's just that it is less than the standard 15 criteria that is provided by the manuf acturer.
16 0
Well, when the manufacturer --
17 A
(WITNESS THORSELL)
The cable manuf acturer I'm talking O
18 a bo u t.
19 Q
Pardon?
D 20 A
(WITNESS THORSELL)
It's less than the standard criteria 21 that's provided by the cable manufacturer.
l 22 (Indica ting. )
l 23 0
Okay.
24 Now, when the manufacturer, Westinghouse or O
Sonntag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 i
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1 whoever, supplied the motor and the box --
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2 A
(WITNESS THORSELL)
Yes, sir.
3 0
-- the manufacturer didn't know what cables would go 4
into that box,-did it, other than the cables necessary
)'
5 for that motor?
6 That is, a minimum number of cable; isn' t that 7
correct?
)
8 A
(WITNESS THORSELL)
Well, the manuf acturer of the box 9
would know that there would be two cables entering that l
10 box to provide power to the high-speed and low-speed i
11 fans.
12 What the manuf acturer would not know -- what the 13 manufacturer of the box, tha t is, would not know --
)
14 would be the size of those cables.
15 He would know the size that he would pick for those 16 cables.
)
17 In general, the cable size that we select in the 18 process of designing is very conservative; and as a 19 resul t, the cables that we use may be slightly larger 20 than what the manufacturer may anticipate.
21 If I can give you an example.
The wiring in your 22 house is probably No. 14 AWG, and the fuses or circuit
)b, 23 breakers in your house are probably 15 amps.
t 24 When I use a No. 14 AWG cable in the design of the
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Sonntaa Reportina Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
C) 14927
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1 Braidwood station, I do not carry more than 6 or 7 amps
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2 in that same wire.
3 0
Well, when.I wire my house, I use a 12 cable --
4 A
(WITNESS THORSELL)
Okay.
()
5 0
-- because I'm even more conservative than you.
6
( Laugh ter. )
7 But in this particular item, this junction box, C) 8 were you only using the cable that was necessary for the 9
motor or did you also have other cable going into the 10 box?
()
11 A
(WITNESS THORSELL)
No.
There were only two cables in 12 the box, the two cables that are required to feed the 13 motor.
C) 14 The motor, in this particular case, is an unusual i
15 motor.
It's a single motor, but it has two windings, a 16 high-speed and a low-speed winding.
()
17 The high-speed winding is a 150-horsepower motor, 18 essentially, and the low-speed winding is a 19 100-horsepower motor.
()
20 Each of the motors is a 3-phase -- or each of the 21 windings is a 3-phase winding for a 3-phase motor.
22 So there are 3 conductors for each that come out of C) g s 23 the motor, 3 what we call pigtails for connecting the
!(
24 power to the motor, so there's 6 pigtails that come out.
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1 We run 2 three-conductor cables to give us 6 l
C) 2 conductors, and the 6 individual conductors were j
3 connected to the respective 6 pigtails.
4 0
Okay.
O 5
By the way, just to clarify, I meant I use a No. 12 6
cable even with a 15-amp fuse or circuit breaker.
l 7
A (WITNESS T!!ORSELL)
Right.
l l
C) 8 JUDGE GROSSMAN:
Fine.
I l
l 9
Mr. Berry, why don't you move your chair around.
10 MR. BERRY:
I won' t take long, Mr. Chairman.
01(~')11 JUoc E GROSSMAN:
Oh, okay.
x/
12 MR. DERRY:
Ilaving read the witnesses' direct i
13 prefiled testimony and --
O 14 JUDGE GROSSMAN:
Is your mike on, Mr. Berry?
15 MR. BERRY:
Yes, it is.
16
!!aving read the witnesses' direct prefiled
()
17 testimony and af ter Mr. Guild's thorough examination, 18 the Staf f has no questions of these witnesses at this 19 time, Mr. Chairman.
()
20 JUDGE GROSSMAN:
Thank you.
21 Redirect, then, Mr. Steptoe.
22 MR. STEPTOE:
Judge Grossman, before I start
()[N 23 redirect, there were two questions that I thought were
( )
24 raised -- I'm not sure whether the Board is interested O
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1 in pursuing -- but during an,e,arly -- with respect to an t
l lO 2
earlier panel.
3 One was Judge Cole's question with,; respect to the I
4 torquing of bolts for for electrical terminations.
I IO 5
don't know whether he wants to' pursue it or not, but I
{
6 want to let -- I want to remind him of that.
l 7
7 J UDG E COL E:
I don't think that Vas my l
0 8
question.
I think Judge Grossman raised that-issue.
l 9
MR. STEPTOE:
- Okay, f
10 The second question was, Judge Grobs~ man, you asked O
11 whether there was a grounding cable -- or grounding --
12 JUDGS GROSSMAN:
Yes.
Okay.,That was just i
13 an aside, but --
E,,
O 14 MR. STEPTOE:
Okay.
I want to give the Board j
15 the opportunity to pursue it if you want to pursue those 1
16 questions.
Otherwise, I'll start my redirect.
O 17 JULGE GROSSMAN:
Yes, tha t's fine.
18 Those were not -- hold off for a second.
19 Okay.
I don' t recall the first question.
Th e O
20 second one was not important, so --
21 MR.-STEPTOE Okay.
22 Mr. Kostait is ihking me for one minute, apparently.
Og 23 A
(WITNESS KOSTAL)
I just want to get one piece of 24 information.
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l g
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MR. STEPTOE:
He wants to get one piece of O
2 information.
3 JUDG E GROSSMAN:
That's fine.
4 1
4 A
(WITNESS K0STAL)
Excuse me.
l l
O 5
MR. STEPTOE:
Thank you, Judge G rossman.
l 6
REDIRECT EXAMINATION l
l 7
BY MR. STEPTOE:
l O
8 0
Mr. Kostal, would you please explain what Sargent &
9 Lundy'F role Was in the RPSR element of BCAP?
10 A
(WITNESS KOSTAL)
Our role in the RPSR element was O
11 limited to a very small role.
12 As part of the BCAP program, we received copies of 13 the concerns that were written in this particular area; O
14 and we were to review those for whether or not there was 15 any technical information in those that would have 16 af fected the plant.
O 17 our review was conducted, and we responded back "no 18 comment" to probably most of the packages that we had 19 received.
O 20 a
okay.
21 Would you identify -- well, did Sargent & Lundy 22 have any responsibility for identifying concerns with O
23 respect to the procedures of plant contractors?
24 A
(WITNESS KOSTAL)
No, we had no concerns, nor did we O
Sonntag Reporting Service. Ltd.
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l l g x.s I
I have -- relative to identifying nor rela tive to O
2 dispositioning them.
3 Q
You had no role in that?
l l
4 A
(WITNESS KOSTAL)
No role.
l O
5 o
Now, wha t role, if any, did Sargent & Lundy play in the 6
RSCAP portion of the BCAP program?
1 7
A
-(WITNESS KOSTAL)
We had no role at all.
l l
O 8.
o Did you -- I take it you had no role -- strike that.
l l
9 You were asked by Mr. Guild whether S & L, prior to l
10 the beginning of the BCAP program, had had some
,m O(V) 11 responsibility for corrective actions at the Braidwood 12 site; is that correct?
13 A
(WITNESS KOSTAL)
Yes, sir.
()
14 o
Did you have some responsibility for some of the 15 corrective action programs which were reviewed as part 16 of RSCAP?
O 17 A
(WITNESS KOSTAL)
As part of our normal role as the 18 engineer at the site, we evaluated the corrective action 19 in terms of if there were discrepancies found through O
20 tha t -- tnrough that corrective action, we would have 21 performed engineering ~ evaluations on those found 22 discrepancies.
O,m 23 o
So I take it f rom your previous answee '-- what role did
(
)
24 you play in BCAP in assessing the adequacy of those O
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1 corrective action programs?
O 2
A (WITNESS KOSTAL)
We played no role in assessing the 3
adequacy of those programs through BCAP.
4 Q
Now, during the time that BCAP program was formulated, 1
0 5
were you involved in that process, Mr. Kostal?
6 A
(WITNESS KOSTAL)
No, sir.
7 0
were you involved in any of the public meetings that O
8 took place as the BCAP program was being conducted?
l 9
A (WITNESS KOSTAL)
I was involved in public meetings l
l 10 once the BCAP program started and once we were reporting O O 11 on a regular monthly basis to the NRC the status of that V
12 program.
t 13 MR. GUILD:
Excuse me.
lO 14 For clarity, Mr. Chairman, when counsel asks "you,"
l l
15 is he referring to Mr. Kostal personally or Sargent &
l 16 Lundy as an entity?
l l
O 17 MR. STEPTOE:
In this case, my question was 18 directed towards Mr. Kostal personally.
19 BY MR. STEPTOE:
l l
O 20 0
At those public meetings, did the NRC ever suggest or l
I 21 indicate to you that Sargent & Lundy ought to meet the 22 criteria for independence set forth in the BCAP program l
O 23 document for the Independent Expert Overview Group?
24 A
(WITNESS KOSTAL)
No, sir.
l l
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1 Q
Did you ever hear them suggest that or indicate that to C) 2 anyone ?
3 A
(WITNESS KOSTAL)
No, sir.
4 0
At those public meetings, was the role of Sargent &
O 5
Lundy in BCAP ever described?
[
6 A
(WITNESS KOSTAL)
Yes, sir.
7 I personally described the role at one of the very
()
8 earliest public meetings; in fact, the earliest public 9
meetings that I'm aware of.
10 I gave a presentation with illustrations showing O()11 the Sargent & Lundy organization that would be involved 12 in BCAP as well as our relationship to BCAP; and at that 13 meeting, in fact, Intervenors' representatives were
()-
14 presen t.
15 0
Who were the Intervenors' representatives who were 16-present at that meeting, sir?
O 17 A
(WITNESS KOSTAL)
Two that I can recall.
One was Mr.
18 Cassel and the other was Charlie Stokes, who was 19 attending with him.
()
-20 Q
Do you know who Mr. Stokes is?
Can you tell us who Mr.
21 Stokes is?
22 A
(WITNESS KOSTAL)
Mr. Stokes was involved in the Byron 23 licensing activities and started to be involved in the
() g_s\\
24 Braidwood, and then all of a sudden we didn' t see Mr.
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Sonntag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
- O 14934 (3
1 Stokes after the first meeting or so.
(3 2
0 Okay.
3 Now, Mr. Stokes was the Intervenors' engineering 4
expert witness in the Byron case, was he not?
- ()
5 A
(WITNESS KOSTAL)
That's correct.
6 MR. GUILD:
Mr. Chairman, excuse me.
7 I certainly can deal with this question on recross;
,(3 8
but I'd suggest that Mr. Kostal doesn't have any 9
competence to speak to whether or not Mr. Stokes started 10 to be involved in Braidwood or not.
w
.()
11 If he's saying that he saw him at a meeting and if 12 it's his recollection that he then didn't see him 13 thereafter, then that certainly is within his knowledge.
()
14 But he certainly doesn't have the competence to 15 know one way or the other what Charlie Stokes' 16 involvement was in the Braidwood litigation.
!(D 17 MR. STEPTOE:
That's certainly true.
18 JUDGE GROSSMAN:
Okay, fine.
19 It's clarified for the record.
- O
-20 MR. STEPTOE:
Okay.
21 BY MR. STEPTOE:
22 Q
Did you ever see any of Intervenors' representives at
- <D 23 any other meeting, Mr. Kostal?
O
(
24 A
(WITNESS KOSTAL)
Yes; at many of them.
- O sonntaa Repor ting se rvice. Ltd.
Geneva, Illinois 60134 (312) 232-0262
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(
)
9 q, 1
Q Who were the Intervenors' representatives or O
2 representative?
3 A
(WITNESS KOSTAL)
Mr. Cassel.
4 Q
Mr. Cassel was the representative?
O 5
A (WITNESS KOSTAL)
He was personally present.
6 Q
At any of those meetings, did any of Intervenors' 7
representives ever suggest that Sargent & Lundy ought to O
8 satisfy -- I'm sorry -- that the requirements for 9
independence in the BCAP program document, with respect 10 to the Independent Expert overview Group, ought also to
<-'s O f.
)
11 apply to Sargent & Lundy?
12 A
(WITNESS KOSTAL)
No, sir.
13 Q
When was the first time that you heard anyone suggest O
14 that Sargent & Lundy -- that the requirements in the 15 BCAP progr am document relating to independence ought to 16 be applied to Sargent & Lundy ?
O 17 A
(WITNESS KOSTAL)
During this last week by Mr.
18 Cassel -- Mr. Guild.
19 Q
During these public meetings, were the BCAP preliminary O
20 results presented?
21 A
(WITNESS KOSTAL)
Yes, sir.
22 0
Who presented them?
O
~s 23 A
(WITNESS KOSTAL)
The results of the engineering I
'N
( )
24 evaluations being performed were presented by me.
O sonntag neporting service. Ltd.
l Geneva, Illinois 60134
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(312) 232-0262
~O 14936
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0 Were they ever presented on an inspection point or l()
2 discrepancy point basis?
3 A
(WITNESS KOSTAL)
We presented them both ways, 4
4 Q
Did the NRC ever indicate to you that the presentation lO 5
of those results on an inspection point or discrepancy 6
point basis reflected a violation of any commitment by 7
Commonwealth Edison Company?
l()
8 A
(WITNESS KOSTAL)
No, sir.
9 JUDGE GROSSMAN:
Excuse me.
10 The witness indicated that it was presented on both O(
11 bases, but I only heard one basis mentioned.
12 Do you want to clarify the record on that?
13 MR. STEPTOE:
Oh, sure.
,0 14 BY MR. STEPTOE:
15 0
What do you mean by "both bases," Mr. Kostal?
-16 A
(WITNESS KOSTAL)
We presented the data initially on 0
17 individual components.
18 For example, I presented a complete cable pan 19 hanger or a complete conduit hanger, and I showed which
- ()
20 elements had discrepancies associated with them.
I 21 I reviewed, during those presentations, some of the.
22 more notable discrepancies and what those ef fects were
!O,-
23 on the R values as well as the safety margins of the 24 components, j(3 Sonntao Reportino Service. Ltd.
Geneva, Illinois 60134 (312) 232-0262
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14937 7'~s
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l l
1 I gave illustrations of dif ferent types of 2
discrepancies through all the different populations and 3
whether or not we were finding a significant number of 4
those types or to characterize what we were finding at
)
5 that point in time.
6 So it was a continual updated status report on the 7
entire given package and a given type of discrepancy.
)
8 I even reviewed it to the point of on an individual 9
attribute basis, which would be an inspection point 10 saying that, for example, "We were having X number of
.,m
)(
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11 loose flex conduit couplings in one population versus 12 the number of clamps that could be missing," or -- at 13 that time I can't remember exactly all the dif ferent
]
14 things, but they did get down to individual attribute 15 bases, which would be inspection point bases types of 16 things.
)
17 JUDG E GROSSMAN:
Okay, Mr. Kostal.
I didn' t 18 try to get all that information from you.
19 But you only mentioned inspection point / discrepancy 3
20 point basis; and you didn't mention, in your answer, 21 item / discrepancy basis, which I understood to be the 22 other basis that you referred to.
[)
23 A
(WITNESS KOSTAL)
Inspection point bases were discussed 24 at subsequent meetings further along in the program.
[)
Sonntag Reporting Service. Ltd.
Geneva, Illinois 60134 (312) 232-0262
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14938
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i j
1 I don't remember the exact date that we gave the
)
2 statistics on inspection point bases, but it did come 3
somewhere in the -- I want to say the spring or early 4
summer of 1985, when we were starting to get further
)
5 along in the program and we could give a more -- a 6
better picture where everything was.
7 (Indica ting. )
)
8 JUDG E GROSSMAN:
Mr. Steptoe, 9
BY MR. STEPTOE:
10 0
Mr. Kostal, did Intervenors' representatives attend any
)(v) 11 of the meetings during which your results were presented 12 on an inspection point and discrepancy point basis?
13 A
(WITNESS KOSTAL)
I know Mr. Cassel attended a number
)
14 of meetings.
15 specifically which meetings he was present at or 16 not present at, I just don't recall.
)
17 But I know that he attended a large number of 18 mee tings, and so he was present at a number of my as 19 well as the BCAP representatives' presentations.
)
20 (Indica ting. )
21 Q
Do you recall anyone suggesting, in any of those public 22 meetings at which the data was presented on an 23 inspection pointdiscrepancy point basis -- whether
)i,,_
's 24 anyone suggested that that presentation of that data in (v)
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Sonntaa Reportino Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262 j
- O r
14939
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that form might be a violation of Commonwealth Edison's 4
!()
2
-commitment to the NRC?
3 A
(WITNESS KOSTAL)
No, sir.
4 Q
Okay.
- ()
5 When was the first time you ever heard that 6
suggestion made?
7 A
(WITNESS KOSTAL)
By Mr. Guild in the courtroom.
i
- ()
8 Q
In the last week?
9 A
(WITNESS KOSTAL)
Yes, sir.
10 MR. GUILD:
Time flies.
!()
)
11 I think it was probably two weeks ago, actually.
12 BY MR. STEPTOE:
13 0
Now, Mr. Thorsell, did anyone review Sargent & Lundy's
- (3 14 evaluations for design significance which were conducted 15 as part of the BCAP program?
16 A
(WITNESS THORS ELL)
Yes, sir.
!(3 17 Q
Did anyone -- any organization other than Sargent &
18 Lundy, I mean.
19 A
(WITNESS THORSELL)
Yes, sir.
()
20 During the conducting of the BCAP program, 21 evaluations were done as discrepancies were received.
22 On three separate instances that I can recall, I (3
23 sat down with Stone & Webster engineers, who were part
)24 of the BCAP CSR engineering group, and reviewed the
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1 methodology as well as the details of specific D
2 evalua tions.
3-In addition to that, our evaluations were subj ected l
4 to r eview, I believe, on two dif ferent occasions by the O
5 IEOG.
6 There was also two separate occasions during the 7
course of BCAP where I met with representatives of the C) 8 NRC to discuss the methodology that was being used in l
9 our evaluations; and subsequent' to completion of the 10 evaluations, a group of NRC representatives f rom Region P
11 III came into Sargent & Lundy's offices and conducted a O
12 review of our evaluations.
13 Q
Now, did you have an opportunity to review -- to observe
().
14 the Stone & Webster -- how Stone & Webster approached 15 their r eview of the BCAP engineering evaluations 16 performed by Sargent & Lundy?
()
17 A
(WITNESS THORS ELL)
Yes, sir.
l 18 Q
Would you describe that, please ?
19 A
(WITNESS THORSELL)
At the time that they reviewed I
().
20 several of our evaluations, we had found those to be not 21' design significant.
\\
22 The Stone & Webster engineers were initially
$3 23 skeptical that each of these discrepancies could be
)
24 found not design significant, and af ter reviewing the --
I l(3 Sonntaa Repor tina Se rvice. Ltd.
Geneva, Illinois 60134 i
(312) 232-0262
O 14941 O
O 1
JUDGE GROSSMAN:
Excuse me.
O 2
Before you go any further, do you intend to call 3
Stone & Webster people in here, Mr. Steptoe?
4 MR. STEPTOE:
No, Judge Grossman.
O 5
JUDGE GROSSMAN:
We're getting into a hearsay 6
problem here.
7 MR. STEPTOE:
. Judge Grossman, the purpose of O
8 this line of examination is simply to indicate the level 9
of review, the type of review, which was performed.
10 It's not to -- it's not to say that because the --
O 1
11 because ERC looked at different calculations, it's U
12
- right.
13 It's more'to rebut the assertion, the implicit O
14 assertion, that because S & L was -- had prior contact 15 with B raidwood, therefore, their evaluations can' t be 16 trusted.
O 17 I am simply eliciting the objective fact that their 18 calculations were reviewed critically.
19 MR. GUILD:
Well, that's exactly the problem, O
20 M ~r. chairman.
It's the " critically" bit.
21 He can say, "I saw a Stone & Webster person in my 22 office, and he shuffled some papers," and he can O
23' probably say what the Stone & Webster man told him.
,Q -24 But if we're going to be, in effect, using the O
sonntag neporting service. Ltd.
j Geneva, Illinois 60134 (312) 232-0262 j
O L
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14942
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Stone & Webster actions and conclusion to buttress
- ()
2 Sargent & Lundy's position and Applicant's position, the 1
l 3
only way to do that and give Intervenor a fair crack at 4
the Stone & Webster people is to bring in the Stone &
10.
5 Webster people.
6 Indeed, the last series of responses are hearsay,
.[
7 and I certainly --
f(3 -
8 MR. STEPTOE:
Excuse me, Judge Grossman.
i 9
He can say far more than that they shuffled some 10 papers.
He can say, based on personal observation, that 4
lO(
)
11 they went through some of those calculations line by 12 line.
13 JUDG E GROSSMAN:
Yes.
But the only probative I
- ()
14 value for this whole of line of questioning is that 15 Stone & Webster supported, in some way or another, 16 Sargent & Lundy's position.
lO 17 Now, I don't think we want to expand the case to 18 tha t.
4 19 MR. STEPTOE:
I don't intend that.
I'm not
()
20 trying to expand the case.
21 I think the probative value is that S & L was i
22 very -- that S & L was conscious of Stone & Webster's C> g s 23 review.
)
24 I am concerned about what S & L -- what the effect
(
j l C) sonntag Repor ting se rvice. Ltd.
Geneva, Illinois 60134 (312) 232-0262
)
14943
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1j' 1
of that was on S & L.
I'm not concerned about trying to
)
2 prove the integrity of S & W's, Stone & Webster's,
{
3 r evi ew.
4 JUDG E GROSSMAN:
Okay.
)
5 I take it, then, you are agreeable to not having 6
any of this testimony used to support the proposition 7
that Stone & Webster approved what Sargent & Lundy was
)
8 doing in any way?
9 Well, you can' t have it both ways.
10 MR. STEPTOE:
Well, I understand.
)(,'.J) 11 My formulation might be slightly dif ferent, Judge 12 Grossman, but I think we' re in essential agreement.
13 What I would be content with is simply allowing
)
14 this examination to indicate that the Sargent & Lundy 15 engineers were conscious of a certain level of review by 16 Stone & Webster.
)
17 J UDG E G ROSSMAN :
Okay.
We'll let it in for 18 that, but we're not going any further than that.
19 MR. STEPTOE:
I agree, Judge Grossman.
)
20 JUDGE GROSSMAN:
Okay.
21 MR. GUILD:
Mr. Chairman, I take it the same 22 principle really applies as well to the references to
)7,
23 the Independent Expert Overview Group and the NRC.
(
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(
)
24 They have to rise or f all on their own footing and l
)
Sonntag Reporting Service. Ltd.
I Geneva, Illinois 60134 (312) 232-0262
b 14944 y
)
1 not simply on the basis of Mr. Thorsell telling us that
)
2 they reached certain conclusions.
3 JUDGE GROSSMAN:
W ell, tha t's correct.
4 That's the ruling that we've made throughout:
That if
)
5
~ anyone is going to rely on someone else's review, 6
whether it's an Inspection Report or an overview, they 7
are to bring in the people making that review.
)
8 We' re not going to allow hearsay testimony as 9
probative evidence of the r eview.
10 MR. STEPTOE:
Okay.
)(
- 11 JUDGE GROSSMAN:
Fine.
12 MR. STEPTOE:
I understand the Board's 13 ruling, Judge Grossman.
[)
14 BY MR. STEPTOE:
15 0
Mr. Thorsell, what was the level of detail of Stone &
16 Webster's reviews that you witnessed?
l[)
17 A
(WITNESS THORSELL)
The level of detail was sufficient i
18 to have them request that Sargent & Lundy revise a 19 number of our evaluations in order to provide greater I) 20 clarification of several issues.
21 Q
Well, Mr. Thorsell, was it your perception, to use Mr.
22 Guild's words, that Stone & Webster just went into a 23 room and shuffled papers?
24 A
(WITNESS THORSELL)
No, sir.
They would not have come
[)
Sonntac Reporting Service, Ltd.
l Geneva, Illinois 60134 (312) 232-0262
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14945
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)
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back and requested that revisions be made to evaluations
)
2 had they merely shuffled papers, j
3 Q
Did you make the revisions and clarifications that they l
4 req uested?
l
)
5 A
(WITNESS THORSELL)
Yes, sir.
i 6
Q Now, if I asked you -- let me just ask you:
l 7
With respect to the reviews performed by ERC and
)
8 NRC, were you conscious, at the time that you were l
l 9
performing the BCAP evaluations, that your work was l
10 being reviewed or going to be reviewed by the ERC 7,~
Z
)
11 engineers and by the NRC Staff ?
I
'x _ /
12 A
(WITNESS THORSELL)
Yes, sir.
13 Q
And, in fact, I think you've already testified that your
)
14 work was reviewed by those two organizations; is that 15 correct?
16 A
(WITNESS THORSELL)
Yes, sir.
)
17 Q
Did Stone & Webster or the ERC or the NRC ever tell you 18 that any of your calculations were in error and had to 19 be changed?
)
20 A
(WITNESS THORSELL)
No, sir.
21 Q
Now, because Mr. Guild is about to ask this, I'll ask 22 it:
23 Did Stone & Webster or ERC or NRC catch the error t
(
24 in CBL -- in the Observation Package CBL 130, which you
)
Sonntag Reporting service. Ltd.
Geneva, Illinois 60134 l
(312) 232-0262
-O '
14946 m
.Q 1
described to the Board earlier this week?
O 2
A (WITNESS THORSELL)
No, sir.
3 Q
Mr. Kostal, back to you.
4 The problems of Systems Control welding have been
'O 5
discussed.
6 Can you compare the Systems Control welding 7
deficiencies identified in NCR 451 with the welding O
8 deficiencies that were found at Byron?
9 A
(WITNESS KOSTAL)
Yes, si r.
Th ey a r e --
10 MR. GUILD:
Obj ection.
- O 11 I'm sure he could, but it's beyond the scope of 12 proper redirect; and I think we have a pretty clear 13 ruling on this exact point already.
,0 14 We've joined this issue, and it's been decided 15 adversely to Applicant, unless we're going to get into 16 what Byron's standards were for Systems Control
!O 17 Corpora tion.
i 18 JUDG E GROSSMAN:
I take it you are referring 19_
to the ruling on Zimmer.
4 O
20 MR. GUILD:
No, sir.
I'm talking about 21 carlier Mr. Kostal wanted to tell the Board what he did 22 at Byron regarding the analysis of Systems control On 23 Corporation welding problems and cable pan hangers.
24 He's now being asked to compare what he did at jO sonntaa Repor tina Se rvice. Ltd.
Geneva, Illinois 60134 (312) 232-0262
--=-
r 14947 Q
l Byron to what he did at Braidwood, and it's the same O_.
2 probl em.
3 If we' re going to make an excursion into what he 4
did at Byron, then indeed we're going to have to have
()
5 more ' discovery of what he did at Byron and some more 6
cross examina tion.
7 It's j ust beyond the scope of --
C) 8 MR. STEPTOE:
Judge Grossman, that wasn' t the 9
. question.
The question was what was the nature of 10 welding deficiencies found at Braidwood compared with O
11 those that had been found at Byron.
l \\.
12 The next question would be what was ' the' t
l 13 corrective -- could' he compare what the corrective 1
O.
14 action was at Braidwood compared with the corrective 15 action which was approved by the Licensing Board at 16 Byron.
O 17 MR. GUILD:
The same obj ection.
18 MR. STEPTOE:
And I am not -- I'm not --
19 JUDG E GROSSMAN:
It take it you are not
[()
20 comparing the magnitude of problems here at Braidwood i
- 21 with Byron, or are you?
\\
22 MR. STEPTOE:
That's implicit in the
[()
23 question, yes, Judge Grossman.
I
\\
l 24 JUDGE GROSSMAN:
Then we have to determine l()
Sonntag Reporting Service. Ltd.
Geneva, Illinois 60134
( 112) 232-0262 i
)
14948 3'xs 1
what the magnitude of the problems were at Byron, and O
2 we' re opening up a new ball game.
Judge Grossman, I believe the 4
record would show us these are the same supplier, the S
5 same hangers and so forth; and I believe it's also fair 6
to say, you know, we can't ignore the fact that 7
Commonwealth Edison and BPI litigated this subject in 9
8 the Byron case.
9 JUDG E GROSSMAN:
Yes, but that's not 10 collateral estoppel in this case.
Tha t's precisely 11 because we have different parties involved here -- or a 12 dif ferent subject area, anyway.
13 MR. GUILD:
The parties are close.
J 14 JUDGE GROSSMAN:
W ell, the parties are 15 different, also.
If it were collateral estoppel, you 16 wouldn' t have to of fer evidence.
D 17 I don' t think we want to expand the scope of this i
18 case into Byron.
19 MR. STEPTOE:
Well, my concern, Judge D
20 G ros sman, is that it's already been expanded by 21 Intervenors on cross examination, and what the record 22 shows now is tha t there are Systems Control welding 9,,,
23 difficulties at the Braidwood plant.
j 24 JUDGE GROSSMAN:
Yes.
D Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
O 14949 iO V
.O 1
MR. STEPTOE:
All right.
I think I can go O
2 about it another way, Judge Grossman.
3 JUDGE GROSSMAN:
Okay.
I'm not trying to 4
discourage you from putting on your case.
O 5
But I just want to point out that if it includes 6
the element of Byron in it, then it's only fair to try i
7 that if it were within the scope.
lO 8
But I don' t think we want to expand it.
I don't 9
want to pursue this.
But in the recess, you can decide 10 what you want to do.
- O 11 I don't want to rush you into abandoning a line of 12 questioning is what I'm trying to say now; but if you 13 can reconstruct the questioning so that it doesn' t O
14 involve what happened at Byron, tha t's fine.
15 Why don't you proceed to another line of 16 questioning.
O 17 MR. STEPTOE:
I'll try a different approach, 18 Judge Grossman.
19 JUDG E GROSSMAN:
Fine.
- O 20 BY MR. STEPTOE:
21 Q
Mr. Kostal, what was the corrective action taken at 22 Braidwood with respect to the welding deficiencies O
23 identified with respect to Systems control-supplied 24 cable pan hangers?
1 JO sonntag neporting service. tea.
Geneva, Illinois 60134 (312) 232-0262 4
iO 14950 (v'~)
2 o
1 A
(WITNESS KOSTAL)
The corrective action is associated
!(3 2
with 451 NCR, in which a sample of 80 hangers was 3
inspected for the welds associated with the Systems 4
Control work.
The results of those inspections were
()
5 documented in weld maps.
6 Sargent & Lundy performed. an engineering evaluation 7
on the design significance of the discrepancies noted.
.()
8 They concluded that there were no design-significant 9
discrepancies and accepted the quality of the work in 10 the Systems Control area.
- Cjt(~mi 11 In addition to that, there was one additional area
\\)
12 where we had an additional corrective action, and that 13 was in the walking down of every single cable pan hanger O
14 and the welds associated with Systems Control for the 15 presence of welds.
16 We evaluated those hangers for the presence of l()
17 welds, of all the discrepancies found.
1P Q
What was done in the event that the welds were 19 identified as missing or partially missing?
!(D '
20 A
(WITNESS KOSTAL)
One of two things occurred:
21 Either we performed an engineering evaluation and 22 determined the design significance and found that the
()
23 portion of missing weld or missing welds was acceptable
)24 to remain in place as is, or we recommended corrective
~
()
Sonntag Repor ting Se rvice. Ltd.
Geneva, Illinois 60134 (312) 232-0262
lO 14951 g \\~-
1 action, which meant the replacement of the missing weld.
O 2
Q Did Sargent & Lundy come to a conclusion with respect to 3
the adequacy of those corrective actions that you just 4
described; namely, the sampling program under NCR 451 0
5 and the walkdown program --
6 A
(WITNESS KOSTAL)
Unde r --
7 0
-- for weld presence?
O 8
A (WITNESS KOSTAL)
Under 708 and 709 --
9 Q
You are referring. to NCR's 708 and 709?
10 A
(WITNESS KOSTAL)
That's right.
That's why the O()11 walkdown program took place.
12 Yes, we drew a conclusion.
We drew the conclusion 1
13 that the work that exists out in the plant as a result 0;
14 of those two programs is adequate and acceptable.
15 Q
Okay.
16 What was the basis for that conclusion?
C) 17 A
(WITNESS KOSTAL)
The basis for that conclusion was, as 18 I mentioned before, the sampling program that was 19 conducted as well as the walkdown program that was O
20 performed.
21 Q
Okay.
22 Is there any other basis for your confidence that Os 23 those corrective actions are adequate?
I 24 MR. GUILD:
Obj ection, Mr. Chairman.
() '
Sonntag Repor ting Se rvice Ltd.
Geneva, Illinois 60134 (312) 232-0262
- O 14952
- O v]
1 He asked the question, he got the answer.
N ow h e 's (3
2 begging the witness to think of something else.
3 It's asked and answered, and it's objected to.
4 JUDG E GROSSMAN:
We'll allow that.
The O
5 witness may even need his -- well, we'll allow that 6
question.
t 7
A (WITNESS KOSTAL)
The other basis that I would have is
- (3 8
the fact that we have, through the walkdown program, 9
performed analysis on all the hangers associated with 10 the cable pan hanger support system, and that those
- O f~'\\
11 calculations do exist in place, which present at this O
12 point -- which, at this point in time, meet the design I
13 obj ectives to stay within the code allowables.
h3 14 (Indica ting) 15 JUDGE GROSSMAN:
Mr. Guild, let me just say, 16 this _isn't a memory test here, and I'm sure the
- O 17 testimony has been discussed with counsel, and if the 18 witness has a failure of memory, I don't think that that 19 ought to detract f rom his testimony.
l()
20 MR. GUILD:
Yes.
21 I just think that the question -- when the 22 questioner suggests that the answer is incomplete, it l
!()[ ~
simply causes the witness to reflect that his previous 23 (h) 24 answer is somehow inadequate and he searches then for 1
l f(3 Sonntaa ReDorting Service, Ltd.
j Geneva, Illinois 60134 (312) 232-0262
)
14953 i
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\\
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1 some adequate answer, and that it's not simply a 3
2
. question of jogging the memory, in my opinion.
3 It's the question of. prompting the witness to come 4
up with a better answer than the answer that he gave.
3-5 It's the same question asked again; but I understand the 6
Chair's ruling.
7 JUDGE GROSSMAN:
Fine.
3 8
BY MR. STEPTOE:
i 9
Q Mr. Thorsell, I'm distributing a one-page document 10 entitled " Bending Radius Observations. "
It's Bates 11 Stamp No. AR 006933006933
12 JUDGE GROSSMAN:
Applicant's Exhibit 153.
13 (The document was thereupon marked O
14 Applicant's Exhibit No.153 for 15 identification as of October 17, 1986.)
l l
16 MR. STEPTOE:
Thank you.
l O
17 BY MR. STEPTOE:
18 Q
Mr. Thorsell, who prepared this document?
19 A
(WITNESS THORSELL)
I did, i
20 Q
When did you prepare it?
- D 21 A
(WITNESS THORSELL)
I believe it was two days ago at 22 your request.
O 23 0
Okay.
24 And, in fact, that was provided to Mr. Guild, was O
sonntag Repor ting se rvice. Lta-Geneva, Illinois 60134 (312) 232-0262
'O.
14954 1
(m\\
- O
1 it not?
()
2 A
(WITNESS THORSELL)
Yes, sir.
3 Q
And he asked you some questions about it earlier this 4
week, did he not?
- O 5
A (WITNESS THORSELL)
Yes, si r.
6 0
Okay.
7 Can you identify for the Board what each column
- (3 8
represents ?
9 A
(WITNESS THORSELL)
The first column, entitled 10
" Observation No.," is a listing of the BCAP observation 4
!(DI T
11 numbers for each of the bending radius observations.
V l
12 The second column is a tabulation of the cable 13 number -- cable numbers associated with each of those
- ()
14 obse rva tions.
15 The third column is an indication of which 16 observation numbers -- or which cables were observed by
!O 17 the okonite Company during Mr. Bartolucci's visit.
18 The next three columns indicate the manner in which 19 the discrepancy identified in the observation was (3
20 dispositioned.
21 The first of those, which says, "Okonite letter,"
i 22 indicates that cable 130-02, which is Cable No. IV P0 0 4,
- <3 23 was dispositioned on the basis of the Laskey June 5, j
24 1985, letter.
( C)
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
O i
14955
('\\
.od 1
The second column "OAD Test" -- OAD refers to
()
2 Commonwealth Edison Company's Operational Analysis --
3 I'm not sure whether it's department or division -- and 4
tests performed on two of the cables by them used to LO '
5 disposition the observation.
6 Q
Excuse me, Mr. Thorsell.
7 What kind of test?
lO 8
A (WITNESS THORSELL)
These were Megger tests or 9
insulation resistance tests.
10 JUDG E GROSSMAN:
I'm sorry.
What kind of
/~N
- O 11 test?
12 A
(WITNESS THORSELL)
It's an insulation resistance test.
13 The instrument that is used for performing that
.:()
14 test is called a Megger, M-E- G-G- E-R.
15 And that testing was done by -- by the Operational 16 Analysis Division, which does all construction testing lO 17 a t Braidwood.
18 The third column, " Analysis," indicates that those 19 observations which were dispositioned by analysis; and (3
20 the four th column, "Out of Scope," indicates that the f
21 last three bending radius observations were determined 22 by BCAP to be out of scope.
!O 23 BY MR. STEPTOE:
g
(
24 0
Mr. Thorsell, there are 12 observations listed on this 1()
Sonntag Repor ting Service. Ltd.
Geneva, Illinois 60134 (312) 232-0262
'O 14956 rs
'O 4
1 page.
- (3 2
Is this a complete listing of all the bending 3
radius violations which were identified by the BCAP 4
inspectors?
h3 5
A (WITNESS THORSELL)
Yes, sir.
6 0
Going to the column marked " Analysis," would you just 1
i.
7 briefly describe what the analysis was that you are
- (3 8
referring to and who performed it?
9 A
(WITNESS THORSELL)
In general, I performed the 10 analysis.
O(
)
11 I would have to go back and check and see if I 12 performed the analysis in all six cases.
I believe that 13 I did; and what it involved was an analysis of the
!()
14 effect of the bending radius violation.
1 15 In each of these cases that were analyzed, the 16 bending radius violation occurred right at the
!(3 17 termination of the conductor of the control cable, and 18 at that point, the insulation is really not required to 19 be on the cable at all.
It's righ t -- right at the
!(3 20 point where the termination is made; and the reason that 21 the bending radius violation occurs is because of the 22 space available to bend the conductors around in order l(3 23 to land the lugs on the -- on the terminal.
k 24 (In di ca ting. )
- (3 Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 4
(312) 232-0262
.. _ _ _.. ~.. _ _ _, _. _ _ _
n O.
l 14957 lO V i
I l
l 1
In general, these occur in limit switches
!O 2
associated with valves.
3 My analysis identifies the fact that the insulation 4
system that is provided is a 600-volt insulation system
,0 5
and that the particular application in question is a 6
120-volt applica tion, and indicates that the failure of I
7 the insulation under a 120-volt. application is highly l
O 8
unlikely.
9 However, the analysis continues-to identify the 1
10 clearance and creepage dist$nces that. Exist, assuming l
O 11 total insulation f ailure, and applies' NEMA standards to l
12 justify that in the event of total insulation failure, 13 there would be no effect on the circuit operation.
O 14 JUDGE COLE:
- NEMA, N-E-M-A ?
15 A
(WITNESS THORSELL)
Yes, National Electrical
~~
)
16 Manuf acturers Associa tion.
O 17 J UDG E G ROSSMAN :,
Excuse me'.
I
(
18 If the bending radius violation were right at the l
19 point of contact with the terminal, isn't there a O
20 danger, the n, that the conductor might have been broken 21 by bending at that particular -- by so much bending at 22 that particular point?
O 23 A
(WITNESS THORSELL)
No, sir.
24 BY MR. STEPTOE:
~O sonntag neporting service. tea.
~
Geneva, Illinois 60134 I
(312) 232-0262
- O 14958 O
1 1
Q Mr. Thorsell, maybe you should draw a picture because of O
2 the kind of bending violation you are talking about.
3 A
(WITNESS THORS ELL)
What I've simplistically represented 4
here is an enclosure of a stem-mounted limit switch.
lO 5
The stem-mounted limit switch is, I would say, 6
approximately two inches wide, perhaps five inches long 7
and perhaps two inches deep, and there is an arm that O
8 comes out of the limit switch, and when the valve moves, 9
it actuates this arm and puts the contacts in one 10 position or another.
lO 11 (In dica ting. )
12 The cable entry is through a hub located at the l
l 13 bottom of the limit switch; and in this case let me 1'O 14 depict a 4-conductor cable entering the limit switch so l
l l
15 that all 4 conductors at this point are contained within l
l 16 a common j acket, and that actually extends up into the l
l l
O 17 body of the limit switch.
l l
18 (In dica ting. )
l l
19 At that point the outer jacket is removed and each l
l O
20 of these conductors is the% te'minated on terminals 21 within the limit switet.
l 22 (Indi ca ting. )
,O 23 On occasion, an electrician would terminate this 24 conductor in this manner.
l I
O Sonntag Repor ting Se rvice. Ltd.
(
Geneva, Illinois 60134 l
l (312) 232-0262 l
)
14959 A
i
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)V l
1 At this point --
l
)
2 0
You are referring to the upper right-hand corner of the I
l 3
drawing?
)
4 A
(WITNESS. THORSELL)
Yes, I'm referring to the upper 5
right-hand corner!
6 And at this point, there is a violation 'of' the 7
minimum bending radius of the conductor.
i 3
8 Now, it's -- within the center portion of. the limit 9
switch is the switch itself, the contacts that change 10 position.
11 The entire assembly is lined with an insulated 12 plas tic.
The cover on it has an insulating gasket, so 13 this entire area surrounding the cable is insulated, at D
14 any rate.
15 (Indica ting. )
16
'Ihat notwithstanding, my analysis assumes that I O
17 have total failure of the insulation at this point, and 18 applies the NEMA standards for clearance distances and 19 creepage distances f rom metallic parts and establishes O
20 that these distances are still maintained.
21 So that even if the electrician had stripped off f
22 the insulation at that point and landed the bare wire
!O 23 similar to the type of connection that would be made to I
,1 24 a switch in your house or an outlet in your house, O
sonntag neporting service. Ltd.
Geneva, Illinois 60134 (312) 232-0262
o 14960 oV 1
that's acceptable.
O 2
0 Mr.. Thorsell,.I think Judge Grossman's question is what 3-is ' die ' likelihood that the conductor would break in that 4
kind of configuration.
O 5
A (WITNESS THORS ELL)
These are all stranded conductors 6
that are -- well, first of all, the material of ' the 7
conductor is copper, which is a relatively sof t O-8 ma teri al.
The copper in cables is annealed to make it 9
even softer and more pliable.
10 These are stranded conductors, which, by virtue of O(
11 the stranding, you have a group of small individual 12 copper wires in the' single conductor, which gives it 13 greater flexibility.
O 14 This type of bend would not affect the conductors 15 in terms of breaking them.
16-(Indicating.)
O 17 The amount of current that would flow -- this is a I
18 No. 14 conductor, by the w ay.
19 The amount of current that would flow in this
()
20 conductor is less than an amp.
It's a 7-strand 21 conductor, and in actuality the -- a single strand of 22 the 7-strand could carry the full current required.
O 23 JUDGE GROSSMAN :
That's a No.14 conductor, 24 and you are telling me that's stranded?
l O
sonntag Repor ting service. Ltd.
Geneva, Illinois 60134 (312) 232-0262
ie; 14961 "N
+v 1
A (WITNESS THORS ELL)
Yes, sir.
(3 2
JUDGE GROSSMAN:
They don' t use -- this is l'
3 AWG 14?
4 A
(WITNESS THORSELL)
AWG 14 refers merely to the cross a
l(3 5
sectional area of all of the copper --
6 JUDG E GROSSMAN:
I understand that.
4 7
A (WITNESS THORS ELL)
-- tha t's in the conductor.
- () '
8 JUDG E GROSSMAN:
But they don' t use a 9
standard 14 conductor?
10 A
(WITNESS THORSELL)
Like you do in your house, no, sir.
O 11 BY MR. STEPTOE:
12 0
Mr. Thorsell, what kind of mechanical forces are placed 1
13
. on that bend?
4
'()
14 A
(WITNESS THORSELL)
Af ter it's installed?
15 0
Yes.
16 A
(WITNESS THORSELL)
None.
-(3 17 0
Well, what if someone tugs on the cable?
18 A
(WITNESS THORSELL)
Well, this cable is contained in a 19 conduit that screws into the hub of the limit switch, so
()
20 the only place that the cable would be accessible for 21 somebody tugging on it would be far removed from the 22 limit switch.
- (3 23 JUDGE GROSSMAN:
Excuse me.
24 Why don' t they use a standard 14 cable?
C) sonntag nepor ting sa rvice tea.
Geneva, Illinois 60134 (312) 232-0262
D.
14962
)
i 3 %J l
Th a t ' s a ve ry sm all s iz e t o -- w ell, w hy do n ' t th ey
(),
2 use that?
3 A
(WITNESS THORSELL)
Okay.
The cable that you -- or the 4
wire that you use in your house, which I assume is what C) 5 you are referring to as being a standard No. 14 --
6 JUDGE GROSSMAN:
Certainly.
7 A
(WITNESS THORSELL)
-- comes as a single conductor.
O 8
In general, most of the control cables that are 9
used are multi-conductor.
l 10 By purchasing a multi-conductor cable, it
- O(}11 f acilitates the installation of the cable.
I only have 12 to pull one instead of pulling 7 or 12 from one location 13 to another.
C) 14 In addition, the basic -- well, if I have -- if --
15 in this particular case, if I used single conductors, I 16 would have to pull the 4 cables off of 4 reels through
!(3 17 the conduit.
i 18 By going with a single 4-conductor cable, I only 19 pull one cable of f of a reel, through this conduit, to
()
20 bring 4 conductors to this location.
21 JUDGE GROSSMAN:
That's not the question.
22 The question is --
0 23 A
(WITNESS THORS ELL)
Okay.
why does the manufacturer 24 JUDG E GROSSMAN:
~
C)
Sonntag Repor ting Se rvice. Ltd.
Geneva, Illinois 60134 (312) 232-0262 i
3 14963 n
)
)\\_/
1 use a stranded No. 14 cable rather than --
3 2
A (WITNESS THORSELL)
Than a solid one?
3 JUDGE GROSSMAN:
-- than a standard solid 4
one?
)
5 A
(WITNESS THORSELL)
In order to provide greater 6
fle xibility.
It makes it easier to bend the cable 7
around.
I) 8 J Lt 1E GROSSMAN:
It also makes it easier to 9
break vrf a conductor somewhere or part of a strand.
10 But I'll accept your word, you are the expert.
D(,
)
11 And you are sure that these are multi-conductor --
\\_/
12 A
(WITNESS THORSELL)
Yes, sir.
13 I believe we have an example here in the courtroom.
[)
14 JUDG E GROSSMAN:
-- or strand -- excuse me.
15 Not multi-conductor, but stranded conductor cables ?
16 You do have a 14 that's stranded?
[)
17 A
(WITNESS THORSELL)
Yes, I believe so.
18 MR. GUILD:
Mr. Chairman, bef ore we leave the 19 su bj e ct, I guess we can mark this diagram as the next
[)
20 Appliicant Exhibit and --
21 MR. STEPTOE:
Applicant's Exhibit 154.
i 22 (The document was thereupon marked 3,,_
23 Applicant's Exhibit No. 154 for
\\
t,
)
24 identification as of October 17, 1986.)
x_-
)
Sonntaa Reoor tina Se rvice. Ltd.
Geneva, Illinois 60134 (312) 232-0262 u
O i
14964
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10' 1
A (WITNESS KOSTAL)
This is 150.
()
2 MR. STEPTOE:
No.
That's 154 because we just 3
marked something as 153.
4 A
(WITNESS THORSELL)
This is a 3-conductor No. 14 cable, 4
lO 5
and I believe if you look inside, you can see that there 6
are 7 strands.
7 MR. STEPTOE:
Mr. Thorsell, j ust f or clarity, i) 8 you are referring to -- are you --
9 A
(WITNESS THORSELL)
I'm -- I'm -- this is a single 10 conductor No. 14 --
OI~
11 JUDG E GROSSMAN:
Yes.
and just referring to earlier
)
12 A
(WITNESS THORS ELL) 13 testimony, you can see the difference in the jacket
'(3 14 thickness between the single-conductor cable and the 15 individual conductor of a multi-conductor cable.
16 (Indica ting. )
- (3 17 BY MR. STEPTOE
18 0
Are they both the same kind of cable?
19 A
(WITNESS THORS ELL)
These are -- are both Okonite
()
20 6 00-volt No. 14 AWG cables.
21 One is a single-conductor cable, the other is a 22 3-conductor cable, which has 3 individual conductors and
()
23 then -- and an over all j acket.
24 0
Mr. Thorsell, I think we just identified two more i
()
Sonntaa Repor ting Se rvice. Ltd.
Geneva, Illinois 60134 (312) 232-0262
- O-14965
.,O O
1 demonstrative exhibits.
- (3 2
The first demonstrative exhibit that Applicant had 3
in this case was a terminal block with a cable attached 4
to it.
'O 5
A (WITNESS THORSELL)
Right.
6 Q
The second one was a big plywood board with a power 7
cable attach'05 fo'it in the shape of a trident.
l(3 8
We have two more cables here that we've just been 9
referring to -- that you have just been referring to; is 10 that correct?
jO(r 11 A
(WITNESS THORSELL)
Yes, sir.
12 Let me return to an earlier exhibit, which is the 13 cable which has a terminal block associated with it, and
- ()
14 I believe this demonstrates the type of lug that is put 15 on these cables, and if you look at the -- at the open 16 end of the barrel, you can see the individual strands.
I()
17 Now, if I were to take this lug and bend it merely 18 like this, that violates the minimum bending radius of 19 this cable.
- (3 20 (In di ca ting. )
21 JUDGE GROSSMAN:
Now, Mr. Thorsell, you are 22 not suggesting that the craf t person took off the l(3 23 insulation at that part, but you are only calculating x
24 i t --
-()
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
.. ~
)
14966 L
O) t-3%/
1 A
(WITNESS THORSELL)
Correct.
[)
2 JUDG E GROSSMAN:
as though it were :off ?
i 3
A' (WITNESS THORSELL)
Correct.
4 In order to -- it's my engineering opinion that
{}
5 there~ is -- there would be no failure of the insulation l
.6 of this cable.
i 7
(Indi ca ting. )
[)
8 I have a stronger engineering opinion that when l
9 this is applied at 120 volts, there -- there definitely i
10 would not be a f ailure in this cable, because this is in i
[)
11 a configuration that is similar to what you can find 12 with the cord of a lamp that you plug into your house,.
13 yet it's with-a larger wire with stronger insulation on C) 14.
uit than what you have in your home.
15 However, in order to_ be conserva tive, in order to 16 base my analysis on factual information that goes beyond
- ) -
17 my opinion as an engineer,.I assumed total failure of
-18 that insulation and demonstrate with published standards I,
19 that there is still sufficient insulation provided-by d) 20 air clearances for this cable to function.
}
21 This, in general, is the nature of the analysis i
l 22 that was done.
')
23 Some of the configurations are different.
If -- if
- j
- (
24 it's the limit switches that are not stem-mounted but i
J l
l'
'()
Sonntag Reporting service. Ltd.
Geneva, Illinois 60134 i
(312) 232-0262
)
14967 1
are associated as an integral part of the valve motor
)
2 operator, this same basic configuration exists, but the 3
picture looks a little bit dif ferent.
4 JUDG E GROSSMAN:
It is correct, is it not,
)
5 that if the craft person had actually taken off the 6
insulation at that point, that would have been a 7
violation, and he would have had to redo the D
8 termination; isn' t that correct?
9 A
(WITNESS THORSELL)
Correct.
10 JUDG E GROSSMAN:
Now --
((
)
11 A
(WI TNESS THOPS ELL)
And even if he had taken it off, it 12 still would have functioned properly.
l 13 But, yes, that would have been identified as an
[)
14 improperly-terminated cable.
15 JUDGE GROSSMAN:
Now, did you actually go 16 back and look at these?
[)
17 A
(WI TNESS THORS ELL)
Yes, sir, every one that I analyzed, 18 I personally investigated.
19 JUDGE GROSSMAN:
It is correct, also, is it f"3 20 not, in making a connection which would have omitted 21 insulation at that point that you have encircled, if 22 that had actually been done, there would be a risk of e
-m 23 shorting out that par ticular circuit, if tha t's done 1
24 originally, before all the other connections are made; a
~)
Sonntaa Repor tina Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
{}
14968 O
1 isn't that correct?
()
2 Well, I don't mean that the short would occur 3
before the other connections are made, but there is a 4
danger that other --
O 5
A (WITNESS THORSELL)
Or i f ' --
6 JUDG E GROSSMAN:
Excuse me.
7
-- other conductors might touch the conductor at
()
8
'that point?
Isn' t that a danger?
9 A
(WITNESS THORS ELL)
The -- there's essentially a channel 10 that runs along here.
O()11 (Indica ting.)
12 Let me just terminate the rest of the conductors 13 and --
O 14 JUDG E GROSSMAN:
W ell, I understand what you 15 are saying now; that, in the final --
16 A
(WITNESS THORSELL)
Right.
O 17 JUDGE GROSSMAN:
-- configura tion --
'18 A
(WITNESS THORSELL)
And you are --
19 JUDGE GROSSMAN:
Excuse me.
Let me finish.
()
20
-- you might have determined there was nothing 21 touching at that particular spot, there were no other 22 conductors or cables touching; is that so?
()
23 A
(WITNESS THORS ELL)
Tha t's true.
24 JUDG E GROSSMAN:
But in making the initial
()
Sonntag Repor ting Service. Ltd.
Geneva, Illinois 60134 (312) 232-0262 te
lOI 14969
- n iOY 1
1 connection there, if that insulation had been lef t of f, JO 2
there is a danger that another conductor might be 3
touching that -- might eventually touch that area?
4 A
(WITNESS THORSELL)
Only during the installation
'O 5
process, if the insulation had been lef t of f, it would 6
provide -- or it would afford the electrician an 7
opportunity to physically touch that area, which is. no f0 8
different than touching this terminal screw, which is 9
also exposed -- okay -- and in actuality, there is not 10 physically room inside here for any of these cables to O
11 change position.
In other words, once you put this 12 cable in here, there isn' t room to take another cable 13 and put it in this location.
- O 14 (Indicating.)
15
'Ihe other thing is, at the time that this 16 connection is made, this cable is not energized, so the
!O 17 electrician is never working with a live --
18 JUDG E GROSSMAN:
Of course.
19 A
(WI'INESS THORS ELL)
-- cable.
O 20 JUDG E GROSSMAN:
But the short would occur 21 after the cable is on, if it were to occur at all?
22 A
(WITNESS THORSELL)
Right.
!O 23 But before the current would be turned on, each.of
'bQ 24 these would be terminated, and once they are terminated, j
l
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l
!O sonntaa Reoor tina se rvice. Ltd.
j Geneva, Illinois 60134
- I,_-.,_______._..._.____,.-____._l
~
~-
- ()
f 14970 c
(3
1-there's no way that you can -- that you can get this
- ()
2-conductor up here physically.
j '
(Indica ting. )
3 1
4 JUDG E GROSSMAN:
I have to say, Mr. Thorsell, (3
5 that's the neatest looking inside of a box that I have i
j 6
ever seen, j
7 The wires are considerably more cramped in the i;()
8 normal box; isn't that so?
9 A
(WITNESS THORSELL)
Well, this -- this box is only a 10 couple inches wide, and the fact that this wire neatly O(
)
11 lies along the side here is not an' accident.
It's the 12 only -- it's the only path available for this wire to i
13 take.
l()
14 (Indica ting. )
15 In the center here is the switch assembly with the 16 contacts that change position, so that there, in l
- O 17 essence, is almost like a channel that is provided in 1
I 18-here, and this wire can only go in this channel.
i l
19 (Indica ting. )
(3 12 0 If the wire were to be placed, say,- in this l
21 region -- and I'm referring to the central region -- of 22 the box, you would not be able to put the -- put the i
!(3' 23 cover on the box.
l 24 (Indica ting. )
i d
I
- j()
Sonntag Repor ting Service, Ltd.
1 Geneva, Illinois 60134 (312) 232-0262
iO 14971 i
IOkl 1
MR. GUILD:
Mr. Chairman, may I ask a lO 2
question about the demonstrative exhibit that the 3
witness was displaying to the Board?
4 JUDG E GROSSMAN:
Ce rtainly.
O 5
MR. GUILD:
Mr. Thorsell, the exhibit that 6
you were showing the Board, that is the cable with a 7
multi-strand conductor connected to the terminal block?
O 8
A (WITNESS THORSELL)
Yes, sir, 9
MR. GUILD:
All right.
10 Now, there is one connection that's been made, and O
11 I gather this particular demonstrative exhibit has been 12 carried back and forth to the bench several times during 13 the course of the proceeding.
()
14 But would you agree that the cable that is 15 connected to the terminal block exhibits jacket 16 wrinkling as "j acket wrinkling," the term, is used in O
17 the Okonite letter?
18 A
(WITNESS 'mORSELL)
I would say that the -- that the 19 wrinkling probably isn't the term that best applies to O
20 this.
21 There is a distortion of the jacket that appears to 22 have resulted from' the terminal block being twisted O
23 around the axes of the cable -- axis of the cable.
O
)
24 MR. GUILD:
Tha t's not wrinkling as the term O
sonntag nepor ting service. tea.
l Geneva, Illinois 60134 (312) 232-0262
O 14972 P
lO 0 1
is used in the Okonite letter?
!(3 2
A (WITNESS THORSELL)
No, sir.
This would be j acket 3
distortion.
4 Wrinkling refers -- and let me see if I can bend
- (3 5
this exhibit sufficiently to get some wrinkling.
5 6
(Indica ting. )
7 Here, if you notice the crease --
l(3 8
MR. GUILD:
- Sure, where I've bent it, that would be 9
A (WITNESS THORSELL) t 10 considered wrinkled.
=(Dy 11 (Indi ca ting.)
L l
12 In general, if you have a larger cable and you bend f
13 it to a very small radius, what you will see is a 14
-rippling on the inside, because the inside of the bend
-,' (3 15 can't contract enough so the outside of the bend is 16 stretched and the inside is compressed together and 1(3 17 wrinkled.
18 MR. GUILD:
The condition that you observed 19 on the -- for the multi-strand single conductor
)(J 20 connected to the terminal box, is it -- does it 21 represent apparent physical distortion of the jacket as 22 that term is used in the Okonite letter?
WD 23 A
(WITNESS THORS ELL)
Yes, sir.
This -- this would not be
(
24 an acceptable j acket condition.
!O Sonntaa Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
O 14973 N.N 9
1 MR. GUILD:
And that jacket condition would
()
2 be such that it would require specific approval by the 3
Okonite Company in order to approve the condition of 4
that minimum bend radius violation?
O 5
A (WITNESS THORSELL)
W ell, this isn't really a minimum 6
bend radius violation per se.
It's a -- it's a cable 7
tha t's been twisted around.
O 8
MR. GUILD:
Assuming that there was a minimum 9
bend radius --
10 A
(WITNESS THORSELL)
If that condition was found in the CXO) 11 field, it would be repaired.
V 12 MR. GUILD:
All right, sir.
13 A
(WITNESS THORSELL)
Th e -- I --
()
14 JUDG E GROSSMAN:
Okay.
15 Mr. Thorsell, do I understand, then, correctly tha t 16 each time you made an analysis, what it amounted to was O
17 viewing the box, determining that wherevor the bend 18 radius violation occurred, there was no other conductor 19 nearby, and that from the air space, there would be no
()
20 dan'ger of any current hitting another conductor; is that 21 a correct statement?
22 A
(WITNESS THORSELL)
Yes, sir.
It -- it not only
' ()
x 23 involves the distance to other conductors, it involves
\\
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24 distance to the metal enclosure, and it's not just the O
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Geneva, Illinois 60134 (312) 232-0262
O 14974
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air space.
You have to assume that there is a degrading O
2 of the insulation for some distance.
3 And so if I can illustrate, there is a distance 4
along the cable from the -- from the location of the O
5 bend at which you -- you have to also assume that 6
there's insulation f ailure.
It's referred to as 7
creepage distance.
O 8
So there's really two types of spatial evaluation.
9 One is along the conductor, and I need to establish a 10 clear path, a certain distance down the conductor, down O-O 11 for creepage, and then I also need clearance around the V
12 conductor.
13 JUDG E GROSSMAN:
Okay.
I had included the O
14 box as a conductor.
15 A
(WITNESS THORSELL)
Right, right.
16 Then it's correct.
O 17 JUDG E GROSSMAN:
And I take it in this case 18 the box is grounded?
19 A
(WITNESS THORSELL)
Yes, sir.
.O 20 I might -- it might be simpler to answer the 21 question you didn' t ask.
22 The ground path for all of the circuits, whether O
23 they are power or control or instrumentation -- the g
24 basic ground path is provided by the conduit and cable
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O Lonntaa Reporting Service. Ltd.
Geneva, Illinois 60134 (312) 232-0262
- O 14975
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1 tray system, which is assembled in a manner to provide l()
2 ground continuity all the way back to the source.
3 JUDGE GROSSMAN:
I see.
i 4
So it acts like an armor cable would be, a DX lO 5
cable ?
6 A
(WITNESS THORSELL)
- Exactly, i
7 JUDGE GROSSMAN:
And tha t's why you don' t
](3 8
have a separate grounding lead in there?
9 A
(WITNESS THORS ELL)
E xac tly, 10 MR. GUILD:
Mr. Chairman, just for j
C(
)
11 clarification, what's creepage, Mr. Thorsell, as you 12 used the term?
13 A
(WITNESS THORSELL)
Creepage would refer to a L()
14 deterioration of the -- or let's see if I can define it 15 literally.
16 If I have an exposed conductor in air, and I need
!O 17 to maintain sufficient distance from other things in 18 order to rely on the air to provide adequate insulation, 19 the simpler of those distance measurements is merely the l
l(3 20 clearance between that conductor and some other item.
{
21 (Indi ca ting. )
22 The creepage distance refers to a distance along j
23 the conductor which refers to how far -- how far down l(3(~~%
( )
24 the conductor I have to go while maintaining that j
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- 3 Essentially it --
4 MR. GUILD:
Does it refer to movement of the i
f()
5 conductor ?
I 6
A (WITNESS THORSELL)
. No, sir.
7 MR. GUILD:
What creeps?
f(3 8
A (WITNESS THORSELL)
It would be electric current that 9
will creep.
f
'10 MR. GUILD:
Okay.
()(
11 JUDGE GROSSMAN:
Mr. Steptoe..
12 BY MR. STEPTOE:
13 0
Mr. Thorsell,- just one-last question here.
1
((3 14 You've been referring to analyses based on
}
15 published NEMA standards?
i 16 A
(WITNESS IHORS ELL)
Yes, si r.
I
!O 17 0
In this analysis column, were you relying on Okonite i
j 18 standards?
i' 19 A
(WITNESS THORSELL)
No, sir, i
!C) 20 0
Mr. Thorsell, my next exhibit is -- which I would like 21 to have marked as Applicant's Exhibit 155, is a letter l
22 dated October 13, 1986.
i l C) 23 JUDG E GROSSMAN:
Excuse me.
l 1
24 Do we have a 15 4?
4 IO sonntaa Reportina service. Ltd.
Geneva, Illinois 60134 (312) 232-0262
o 14977
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O 1
It's on the board.
()
2 JUDGE GROSSMAN:
Oh, I see.
Okay.
3 The sketch is 154.
4
.(The document was thereupon marked O
5 Applicant's Exhibit No.155 for 6.
identification as of October 17, 1986.)
7 BY MR. STEPTOE:
C) 8 Q
It's f rom you to Mr. Klein of the Okonite Company, is 9
that correct?
10 A
(WITNESS THORSELL)
Yes, sir.
Og 11 Q
You wrote that letter?
12 A
(WITNESS THORSELL)
Yes, sir.
13 Q
And you were examined by Mr. Guild with respect to that O
14 letter, were you not, earlier this week?
15 A
(WITNESS THORS ELL)
Yes, sir.
16 Q
Referring to the -- are the statements that you make in O-17 this letter true, to the best of your knowledge and 18 belief?
19 A
(WITNESS THORSELL)
Yes, sir.
O 20 MR. STEPTOE:
I move that Applicant's Exhibit 21 155 be admitted into evidence.
22' MR. GUILD:
I have no objection.
O 23 JUDG E GROSSMAN:
No obj ection, Mr. Guild?
24 MR. GUILD:
No obj ection, Mr. Chairman.
O sonntag Reporting Service. Ltd.
Geneva, Illinois 60134 L
(312) 232-0262
O 14978
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(
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1 JUDGE GROSSMAN:
Mr. Berry.
O 2
MR. BERRY:
No problem, Mr. Chairman.
3 JUDGE GROSSMAN:
Received.
4 (The document was thereupon received into O
5 evidence as Applicant's Exhibit No.155.)
6 MR. GUILD:
Counsel, you didn't offer 153; and 7
I have no objection to it, ei th e r.
O 8
MR. STEPTOE:
Okay.
May I of fer Applicant's 9
Exhibit 153, which is Mr. Thorsell's chart.
10 JUDG E GROSSMAN:
And 154, also, the sketch C( ~')
11 which you will reproduce?
\\ d' 12 MR. STEPTOE:
Yes, Judge Grossman.
13 What I thought our arrangement was is that I have
.O 14 to get the reproductions.
15 JUDGE GROSSMAN:
Yes, tha t's correct.
16 We'll adnit 153 at this time.
O 17 (The document was thereupon received into 18 evidence as Applicant's Exhibit No. 153.)
19 MR. STEPTOE:
Mr. Thorsell, I'm handing you a O
20 letter dated October 14, 1986, to you from Mr. Klein, 21 which I'd like marked for identification as Applicant's 22 Exhibit No. 156.
(3(~s (Indi ca ting. )
23 x
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24 (The document was thereupon marked x_/
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1 Applicant's Exhibit No.156 for
-()
2 identification as of October 17, 1986.)
3 BY MR. STEPTOE:
4 0
Mr. Thorsell, is this a letter which was provided Mr.
O 5
Guild earlier this week?
6 A
(WITNESS THORSELL)
Yes, sir.
7 Q
And did he cross-examine you with respect to the
()
8 contents of that letter?
9 A
(WI TNESS THORS ELL)
Yes, si r.
10 MR. STEPTOE:
Okay.
I'm not offering this e
O(
))
11 into evidence, Judge Grossman, but I would like it to
%j 12 travel with the record.
13 JUDGE GROSSMAN:
Tha t's fine.
O 14 MR. STEPTOE:
I was planning, Judge Grossman, 15 to of fer Applicant's 151, 152, through this witness, but 16 I still don' t have the copies, so I'll have to pass over h3 17 that for the time being.
18 BY MR. STEPTOE:
19 Q
Now, Mr. Thorsell, I believe, in response to questioning
()
20 from Mr. Guild the first day, you stated that stress.is 21 not a factor in your evaluations of cable for BCAP; is 22 that correct?
- O 23 A
(WITNESS THORSELL)
Yes, sir.
n h
( )
24 0
Why isn't stress a factor in your evaluation for cable?
-(J Sonntag Reporting Service Ltd.
Geneva, Illinois 60134 (312) 232-0262
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14980 i
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J l
A (WITNESS THORSELL)
W ell, stress, in the context that
)
2 we've generally been referring to it in these 3
proceedings, is the stress that results from the 4
application of mechanical forces.
)
5 I t -- in the specific cases that Mr. Kostal has 6
discussed -- for example, in order to determine the 7
capacity of a welded connection, there's an assessment
)
8 of the forces that that connection can withstand by 9
determining the allowable stress, and then that stress 10 is compared to code allowable stress or design stress in
)(t-'s) 11 order to establish reduction factors or design L_;
12 significance.
13 (In di ca ting. )
]
14 In obj ective electrical observations, to the degree 15 that that type of stress is involved, the stress 16 resulting f rom mechanical force, such as different J
17 allowable stresses that would result from a dif ferent 18 configuration of a support, those -- the design 19 significance evaluation is done utilizing stress, but
[)
20 that evaluation is also done by Mr. Kostal.
21 The evaluations that I'm involved with don't relate i
22 to stress resulting f rom the application of the forces.
),-s 23 My evaluations involve current-carrying capacity, for
(
24 exampl e, and in that case, my determination of a I
i
[)
Sonntag Repor ting Se rvice. Ltd.
l Geneva, Illinois 60134 (312) 232-0262
O 14981 O
!Ok l'
. reduction factor would be to look at the as-built
- O 2-current-carrying capacity and compare that with the 3
as-designed current-carrying capacity, and if I evaluate 4
design significance, I would look at the as-built IO _
5 current-carrying capacity and compare that with the 6
design-required current-carrying capacity, j
7 Q
Mr. Thorsell, I believe you also referred to stress in
- O 8
the dielectric as something that is involved with --
9 A
(WITNESS THORSELL)
Correct.
10 0
-- with cable evaluations?
Of 11 A
(WITNESS THORS ELL)
Correct, correct.
12 In evaluating, I'll say, bending radius, for an 13 example, stress is a factor in that there is a -- that 1
.O 14 the bend radius violation will result in the application 15 of stress on the insulation and may change the 16 dielectric properties of that insulation.
- O 17 Now, the dielectric stress is a stress that results 18 from electromagnetic forces rather than mechanical i
19 forces, and I do not calculate that value of stress or 10 20 compare stress levels to some other calculated or code 21 allowable stress levels.
I merely utilize cable I
22 manuf acturer's prescribed rules of thumb, if you will,
.!O 23 to determine acceptability of that condition, so my --
(
24 where stress is a f actor in obj ective observations, that (O
sonntag nepor ting se rvice. Lta-Geneva, Illinois 60134 (312) 232-0262
)
14982
(
)
) N_/
1 stress is calculated by Mr. Kostal.
[)
2 For the types of evaluations that I have done, 3
either stress was not involved or the type of stress 4
that was involved did not enter into my evaluation.
- )
5 0
Mr. Thorsell, you were asked by Mr. Guild what Mr.
6 Bartolucci's qualifications were and you said you didn' t 7
know.
)
8 Do you know now what Mr. B a r tolucci ' s 9
qualifications are?
10 A
(WITNESS THORSELL)
Yes, sir.
I contacted the Okonite em
[)(
)
11 Com pa ny.
\\_ /
12 Mr. Bartolucci is a senior staff engineer with the 13 okonite Company.
He has a bachelor of science degree in
[)
14 electrical engineering and a master of science degree in 15 me t all ur gy.
He has been with the Okonite Company since 16 1979, and has prior -- or has cable and power industry
[)
17 experience prior to joining the Okonite Company.
18 0
I believe there's some discussion of the wording in Mr.
19 Laksey's June 5, 19 86, lette r -- 19 85, letter to you,
[]
20 Mr. Thorsell, in which Okonite declined to make a design 21 significance evaluation of the minimum bend radius 22 violations which you showed to them.
3
_s 23 What is your understanding of why Okonite declined 7
i i
1 5
)
24 to make that design significance evaluation?
\\m,-
O Sonntaa Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
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'O 14983 O
OU 1
MR. GUILD:
Obj ection, Mr. Chairman.
()
2 The witness is not competent to speculate what 3
Okonite's basis was.
His understanding of that basis is 4
simply irrelevant.
()
5 MR. STEPTOE:
It's his understanding of the 6
letter that he received in the normal course of events, 7
Judge Grossman.
C) 8 MR. GUILD:
If we're going to establish what 9
the basis was or wasn't for Okonite's position, they 10 need to put up Okonite.
C 11 Mr. Thorsell's understanding is simply irrelevant 12 to establish that point.
13 MR. BERRY:
Well, not only that, I believe
()
14 the question has been asked and answered.
15 I believe we have Mr. Thorsell's understanding of 16 that.
I believe we've had -- we've heard f rom him on 0
17 that.
18 My recollection is -- well, I won' t characterize 19 what I recall the testimony being, but I do believe that
()
20 this particular matter has been addressed by Mr.
21 Thorsell on the record already.
22 MR. STEPTOE I don' t recall that, Judge
()
23 G ros sma n.
24 J UDG E G ROSSMAN :
Do you have an understanding
()
Sonntag Repor ting Se rvice. Ltd.
Geneva, Illinois 60134 (312) 232-0262
)
14984
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1 n ow o r --
)
2 MR. BERRY:
Yes.
It's my understanding that 3
the witness had testified that Okonite refrained from --
4 where is the letter -- from --
)
5 JUDGE GROSSMAN:
From making evaluations 6
unless they actually observed --
7 MR. BERRY:
Yes, yes, unless they observed
- )
8 and had the data to back up the --
9 JUDGE GROSSMAN:
Tha t's my recollection, too.
10 MR. BERRY:
-- observation.
[Xm) 11 JUDGE GROSSMAN:
So it's been asked and L!
12 answ ered.
13 It would only complicate the record to get a
[)
14 dif ferent answer at this point, Mr. Steptoe.
15 MR. STEPTOE:
Okay.
16 JUDGE GROSSMAN:
Is there a dif ferent ancwer?
[)
17 We'll allow the question.
18 MR. STEPTOE:
I was asking for a slightly 19 different answer, Judge Grossman.
[)
20 There are all sorts of proximate causes and 21 underlying causes.
22 J UDG E G ROSSMAN :
But that's not going to be 23 competent evidence as to -- he can give his
,s (v) 24 understanding, and that's his judgment, but I don't l
l l
J Sonntaa Renor tina Se rvice. Ltd.
i Geneva, Illinois 60134 (312) 232-0262
O 14985 (3
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I 1
believe that we'll accept that as competent evidence as j
C) 2 to what Okonite actually used as the standards.
1 l
3 We'll make that ruling.
I don't see how he could j
4 be competent to do that; but he can certainly give his
()
5 judgment, if he wants, but that's as far as it will go.
l l
i 6
MR. STEPTOE:
All righ t.
l l
l l
7 BY MR. ST8PTOE:
C) 8 Q
Mr. Thorsell, what is your understanding?
9 A
(WITNESS THORS ELL)
W ell, the letter that was sent to
~
10 the Okonite -- well, first of all, the letter was not to
,m C(
')
11 me.
I believe it was to Mr. Eisenbart to --
(_'
12 JUDG E GROSSMAN:
I'm sorry.
I can't hear.
13 A
(WITNESS THORS ELL)
The letter was not addressed to me.
l
()
14 It was addressed to a Mr. Eisenba r t.
Mr. Lasky's letter 15 of June 5, 1985, was addressed the Mr. Eisenba r t.
16 MR. GUILD:
It was Intervenors' Exhibit O
17 162 -- tha t was the observa tions -- and the attachment 18 to the observations.
19 A
(WITNESS THORSELL)
Right.
That letter was in response
()
20 to Mr. Bojan's letter, which asked if Okonite Company --
21 whether the conditions observed were design significant 22 or not.
C),_
23 A cable manuf acturer sells cable which has certain
(
h
(
)
24 specified characteristics associated with it.
A cable s-C) sonntag Reporting service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
14986 Om l_
manufacturer can tell you whether his cable -- whether D
2 the installed condition of that cable affected those 3
specified characteristics or whether it didn't.
4 In other words, if I were to ask the cable O
5 manufacturer, "Is this cable good,"
if his answer is 6
yes, his answer means, "That cable will meet all of the 7
specified requirements that I have provided to you for O
8 that cable. "
9 (Indi ca ting. )
l l
10 When you use a term like design significance, the l
C 11 cable manufacturer is essentially asked to make an 12 evaluation that includes knowledge of the application of l
13 that cable.
O 14 In this particular case, it's a 600-volt cable.
He 15 does not know what voltage it's being applied at, he 16 does not know what temperature that cable will be --
1 O
17 what environmental temperature that cable will exist in, 18 he does not know what current that cable will carry.
19 And so it did not surprise me that the cable O
20 manuf acturer. declined to take a position on design 21.
significance because he did not know what was meant by 22 design significance.
It's not a term that he is O
23 familiar with.
g 24 And to verify that my understanding of that O.
sonntaa nenor tina se rvice. Ltd.
Geneva, Illinois 60134 l
(312) 232-0262
14987
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1 reasoning for not taking a position on design 2
significance was correct --
3 MR. STEPTOE:
Excuse me.
4 Mr. Thorsell, you are going to have a hearsay I
O 5
answer if you are going to talk about the phone call j
(
6 with Okonite.
7 A
(WITNESS THORS ELL)
All right.
l 3
8 J UDG E G ROSSMAN :
Now, Mr. Thorsell, nothing 9
precluded you from supplying the manuf acturer with 10 exactly the specifications that you had in mind?
l 9
11 A
(WITNESS THORS ELL)
Tha t's true.
12 J UDG E G ROSSMAN :
And that was your normal 13 course of operation with regard to opinions from that v
14 manufacturer, wasn't it, that you supplied all the data 15 that you thought was necessary and, on that basis, th e 16 manuf acturer gave you an opinion?
2 17 A
(WITNESS THORS ELL)
Yes, Judge Grossman; but the level 18 of detail of the information supplied to the 19 manuf acturer normally was not very extensive.
20 By that I mean, it was not necessary to tell the 21 manuf acturer the details of the -- of the circuit that 22 the cable was involved in, the current that the cable v
23 will be carrying.
j 24 In general, when we went back to thd manuf acturer Sonntag Repor ting Se rvice. Ltd.
)
Geneva, Illir.ois 60134
(
(312) 232-0262
14988 i,
)
'O' 1
for approval, he would approve that cable for all of the
)
2 specified conditions that he manuf actured the cable to, 3
You are correct in saying that I could have gone 4
back a second time to the Okonite Company and said, "I
)
5 understand your reservation about the term ' design 6
significance' because you don't have the data on which 7
to make that evalua tion.
Let me explain that this cable
)
8 is in this circuit, it's in this environment, it carries 9
this current,"
and all of the other per tinent data that 10 the cable manufacturer would need to make that decision, I
l 4,-)
11 but a t tha t point, it -- it's easier to just test the v
12 cable to determine its adequacy.
13 (In di ca ting. )
b 14 BY MR. STEPTOE:
15 0
Mr. Thorsell, outside of the BCAP program, when you l
16 observed the minimum bending radius problem in the 1
O 17 field, do you ever go to Okonite and ask them to approve l
18 the cable?
l 19 A
(WITNESS THORSELL)
Yes, sir.
O 20 Q
Okay.
21 In those circumstances, do you -- do you -- what f
22 specific request -- what is your specific request to IO
_s 23 okonite?
s
(
24 Well, let me rephrase that.
O Sonntag Repor ting Se rvice. Ltd.
Geneva, Illinois 60134 (312) 232-0262
14989 1
Do you ask them for an opinion on design J
2 significance ?
3 A
(NITNESS THORS ELL)
No, si r.
4 0
What do you ask them for?
D 5
A (WI TNESS THORS ELL)
Whether the cable as installed is 6
acceptable, acceptable meaning will it meet all of the 7
specified requirements of that cable, not dependent on J
8 the other conditions under which the cable is applied.
9 (In dica ting. )
10 0
Mr. Thorsell, there was some discussion by Mr. Guild --
Si 11 or questioning of you by Mr. Guild, and he asked you to 12 agree that for purposes of your evaluation, you 13 considered the equipment to be an empty box with a 0
14 certain load in it for purposes of BCAP program.
15 Do you recall that questioning?
16 A
(WITNESS THORSELL)
Yes, sir.
O 17 Q
In your BCAP evalua tions, do you regard the equipment as 18 an empty box?
19 A
(WITNESS THORSELL)
It depends on what I'm evaluating.
's 20 The purpose of the BCAP program was to assess th e 21 work that was done by the contractors in the field in 22 building the plant.
C),__
In the case of the electrical contractor, the work 23 i
)
24 that the electrical contractor does relative to
?
Sonntaa Reportino Service. Ltd.
Geneva, Illinois 60134 (312) 232-0262
14990 j
1 equipment that is provided by vendors f alls into three
'i 2
categories.
3 One type of work that the electrical contractor 4
does is to mount that equipment, which is either to bolt t;
5 it or weld it to the floor or a beam or a column or a 6
wall, essentially; and in terms of evaluating the 7
adequacy of that mounting, calcolations are done by Mr.
s) 8 Ko s t al in which that equipment is merely considered to 9
be a box representing a load.
Essentially --
10 0
Mr. Thorsell, you just said the calculations are done by 9
11 Mr. Kostal ?
12 A
(WI TNES S THORS ELL)
Yes, si r.
13 0
By him personally?
14 A
(WITNESS THORSELL)
By the structural department of s
15 Sargent & Lundy.
16 (Indi ca ting. )
O 17 Okay.
The second type of involvement that the 18 electrical contractor has with equipment is to terminate 19 power and control cables to that equipment; and that was 20 addressed in the BCAP program in the cable population 21 under termination, that that termination was to the 22 righ t loca tion, done in the right manner.
t;,,
23 The third area of involvement of the electrical 24 contractor comes in modification of the equipment.
1)
Sonntag Repor ting Se rvice. Ltd.
Geneva, Illinois 60134 (312) 232-0262
14991 2
1 The electrical contractor may be directed to change O
2 some wiring, to add a component, to delete a component.
3 That aspect of the electrical contractor's work was 4
addressed in the BCAP program under electrical equipment O
5 installation in the category entitled, " Field 6
Modifications," so to the extent that field 7
modifications were done, cables were connected as well O
8 as equipment being mounted, all of that's addressed in 9
the BCAP program, and we evaluated observations in each 10 of those areas.
Gl 11 JUDG E GROSSMAN:
That third item, 12 modifica tion, tha t would include, would it not, changing 13 the siz e of the junction box?
O 14 A
(WITNESS THORSELL)
W ell, in general the contractor 15 would install junction boxes, and if a junction box 16 changed size during the course of construction -- if our O
17 design changed the size of the j unction box, the -- the 18 junction box of the previous size would have been 19 removed and a new junction box of the proper siz e 20 installed.
21 (Indi ca ting. )
22 JUDGE GROSSMAN :
Okay.
O, 23 And that would fit under that third department,
)
24 wouldn't it?
m O
sonntag neporting service, Ltd.
Geneva Illinois 60134 r
(312) 232-0262
14992 i
./
1 A
(WITNESS THORS ELL)
No.
The third area, the field O
2 modi fica tion, would involve changing vendor wiring 3
inside a vendor-supplied panel or adding an electrical 4
com ponent, such as a relay, to a vendor-supplied panel, O
5 and wiring that relay in accordance with the wiring 6
diagrams provided to him.
7 JUDGE GROSSMAN:
I'm sorry.
O 8
Who would change the junction box if you required 9
that change ?
10 A
(WITNESS TH ORS ELL)
The electrical contractor; but 9l 11 that -- in the BCAP program, that would -- tha t would be 12 just addressed under the junction box category instead 13 of the field modification category.
O 14 (Indi ca ting. )
15 JUDGE GROSSMAN:
I see.
16 By the way, while we' re at it, all these other O
17 boxes that you were observing the bending radii in, were 18 they also vendor-supplied boxes, and I'm referring to --
19 A
(WI TNES S THORS ELL)
Yes.
D 20 J UDG E G ROSSMAN :
-- Applicant's Exhibit 153, 21 the bending radius observations list?
22 A
(WITNESS THORSELL)
Yes, sir.
O, 23 JUDGE GROSSMAN:
Th ey wer e ?
I
)
24 A
(WITNESS THORSELL)
Yes, sir, yes.
'O Sonntaa Repor tina Se rvice. Ltd.
Geneva, Illinois 60134 (312) 232-0262
14993 i
1 JUDGE GROSSMAN:
Okay.
l 2
A (WITNESS THORSELL)
They were not the sheet metal 3
junction boxes that the contractor installs as part of 4
the conduit system in order to provide hold points or C
5 termination points.
They are essentially little pieces 6
of equipment.
7 In the case that I've represented on Applicant's O
8 Exhibit 15 4, that is a stem-mounted limit switch.
There 9
were also, to the best of my recollection, the limit 10 switches that come as an integral part of the motor
$l 11 operator -- of motor-operated valves.
12 (In di ca ting. )
13 DY MR. STEPTOE:
O 14 Q
Okay.
15 Mr. Thorsell, did the BCAP inspectors verify that 16 the proper type and size of junction box was installed O
17 in the field with respect to an item that was within 18 their sample population ?
19 A
(WITNESS THORSELL)
Yes, sir.
O 20 JUDGE GROSSMAN:
When you switch to a new 21 topic, we'll take a break, i
We can take a break right now.
Or 23 JUDG E GROSSMAN:
Okay.
10 minutes.
)
24 (W HER EU PO N, a recess was had, after which u
O sonntag neporting service. Ltd.
Geneva, Illinois 60134 (312) 232-0262
14994 gv 1
the hearing was resumed, as f ollows:)
()
2 JUDG E GROSSMAN:
Proceed, Mr. Steptoe.
3 MR. STEPTOE:
Okay.
4 BY MR. STEPTOE:
O 5
Q Mr. Thorsell, I'll hand you a document, which has been 6
received in evidence as Applicant's Exhibit 124, which 7
is the L.
K.
C.
Comstock installation inspection O
8 procedure.
9 (Indica ting. )
10 A
(WITNESS THORSELL)
Yes, si r.
ed 11 Q
Mr. Thorsell, looking at the first page, that indicates 12 that Sargent & Lundy -- that's a Sargent & Lundy stamp 13 marked " Reviewed and Accepted"?
O 14 A
(WI TNESS THORS ELL)
Yes, si r.
15 0
Is that Sargent & Lundy's stamp?
16 A
(WI TNES S THORS ELL)
Yes, si r.
O 17 Q
And does that -- what does that stamp indicate, briefly?
18 You've already discussed that.
19 A
(WITNESS THORSELL)
That stamp indicates that Sargent &
20 Lundy have reviewed this procedure for technical 21 adequacy and found it to be technically adequate -- or 22 found those portions of the procedure that involve 0,
23 technical items to be adequate.
7
(
24 Q
Now, would you turn to Section 3.4.5, which is on Page 4
(
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1 of 9 of that procedure.
O 2
A (WITNESS THORSELL)
Yes, sir.
3 0
What does that -- could you just describe what that 4
section covers?
O 5
A (WITNESS THORSELL)
The section covers minimum bending 6
radii and training radii.
It states that the minimum 7
bending radii and training radii are not exceeded.
C) 8 Reference Drawing 0-30008 for minimum bending and 9
training radii.
10 Q
Does the procedure distinguish between bending radii and 11 training radii?
12 A
(WITNESS THORSELL)
Yes, sir.
13 Q
Okay.
()
14 Now, Drawing No. -- Reference Drawing 0-30008 is, 15 in fact, Applicant's -- what has been marked for 16 identification as Applicant's Exhibit 152, which is the O
17 drawing, is it not?
18 A
(WITNESS TH ORSELL)
Yes, sir.
19 I should clarify that Drawing 0-3000B has more than O
20 just one sheet to it.
The exhibit, I believe, is just 21 the first sheet of that drawing.
The other sheets 22 contain the same information for other cable 0,_
23 cons truction s.
(
N A
)
24 Q
And, in fact, that sheet, Applicant's Exhibit, marked v
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D 14996 3' v 1
f or iden tifica tion, 15 2, includes informa tion with D
2 respect to minimum bending radii and minimum training 3
radii, does it not?
4 A
(WITNESS THORSELL)
Yes, sir.
J 5
0 Okay.
6 Now, referring down the page to Item No. -- to 7
Paragraph No. 3.4.7, could you describe what that item J
8 pertains to?
9 A
(WITNESS TH ORSELL)
The item pertains to cable damage, 10 and references Attachment A-1 for evalua tion of cable 11 damage.
12 0
okay.
13 And is this the standard that Comstock -- that
[)
14 Comstock inspectors used in inspecting cable?
15 A
(WITNESS TH ORSELL)
Yes, sir.
16 Q
Okay.
[]
17 Now, could you turn to Attachment A-1 of the 18 procedure, which is also entitled " Appendix B. "
19 Could you just describe what is found on that page?
20 A
(WITN ESS THORS ELL)
Attachment A-1 is entitled, 21
" Appendix D, Owner's Criteria for Evaluation of Damaged 22 Ca ble s. "
e.
23 0
And what are those criteria, sir?
p
)
24 A
(WI TNESS THORS ELL)
"A, a kink or twist is found that is 1
Sonntao Reportina Service, Ltd.
Geneva, Illinois 60134 s312) 232-0262
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14997
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s 1
caused by compressing a loop or less than minimum bend j
2 radius; a gouge is found and is deeper than 50 percent 3
of the thickness of the jacket; a permanent 4
identification in the j acket is found and is deeper than O
5 the thickness of the j acket. "
6 Q
Now, sir, turning to Applicant's Exhibit 131, which has 7
also been received in evidence, it's entitled, " Cables."
O 8
In that package -- I think it's the third tab --
9 there is a document entitled " Checklist Instruction for 10 the Cable Population"?
11 A
(WITNESS THORS ELL)
Yes, si r.
12 Q
Is that the -- are those the checklist instructions 13 which are used by the BCAP inspectors?
O 14 A
(WITNESS THORSELL)
To the best of my knowledge, they 15 are.
16 0
Okay.
1 17 Now, referring to -- is there a section of that 18 section, checklist instructions, which has to do with 19 cable damage ?
J 20 A
(WITNES S THORS ELL)
Yes, si r.
21 Q
Okay.
22 What were the criteria which the BCAP inspectors C) p 23 were told to look for in identifying cable damage?
(
8
(
)
24 A
(WITNESS THORSELL)
They were to identify a kink or
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Sonntag Repor ting Se rvice_. Ltd.
Geneva, Illinois 60134 (312) 232-0262
14998 1
twis t, a gouge in the cable jacket and depth of gouge in 2
the j acket, an indentation in the j acket.
3 MR. GUILD:
Excuse me.
4 Where is the witness reading f rom?
f, 5
A (WI TNESS THORS ELL)
I believe this is on Page 7 of 7 6
under --
7 MR. GUILD:
Yes.
Thank you.
O 8
A (WI TNESS THORS ELL)
Attribute No. 9.
9 BY MR. STEPTOE:
10 0
How do those criteria compare with the criteria in the ed 11 Comstock inspection criteria -- in the Comstock 12 inspection procedure, Mr. Thorsell ?
13 A
(WITNESS THORS ELL)
The criteria in the BCAP O
14 instructions are more stringent than the criteria 15 contained in the Comstock inspection procedure.
16 Q
Now, Mr. Thorsell, Mr. Kostal was asked a question about O
17 trending of BCAP-identified deficiencies.
18 Do you recall that question?
19 A
(WI TNES S THORS ELL)
Yes, sir.
O 20 0
What trending was done of BCAP-identified discrepancies 21 by Sargent & Lundy?
22 A
(WITNESS TH ORS ELL)
Well, the purpose of 'the trending
{D 23 was to use engineering judgment to determine if there
/
s
! \\
)
24 were any design significant conditions that had gone O
Sonntaa Reoor ting Se rvice, Ltd.
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undetected during the construction process or to -- to
'D 2
provide assurance that no design significant conditions 3
had gone undetected.
4 The nature of the analysis that we did took three O
5 forms.
6 The one that was addressed by Mr. Kostal concerned 7
the review of all notable discrepancies.
O 8
Notable discrepancies were tabulated, and in any 9
attribute where a more than one percent trend had been 10 identified of notable discrepancies, the nature of those ed 11 discrepancies was evaluated to determine if they had the 12 potential for design significance if they occurred at 13 other locations within the plant than those that were 14 included in the BCAP sample.
15 (In dica ting. )
16 In addition to that, all discrepancies, whether O
17 they were notable or insignificant, were tabulated, and 18 any attribute that showed a five percent discrepancy 19 rate or greater was evaluated to determine its impact on O
20 the construction of the plant.
21 Now, beyond tha t, each of the discrepancies was 22 assessed as to whether it had a potential for design lJ,
23 significance had it occurred at other locations; and as I
'N 24 a result of this assessment, there were two v
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1 recommendations that were made by BCAP.
i 2
One was to review attachment of conduits to 3
suppor t.
The second was to r eview the installation of 4
stiff eners where requi red.
5 To the best of my recollection, the stif fener 6
cencern was identified through the one percent. sieve of 7
the notable discrepancies, j
8 The attachment to conduit supports was identified 9
by a review of the nature of each of the discrepancies.
10 In other words, there was not a one percent gd 11 occurrence of attachment to conduit supports, but it was 12 an area in which we felt there was a potential for 13 design significance if it occurred at the most O
14 unf avorable location in the plant, and as a result, 15 recommended that all attachment to conduit supports be 16 reviewed.
O 17 Q
Where are the results of this trending found?
18 A
(WITNESS THORS ELL)
Tney are found in the documents that 19 were forwarded to BCAP, and the ultimate recommendations O
20 are contained in the BCAP report.
21 (Indica ting. )
22 Q
Okay.
D_
23 MR. GUILD:
Mr. Ch ai rm an, the witness
!(
24 responded by saying, in par t, tha t BCAP made two p
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recommendations and he identified them.
C 2
Do I understand his answer to mean that Sargent &
3 Lundy made those recommendations?
4 Is he testifying from personal knowledge or is he S
5 testifying about something that someone else did?
6 A
(WITNESS THORSELL)
Sargent & Lundy made those 7
recommendations to BCAP and BCAP included those 8
recommendations in their report.
v 9
MR. GUILD:
Understood.
10 BY MR. STEPTOE:
Gd 11 Q
Mr. Thorsell, are you speaking with respect to -- from 12 personal knowledge with respect to this trending?
13 A
(WITNESS THORSELL)
Yes, sir.
O 14 MR. STEPTOE:
Okay.
f 15 MR. GUILD:
Mr. Chairman, I'd ask that 16 Applicant make available for inspection --
t) 17 J UDG E G ROSSMAN :
Could you speak up.
18 MR. GUILD:
Yes.
I'd ask that Applicant make 19 available for inspection the transmittals by Sargent &
'D 20 Lundy of the trending that they performed.
21 MR. STEPTOE:
All that was copied and 22 provided to Intervenors back in May, Judge Grossman.
C),
23 J UDG E G ROSSMAN :
Oh, okay.
)
24 MR. GUILD:
Well, it m ay w ell h ave bee n --
(
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Sonntag Reporting Service. Ltd.
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3-1 JUDGE GROSSMAN:
W ell, if you could identify
[)
2 that for Mr. Guild off the record, that would be fine.
3 MR. STEPTOE:
Sur e, sure.
4 Judge Grossman, I have a little bit more, but I was
[)
5 planning to use the demonstrative exhibits, but I think 6
I could wait until Monday to do that if any of the panel 7
members want to ask any f urther questions before we
[)
8 adj ourn.
9 I don' t want to use up all the time by starting on 10 some thing like tha t, ed 11 J UDG E G ROSSMAN :
Okay.
That's fine.
12 Did you want to question now?
13 MR. STEPTOE:
I thought we were ending at --
[)
14 e xcuse me.
I thought we were ending a t 11:00.
15 JUDG E GROSSMAN:
We' re ending at 11:00, yes, 16 tha t's correct.
[]
17 MR. STEPTOE:
I'm sorry.
I'm using the wrong 18 cloc k.
19 J UDG E G ROSSMAN :
I'm sorry.
That clock is 20 off.
21 We have 25 minutes to go.
i 22 MR. STEPTOE:
All right.
D, 23 Well, then I do have time to go into this.
l l '
i 24 BY MR. STEPTOE:
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15003 J
l Q
Mr. Kostal, I'm going to hand you two more demonstrative D
2 exhibits.
3 (In dica ting. )
4 They are the fif th and sixth demonstrative exhibits O
5 that we have used.
6 Perhaps you can take them up to the Board so they 7
can see th em.
Z) 8 Would you identify each one, pl ease.
9 A
(WITNESS KOSTAL)
Yes.
What each of these represents 10 is an attachment of a Unistrut to an end plate, which is ej 11 a 3/8 inch thick A36 plate.
12 Q
One of these is marked A and one of these is marked B?
13 A
(WITNESS KOSTAL)
Yes, sir.
)
14 Q
Now, do these -- how do these correspond, if at all, to 15 the diagram which has been admitted into evidence --
16 which has been created, which is Applicant's Exhibit 17 145, which I don't think has yet been received into 18 evidence?
19 A
(WITNESS KOSTAL)
The application between these two T) 20 exhibits and my exhibit -- the Exhibit 145 is to address 21 the area at the top of the Unistrut where I had 22 indicated in the past we had found certain discrepancies j
D,_
23 relative to the length of weld provided across that lip.
l 24 Q
Okay.
)
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15004
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1 So they are the same thing?
)
2 A
(WITNESS KOSTAL)
They correlate to the same thing.
3 Q
All right.
4 Now, you were asked a number of questions by Mr.
)
5 Guild, the point of which was -- he was asking you how 6
could Comstock inspectors have missed the weld 7
discrepancies at the lip of the Unistrut where it's D
8 welded to the plate.
9 Could you identify the welds -- on the 10 demonstrative exhibit, the weld deficiencies that you pl 11 were talking about with Mr. Guild?
12 A
(WITNESS KOSTAL)
Yes, sir.
13 MR. GUILD:
You are looking at B now, Mr.
D 14 Kostal?
15 A
(WITNESS KOSTAL)
If you look at B, and if you look at 16 the top of B, you will notice that these welds are --
D 17 they do not completely go all the way around.
Some stop 18 at the center, some stop maybe a little less than the 19 center.
[)
20 But what we' re talking about compared to a -- let's 21 say a perfect sam ple, that weld demonstrates the run l
22 that we' re talking about across the top that would go D
23 all the way across and engage that incomplete 24 3/8-of-an-inch dimension, r
I
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1 BY MR. STEPTOE:
2 Q
The sample you referred to as perfect is A?
3 A
(WITNESS KOSTAL)
Perfect is A.
4 Q
You are saying it's perfect in terms of the weld coming D
5 around the corner; correct?
6 A
(WITNESS KOSTAL)
Right, in terms of the amount of weld 7
going around the corner that would be specified.
m) 8 The difference between A and B is the fact that 9
Held B is slightly shorter and --
10 Q
Would the weld on B be termed a discrepancy?
O 11 A
(WITNESS KOSTAL)
Yes, si r, each one of those is 12 considered a discrepancy, and it would be a discrepancy 13 by various dimensions, and it's reported a discrepancy E) 14 down to, examples that I've seen, a 1/8-inch and 1/16 of 15 an inch.
16 JUDG E COLE:
All this is in the 3/8 inch O
17 portion shown on Exhibit 145?
18 A
(WITNESS KOSTAL)
Yes, sir.
19 BY MR. STEPTOE:
O 20 Q
Now, what weld would the Comstock inspector have been 21 inspecting in the field?
22 A
(WITNESS KOSTAL)
What the Comstock inspector would be 23 inspecting is -- if I had tha t -- we won't show that
(
)
24 other illustration, but this plate is attached to the O
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1 ver tical plate, and the welds that are made are the
])
2 welds across the top, which attach this plate, this 3/8 3
inch A36 plate, to the tube steel.
There's a weld 4
across the top and there was a weld across the bottom.
[)
5 They would be inspecting these welds.
6 (Indica ting. )
7 In some other details, there are some welds that go
- )
8 across the sides.
They would be inspecting in other 9
details welds that go across the side, so th ei r 10 inspection is for a different set of welds.
gj 11 Q
Just so we're clear, who made the -- who made -- in 12 general, who makes the welds that are shown attaching 13 the Unistrut to the baseplate on Exhibit A and Exhibit D
14 B?
15 A
(WITNESS KOSTAL)
These are welds supplied by System 16 Con tr ol.
[)
17 What we would receive at the site would be a 18 horizontal member of a certain dimension, and these two 19 end plates would be attached at the f abricating shop by D
20 Systems Control and delivered to the plant, which would 21 then be a stockpile of components of certain dimensions 22 that could be used in the assemblies of the hangers.
- )
23 0
- Okay, i/
)
24 J UDG E COLE:
So you are referring, then, to
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m ad 1
the Unistrut is what's stockpiled?
D 2
A (WITNESS KOSTAL)
The Unistrut with the end plate and 3
this weld performed by System Control is what's 4
delivered to Comstock for installation.
D 5
BY MR. STEPTOE:
6 Q
Now, Mr. Kostal, are there any installations where 7
Comstock rather than Systems Control might make a weld C
8 of the Unistrut to the baseplate like this for cable pan 9
hangers ?
10 A
(WITNESS KOSTAL)
Yes, sir, yes, sir.
ed 11 For example, if the assembled length for a given 12 hanger was too long, they could possibly cut of f this 13 Unistr ut and attach another weld of another plate.
O 14 They would use a different weld process, by the 15 w ay.
16 This is done in the field -- in the shop under a O
17 certain wire -- under one weld process in the shop.
In 18 the field it would be done using a stick weld process.
19 0
Okay.
O 20 By looking at the drawings available to you, 21 Mr.Kostal, is it generally possible to determine who 22 made this kind of weld on the cable pan hanger without a (3,
23 field inspection?
7
(
24 A
(WITNESS KOSTAL)
No, sir.
v;
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Sonntag Repor ting Service Ltd.
Geneva, Illinois 60134 (312) 232-0262
15008 x
l N.
We may, in fact, return to these 2
on Monday, but that's all I need to do today, Judge 3
G ros sman.
4 MR. GUILD:
Mr. Chairman, may I ask a few C
5 questions about the demonstrative exhibit?
6 JUDG E GROSSMAN:
Fine.
Why don' t you voir 7
dire on that.
[?
8 VOIR DIRE EXAMIN ATION 9
BY MR. GUILD:
10 0
Mr. Kostal, who prepared these exhibits?
Od 11 A
(WITNESS KOSTAL)
These exhibits were -- hold on one 12 second.
I can get an answer.
13 Q
I guess the word is fabricated.
O 14 MR. STEPTOE:
Mr. Gieseker has the answer.
15 I believe he's still under oa th.
16 J UDG E G ROSSMAN :
Yes, you've been sworn.
O 17 Mr. Gieseker, why don' t we have your answer.
18 MR. GIESEKER:
Those welds are made in the L.
19 K.
Comstock fab shop under the direction of Mr. Russ
()
20 Vannier.
21 MR. STEPTOE:
Why were they made, Mr.
22 Gieseker?
C, 23 MR. GIESEKER:
To demonstrate the weld
)
24 problem tha t Mr. Cassel -- Mr. Kostal was explaining, sv C)
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15009 l
v 1
MR. STEPTOE:
So these are not -- neither one t) 2 of these is a Systems Control weld?
3 MR. GIESEKER:
Tha t's correct.
4 MR. STEPTOE:
Okay.
()
5 MR. GUILD:
What instructions were given to 6
the f abricator of the example that represent the 7
dis crepant condition by way of dimensions of the weld to C) 8 be prepared?
9 MR. GIESEKER:
I wasn' t personally there.
10 It's my understanding from Mr. Vannier that they ed 11 wanted to demonstrate the wraparound properties of 12 the -- an acceptable weld versus what's typically found 13 in the field.
()
14 MR. GUILD:
All right, si r.
15 You don' t know what length instructions were given 16 to the fabricator of the demonstra tive exhibit that's to O
17 demonstrate the defective weld?
18 MR. GIESEKER:
Not personally, no.
19 MR. G UILD :
That's all I have.
()
20 REDIRECT EXAMINATION 21 (Continued) 22 BY MR. STE PTOE :
- (Oc 23 Q
Mr. Kostal, have you actually seen installations similar
'T 24 to this one where the welds were prepared by Systems v
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15010 j'-
1 Control?
)
2 A
(WITNESS KOSTAL)
Yes, sir.
3 Q
Are these exhibits accurate representations of the 4
conditions that you have seen in the field where Systems
)
5 Control welding deficiencies have been found?
6 A
(WITNESS KOSTAL)
Yes, sir.
7 MR. GUILD:
W ell, Mr. Chairman, I guess the
)
8 problem is:
Representative of what; of the only one 9
that's ever been out there and this is, therefore, an 10 accurate representation?
Dl 11 Obviously we're representing something that occurs 12 in numbers with varying physical attributes.
13 A
(WITNESS KOSTAL)
W ell --
)
14 J UDG E G ROSSMAN:
Mr. Kostal, did you have 15 something to say?
16 A
(WITNESS KOSTAL)
Well, what I can answer is this is --
p 17 this has occurred on a number of occasions, not just 18 once.
19 In fact, just the example I went over with in the I) 20 104 popula tion, this is one of the reasons why some of 21 those welds were miscounted, and in that population 22 alone, there were more than just one.
Ther e wer e -- I
)c _
can get the count for you, but there were a number of 23 24 them that were exactly this condition.
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1 I have personally seen this over the years at both J
2 Byron and Braidwood; and that this has been a condition 3
that was noted at Byron years ago and is still, and it's 4
present at Braidwood today as well as Byron today.
J 5
MR. GUILD:
My point, though, Mr. Chairman, 6
only is when he says "this condition," it's a condition 7
that varies with the length of the weld, and we have no O
8 evidence of what the instructions were of the preparer 9
of the demonstra tive exhibit as to what weld length to 10 w el d.
Gj 11 This is not a single condition.
It is a multiple 12 condition that varies in the field.
Tha t's my only 13 point.
O 14 MR. STEPTOE:
Well, it's a fair point that 15 Mr. Guild makes, but that doesn' t af fect the value of 16 these exhibits.
O 17 One doesn't need to bring in a photographer to say 18 that the photograph is a fair representation of 19 something the witness saw.
O 20 JUDG E GROSSMAN :
W ell, to the extent that 21 these are used to demonstrate that the missing portion 22 is only an insignificant portion of the total weld, the O _
exhibits don' t really represent that, because what that 23 24 proportion is is really an individual-case determina tion O
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1
%d" l
for which calculations were made with regard to O
2 discrepancies.
3 If this is typical of them could only be determined 4
by looking at those case-by-case calcula tions.
O 5
MR. STEPTOE:
Well, perhaps --
6 JUDGE GROSSMAN:
I would assume that if this 7
represented all of them, that all of them would have O
8 been classified as insignificant.
9 To the extent that some were classified as Z 10 category, they obviously were shorter welds with a Gd 11 greater portion missing.
12 MR. STEPTOE:
That's perfectly true, Judge 13 Grossman.
O 14 It's clear that there is a variety of -- there 15 would have to be a variety of conditions that would be 16 found in the field, and these could not possibly O
17 represent all of them.
18 JUDG E GROSSMAN:
Okay.
19 Mr. Kostal, would you agree that generally a Z
()
20 category -- Z item would have a greater proportion of 21 weld missing to total weld than these demonstrative 22 exhibits?
O, 23 A
(WITNESS KOSTAL)
These would be classified as a
\\
24 Category X.
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15013 Y
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I 1
1 JUDGE GROSSMAN:
Okay.
v 2
A (WITNESS KOSTAL)
There would be no reduction, because
{
t 3
in terms of our reviewing through the other walkdown
[
]
4 programs, we have now defined the quantity of weld O
5 required is to the center line of this circular section.
{
l 6
(Indi ca ting. )
7 What we have been -- what has been observed and 1
D 8
documented through the BCAP program has been missing l
9 portions of welds that I have personally seen in 10 observation packages down to 1/16th-of-an-inch of that 11 total.
12 This would represent, on these various four 13 corners, anywhere from what I would say is somewhere
)
14 around 1/4-inch to 1/8-inch.
15 MR. STEPTOE:
Missing or present?
16 A
(WITNESS KOSTAL)
Missing, missing.
O 17 MR. STEPTOE:
All righ t.
18 JUDG E GROSSMAN:
1/4 to 1/8.
19 But, in any event, we're talking about proportion C
20 now of the missing weld to the total weld in order to 21 categorize it as an X, Y or Z item; isn't that correct?
22 A
(WITNESS KOSTAL)
This -- in order to classify -- to O,
23 characterize this as an X, Y,
Z, you take this weld
's
)
24 length, this weld length, this weld length on both O
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sides.
I
'O 2
(Indica ting. )
3 That's how you characterize this as an X, Y,
Z, l
4 because the only way you can do a stress analysis is to O
5 take all of these welds into account simultaneously.
6 This little portion of weld you just can' t analyze by 7
it s el f.
l 10 8
J UDG E G ROSSMAN :
No.
l 9
What I am trying to say, and I think you are I
10 agreeing, is that the analysis requires a comparison of j
11 the missing portion of weld with the total weld?
12 A
(WITNESS KOSTAL)
That's correct.
l l
13 JUDGE GROSSMAN :
And to the extent that the h
14 missing portion is small in comparison to the total I
15 w el d, it's more likely that the item would be classified l
16 as an X than as a Z?
I l
O 17 The greater the proportion of the missing weld to 18 the total weld, the greater the chance of it being more 19 significant?
O 20 A
(WITNESS KOSTAL)
It would have been classified between 21 a Y and a Z because we would have done an area 22 reduction, which would have given us a Y.
Q_
23 MR. STEPTOE:
I'm sorry, Mr. Kostal.
Fi rs t i
24 you said X and now you j ust said Y.
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15015 x-
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i 1
A (WITNESS KOSTAL)
I'm sorry.
I better back up one j
I' 2
step.
3 The X by -- these would have been classified Y; but l
l 4
what I was intending to mean by an X was that there
'?
5 would have been zero reduction in the capacity of the J
6 weld as far as our analysis is concerned, because our 7
analysis only needs the weld to the center line.
O 8
So f rom an analysis point of view, there would be 9
no reduction in capacity if it went to the center line 10 of the weld, but from the documentation point of view in ed 11 the BCAP grogram, we would have characterized each one 12 of these either as a Y or a Z depending on tha t r eview 13 that I had talked about,.which is the R val'ue review.
14 JUDGE GROSSMAN:
Okay, fine.
15 I'm only just trying to point out that this doesn't 16 represent all of 'the cases.
D 17 Whatever the determination was with regard to the 18 calculation would indicate what propor tion of weld was 19 missing?
D 20 MR. STEPTOE:
That's agreed, Judge G rossman.
21 MR. GUILD:
Mr. Chairman, just for clarity, 22 in these cases, in the case of the demonstrative exhibit O,_
23 marked B with the discrepancy, the weld exceeds tha t 24 requi rement Mr. Kostal spoke of.
It goes at least to i
I f
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(312) 232-02G2
15016 s
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the midpoint of the bend in the Unistrut.
O 2
A (WITNESS KOSTAL)
Not in all cases.
3 I showed -- we gave four different cases here.
One 4
case does.
In this other case, it doesn' t go to th l
K, 5
center line.
l f
6 MR. GUILD:
All right, sir.
7 In one case it does, in one case it doesn?
t
'O 8
A (WITNESS KOSTAL)
Right.
9 So we were trying to show, through this 10 illustration, there is a variety of lengths that could 11 be measured on this top section, and that these would 12 have been recorded as discrepant in BCAP, and the --
13 maybe I better stop.
O 14 (In di ca ting. )
15 JUDGE GROSSMAN:
Well, let me clarify that 16 again.
O 17 If it met the center line, then it would not be 18 considered discrepant?
19 A
(WITNESS KOSTAL)
It would have been reported in BCAP O
20 as a discrepancy.
21 In terms of our evaluation, if it met the center 22 line, it met the intent of a sufficient weld such that O,
23 there is no reduction capacity.
s
(
)
24 That became the criteria in the f urther walkdown O
Sonntag Reporting Service. Ltd.
Geneva, Illinois 60134 (312) 232-0262
m 15017 y
1 program that was conducted per our procedure BIBB835, O
2 which was the walkdown procedure for weld presence.
3 In our further walkdown procedure for weld 4
presence, if we were missing a 1/16-inch of that run, we O
5 would have not -- that would have not been documented.
6 We would have only documented the missing weld presence 7
if it didn't at least go to the center line.
Tha t's the
~'
8 distinction.
9 JUDGE GROSSMAN:
Okay.
10 Now, looking at Applicant's Exhibit 145, what you ed 11 show there for the 3/8 inch, of course, is not the 12 center line.
13 In order for it to meet the center line -- please
'l 14 don' t doctor the e xhibit -- it would really be 3/16 of 15 an inch, wouldn' t it?
16 A
(WITNESS KOSTAL)
Tha t's correct.
'l 17 JUDG E GROSSMAN:
Okay.
18 MR. GUILD :
And, Mr. Ch ai rman, th e 19 demonstrative exhibit that Mr. Kostal properly points C'
20 out has four welds on it, not just two, and they va ry in 21 the -- in the length of the welds.
22 Some appear to be less than the required standard C_ _
that was adopted in the walkdown, don't go to the center 23
/
24 line, and some go past the center line?
C<
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i x
-Y l
A (WITNESS KOSTAL)
Right.
C?
2 So we would have documented, for example, in the 3
walkdown program for -- this weld right here does not go 4
to the center line.
In the walkdown program, we would O
5 have documented that f act.
6 (Indica ting. )
7 JUDGE GROSSMAN:
Okay, fine.
O 8
MR. GUILD:
Excuse me.
Judge Grossman, that concludes 10 what I needed to get to today.
qH 11 JUDGE GROSSMAN:
Okay.
12 So you will continue, then, on Monday ?
13 MR. STEPTOE:
That's correct, Judge Grossman, f) 14 JUDG E G ROSSMAN:
Unless there's something 15 f ur the r --
16 MR. MILLER:
Your Honor, I j ust have one O
17 matter.
18 I was under the impression that Dr. Hulin's 19 testimony had been prepared in final form and served on
()
20 the parties and the Board some time ago.
21 I find that it was not.
I apologize to the Board 22 and parties.
23 I'd like the record to reflect I'm distributing O,_~w
)
24 copies of Dr. Hulin's testimony a t this time.
1 i
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1 gN_d 1
JUDGE COLE:
The paper is still warm.
O 2
JUDG E G ROSSMAN:
Yes.
It's either hot of f 3
the press or it's been sitting in this room overnight.
4
( Laugh ter. )
- O 5
MR. MILLER:
It's hot of f the pr ess.
6 JUDG E GROSSMAN:
If that concludee what we 7
have today, we will adjourn until 2:00 o' clock gn Monday 0
8 in the same place, courtroom 1743.
9 (W HER EU PON, the hearing of the 10 above-entitled atter was continued to Of 11 October 20, 19 86, a t th e ho ur of 2 :0 0 P.
12 M.)
13 O
14 15 16 O
17 18 19 O
20 21 22 0( ~~
23
$x -)
24
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NO PAGE NUMBER CERTIFICATE OF OFFICIAL REPORTER O
This is to-certify that the attached proceedings before the UNITED STETES NUCLEAR REGULATORY COMMISSION in the matter of:
NAME OF PROCEEDING:
Braidwood Station Units 1 62 4
DOCKET NO.:
50-456/457-OL PLACE:
Chicago, Illinois DATE:
Friday, October 17, 1986 were held as herein appears, and that this is the original j
transcript thereof for the file of the United States Nuclear j
Regulatory Commission.
i j
j (sigt) L m M L,1 (TYPED)
Official Reporter Reporter's Affiliation
.O s.
1
.