ML20197B422
| ML20197B422 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 10/24/1986 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| CON-#486-1367 OL, NUDOCS 8610300291 | |
| Download: ML20197B422 (107) | |
Text
owngR' 050.G UN11ED STATES I
NUCLEAR REGULATORY COMMISSION IN THE MATTER OF:
DOCKET NO:
50-456 OL 50-457 OL COMMONWEALTH EDISON COMPANY l
(Braidwood Station, Units 1 & 2) l l
i LOCATION:
CHICAGO, ILLINOIS PAGES: 15,696,- 15,801 DATE:
FRIDAY, OCTOBER 24, 1986 0
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ACE-FEDLTO.L REPORTERS, INC.
Chic:al Rewrters 444 North Capitol Street Washington, 'D.C. 20001
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.VAEC%M CCVERACE
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2 UNITED STATES 'OF AMERICA 3
NUCLEAR RDGULATORY COMMISSION 4
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 5
6
_ _________________x In the Matter of:
7
' : Docket No. 50-456 COMMONWEALTH EDISON COMPANY, :
50-457 8
(Braidwood Station, Units 1 9
and 2)
__________________X 11 Page: 15,696 - 15801,
f O 12 United States = District Court House 13 Courtroom 1743 Chicago, Illinois 60604 Friday', - Octobe r' 24, 1986 15 16 The hearing in the above-eniitled matter reconvened 17 at 8:20 A.
M.
18 BEFORE:
19 JUDG E HERBERT G ROSSMAN, Ch airman 20 Atomic Safety and Licensing Board U.
S.
Nuclear Regulatory Commission 21 Washington, D.
C.
22 J UDG E RICH ARD F.
COLE, Pember,,
Atomic Safety and Licensing Board 23 U.
S.
Nuclear Regulatory Commission Washington, D.
C.
24 l
J UDG E A.
DIXON CALLIH AN, Member, 25 Atomic Safety and Licensing Board U.
S.
Nuclear Regulatory Commission 1
l l
Sonntag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
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15697
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Washington, D.
C.
2 APPEARANCES:
3 On behalf of the Applicant:
4 PHILIP P.
STEPTOE, III, E SQ.
Isham, Lincoln & Beale 5
Three First Na tional Plaza Chicago, Illinois 60602 6
7 On behalf of the Nuclear Regulatory Commission Staff:
8 GREGORY ALAN BERRY, ESQ.
9 ELAINE I.
CH AN, E SQ.
U.
S.
Nuclear Regulatory Commission 10 7335 Old Georgetown Road Bethesda, Maryland 20014 11
)
On behalf of the Intervenor:
[)
12
\\_,/
ROB ERT GUILD, ESQ.
14 15 16 17 18 19 20 21 22 23 24 O(_,)s 25 Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
15698 3
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1 EXHIBIT INDEX MARKED R ECE 1V ED 2
Intervenors' Exhibit No. 182 15702 15714 1
3 Intervenors' Exhibit No. 183 15715 15733 4
Intervenors' Exhibit No. 184 15738 15749 4
5 6
7 8
L i
9 10 11 i
12 13 14
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i 15 16 1
l 17 18 19 20 i
21 22 23 24 i
25 L
r Sonntag Reporting Service, Ltd.
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1 TESTIMONY OF 2
GEORG E F.
MAR CU S AN'IHONY J.
D' ANTONIO 3
FRED D.
FORREST TONY C.
FR AZ IER 4
CROSS EXAMINATION (Continued) 5 BY MR. GUILD:
15700 6
CROSS EXAMINATION BY MS. CH AN :
15778 l
BOARD EXAMINATION 8
BY J UDG E GROSSMAN:
15780 9
BOARD EXAMINATION BY JUDG E COLE:
15787 10 BOARD EXAMINATION 11 BY J UDG E G ROSSMAN :
15794 h(,_/
12 CROSS EXAMINATION (Con tin ued)
BY MS. CH AN :
15797 13 9
BOARD EXAMINATION 14 BY J UDG E GROSSMAN:
15799 15 f
16 l
l 17 18 19 20 21 22 23 24 iv) 25 t
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1 JUDGE GROSSMAN:
The hearing is reconvened.
2 This is the 80th day of hearing.
3 The witnesses remain sworn.
4 Mr. Guild, continue with your cross examination --
5 MR. GUILD:
Thank you, Mr. Chairman.
6 JUDGE GROSSMAN:
please.
7 MR. GUILD:
Good morning, gen tleme n.
8 A
(WITNESS MARCUS)
Good morning.
9 A
(WITNESS D' ANTONIO)
Good morning.
10 A
(WITNESS FORREST)
Good morning, 11 A
(WITNESS FRAZIER)
Good morning.
12 BY MR. GUILD:
13 Q
Let's talk a little bit about the history of the PTL 14 overinspection of the Comstock electrical scope of work.
15 Now, to recap it, as I understand, Mr. Marcus, the 16 overinspection by PTL commenced early 1977, and it was
)
17 at the Q A Department -- Edison Q A Department's 18 initiative that such a program was instituted for l
19 Braidwood?
20 A
(WITNESS MARCUS)
That's correct.
21 Q
All right.
22 And that for the period of years leading up 23 until -- up until 19 80, there was a roughly 10-percent 24 overinspection of Comstock welds with no sample 25 expansion until December of 1980?
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1 A
(WITNESS MARCUS)
Tha t's par tly correct.
2 When the program first started, 1977, there was a 3
requirement to overinspect 50 percent of Ernst -- the 4
work performed by Ernst --
5 0
All right, si r.
6 A
(WITNESS MARCUS)
---but it is correct that it was 7
1980, December of 1980, that the expansion feature was 8
incorporated into the program.
9 0
All right.
Then maybe I missed one intervening step.
10 When did you go to 10 percent as the overinspection 11 rate?
[
12 A
(WITNESS MARCUS)
We have that date.
-v 13 Perhaps one of the --
14 A
(WITNESS FORREST)
I believe it was some time in 1978.
15 Q
' All right, si r.
16 Then at least at the point when Comstock came on as 17 electrical contractor, you were doing 10 percent?
18 A
(WITNESS FORREST)
That is correct.
19 A
(WITNESS FRAZIER)
That is correct.
20 0
With no sample expansion until that feature was added in 21 December of 1980.
22 A
(WITNESS D' ANTONIO)
Correct.
23 A
(WITNESS MARCUS)
Correct.
24 Q
So let's look at some documents that reflect this aspect 25 of the PTL history.
x Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262 4
15702 O
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-1 I've got a collection of memos that were made 2
available in discovery, gentlem en, and the first of them 3
is a December 29, 1980, memo -- if you can share those, 4
I'd appreciate it -- reflecting the initial aspect of j
5 sample expansion.
6 (Indicating.)
7 MR. GUILD:
Mr. Chairman, I'd ask this 8
document be marked as Intervenors' Exhibit 182, please.
9 (The document was thereupon marked 10 Intervenors' Exhibit No. 182 for 11 identification as of October 24, 1986.)
l 12 BY MR. GUILD:
13 Q
Now, we can briefly look through this.
14 This cover memo from Mr. Sommerfield of Edison QA 15 to Mr. Smetana --
16 A
(WITNESS D' ANTONIO)
Smetana.
1 17 Q
Mr. Smetana, is he a PTL man?
18 A
(WITNESS FORREST)
He was my predecessor as the site 19 manager.
20 0
All right, sir.
I 21 That is the memo that effected the sample expansion 22 in December of 1980?
23 A
(WITNESS FORREST)
That's correct.
24 Q
All right, sir.
25 Now, if you turn through the documents in order,
(
4 i
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1 there is a March 22, 1984, memorandum, and this 2
alerted -- this is f rom Mr. Shew ski, signed by Mr.
3 Pitzpatrick for Mr. Shewski, to PTL, and this was the 4
first Edison direction to PTL to begin to develop what 5
was to be the 25 percent overinspection rate of site 6
contractors?
7 A
(WITNESS MARCUS)
That is correct.
8 Q
All right, sir.
9 Now, I notice that the language appearing in this 10 March 22nd memo, about two-thirds of the way in this 11 first paragraph, reads, quote, "The overview inspection s
{ j}
12 program shall be developed so as to provide, in 13 conjunction with site Q A direction, for up to 25 percent 14 overview of contractor QC inspection activities."
15 Now, what I want to focus on is the language "up 16 to 25 per cent. "
17 Was it envisioned, gentlemen, that at this time 18 there might not be a fixed 25 percent overinspection of 19 contractor activities, but that there may be some lesser i
20 rate of overinspection?
21 A
(WITNESS MARCUS)
I believe that's correct.
22 What we were trying to do is to achieve a goal of i
23 25 percent.
24 I believe the language in this memo reflects what
(
25 our thinking was at that time, and it also reflects the Sonntag Reporting Service, Ltd.
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1 longuage that was in the response which we sent to the 2
NRC in July of 1984.
3 Q
All right, sir.
4 Now, the next memorandum, written the following 5
day, March 23, 1984, f rom Mr. Q uaka, the site Edison QA 6
Superintendent, to various contractors, "Subj ect:
7-Braidwood Station ~ 0verview Group - Current Status and 8
Update," again, in the second paragraph, uses the i
9 conditional language, quote, " Attempt to overinspect 25 10 percent of all current contractor activities."
11 This also reflects the 25 percent being a goal 12 rather than a fixed rate?
13 A
(WITNESS MARCUS)
That is correct.
'l 14 Q
All right, sir.
I 15 The move to 25 percent, as.you acknowledged I
16 yesterday, Mr. Shewski -- Mr. Marcus -- e xcuse me -- was i
17 as a result of Edison's July commitment to the NRC in 18 response to Inspection Report 8309?
19 A
(WITNESS MARCUS)
It did show up in the July response 20 to 8309, but prior to that response, our Edison QA 21 staff -- that is, Mr. Shewski and myself and other 22 corporate members of the Edison Company -- met with the I
23 NRC in March, during an enforcement conference, and I 24 believe that was the first time where the suggestion 25 came up orally that we would work on expanding our i
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overinspection program.
2 O
I see.
All right, sir.
3 And, of course, the Inspection Report itself, 8309, 4
was not published until May of 1984, and the company's 5
res pon se, as we've seen yesterday, was in July of '84, 6
but there were discussions with the NRC at which the 7
25-percent figure was established?
8 A
(WITNESS MARCUS)
That is correct.
9 Q
All right, si r.
10 Now, the next document in this package, marked 11 Inte rvenors' Exhibit 182, is a November 1, 1984,
[]
12 memo -- Mr. Forrest, it appears to bear your i
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13 signature -- to Mr. DeWald, the Comstock Quality Control 14 Manager.
15 And this details how you were to implement that 25 16 percent overinspection rate?
17 A
(WITNESS FORREST)
That is correct.
18 0
All right, si r.
19 And, again, the language that is used here is, "PTL 20 will begin to inspect 100 percent of approximately 25 21 percent of the requested installations," and then you 22 use examples to explain how you implement that?
23 A
(WITNESS FORREST)
That's correct, sir.
24 Q
Now, again, that's a change from simply the process
(
25 that's described in your testimony, where you would get a
Sonntag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
15706 jv l
1 an inspection request, you would note that there are 100 2
welds contained.in the components reflected in that i
3 r eques t, and the PTL inspector would choose, in an 4
at-random basis, not a random basis, but a grab-sample 5
basis, -if you will,10 in that instance and in this 6
e xample, or 10 percent, and then conduct 7
overinspections ?
8 A
(WITNESS FORREST)
That's correct.
i 9
0 All right.
10 In this case, you moved to a system where you did 11 25 of the welds -- I'm sorry -- you did 25 percent of i
12 the work submitted and 100 percent of each of the welds j
13 on the -- on the components that were selected for 4
14 inspection?
15 A
(WITNESS FORREST)
That's correct.
16 Q
All right, sir.
17 Now, again, the 25 percent overinspection rate, as 18 particularized in your explanation, was to begin not 19 until November 2, 1984, and that's the date that appears j'
20 in this letter?
21 A
(WITNESS FORREST)
That's correct --
22 Q
All right.
23 A
(WITNESS FORREST)
-- although we did start 25 percent i
24 overinspection on another contractor prior to November.
25 I believe it was some time in July.
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Q All right.
2 But for Comstock, it was November of ' 84 ?
3 A
(WITNESS FORREST)
Tha t's correct.
4 Q
All right, sir.
5 The next page, an April 26, 1985, memorandum, Mr.
6 Quaka to Mr. Shamblin, and here it appears that Mr.
7 Quaka of Edison QA was authorizing Comstock and PTL, the 8
response of the respective parties, to reduce the 9
overinspection rate from 25 percent down to 10 percent, 10 and on the stated basis that the, quote, " Trend of 11 reduced deficiencies noted for the first three months of N )h 12
- i this year"?
13 A
(WITNESS MARCUS)
That's correct.
14 Q
All right.
15 Now, do I understand correctly that PTL performed 16 that trend of rates of overinspection non-conformances, 17 and it was on the basis of PTL's trend of the 18 non-conformance rates for those periods that Mr. Quaka, 19 in turn, acceded to the request to reduce the 20 overinspection rate?
21 A
(WITNESS D' ANTONIO)
It was a decision made in Edison 22 quality assurance for that reduction.
23 The data was gathered by PTL and provided to 24 Commonwealth Edison quality assurance, who made the 25 decision to reduce down to 10 percent based on that data Sonntag Repor ting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
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4 15708 n
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1 provided.
1 2
Q All right, sir.
]
3 Who is Mr.
C. Rufo, R-U-F-0 ?
?
4 A
(WITNESS D' ANTONIO)
He is the PTL supervisor j
5 responsible for the overinspection activity.
6 Q
All right, sir.
7 And was it Mr. Rufo who performed the trend on i
8 which the decision to reduce the overinspection rate was j
9 based?
10 A
(WITNESS D' ANTONIO)
He did not make the decision.
He l
11 provided us with the data that the decision was based i
i 12 on.
i s
1 13 Q
Yes.
14 He was the PTL man who performed the trend analysis t
15 that was the basis, though, for the decision to reduce i
j 16 the overinspection rate; is that correct?
17 A
(WITNESS D' ANTONIO)
Well, again, he provided us with i
18 the data.
The decision was made by Commonwealth Edison f
19 quality assurance.
i 20 0
All right, sir.
21 Who w as Mr. Kunz mann, K-U-N-Z-M-A-N-N?
22 A
(WITNESS D' ANTONIO)
He was a Commonwealth Edison i
23 employee that worked within the PTL group.
i 24 0
W ell, sir, in fact, on April 24, 1985, Mr. Rufo j
25 submitted the results of PTL's trending of the 5
Sonntag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
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l non-conformances to Mr. Kunzmann of CECO QA?
2 I'm showing you a document dated April 24, 1985, 3
that is not in the packe t.
It's another document.
4 (Indica ting. )
5 A
(WITNESS D' ANTONIO)
Yes, sir.
6 MR. STEPTOE:
May I see that document, 7
please?
8 MR. GUILD:
Sure.
9 It bears a Bates Number of -- I can' t read it.
10 A
(WITNESS MARCUS)
Bates --
11 MR. GUILD:
Yes.
Ih 12 A
(WITNESS MARCUS)
The Dates Number is 2324.
N.I 13 MR. GUILD:
Yes, AR232 4.
14 BY MR. GUILD:
15 0
And in that document -- by that document, PTL did submit 16 their trend analysis for the period in question to 17 Commonwealth Edison QA; correct?
18 A
(WITNESS D' ANTONIO)
A review of the results, as it 19 states.
20 0
Well, in full -- let's read it in full.
21 "On 4/24/85 PTL performed a review of the VW 22 repor ts" -- visual weld repor ts?
23 A
(WITNESS D' ANTONIO)
Tha t's correct.
24 Q
- Okay, "f or the time periods" -
" time period 1/1/85 to 25 s
Sonntag Reporting Service, Ltd.
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4/12/85 for the purpose of trending the 2
non-conformances.
The result are as follows. "
3 For the month 1/1 to 2/11, there was shown a 9.6 4
percent -- I take it that's a 9.6 percent rejection rate 5
or non-conformance rate?
6 A
(WITNESS D' ANTONIO)
Yes, sir.
7 Q
For the month 2/12 to 3/11/85, an 8.7 percent 8
non-conf ormance or rej ection rate?
9 A
(WITNESS D' ANTONIO)
Yes, sir.
10 0
And for the month 3/12 to 4/11/85, a 6.3 percent 11 non-conformance or rejection rate;?
12 A
(WITNESS D' ANTONIO)
Based on the VW reports, that's 13 correct.
14 Q
All righ t.
15 Now, on the basis of PTL's performance of that 16 trend and submission of that data to Edison QA, Mr.
17 Kunzmann of Edison Q A, in turn, requested that the 18 reduction in overinspection from 25 to 10 percent be 19 effected?
20 A
(WITNESS D' ANTONIO)
Yes, si r.
21 Q
Okay.
22 And that's by a memo of April 25, 1985.
- Again, 23 it's not in the package.
24 Do you have it?
25 A
(WITNESS D' ANTONIO)
I have it, sir.
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l Q
All right.
-2 And who is Mr. -- who is the addressee, Mr.
3 Wilmere ?
4 A
(WITNESS D' ANTONIO)
Wilmere.
5 Q
Wilmere ?
6 A
(WITNESS D' ANTONIO)
Yes.
7 He was the CECO QA supervisor responsible for PTL 8
activities at that point in time.
9 Q
All right.
10 So it was his -- well, did he have decision-making 11 authority with respect to the overinspection rate?
12 A
(WITNESS D' ANTONIO)
I believe he concurred with Mr.
N 13 Quaka and possibly Mr. Fitzpatrick relative to the 14 reduction.
15 Q
Okay.
16 Mr. Kunzmann, the CECO Q A supervisor for PTL --
17 A
(WITNESS D' ANTONIO)
For overinspection.
18 Q
-- for overinspection -- okay -- who received the data 19 from Mr. Rufo of PTL, stated to Mr. Wilmere, "I'd like 20 to drop the L.
K.
C. overinspection coverage rate from 21 the current 25 percent to 10 percent.
We have 22 experienced a very positive trend rate f rom 9.6 percent 23 rejection in January, 8.7 percent for Februa ry, to 6.3 24 percent for April.
These rates were calculated from the 25 PTL reports without correction factors for PTL errors or i
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disputes, and the actual rates may be lower."
2 And on the basis of that recommendation, Mr.
3 Wilmere approved and Mr. Quaka concurred in and the rate 4
was reduced?
5 A
(WITNESS D' ANTONIO)
I believe so,- yes, sir.
6 Q
So you told the NRC that you were -- that you we _ going 7
to overinspect 25 percent of Comstock's work.
You told 8
them that in March; confirmed it in January -- in July, 9
Mr. DelGeorge's letter; didn't get around to starting it 10 until November; and then in April, April of 1985, 4, 5 11 months later, you reduced it back to 10 percent?
[
')
12 A
(WITNESS D' ANTONIO)
Tha t's correct?
\\J' 13 A
(WITNESS MARCUS)
It need be stated that that 25 percent 14 was an open-ended quantity that could either have. been 15 reduced or escalated based on the results of the 16 ove rins pe ction.
17 It would not prevent us f rom increasing the 18 percentage over 25 percent or reducing it accordingly 19 based on the results.
20 0
All right, si r.
21 Now, if you would, return to the documents --
22 series of documents that have been marked Intervenors' 23 Exhibit 182, 24 You reduced it, the overinspection rate, down to 10 (A) 25 percent again, Mr. Quaka's memo of April 26,
'85, but on l
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1 June 18th of '85, you discovered that that reduction was 2
based on an erroneous interpretation of the trending 3
data, and the decision was ef fected to, again, increase 4
the overinspection rate at this time from 10 to 20 5
per cent?
6 A
(WITNESS D' ANTONIO)
Yes, sir.
7 Q
All right.
8 The first paragraph of the June 18,
'85,
- letter, 9
Messrs. Kunzmann and Quaka to Mr. Shamblin, "Please 10 inform L.
K.
C. that cite QA has directed PTL to 11 increase their sample of overinspections from 10 to 20
[
12 percent of LKC's visual welding inspections.
This
't 13 action is a result of a reanalysis of overinspection 14 visual weld rej ections f rom August, 1984, to May, 1985.
15 "As a result of this reanalysis, a more accurate 16 trend was provided," and there's an attached set of 17 data.
"The previous trend reported," in the referenced 18 letter, the preceding 4/26/85 memo, " reflected accepted 19 and rejected PTL Inspection Reports.
This reanalysis 20 trended the actual number of welds accepted and 21 r ej e cted. "
22
- November,
'84, Fe br ua ry,
'85, and May,
'85, all 23 fell below the 90 percent acceptance rate; correct?
24 A
(WITNESS D' ANTONIO)
That's correct.
(v) 25 0
All right, si r.
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MR. GUILD:
Mr. Chairman, I would of fer 2
Intervenors' Exhibit 182 in evidence.
i 3
JUDGE GROSSMAN:
Any objections?
?
4 MR. STEPTOE:
No obj ection.
j J.
5 MS. CHAN:
No objection from the Staff.
6 JUDGE GROSSMAN:
Received.
7 (The document was thereupon received in 8
evidence as Intervenors' Exhibit No.
9 182.)
10 BY MR. GUILD:
l 11 Q
All right, sir.
12-Now, let's talk about the points where Edison I
l 13 suspended and then reinstituted PTL overinspections of
]
14 the Comstock work.
15 Let me show you another series of documents which 16 I'd ask be marked as Intervenors' Exhibit 184.
i
{_
17 (Indica ting. )
18 JUDGE GROSSMAN:
I'm sorry.
19 Are you marking something as 184?
20 MR. GUILD:
Yes, si r.
21 JUDG E GROSSMAN:
We don't have a 183 yet.
22 MR. GUILD:
Yes, I'm getting ahead of myself, j
23 Judge.
24 I'm sorry.183 is what it should be.
25 JUDGE GROSSMAN:
Okay.
This is marked as l
g j Sonntag Reporting Service, Ltd.
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1 183, the n.
2 (The document was thereupon marked 3
Intervenors' Exhibit No. 183 for 4
identification as of October 24, 1986.)
5 BY MR. GUILD:
6 Q
Now, gentlemen, the first document in the series bears a 7
May 4, 1981, date, and this ef fects a suspension of the 8
PTL overinspection activities, quote, "Since PTL visual 9
Weld Inspectors are assisting L.
K. Comstock QC in the 10 inspection of electrical hanger welds"; correct?
11 A
(WITNESS D' ANTONIO)
Yes, si r.
12 Q
And that suspension was effected by Mr. Sommerfield, 13 then the QA Superintendent at Braidwood, by 14 communication to Mr.
R.
Brown.
15 I take it Mr. Brown was a Comstock QC Manager at 16 the time?
17 A
(WITNESS D' ANTONIO)
I believe that's correct.
18 0
All right.
19 With a copy to Mr. -- I'm sorry -- Smetana?
20 A
(WITNESS D' ANTONIO)
Smetana.
21 Q
Smetana?
22 A
(WITNESS D' ANTONIO)
Yes.
23 Q
All righ t, sir; all right.
24 Now, that second memo simply acknowledges -- it
(
25 appears to be Mr. Smetana acknowledging that suspension i
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and returning the number of requests for overinspection ll 2
because of the suspended overinspection activities --
3 A
(WITNESS D' ANTONIO)
Yes, si r.
4 Q
-- correct?
5 All right.
The third memo -- I apologize for the 6
light copy, but I take it the originals are probably 7
also pretty ligh t.
8 June, 1981, this memorandum - states, "Please resume 9
previous sampling of Comstock welds for visual weld 10 inspection."
l 11 I can' t make out who the signatory is to the 12 document, but --
i 13 A
(WITNESS D' ANTONIO)
D.
B row n.
14 Q
Mr. Brown?
15 A
(WITNESS D' ANTONIO)
Yes, sir.
16 0
All right.
17 So that could be Comstock requesting that the 18 overinspection resume?
19 A
(WITNESS D' ANTONIO)
No, sir.
20 D.
Brown is -- you are confusing it with R. Brown, l
21 I believe.
22 0
Yes, I am.
23 A
(WITNESS D' ANTONIO)
D.
Brown was the supervisor in 24 quality assurance responsible for the area at that point
()25 in time.
i Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
15717 O) i' u./
1 Q
He was an Edison employee?
2 A
(WITNESS D' ANTONIO)
That's correct.
3 Q
All right, sir.
i 4
So it's Edison QA requesting a resumption of 5
overinspection in --
6 A
(WITNESS D' ANTONIO)
Of PTL, yes, sir.
7 Q
-- June of 19817 8
All right, sir.
Now, the next document in the 9
series, September,1982, again suspends the 10 overinspection activities on the basis that, quote -- on i
11 the basis, quote, "Due to the weld inspections being
[
\\t 12 conducted by PTL on L.
K.
C. welding on Saturdays"?
V 13 A
(WITNESS L' ANTONIO)
Yes, sir.
14 Q
All right.
15 I take it that reflects the f act that PTL was 16 loaning Comstock inspectors to do Saturday work, doing 17 first line quality control inspection on welds?
18 A
(WITNESS D' ANTONIO)
On Saturdays, yes, si r.
19 0
All righ t, sir.
20 Now, the next document that I found in order is a 21 November 8, 1982, doc umen t, and it calls for, again, a 22 suspension of overinspection activities, "This memo to 23 document our previous verbal direction to hire two Level i
24 II" --
25 A
(WITNESS D' ANTONIO)
VW.
l Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 4
l (312) 232-0262
. _.~ ~.
15718
/
k
)
v 1
Q Yes.
2
" visual Weld Inspectors to work at L.
K.
C.
i' 3
until such time as L.
K.
C.
is current.
When these J
4 personnel are released f rom L.
K.
C.,
they are 5
immediately to begin the AWS Weld undercut survey."
6 Well, I guess it isn't explicit.
i 7
Did that effect a suspension of overinspection 8
activity, gentlemen, do you know, this November 8th 4
9 memo?
10 Actually, look at the next document, if you would, 11 gen tlemen.
It may explain it.
There's also a November 12 8,
'82, memo that says, "Please reinstitute the 13 10-percent overinspection. "
14 A
(WITNESS MARCUS)
Fred, you have the document.
j 15 A
(WITNESS FORREST)
That is correct.
16 The first memo -- the first 11/8 memo is not a 17 sus pen sio n.
18 0
I sec.
All right, sir.
l 19 So it's the second November 8th memo that addresses 20 the suspension that was taken -- that took effect l
21 9/20/82; is that correct?
22 A
(WITNESS FORREST)
Yes, sir.
23 Q
So the suspension period in this case ran from September 24 20, 1982, based on the Saturday work by PTL inspectors b) 25 on Comstock work, and was 11f te.1 November 8, 1982, when
(
l Sonntag Reporting Service, Ltd.
i Geneva, Illinois 60134 I
(312) 232-0262
15719
,I v
1 PTL stopped assisting Comstock in visual weld 2
inspections?
3 A
(WITNESS MARCUS)
Yes, stopped assisting them on 4
Sa tur days.
5 Q
Stopped assisting them on Saturdays.
6 "okay.
I hope we did some good."
7 And it's signed -- whose initials are those down in 8
th e --
9 A
(WITNESS FORREST)
That's Mr. Smetana's initials.
10 0
"Okay.
Hope we did some good. "
All right.
11 So that the second November 8,1982, memo that says
[ )
12 that PTL is loaning two Level II visual Weld Inspectors V
13 to work at Comstock, that did not effect a suspension; 14 is that correct?
15 A
(WITNCSS FORREST)
Yes, that is correct.
16 Q
All right, okay.
17 And the next -- in turn, the next memo bears two 18 dates, October 27, 19 83, and November 15, 1983.
19 Now, this does effect a suspension, quote, "Since 20 PTL is supplying two f ull inspectors and three 21 additional visual Weld Inspectors Saturday" -- I take it 22 tha t abbr evia tion means Sa turday ?
l 23 A
(WITNFSS D' ANTONIO)
Yes, sir.
"The 10-percent overinspection of" -
"the 10-percent 24 0
I (n) 25 overinspection of," and I take it it must be Comstock l
~
Sonntag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
15720 o
1 off the page there?
2 A
(WITNESS D' ANTONIO)
Yes, sir.
3 0
"may be suspended until L.
K. C. reaches authorized 4
level of VW Inspectors.
Effective date 10/27/83," I 5
see.
6 And it's signed 11/15/83?
7 A
(WITNESS D' ANTONIO)
Yes, sir.
8 0
Who signed the memo?
9 A
(WITNESS D' ANTONIO)
It appears to be D. Brown.
i 10 Q
All right, sir, i
11 Now, that appears to suggest that there was, I
12 indeed, a suspension of PTL overinspection activities in 13 November of 1983.
l 14 Now, if you would, Mr.
D' Antonio, there's a i
15 reference -- the correction that you made to your l
16 testimony, which appears, I believe, at Page --
17 A
(WITNESS D' ANTONIO) 10, I believe.
I 18 Q
-- Page 10, yes.
I 19 All right, sir.
Now, in your testimony at Page 10, 20 you originally stated that the second suspension began j
21 October 27, 1983 -- all righ t, sir?
i 22 A
(WITNESS D' ANTONIO)
Uh-huh.
and extended to March 23, 1984?
23 0
24 A
(WITNESS D' ANTONIO)
Yes, sir.
(
25 Q
All right.
Sonntag Reporting Service, Ltd.
i Geneva, Illinois 60134 (312) 232-0262
15721 (3)
(
v 1
Now, I see a suspension -- and then you changed 2
your testimony to reflect that the suspension period 3
ended December of 1983 --
4 A
(WITNESS D' ANTONIO)
Yes, sir.
5 0
-- correct?
6 Okay.
Now, where was the -- what's the basis for 7
dating the initiation of this suspension period October 8
27 th ?
9 A
(WITNESS D' ANTONIO)
Based on the effective date in the 10 11/15 memo dated 10/27/83.
11 Q
I see.
-'s
(
)
12 A
(WITNESS D' ANTONIO)
Excuse me.
\\v/
13 Q
So it's this memo that started the suspension?
14 A
(WITNESS D' ANTONIO)
Yes, sir.
15 0
All right.
16 Now, the next memo that I have in the series on 17 suspensions is June 22, 1984 --
18 A
(WITNESS D' ANTONIO)
- 26th, 19 Q
Yes, June 26th -- I'm sorry -- tha t's correct.
20 And we've discussed the -- we discussed the March 21 23, 1984, memo, and that's a portion of Intervenors' 22 Exhibit 183, is it not, the March 23, 1984, memo?
23 That's the memo from Mr. Quaka to the site contractors 24 on which you originally believed -- on which you r
s
(
)
25 originally based your resumption date testimony; Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
15722 1
correct?
2 A
(WITNESS D' ANTONIO)
Yes, sir.
3 Q
All right.
4 Now, aside f rom the November,
'83, memo, which i
5 initiated the suspension, ef fective 10/27/83, "until L.
6 K.
C.
reaches authorized level of VW inspectors," I 7
don't see any other memorandum reflecting that the j
8 overinspections were to be resumed.
j 9
A (WITNESS D' ANTONIO)
I think we established that i
10 yesterday, t
11 Q
All right, i
12 There is no such memo?
s 13 A
(WITNESS D' ANTONIO)
To the best of my knowledge, that's 14 correct.
15 0
All right.
16 Now, the trigger for the resumption of i
17 overinspections was L.
K. Comstock reaching its l
18 authorized level of individual Weld Inspectors.
19 Did you determine when that precondition was met?
20 A
(WITNESS D' ANTONIO)
I am not aware --
I 21 Q
All right, si r.
i 22 A
(WITNESS D' ANTONIO)
-- when that was met, when they j
23 reached their authorized level of VW inspectors.
24 Q
Do you know whether or not Comstock was at its i
25 authorized level of visual Weld Inspectors by the end of i
l Sonntag Reporting Service, Ltd.
I Geneva, Illinois 60134 j
(312) 232-0262
15723 rh
\\v) 1 December of 1983?
2 A
(WITNESS D' ANTONIO)
I do not know.
3 0
All right, si r.
4 Do you know whether they reached their authorized 5
level of visual Weld Inspectors by March of 1983 --
6 1984, excuse me -- the date you originally believed the 7
sus pension --
8 A
(WITNESS D' ANTONIO)
By then I believe they did, yes, 9
si r.
10 Q
All righ t, sir.
11 Now, the next document -- again, the June 26,
'84,
[}
12 memo provides that PTL visual Weld Inspectors are to
\\J' 13 work for L.
K.
Comstock functioning as L.
K.
C.
14 inspectors on a temporary basis.
15 All righ t, sir?
16 A
(WITNESS D' ANTONIO)
Yes, si r.
17 MR. STEPTOE:
Excuse me.
18 Did you say inspectors?
19 MR. GUILD:
Well, yes, I think I misspoke.
20 It appears to be a single inspector referred to.
21 BY MR. GUILD:
22 0
Is it just one inspector?
23 A
(WITNESS FO RREST)
One inspector.
24 Q
All right, sir.
O )
25 So you were detailing -- or there was to be the Sonntag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
15724
(
(
)
x-1 detailing of a PTL inspector to work for Comstock?
2 A
(WITNESS FORREST)
That is correct.
3 Q
All right.
4 And that was to take place the next day, June 27, 5
1984; correct?
You signed that memo, Mr. D' Antonio ?
6 A
(WITNESS D' ANTONIO)
Yes, sir.
7 0
okay.
8 Did the PTL 04erinspection of Comstock work get 9
suspended as a result of detai!.ng that PTL' inspector to 10 Comstock?
11 A
(WITNESS FORREST)
No, it did not.
O
/
i 12 I think there's a clarification that we have to
'%.-l 13 make.
14 Q
Yes, si r.
15 A
(WITNESS FORREST)
There's two different situations 16 where we assisted Comstock in the performance of their 17 work.
18 Going back to the '82 memos, PTL people were 19 utilized on Saturdays.
They were performing first-line 20 inspections for Comstock.
21 During those periods, we suspended the overview 22 inspection.
23 This particular case here, we loaned a PTL l
24 inspector to Comstock.
Ile functioned as a Comstock l
f%
- (x_-)
2 5 inspector completing Comstock documentation, and the Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
15725 O
1 overview was not suspended.
2 0
What was this gentleman's name?
3 A
(WITNESS FORREST)
Mark Lorts.
4 Q
Mark --
5 A
(WITNESS FORREST)
Lorts.
6 Q
Can you spell his last name for the record?
7 A
(WITNESS FORREST)
L-0-R-T-S.
8 Q
Did he return to PTL later?
9 A
(WITNESS FORREST)
Yes.
10 0
Did he perform overinspection of Comstock activity at a 11 later date?
12 A
(WITNESS FORREST)
I believe he did --
l 13 Q
All right, si r.
14 A
(WITNESS FORREST)
-- but he did not overview his own i
15 work.
j 16 I think that should be understood.
17 Q
All right, sir.
18 Does that complete your answer?
19 A
(WITNESS FORREST)
Yes.
4 20 Q
Let's look at the next memo.
It's a March 5, 1985, memo 21 f r om a T.
Ronkoski to Larry Seese, apparently, "Su bj ect:
22 PTL Reports - Third Party Overview Requests.
23 Now, can you identify Mr. Ronkoski?
24 A
(WITNESS D' ANTONIO)
Proj ect Construction Engineer in 25 the electrical area.
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
l 15726 i
1 Q
" CECO QA has requested that L.
K.
C. Level III and PTL's 2
Level III" -- it's a very poor copy.
I apologiz e --
3
" inspect these reports together," et cetera.
4 Now, your original may be somewhat better.
I trust 5
that the copy I got was probably as bad as yours.
5 Can you tell me whether this reflected the use of a 7
PTL Level III to overinspect other -- not overinspect --
8 let me rephrase that.
9 Did this reflect the loan of a P'IL Level III to 10 Comstock?
11 A
(WITNESS D' ANTONIO)
No, sir, not at all.
12 0
-All right.
13 What exactly was the nature of the working 14 relationship between.the PTL and Comstock inspection 15 people that was reflected in this memo?
16 A
(WITNESS D' ANTONIO)
What this memo is regarding is a f.
17 certain population of reports that -- rej ects received l
18 by Comstock, who took exception to the dispositions 19 provided by the PTL overinspectors.
[
20 As a result of the original Comstock QC inspections 21 and the PTL overinspections being conducted by Level II 22 Ins pect ors, it is common to refer these situations to 23 the Level III's of each organization to see if the 24 situation can be resolved, and that's what this memo is 25 addressing.
l L
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
(
p
F 15727 O
1 Q
All right, si r.
2 I take it there was no suspension of PTL 3
overinspection ef fected by this memo?
4 A
(WITNESS D' ANTONIO)
Not at all, sir.
5 Q
Finally, the last document in what's been marked as 6
Intervenors' 183 for identification, PTL memo, Mr. Rufo 7
to Mr.
D' Antonio, December 12, 1985.
8 And I take it this memo responds to the findings 9
made by the NRC in Inspection Report 8521 and 22, Mr.
10 Mendez' and Mr. Neisler's inspection that we spoke of 11 yesterday ?
12 A
(WITNESS D' ANTONIO)
Can I read the document, please?
13 Q
Sure.
Please do.
14 A
(WITNESS D' ANTONIO)
Could I have the question read 15 back, please ?
16 MR. GUILD:
I'll rephrase it.
-17 A
(WITNESS D' ANTONIO)
Certainly.
18 BY MR. GUILD:
19 0
This memo, it responds to findings made by the NRC?
20 It doesn't obviously explicitly refer to the NRC, 21 but it reflects the findings in the unresolved item and 22 the item of non-compliance that we discussed yesterday, 23 and that was Mr. Mendez' and Mr. Neisler's inspection
,24 reported in 8521 and 8522?
25 A
(WITNESS D' ANTONIO)
Not at all, sir.
l Sonntag Reporting Service, Ltd.
i Geneva, Illinois 60134 (312) 232-0262
~
i
'f 15728 l
1 Q
No relationship?
2 A
(WITNESS D' ANTONIO)
No, sir.
3 0
All right, si r.
f 4
Well, it reflects the fact, does it not, that there 5
had been PTL rejected weld attributes that were not 6
addressed by L.
K.
Comstock?
l 7
A (WITNESS D' ANTONIO)
Yes, si r.
8 Q
All right.
4 9
You discovered that fact -- that fact was brought 10 to your attention by Mr. Neisler or Mr. Mendez when they 11 performed their inspections, when they identified the
(
12 instance of the Inspection Report from 1980 of 1,215 13 welds where you had identified 13 percent rejects in the 14 sample and those rejects had not been repaired or 15 evaluated by L.
K.
Comstock ?
16 A
(WITNESS D' ANTONIO)
What this is addressing is certain 17 attributes, not complete rej ect reports.
3 18 (Indica ting.)
19 Some items of the report is what they are 1
20 addressing here in that sentence, "During this time 21 period of inspection, there were instances that PTL 1
22 rejected weld attributes and they were not addressed by 23 Comstock."
That is not addressing the overall reports 24 that were not contained on the reject log.
(Oj 25 (Indica ting. )
Sonntag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
.-~
15729
,/-
( s!
~
1 Q
Okay.
2 And there's no relationship between the NRC's 3
findings in November of 1985 -- the repor t was December, 4
of course -- no, I'm sorry.
The report was, indeed, 5
November -- no rela tionship between the NRC's 6
findings --
7 A
(WITNESS D' ANTONIO)
And that document?
8 Q
-- and this document?
9 A
(WITNESS D' ANTONIO)
No, sir.
10 Q
All right.
11 The second paragraph refers to -- it says, "We
/ ~,
12 currently hold 64 open ICR's addressing these with 13 several hundred to f ollow. "
14 And I take it those ICR's reflect the PTL-rejected 15 attributes that were to be addressed by L.
K.
Comstock?
16 A
(WITNESS D' ANTONIO)
Yes, si r.
17 Q
But at the time of this letter, had not been addressed?
18 A
(WITNESS D' ANTONIO)
Tha t's correct.
19 Q
All right.
The open items, in other words.
20 All right.
The f ollowing -- the final paragraph, 21 though, refers to the f act that you simply did not have 22 sufficient manpower to do the following, "Due to the 23 QCIRP program, the" -- it says, "the OI department is 24 being staf fed by only two individual weld electrical
/~T
( )
25 inspectors.
This is not enough people to subsidize both Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
'T 15730
. /s 1
the L.
K.
C. open items and normal OI VW inspection."
2 I take it that's overinspection of individual 3
welds ?
i 4
A (WITNESS D' ANTONIO)
That's correct.
5 Q
All right, okay.
6 And it concludes by saying -- I have omitted some 7
language -
"We are requesting that CECO QA concur with 8
us in suspending electrical OI inspection until'this 9
backlog of L.
K.
C.
ICR's can be completed. "
10 And that was agreed to for a limited period of 11 time; correct?
12 A
(WITNESS D' ANTONIO)
Based on PTL having a data base for 13 the Comstock inspectors at that time, the performance of 14 the overinspection program.
15 0
Okay.
16 And how long was that suspension effective?
i 17 A
(WITNESS D' ANTONIO)
Based on the dates on the report, 18 it appears that it was effective December 16th, which is 19 indicated by the quality assurance signatures, the three 20 signatures at the bottom --
21 Q
Yes.
22 A
(WITNESS D' ANTONIO)
-- and it indicates through January 23 3, 1984, only.
24 Q
You didn't mention this December suspension period in 25 your testimony?
s Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 4
(312) 232-0262
15731 g
(Vl 1
A (WITNESS D' ANTONIO)
No, si r.
2 Q
Now, does this reflect that PTL was performing some work 3
with respect to the Comstock open ICR's aside from 4
overinspection work?
5 A
(WITNESS FORREST)
When we began the expanded overview 6
program in June of 1985, we did have on the books a 7
number of Comstock rej ects prior to June of '85.
8 Essentially what we did is we tracked both of those 9
items separately.
10 It was essentially in June of '85 that we began a 11 brand new program.
It was a computer-based program
[V) 12 where we entered everything in the computer and we could 13 track it as such.
14 (Indica ting. )
15 Prior to tha t, our rejects were basically in our 16 logs.
Okay ?
17 I believe what they were talking about in this 18 letter in December of '85, we were still in the process 19 of closing out a lot of the rej ects and Comstock 20 correspondingly was closing out a lot of rejects under 21 the old program.
22 The problem was, in order to close out the items 23 under the old program, we did not have enough people 24 available to us to maintain our percentage in the p
J 25 electrical area under the new program.
Okay ?
(s_ /
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
15732
/N 1
(Indica ting. )
2 Now, we only suspended just the Comstock visual 3
w elds.
We still continued to perform overinspections in 4
the mechanical area, civil area and so on, i
5 0
All right, si r.
6 So if I'm understanding you correctly, there were
~
7 PTL people working on these open items, the backlogged t
8 open items?
9 A
(WITNESS FORREST)
Yes.
10 Q
All right.
11 What were they doing?
(
12 They were reinspecting those open items that had 13 been closed?
14 A
(WITNESS FORREST)
That is correct.
15 0
All right, si r.
16 MR. GUILD:
Mr. Chairman --
17 JUDGE GROSSMAN:
Let's go of f the record.
18 (There followed a discussion outside the 19 record.)
20 JUDG E GROSSMAN:
Back on the record.
21 MR. GUILD:
I'd of fer, at this time, 22 Intervenors' 183, Mr. Chairman.
23 JUDGE GROSSMAN:
Any objection ?
24 MR. STEPTOE:
No obj ection.
(
25 MS. CH AN :
No objection from the Staf f.
Sonntag Reporting Service, Ltd.
)
Geneva, Illinois 60134 (312) 232-0262
15733 I
I
\\_J l
JUDGE GROSSMAN:
Received.
2 (The document was thereupon received in 3
evidence as Intervenors' Exhibit No.
4 183.)
5 MR. GUILD:
May I have just one moment, Mr.
6 Chairman, please?
7 JUDG E GROSSMAN:
Do you want a recess now, 8
Mr. Guild?
9 MR. GUILD:
If I could have a moment, I think 10 I can find my place, Mr. Chairman.
11 Yes, perhaps if I could take a five-minute recess,
(
i 12 Mr. Chairman.
\\
]
x._
13 JUDG E GROSSMAN:
Okay, fine.
14 (WHEREUPON, a recess was had, after which 15 the hearing was resumed as follows:)
16 JUDGE GROSSMAN:
Mr. G uild.
17 MR. G UILD:
Thank you, Mr. Chairman.
18 BY MR. GUILD:
19 Q
Now, gentlemen, turning to another subject:
20 The PTL overinspections of L.
K. Comstock's work 21 were performed by inspectors who were certified to the 22 ANSI N45.2.6 standard for Quality Control Inspector 23 certification?
24 A
(WITNESS FORREST)
Tha t's correct.
)
25 A
(WITNESS FR AZIER)
That's correct.
iO Sonntag Repor ting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
15734
/
'a t
/
'v/
1 Q
We talked yesterday about the results of the QCIRP of 2
the PTL inspectors.
3 Those inspectors that were certified to the ANSI 4
standard as Level II Quality Control Inspectors, I take 5
it, were doing these overinspections of Comstock's work?
6 They were Level II Inspectors under the ANSI standard, 7
were they not?
8 A
(WITNESS FORREST)
Yes, th ey were.
9 0
All right, sir.
10 These Level II Inspectors did not inspect to the 11 same standards that the L.
K.
Comstock inspectors were (n) 12 supposed to inspect to, did they ?
%)
13 A
(WITNESS FORREST)
Not the same specific procedure, but 14 both the Comstock inspection procedure and the PTL 15 inspection procedures are based on requirements of the 16 AWS standa rd.
17 (In dica ting. )
18 Q
All right, sir.
19 A
(WITNESS FORREST)
The procedures may not be verbatim, 20 you know, with each other, but th ey bo th me t th e 21 requirements of AWS Dl.l.
22 Q
All right sir.
23 The acceptance criteria themcelves may have varied 24 in cases?
/
\\
25 A
(WITNESS PORRES T)
No, it should not have.
(v)
Sonntag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
15735 x
L) 1 Q
Oh, it'didn't?
2 A
(WITNESS FORREST)
No.
3 As an example, the undercut criteria for Comstock t
4 is the same for PTL.
Size and length requirements for 5
Comstock is the same for both organizations.
6 Q
All righ t, sir.
7 Well, the procedures may have varied, then?
You 8
would agree with me that far, the inspection procedures 9
may have varied?
10 A
(WITNESS FORREST)
Yes.
11 Q
All righ t.
12 But it's your position that the PTL inspectors 13 utilized the weld acceptance criteria that are required 14 by the AWS Dl.1 Code-1975?
15 A
(WITNESS FORREST)
That is correct.
16 Q
Well, sir, that isn't exactly correct, is it, given the 17 fact tha t, by your own testimony, you estimate that some 18 7 percent of the total welds that were overinspected by 19 PTL were overinspected in violation of the requirements 20 of the AWS Code, since they were overinspected in a 21 painted condition?
22 A
(WITNESS MARCUS)
I'd like to comment on that.
23 0
You have to answer yes or no directly to the question.
24 In fact, you do?
s 25 A
(WITNESS FORREST)
There was a portion of the welds in i
Sonntag Repor ting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
15736
\\
l our data base that are inspected through paint, yes.
2 Q
Yes, sir.
3 And that is inconsistent with the requirements of 4
the AWS Code for performing visual inspection of welds, 5
is it not?
1.
6 A
(WITNESS MARCUS)
That is not correct, i
7.
Q W ell, sir, Mr. Marcus, let me ask you that question 8
directly.
9 Does the Nis Code permit the individual inspection i
10 of welds in a painted condition, in your opinion?
i 11 A
(WITNESS MARCUS)
My comment was in regards to the 12 Nuclear Construction Issues Group, the new standard that 13 is used for tne inspection of welds.
14 Q
All right, si r.
15 Well, I'll be happy to let you explain that point 16 in a moment, but what I'd like you to address most e
(
17 directly is the question of the AWS Dl.1-1975 visual l
18 weld acceptance criteria.
1 19 And don' t you acknowledge that to the extent at 20 least that PTL performed visual inspections of welds l
21 that were in a painted condition, some 7 percent of the l
l 22 w elds, by your estimate, that in that regard, PTL did 1
l 23 not adhere to the AWS visual weld acceptance standards?
24 A
(WITNESS MARCUS)
I would -agree with that; but I have l
25 to qualify it, Mr. Guild, because PTL was doing an l
l Sonntag Repor ting Se rvice, Ltd.
l Geneva, Illinois 60134 L
(312) 232-0262
15737 1
1 overins pe ction, and the overinspection, I beli eve, is 2
not directly addressed in the AWS D1.1 code.
They talk 3
about first line QC inspections, i
4 Q
Well, they talk about inspections.
5 They don't make any distinction whether it's a 6
first line, second line, third line overinspection or i
7 a nything else, do th ey ?
8 A
(WITNESS MARCUS)
No; but the new V Reg criteria does, 9
and that's why I was trying to introduce that, in order i
10 to clarify --
11 Q
Yes.
12 A
(WITNESS MARCUS)
-- the ANS requirement.
13 0
Well, in may be compliance with some other standard, but j
14 there's not compliance with the AWS Dl.1 acceptance 15 criteria to the extent AWS Dl.1 prohibits accepting 16 welds that are in a painted condition?
17 A
(WITNESS MARCUS)
That is correct; but PTL was not 18 doing a first line QC inspection.
Comstock was 19 performing this inspection.
PTL was doing an 20 overinspection.
21 Q
All right sir.
22 But you are assuming, for purposes of your 23 tes timony, that the agreement rate between the PTL Weld 24 Inspectors and the Comstock inspectors is an effective 4
25 measure of the Comstock inspectors' work performance?
1-Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
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s 1
A (WITNESS MARCUS)
Yes, I am, and we believe that it is.
2 Q
All righ t, sir.
3 JUDGE GROSSMAN:
Excuse me.
4 By the way, let's get the ground rules right for a 5
panel answering questions.
6 When someone starts to answer a question, he's 7
entitled to finish, even if someone else on the panel 8
doesn't agree, and then after he's finished, the other 9
person on the panel can indicate what his position is.
10 So we don't want anyone being cut off and then 11 having some other answer given in place of what would
/~
(
's 12 have been given.
v/
13 A
(WITNESS MARCUS)
I apologiz e, Judge G rossman.
I 14 didn't realize I was doing that.
15 BY MR. GUILD:
16 Q
Gentlemen, let's look at some documents on this 17 question.
I'll give you two, and if you would share, 18 pl ea se.
19 (Indica ting. )
20 Now, the first page of the document --
21 MR. GUILD:
Mr. Chairman, I'd ask that this 22 set of documents be marked for identification as 23 Intervenors' Exhibit 184, pl ease.
24 (The document was thereupon marked (ql 25 Intervenors' Exhibit No. 184 for j
Sonntag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
)
15739
/
i, 5G' 1
identification as of October 24, 19 86.)
2 BY MR. GUILD:
3 Q
Gentlemen, the first document is a memorandum from Mr.
4 Brown, Mr. Brown of Edison Q A, bearing a date of 5
Nov embe r 24, 1981, to Mr. Smetana of PTL, and it 6
explicitly authorizes PTL to visually inspect Comstock 7
welds that have been painted, that are in a painted 8
condition; correct?
9 A
(WITNESS MARCUS)
That's correct.
10 Q
All right.
11 It gives the explanation that you offered, Mr.
[ -,')
12 Marcus, and that is that PTL's performing a sample
'%.J 13 survey of work that has received an inspection before 14 pain ting ?
15 A
(WITNESS MARCUS)
Yes, sir.
16 Q
All right.
17 Now, starting with that document, let me ask you to 18 leaf through this series of documents and, if you will, 19 there is a handwritten document with "for reference 20 only" stamped in the middle of it, and it's on the 21 letterhead -- it says, "From the desk of Thomas 22 Corcoran."
23 Do you see that?
24 A
(WITNESS MARCUS)
Yes, sir.
(p) 25 0
All right.
%/
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
15740
>""s U
1 Now, by this memorandum, Mr. Corcoran appears to 2
take Mr. Brown, the Edison Q A man's authorization to 3
PTL -- appears to take Mr. Brown's authorization and 4
apply that authorization for inspection of welds in a 5
painted condition not to an overinspection, but to the 6
first line quality contral inspections being performed 7
by L.
K.
Comstock Visual Weld Inspectors?
8 A
(WITNESS MARCUS)
That is correct.
)
9 Q
All right.
10 It makes specific reference, " Note: The above has 11 been PTL's methods and CECO QA (D. 3rown) has no 12 obj ection to this recorded method of visual inspections.
13 T.
Corcoran."
1 14 All right.
Well, now, is there any stipulation in 15 Mr. Brown's memorandum -- tha t is, the November 24, 16 1981, memorandum -- that PTL inspection of welds in a J
17 painted condition be documented in any fashion?
18 A
(WITNESS MARCUS)
No, there is not, i
19 Q
All right, si r.
20.
Now, preceding Mr. Corcoran's memo -- that is, the l
21 handwritten June 13, 1983, memo -- there is a memorandum l
22 from Mr. DeWald to Mr.
D.
- Brown, i
23 Do you see tha t, sir ?
24 Mr. DeWald's memo is dated March 9,1984.
25 A
(WITNESS MARCUS)
Yes, I have it, i;.
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
15741
/N i
i V
1 1
'O With reference to the Corcoran note, the second 2
paragraph, quote, "This note also indicates your 3
concurrence although there is nothing in writing from 4
you.
This-has caused inspections of painted welds to be 5
performed and indicated on the checklist."
He goes on, l
6 Mr. DeWald does, "This is totally out of the scope of 7
our weld procedure and feel it is an NCR type item as 8
there have been inspections performed to T.
Corcoran's j
9 memo / note.
Please give this your immediate attention.
10
- Signed, I.
F. DeWald."
11 All right.
Now, the last -- not the last, but 12 behind Mr. Corcoran's memo, there is, indeed, an L.
K.
x 13 Comstock weld inspection checklist bearing a date of --
14 under the QC Inspector signature box, of March 5, 1984, 15 and noting the fact that the visual inspection was 16 performed of painted surf aces?
I j
17 A
(WITNESS MARCUS)
That is correct.
18 Q
Now, so DeWald writes to Brown and Mr. Brown -- Mr.
I 19 DeWald writes to Mr. Brown asking for immediate l
20 attention, March 9, 1984.
l 21 Mr. Brown waits until August 13, 1984, and he l
l 22 writes Mr. DeWald back; correct?
l 23 A
(WITNESS MARCUS)
I believe that's what the document 24 shows, Mr. Guild.
25 0
All right.
l Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 l
(312) 232-0262
15742 fmO 1
A (WITNESS MARCUS)
I also have additional information on 2
that subj ect, though.
3 I spoke with Mr. Brown --
4 0
Well, sir, I mean, you may have some additional 5
inf orma tion, but I really would ask that your lawyer 6
address that on redirect, if there's something else that 7
Edison feels they should share; but you've been 8
responsive to my question, and I'm simply asking you 9
whether or not there was a response by Mr. Brown.
10 And that response is contained in the document 11 before you, is it not?
[d h
12 A
(WITNESS. MARCU S)
Yes, sir.
i 13 Q
All right.
14 Mr. Brown appears to express an opinion in this 15 memorandum about the circumstances of Mr. Brown -- of f
16 the original authorization --
i 17 A
(WITNESS MARCUS)
That is correct.
i 18 Q
-- the 1981 areas?
19 In here it is in August of '84 and he's -- he's --
20 there in his communication to Mr. DeWald referring to a 21 reverification of the present size and length of weld 22 added to the main control boards?
t 23 A
(WITNESS MARCUS)
Yes, sir; but the --
24 Q
All right.
25 A
(WITNESS MARCUS)
-- 1981 memo to Mr. Brown and the i
Sonntag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
15743 j-f 1
Corcoran memo, as near as I can tell from the I
2 investigations I have done, are not related.
3 Q
Oh, th ey ar e no t.
4 So that the D.
Brown '81 memo was not the basis, as 1
5 best you can tell, for the Corcoran memo?
6 A
(WITNESS MARCUS)
That is correct.
7 Q
All right.
8 Well, was there a D.
Brown -- is there anything in 9
writing from Mr. Brown or was it simply, from all 10 appearances, an oral authorization?
11 A
(WITNESS MARCUS)
There was an oral discussion on the 12 subj ect.
13 Q
All. right.
14 And I take it that you weren't present, but you've 15 come to that understanding from talking to participants 16 in that discussion?
17-A (WITNESS MARCUS)
Yes, sir, it came from a conclusion 18 from discussing this subject with Mr. Brown.
19 0
Mr. Brown.
All righ t, sir; all right.
20 Now, so we have the Brown memo to DeWald in August 21 of '84, which really concludes there was not any 22 intention for L.
K.
C.
to perform visual weld inspection 23 for weld quality through paint.
Okay.
24 But during this period of time, PTL was doing it, 25 weren' t they ?
This Brown memo of August of '84 had no Sonntag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 4
(312) 232-0262
15744
~-)
\\
i 1
ef fect on PTL's practice? -
2 A
(WITNESS MARCUS)
Yes, sir, PTL was doing an 3
overins pe ction.
4 0
Of welds through paint?
5 A
(WITNESS MARCUS)
They were not doing a first line QC 6
inspection.
7 Q
Right.
8 But they were doing their overinspection through 9
paint?
10 A
(WITNESS MARCUS)
They were allowed to do 11 overinspection through paint, yes, si r.
12 Q
All righ t, sir.
13 Now, finally, if you skip past the weld inspection 14 ch ec klis t, the Form 19, there is a September 29, 1984, 15 memorandum, Mr. Smith, the Q A supervisor, general 4
j 16 supervisor at Braidwood, Mr. Miller, a QA Inspector, to 17 you, Mr. Forrest, and it says --
l 18 JUDGE COLE:
You mean September 19th, don't 19 you, Mr. Guild?
20 MR. GUILD:
That's what I meant to say, Judge, 21 September 19, 1984.
22 BY MR. GUILD:
23 0
"This is to reaffirm the Ceco position that first l
24 line visual weld inspection must be performed on welds
)
25 in the unpainted condition."
Sonntag Repor ting Se rvice, Ltd.
I, Geneva, Illinois 60134 (312) 232-0262
15745 7
l 1
's /
j 1
Again, it's not changing PTL's practice.
It's 2
simply confirming to PTL that Comstock is supposed to be 3
doing it in an unpainted condition; correct?
4 A
(WITNESS FORREST)
I don' t know if this memo has any 5
relationship to any Comstock documentation or any of 6
their practices.
7 Q
Well, it specifically relates to Comstock.
It says 8
tha t -- well, I guess it doesn't, does it?
9 A
(WITNESS FORREST)
No, it does not.
10 Q
It could be PTL's first line visual inspection --
11 A
(WITNESS FORREST)
That's what I was saying.
s
(
')
12 Q
-- because PTL was doing first line visual weld
's J 13 inspection, were they not?
14 A
(WITNESS FORREST)
Tha t's corr ect.
15 Q
You were doing some of Comstock's work?
16 A
(WITNESS FORR EST)
No, si r. Th ey --
17 Q
You were doing some of it, of Comstock's work?
18 A
(WITNESS FORREST)
Through paint, you mean?
19 Q
No, no.
20 You were doing some first line visual inspection of 21 Comstock's work to the extent --
22 A
(WITNESS FORREST)
Not during this time frame, no.
23 0
W ell, to the extent that you had people that were loaned 24 to Comstock to perform visual inspections as a first
/%
)
25 line inspector, they were doing first line inspection of Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
15746 s
1 Comstock's work?
2 A
(WITNESS FORREST)
Oh, okay, I understand.
3 Yes.
4 Q
All right; all right, sir.
5 Then following behind that document there is a 6
Janua ry, 1985, document.
7 Mr. Forrest, you were writing Mr. Quaka and you 8
transmit -- or you refer -- make reference to the D.
9 Brown November 30,
'81, authorization memo; correct?
10 A
(WITNESS FORRES T)
That is correct.
11 Q
And you ask for confirmation that the visual inspection
(
- 12 of welds by PTL of the Comstock work can continue in a N-.
13 painted condition?
i-14 A
(WITNESS FORREST)
That is correct.
15 Q
And he gave you that authorization.
16 Again, you asked him for a timely response in i
17 Janua ry, and Mr. -- or the CECO Q A, Mr. Quaka, didn't 18 respond directly, but Mr. Kunzmann of CECO QA responded 19 on March 19, 1985, and he told you for the time being s
20 you should keep it up?
l 21 A
(WITNESS FORREST)
That is correct.
l 22 Q
All right.
23 And you didn't finally change the practice until I
24 later in 1985?
Was it May or June of 1985?
l O
' ( )
25 A
(WITNESS FORREST)
June of 1985.
Sonntag Repor ting Se rvice, Ltd.
i Geneva, Illinois 60134 (312) 232-0262
15747' 1
l 1
MR. GUILD:
Mr. Chairman, I offer 2
Intervenors' 184 at this time.
3 JUDGE GROSSMAN:
Any objection?
4 MR. STEPTOE:
I think I may have an 5
objection, Judge Grossman.
Let me take a moment here.
6 I have no obj ection to the first page, Judge 7
G ro s sman, or to -- I do object to the pages AR2344, 8
2345, 2346, 2347 on grounds of relevance as it relates 9
to Comstock inspecting welds, and I have no objection to 10 the last three pages of this document.-
11 MR. GUILD:
Mr. Chairman, I guess there are
\\
t 12 two points in response.
13 Fi rs t, even as part of the PTL case, if the weld l
14 inspections were originally performed in a painted j
15 condition and then were overinspected, again, in a i
16 painted condition, that has an effect on the accuracy of 17 the res ults, f
18 Paint is paint is paint.
If the paint was on there i
19 two steps before, it has just as much of an impact on i
20 the accuracy of the results of the overinspection as it 21 did if it was on the second step.
22 More to the point, I think:
l l
23 This series of documents was only made available l
24 during the rebuttal discovery.
I only learned that 25 there was a document reflecting L.
K.
Comstock first l
f Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
._=
15748 s
L 1
line inspection through paint when these documents.were 2
made available in preparation for this panel's 3
tes timony.
4 I certainly -- when we had the extended discussion 5
about Mr. Hunter and inspection through paint, and I 6
tried to make reference to an NCR item of non-compliance 7
relating to another contractor, if I had known that 8
there were direct comments that showed that Comstock had i
9 inspected through paint, I certainly would have of fered 10 them at that time.
11 I learned of them only subsequent to that 12 testimony.
13 J UDG E G ROSSMAN :
Miss Chan, any obj ection?
14 MS. CHAN:
The Staff would like to note for 15 the record and request that the fourth page of 16 Intervenors' Exhibit 184, where it's stamped across the 17 center "For Reference Only," that that be admitted as an 18 in-camera document.
i 19 JUDG E G ROSSMAN:
I'm sorry.
l l
20 Pardon ?
21 MS. CH AN :
That that item be admitted as an r
l 22 in-camera document because it refers to a matter 23 currently under investigation by the Office of 24 Inves tiga tion.
25 JUDG E G ROSSMAN:
W ell, I don't see any basis Sonntag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
15749 l
1 for putting something in camera that is not confidential 2
on the basis of there being a confidential investigation 3
going on, so that doesn't seem to merit withholding the 4
docmnent.
4 5
Any other objection?
6 MS. CH AN:
No.
Other than that, the Staff 7
has no objections to Intervenors' 184.
8 J UDG E G ROSSMAN :
The obj ection's overruled.
9 We'll admit 184.
10 (The document was thereupon received into 11 evidence as Intervenors' Exhibit No.
O 12 184.)
13 BY MR. GUILD:
14 Q
Now, gentlemen -- I guess more particularly Mr. Frazier, 15 if you would turn to Page 9 of your testimony, your 16 prefiled testimony, where you discuss the practice of 17 inspection through paint.
18 MR. STEPTOE:
What page was that?
19 MR. GUILD:
Page 9 of the prefiled testimony.
}
20 BY MR. GUILD:
21 Q
Now, first of all, you state there, Mr. Fr az ie r, that i
22 PTL inspectors noted any weld that had been inspected i
23 through paint in the inspection form.
24 Now, I found a -- Mr. Corcoran seems to give that I
direction to the Comstock inspectors who did the first 25 Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
15750
(
)
N/
1 line of inspections through paint; that is, note in the 2
remarks section.
3 Is there any written procedure or directive from 4
PTL to its inspectors that when they inspected -- or 5
overinspected through paint, that such a notation be 6
made in the remarks section?
7 A
(WITNESS FR AZIER)
There was no written directive to 8
the inspectors to make those comments.
9 0
I see.
10 A
(WITNESS FR AZIER)
It was all verbal.
11 Q
I see.
All right, si r.
j 12 So you assumed that such a notation was made in all
- v 13 cases where the PTL overinspectors performed their 14 inspections through paint, and that's the basis for your 15 testimony at Page 9?
16 A
(WITNESS FR AZIER)
I have no reason to doubt that they 17 did not.
18 Q
All right, sir.
19 But you made that assumption, did you not?
20 A
(WITNESS FR AZIER)
Yes.
21 Q
All righ t, sir.
22 Now, then you make an estimate here that 7 percent 23 of the total welds overinspected by PTL of Comstock's 24 welds were overinspected in a painted condition, and you
,r'\\
(
i 25 make a reference to the fact that there were a review --
s_/
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
15751 g
\\_/
1 there was a review conducted of the PTL overinspection 2
checklists --
3 A
(WITNESS FR AZIER)
That is correct.
4 0
-- is that correct?
5 All right.
Now, did you count each of the 6
instances where it was indicated on that checklist in 7
the remarks section that a weld had been overinspected 8
through paint?
9 A
(WITNESS FR AZIER)
I believe that is correct, because 10 there were instances where, on one component, not all of 11 the welds would have been painted.
,M 12 Q
Right.
(x -)
13 A
(WITNESS FR AZ IER)
There could be some in a coated 14 condition, some uncoated.
15 Q
I guess that's one question.
16 My question is:
17 In all cases, did they -- did the PTL overinspector 18 indicate specifically which welds were overinspected in 19 a painted condition and which welds were not?
20 A
(WI TNESS FR AZIER)
Yes, th ey did.
21 Q
All right.
22 And how did they do that?
Did they give you a 23 weld number or --
24 A
(WITNESS FR AZ IER)
Yes, they did.
(J 25 0
And how did you know which welds those were?
H ow do Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
15752
(~
/
1 you know which welds those were, if'you do?
2 A
(WITNESS FR AZIER)
By the numbering system that the 3
inspector used.
4 Q
All righ t.
5 How do you know what weld that refers to on the 6
component ?
7 A
(WITNESS FR AZIER)
On the component itself ?
8 Q
Yes.
9 A
(WITNESS FR AZ IER)
Unless there was an unacceptable weld 10 on the component, there would not be a weld map drawn.
11 It would just indicate that the entire assembly had been
('
')
12 inspected.
\\_ /
13 Q
Yes.
14 A
(WITNESS FR AZIER)
The inspector would note the weld 15 identification in the field, such as A, B,
C or 16 something of that nature.
17 (In di ca ting. )
18 Q
All righ t, sir.
19 But you can't tell which particular weld it is f rom 20 looking at the PTL checklist?
21 A
(WITNESS FR AZ IER)
Not from looking at the checklist, 22 no.
23 Q
All righ t, sir.
24 And I take it that there's no unique identifier,
,a
( )
25 even in the field, tha t's necessarily presen t l
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
.15753
,c\\
I
)
%J l
identifying a particular weld to a particular PTL 2
checklist indication or notation, is there?
3 A
(WI TNESS FR AZIER)
That is correct, the details are not 4
enumerated in any way.
5 Q
All right, si r.
6 Now, so you counted the instances -- or you and 7
your people, I take it -- the reference here is, "Mr.
8 Forrest and I and personnel working for us reviewed our 9
inspection records. "
10 So you reviewed all your inspection records; is 11 that correct?
(s
\\_-}
12 A
(WITNESS FR AZIER)
All of our Comstock inspection
(
13 records.
14 Q
All right.
15 And you noted all the instances where the PTL 16 overinspector had noted a weld inspected in a painted 17 condition?
18 A
(WITNESS FR AZIER)
That is correct.
19 Q
And you counted those instances?
Did you count those 20 instances?
21 A
(WITNESS FR AZIER)
Yes, sir, we did.
22 0
Okay.
23 And how many total welds did you count that were 24 in di ca ted tha t yo u -- th a t yo u -- h ow m a ny of tho se
(,r8) 25 welds did you count had been indicated on the checklist Sonntag Reporting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
c
)
15754 7
(
)
N_/
1 as having been inspected in a painted condition? L 2
A (WITNESS FR AZIER)
I'm not sure of the exact number of 3
w elds.
4 I think --
5 A
(WITNESS FORREST)
I think it was the figure somewhere 6
around 1,500.
I'm not s ure.
Whatever 7 percent of 7
28,000 is.
8 (In di ca ting. )
9 Q
Okay.
10 Does :he -- and, in effect, does the 7 percent --
11 the approximate 7-percent figure represent an estimate?
I' )
12 A
(WITNESS FORREST)
No, it does not.
/
13 Q
Tha t's an exact coun t --
14 A
(WITNESS FORREST)
That is correct.
15 A
(WI TNESS FR AZ IER)
Tha t is correct.
16 0
-- of the instances where that was indicated on the 17 checklist that the inspection had been done through 18 paint?
19 A
(WITNESS FORRES T)
That's correct.
20 Q
All right, si r.
21 A
(WITNESS MARCUS)
Mr. Guild, I could add on this point 22 that we do have a tabulation of welds inspected through 23 paint similar to the Exhibit Attachment No. 2 in my 24 tes timo ny.
n
(
)
25 It's not in my testimony, but we did turn it over x
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0252
15755
,.. ~
i
\\
\\_)
1 as part of the document discovery.
2 Q
I see.
3 What does it tell us, Mr. Marcus?
4 A
(WITNESS MARCUS)
It's a computer runof f that shows by 5
months the welds -- the numbers of welds which were 6
inspected in the painted condition, the number of welds 7
which were inspected in the unpainted condition and the 8
agreement rates comparing both painted and unpainted.
9 0
I see.
All right, sir.
10 Now, the practice of painting -- accepting welds 11 through paint -- or overinspecting welds through paint (p) 12
-- let me be more precise -- was changed ultimately?
x_/
13 Af ter being in place for some five years for Comstock 14 overinspection, it was changed in June of 1985; is that 15 correct?
16 A
(WITNESS MARCUS)
That is correct.
17 Q
All right.
18 In June, 1985, I assume substantial -- a 19 substantial part of L.
K.
Comstock's weld inspection 20 work had already been performed and overinspected?
21 A
(WITNESS MARCUS)
That is correct.
22 0
What was the basis for eliminating the overinspection of 23 welds through paint in June of 1985, then ?
24 A
(WITNESS MARCUS)
Basically, in June of 1985, as you rh
(~s) 25 stated earlier, the program was changed to more directly Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262 1
15756
,r \\
k N/
1 assess an individual inspector's performance, and we 2
wanted to have the most accurate picture that we 3
possibly could have because we were reporting -- going 4
to begin reporting on an inspector basis as opposed to a 5
contractor basis.
6 Q
Okay, sir.
7 A
(WITNESS MARCUS)
So, in addition to eliminating the 8
ability of doing an overinspection through paint, we 9
also added the third-party overview to make sure that 10 the inspector had the benefit of a third-par ty judgment 11 regarding each rejection, (n) 12 Q
Yes, si r.
'LJ 13 And both those matters enhanced the accuracy of 14 overinspection, in your opinion?
15 A
(WITNESS MARCUS)
Yes, sir.
16 0
All right.
17 Now, Mr. Marcus, let's talk a li ttle bit about the 18 evalua tive testimony tha t you presented.
19 First of all, you identify Mr. Asmussen as an 20 inspector whose overinspection acceptance rate was 21 suf ficiently low that you have determined that it's 22 appropriate that certain follow-up actions be taken with 23 respect to the adequacy of his work?
24 A
(WITNESS MARCUS)
Tha t is correct.
/
\\
(
)
25 0
All righ t.
xs Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
15757 f^s
/
1 And wha t follow-up actions have been taken, si r, as 2
of today ?
3 A
(WITNESS MARCUS)
We did two things:
4 We advised Comstock about the performance of Mr.
5 Asmussen by way of letter, and also attached to that 6
letter indicated what his performance -- the history of 7
his QC inspection performance had been and apprising 8
them that we were going to watch his inspections more 9
closely and gather additional information from which we 10 would make judgments regarding any future actions, 11 In addition to that, we also instructed PTL to
)
12 perform a 50-percent overinspection on the future work
./
13 performed by Mr. Asmussen.
14 Q
All right, si r.
15 And what had been the results, if any, to date of 16 providing a closer watch of Mr. Asmussen's work?
17 A
(WITNESS MARCUS)
I j ust recently reviewed that data, 18 and there has been very little additional over -- first 19 line QC inspection which has been performed by Mr.
20 A smussen.
21 Q
In the welding area or at all?
22 A
(WITNESS MARCUS)
Tha t's correct.
j l
23 Q
In welding?
l l
24 A
(WITNESS MARCUS)
In welding.
)25 0
dkay.
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 l
(312) 232-0262 1
15758
(
)
N..J l
And I take it, then, insufficient information to 2
form any further opinion?
3 A
(WITNESS MARCUS)
That is correct.
4 Q
All right, sir.
5 Now, I take it that in the case of Mr. Asmussen, 6
the history was a history that was derived from the data 7
that you have acgaired for purposes of presenting this 8
rebuttal testimony and was not a history that was based 9
on data that was directly available to Comstock 10 management at the time it was acquired?
11 A
(WITNESS MARCUS)
That is correct, that the history (n) 12 which we're talking about was formulated during the
'y_.,l 13 preparation for this testimony.
14 Q
All right, si r.
I 15 Now, back in -- if you would look at your 16 attachment, please, to your testimony for Mr.
17 Asmussen --
18 MR. GUILD:
And, Mr. Chairman, Members of the 19 Board, there are these print-outs that are attached to l
20 the -- to this panel's testimony.
l 21 I'm looking at Bates Number AR 54.
I trust that 22 that same numbering system is on the Board's copies.
23 It's a table for Mr. Asmussen.
His name appears in l
24 the upper lef t-hand corner of the document, if you look (o) 25 at it lengthwise.
All right, m/
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
i
~
i 15759 OQ.
l BY MR. GUILD:
2 Q
Now, Mr. Asmussen's overall agreement rate was 73.73 3
per cen t --
4 A
(WITNESS MARCUS)
That is correct.
5 0
-- for the period in question?
6 That was for beginning June of '84 through April of 7
'86?
8 A
(WITNESS MARCUS)
Yes, sir.
9 Q
All right.
.10 Now, Mr. Asmussen's agreement rate was only 75 11 percent in June of '84 -- or is that a 73?
a[ )
12 I guess it's 73.
These computer numbers always
'13 phase me.
14 Is that 73?
15 A
(WITNESS MARCUS)
Yes, sir, in June of '84, the 16 agreement rate was 75 percent --
17 0
75.
Okay.
18 A
(WITNESS MARCUS)
-- on the basis of a total 19 overinspection of 4 welds.
20 0
All right.
21 And in July of '84, it was 73.91 percent on the 22 basis of an overinspection of 69 welds; correct?
23 A
(WITNESS MARCUS)
That's correct.
24 0
And in September of -- well, in August, 75 percent f or 25 6 8 welds, and in September, 72.73 percent for 33 welds, l
~
4 Sonntag Repor ting Se rvice, Ltd.
Geneva,. Illinois 60134 (312) 232-0262
15760 p-i
%,,/
1 all 1984 results?
2 A
(WITNESS MARCUS)
That is correct.
3 Q
All right.
4 Well, now, if these were of weld inspections 5
performed by Mr. Asmussen back in 1984, do you know 6
whether or not L.
K.
Comstock management took any action 7
with respect to Mr. Asmussen's work performance at the 8
time he was performing the work?
9 A
(WITNESS MARCUS)
I do not.
10 Q
Do you know whether or not they had any knowledge of Mr.
11 Asmussen's acceptance rates until you told them about
[ )
12 that af ter you had aoguired the data in preparation for U
13 your testimony?
14 A
(WITNESS MARCUS)
I do not.
15 0
All right, si r.
16 Now, let me ask about another couple of inspectors.
17 You talk in your testimony about two other 18 inspectors whose agreement rates as calculated the 19 way -- based on PTL data, were below the acceptance 20 criteria of 90 percent, even after you eliminated their 21 lowest mon th, and that's Messrs. Lesh and Stout; 22 correct?
23 A
(WITNESS MARCUS)
Yes, I examined their agreement 24 rates.
/'N (na) 25 0
All right, sir.
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
1 15761
\\
}
w/
1 Now, if I could ask you to turn to the results for 2
Mr. Lech, L-E-S-H -- that's AR 102 -- do you have that, 3
sir ?
4 A
(WITNESS MARCUS)
Yes, sir.
5 Q
Okay.
6 Now, Mr. Lesh had an overall agreement rate 7
uncorrected of 84.13 percent; correct?
8 A
(WITNESS MARCUS)
That is correct.
9 Q
All right.
10 Now, from the very beginning of his overinspection 11 results, August, ' 83, he was below -- he exhibited an
[
')
12 agreement rate below the acceptance criteria of 90
'O' 13 per cent?
14 That month he had 81.82 percent?
15 A
(WITNESS MARCUS)
That is correct.
16 Q
All right.
17 Again, in October of '83, he exhibited an 18 unacceptable rate of -- or one below the acceptance 19 criteria, I mean, of 75 percent; correct?
20 A
(WITNESS MARCUS)
In October of 1983, his agreement 21 rate was 75 percent, that's correct.
22 0
Yes.
23 And in November of ' 83, it was 72.41 percent?
24 A
(WITNESS MARCUS)
Yes, si r, based on the total l (M l
t
)
25 population of 29 welds, i
l l
Sonntag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 l
(312) 232-0262
1 15762 rx e
1 Q
Okay.
2 March, ' 84, based on only.10 welds, he bounced back 3
to 100 percent?
4 A
(WITNESS MARCUS)
Yes, sir.
5 Q
All righ t.
6 Now, there appears to be a gap of several months 7
where Mr. Lesh either wasn't overinspecting or didn't 8
. perform weld inspection.
9 Do you know which it was?
10 A
(WITNESS MARCUS)
I do not.
11 Q
Okay.
())
[
12 Does anybody else on the panel know the answer to 13 that question?
14 A
(WITNESS FORREST)
No, I do not.
15 A
(WITNESS D' ANTONIO)
No, si r.
16 A
(WITNESS FRAZIER)
No.
17 Q
Now, do you know whether or not any action was taken 18 with respect to Mr. Lesh's work performance on the basis 19 of his over -- of his inspection activities back in i
20 August of 1983?
c
^
21 A
(WITNESS MARCUS)
No, si r, I do not.
22 Q
How about based on any action taken based on his 23 inspection activities for the months of October and 24 Nov embe r, 1983?
25 A
(WITNESS MARCUS)
No, si r, I do not.
l
{
l Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
r 15763
,~
.i
/
' s' 1
Q Okay.
2 Now, your --
3 A
(WITNESS FORREST)
Could I add something, please ?
4 0
Yes, please, s ur e.
5 A
(WITNESS FORREST)
Comstock is given a copy of all of 6
our ove rview Inspection Reports.
7 Q
Right.
8 But they don' t have inspectors' names on them --
9 th ey didn' t a t th e time prior t o --
10 A
(WITNESS FORREST)
No, they did not.
11 0
Th ey did no t.
All right.
[ ')
12 Now, you state in your testimony, Mr. Marcus, at 1._/
13 Page 22, that Mr. Lesh was terminated subsequently in 14 April of 1984; correct?
15 A
(WITNESS M ARCUS)
Yes, sir.
16 0
All righ t.
17 Now, what was the grounds for terminating Mr. Lesh 18 a t tha t time ?
19 A
(WITNESS MARCUS)
I don' t know what the grounds were.
i 20 I took that off of the records which showed the 21 certification dates and termination dates, and the 22 reasons for termina tion are not shown, i
l 23 0
I see.
l 24 Do you have any knowledge of whether Mr. Lesh was l
l'%
25 terminated because of adverse inspection work (v) l l
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
15764
- n
~
t i
V
{
l pe rforman ce ?
2' A
(WITNESS MARCUS)
No, sir, I do not.
3 0-All right.
4 The other gentleman whose score came below the 5
90-percent threshold, even when you eliminated his 6-lowest monthly acceptance. rate, was Mr. Stout, Mr.
7 He rs ch el S to ut.
?
8 Would you refer to Mr. Stout's results, please ?
9 Th ey appea r a t AR 139.
10 A
. (WITNESS MARCUS)
Yes, sir, I have it.
11 Q
All right, si r.
(
12 Now, Mr. Stout's overall acceptance rate was 83.9 l
13 pe r cen t -- 83.09 per cent; correct?
}
14 A
(WITNESS MARCUS)
That is correct.
I 15 0
All right.
16 Mr. Stout exhibited below acceptable agreement l
17 rate -- tha t is, below your 90 percent acceptance 18 criteria -- for welding in the month of June, 1984; 19 correct?
l l
20 A
(WITNESS MARCUS)
Yes, in June of 1984, his agreement 21 rate was 71.79 percent.
22 0
All right.
23 In October,
'84, his agreement rate was 84.62 24 percent; correct?
)
25 A
(WITNESS MARCUS)
That's correct.
I Sonntag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 4
(312) 232-0262
15765 f-)
-t
\\
,)
1 Q
And in February of '85, his agreement rate was 0?
Ther e 2
were eight welds inspected, and they were all found to 3
be r ej ecta ble ?
4 A
(WITNESS MARCUS)
Yes, sir.
5 Q
All right.
6 Now, do you know whether or not any action was 7
taken by Comstock management with respect to Mr. Stout's 8
work performance -- that is, the accuracy of his quality 9
control inspections -- during the period -- for the 10 period of June, 1984?
11 A
(WITNESS MARCUS)
I do no t.
12 Q
Okay.
C, 13 Is your answer the same for the periods -- other 14 periods where his rate was below the 90 percent 15 acceptance?
16 A
(WITNESS MARCUS)
Yes, si r.
17 Q
All right.
18 Now, do you know if any action was taken against 19 Mr. Stout for the adequacy of his quality control 20 inspection work performance?
21 A
(WITNESS MARCUS)
I do not.
22 But I do know that some of the rejects which are 23 listed in this analysis have been subjected to 24 subsequent third-party review and have been determined
(%.
25 to be acceptable, gw Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
15766 m
1 Q
I see.
2 So Mr. Stout's rates went up?
3 A
(WITNESS MARCUS)
Yes, si r.
4
-Q Do you know what they went up to, based on the ' third 5
par ty's r eview ?
6 A
(JITNESS MARCUS)
I ' don' t have all the results of the 7
third par ty's r eview, but I know that at least five of 8
the rej ects were overridden by the third party.
9 Q
Five for what period; do you know?
10 JUDGE COLE:
Isn't that shown on the page, 11 sir, on Mr. Stout's Page 139?
12 MR. GUILD:
I see an overridden agreement 13 rate.
14 A
(WITNESS MARCUS)
I have some notes that I used in 15 summarizing and analyzing the data, and I show an 16 additional 5.
So I believe that I've.got a report that 17 shows an additional 5.
18 I could be in error, but I believe so.
19 BY MR. GUILD:
20 0
Well, sir, his original agreement was 79.41 percent, but 21 tha t, after overrides, it went up to 83.09, but I've 22 been discussing the overridden rate.
23 Wouldn't that already include any counting for 24 third-party overviews?
25 A
(WITNESS MARCUS)
I'd like to correct what I said.
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
15767 7 s
(
)
%./
1 I think what I did here now, as I look at the 2
arithmetic, I take into account the override and I 3
subtract the one month where he had his lowest 4
performance.
Then I end up with an agreement rate of 5
8 8.2 8 percent.
6 Q
I see.
7 A
(WITNESS MARCUS)
That's what it shows.
8 Q
All right.
9 That's with the overridden rates?
10 A
(WITNESS MARCUS)
Yes, si r,
11 Q
Understood.
All right.
[
12 Now, let's take the case of -- one other case, and V
13 that is for the present L.
K.
Comstock Quality Control 14 Manager, Mr. DeWald.
15 You don't have any data displayed in your testimony 16 for Mr. dew ald, do you?
17 A
(WITNESS MARCUS)
That's correct.
18 Q
And why is that?
19 A
(WITNESS MARCUS)
I do not.
20 I do n' t kn ow that I can answer that question 21 directly.
22 Whether -- maybe Mr. Forrest --
23 Q
Sure.
24 A
(WITNESS PO RRES T)
I don't believe Mr. DeWald was i
!s
)
25 performing field inspections during the period that this l
L/
i I
l Sonntag Repor ting Service, Ltd.
l Geneva, Illinois 60134 (312) 232-0262
15768 i
1 data base represents.
2 0
In other words,-Mr. DeWald had no field inspections in f
3 or after June of 1982, when your data base begins?
4 A
(WITNESS FORREST)
July of '82.
i 5
Q July of ' 82 ?
2 6
A (WITNESS FORREST)
No, we do not have any overview 7
results on Mr. DeWald after July of 1982.
1 i
8 Q
All righ t.
9 Well, do you know whether or not'Mr. DeWald did any 10 field inspections at Comstock after July of 1982?
I 11 A
(WITNESS' FORREST)
I do not know.
12 (In dica ting. )
{
13 0
But, in any event, there are -- there is no -- no data 14 on Mr. DeWald ?
15 A
(WITNESS FORREST)
That is correct.
16 Q
Was data -- I assume there were overinspections 17 performed of Mr. DeWald's first-line QC inspections f
l 18 before July of 1982?
19 A
(WITNESS FORREST)
I believe we do have some on him, i'
20 yes.
21 Q
And do you know what Mr. DeWald's agreement rate is for
{
22 any period when you have overinspections of Mr. DeWald's l
23 work?
i 24 A
(WITNESS FORREST)
No, I do not.
25 Q
Does anybody else on the panel know the answer to that j
i f
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 i
(312) 232-0262
i.
15769 O
1 question?
i 2
A (WITNESS MARCUS)
I do not.
3 A
(WITNESS ' D' ANTONIO)
No, sir.
4 A
(WITNESS FR AZIER)
No, sir.
5 Q
Has that data been acquired?
Is there such data?
6 A
(WITNESS MARCUS)
We did not go back prior to July of I
7 1982 in assembling the data for analysis as we did for 8
this four-year period.
9 Q
All right, sir.
10 so other than the raw inspection reports from Mr.
11 DeWald, there are no assembled data showing -- from j
12 which you could derive his acceptance -- agreement rate?
l 13 Excuse me.
i 14 A
(WITNESS MARCUS)
That's correct, it's not readily at our fingertips; but the same type of analysis as we did 15 I
16 here certainly could have been done for prior to July of 17 1982.
18 0
Right.
19 It simply wasn' t done ?
20 A
(WITNESS MARCUS)
Tha t is correct.
21 Q
Understood, all right.
22 Finally, let's talk about one other case, and that i.
23 is the case of Mr. Rick Martin.
i 24 You do have some data on Mr. Mar tin, do you not?
)25 A
(WITNESS MARCUS)
Yes, sir.
Sonntag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
\\
15770 4
l Q
All right.
2 Now, Mr. Martin -appears at Page AR 107 of your 3
attachment, gen tlemen.
Mr. Martin's data extends from 4
J uly, 1982, through October of 1983.
5 Now, I take it that's indicative of the fact that f'
6 you performed no welding overinspections for Mr. Martin 7
after that period; is that correct?
8 A
(WITNESS MARCUS)
That is correct.
9 0
All right.
10 Do you know whether or not Mr. Martin performed any l
11 first-level welding quality control inspections after 12 the period shown in your table?
i 13 A
(WITNESS MARCUS)
After October of 19837 i
14 Q
Yes.
4 15 A
(WITNESS MARCUS)
I don't believe that he did, i
16 Q
All right, si r.
17 Now, Mr. Martin exhibits an overall agreement rate 1
18 in excess of your acceptance criteria.
His rate overall 19 is 92.4 8 percent.
l 20 A
(WITNESS MARCUS)
Yes, si r.
21 Q
All right.
T 22 And Mr. Martin's case, therefore, does not fall 23 into any of the three categories of adverse data or 24 adverse results that were subj ect to your analysis, Mr.
i j(
25 Marcus; correct?
Sonntag Reporting Service, Ltd.
1 Geneva, Illinois 60134 l
(312) 232-0262
i 15771 pb 1
A (WITNESS MARCUS)
That is correct.
2 Q
All right.
3 Mr. Martin has a couple of months that go below 4
your acceptance criteria.
He has the months -- for the 5
month of March,-'83, he's j ust a shade below at 89.11 6
percent for 101 welds; correct?
7 A
(WITNESS MARCUS)
Yes, sir, that's correct.
8 Q
All right.
9 For the month of June,1983, he's quit a bit below 10 at 64.71 percent, 24 welds ?
4 11 A
(WITNESS MARCUS)
Yes, sir.
12 0
All right.
'%d 13 And he's a shade below, just a shade, for the month 14 of September, 19 83, where he gets 87.69 percent?
I 15 A
(WITNESS MARCUS)
Yes, sir.
16 Q
All right.
i 17 Now, do you know whether or not Mr. Rick Martin was i
18 ever -- whether or not any action was ever taken by L.
i 19 K.
Comstock management with respect to Mr. Martin 20 because of inadequacies in his first-line quality 21 control weld inspection?
l 22 A
(WITNESS MARCUS)
Yes, si r, there were actions taken.
i 23 0
And what actions were those, Mr. Marcus, as you
{
24 understand them?
i
(
25 A
(WITNESS MARCUS)
Well, in early -- in mid-1982, I f
Sonntag Repor ting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
15772 t
v 1
believe there were some overinspections which were 2
performed on Mr. Martin's work -- I believe it was in 3
June of 1982 -- and Comstock had performed an analysis 4
or at least was aware of the -- Mr. Ma r tin's 5
pe rf orman ce.
6 On the basis of a f airly high rej ection rate, a 7
group of reports in June of ' 82, his certification as a 8
Welding Inspector was withdrawn.
9 Q
And he subsequently got it back and performed 10 inspections in August,
'82, January, February, Ma rch, 11 A pr il, May, June, J uly, Augus t, September, October, 12 1983?
LJ 13 A
(WITNESS MARCUS)
Yes.
There's a whole sequence of 14 events with Mr. Mar tin.
15 But, yes, he did receive his certification back, I 16 believe, in December of 1982.
17 Q
All righ t, sir.
18 Well, for the months before your data base is 19 displayed here -- and that is, f r om the months bef ore --
20 using the same methodology that you employed here -- do 21 you know what Mr. Mar tin's agreement rates were?
22 A
(WITNESS MARCUS)
I do not have the agreement rates;,
23 but there was a review of reports for June of 1982; and 24 on the basis of a -- of a number of those reports, there A(J}
25 was a fairly sizable number of rejects which were Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
1 15773 DV 1
assigned to Mr. Martin.
2
'O Okay, sir.
Well, that all is a little bit mushy because 3
you are talking about some reports and high reject -rates 4
in those reports.
5 But what I'm trying to ask f or -- to control--- for 6
Mr. Martin, using the same data base and methodology 7
approach used in acquiring this data and using all the 8
overinspections for the period, can you tell me what Mr.
9 Martin's acceptance rate for any of those periods were 10 that were the basis, as you understand it, for taking 11
~ action against him to lift his certs?
[J')
12 A
(WITNESS MARCUS)
No, si r, I cannot.
13 0
It was Comstock who took the action in July of 19827 14 A
(WITNESS MARCUS)
Yes, si r.
15 Q
Do you know-whether or not the period -- for the periods 16 on which Comstock management relied, Mr. Martin's 17 agreement rates, in fact, were in excess of the 18 90-percent threshold that you have used as an acceptance l
19 criteria for weld inspecting?
l 20 A
(NITNESS MARCUS)
I do not know the basis which 21 Comstock tsed in withdrawing his certification in July 22 of '82.
l 23 0
Right.
I understand that.
24 And I guess you also don't know whether or not his 25 results for those periods was above 90 percent; is that y
I Sonntag Reporting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
15774 g!
i
\\- /
1 right?
2 A
(WITNESS MARCUS)
I do not.
I just know that there are 3
a number of reports with a sizable number of rejects.
4 Q
All right.
5 But when you take all of his results on average for 6
that period, it may have been over 90 percent, it may 7
have below 90 percent; you simply don' t know?
8 A
(WITNESS MARCUS)
I do not know, tha t's correct.
9 0
Okay.
10 Now, October of '83 is when Mr. Martin's weld 11 inspection data stops.
[/')
12 And I take it, as we've agreed, that sometimes to
\\_.
13 imply that there were no overinspections establishes 14 there were no overinspections for Mr. Martin af ter that 15 date, and implies that he didn't do any first-line 16 welding inspection for Comstock; correct?
17 A
(WITNESS MARCUS)
That is correct.
18 0
All right.
39 Now, Mr. Martin's last result was 100 percent for 20
- October,
'83, and his overall rate since he was doing 21 weld inspection was 92.4 8 percent.
22 Do you know on what basis Mr. Martin stopped 23 performing weld inspections?
24 A
(WITNESS MARCUS)
Yes, si r, 1 do.
(m) 25 0
Okay.
x,/
l Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
15775
,/-
)
%./
1 Did it have -- was it based on this agreement rate 2
for his -- on his PTL agreement rate?
3 A
(WITNESS MARCUS)
No, si r, it was not.
4 0
Was it based on the accuracy of his weld inspections?
5 A
(WITNESS MARCUS)
Pa r tly.
6 0
In what respect do you understand that Mr. Martin's --
7 the fact that Mr. Martin did not continue to perform 8
weld inspection was based on his inspection accuracy?
9 A
(WITNESS MARCUS)
Yes, sir, in September of 1983, we 10 conducted a General Office Audit at the Braidwood site, 11 an audit which I managed; and in that audit 9 findings
[m 12 were identified against Comstock.
N_
13 3 of those 9 findings were associated with Mr.
14 Martin's performance.
One of the findings was that he 15 was photocopying inspection reports and signing off 16 af ter the work was completed.
17 0
Yes.
18 A
(WITNESS MARCUS)
So it was a work practice problem 19 which we had with that at that point.
20 0
All right.
21 How about the other two practices associated with 22 Mr. Martin aside from the checklist issue?
23 A
(WITNESS MARCUS)
Another finding dealt with a review 24 of inspections in the field that he had performed, and i
(A) 25 it was found by our audit team that a number of the x_-
Sonntag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
l 15776
/T Q,]
1 hangers with welds which he had accepted were judged to 4
2 be unacceptable, so he had an unacceptable work 3
perf ormance in the field.
4 0
All right.
5 How about the third item, audit finding, associated 6
with Mr. Martin?
7 A
(WITNESS MARCUS)
The third finding that dealt with Mr.
8 Martin -- he was performing inspections during a time 9
period that he was not certified to be working.
10 0
After his certs had been pulled earlier, July of '82, as 11 you stated?
(
12 A
(WITNESS MARCUS)
Yes, si r.
v 13 0
All right.
14 A
(WITNESS MARCUS)
That was the basis for Comstock 15 withdrawing his certification on October 5, 19 83.
16 0
All right, sir.
Well, let's look at that a moment now.
17 One of those items you did state was -- one of 18 those audit items associated with Mr. Martin, which you 19 understand was the basis for Comstock management action 20 taking him of f weld inspection, was, indeed, associated 21 with his inspections in the field, the unacceptable 22 condition of some hangers that he had performed 23 inspections on.
24 Now, let's look at Mr. Martin's da ta base here.
O )
25
(
Can you tell me where those unacceptable hangers Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
15777 O
1 appear in the PTL overinspection results for Mr. Martin?
2 A
(WITNESS MARCUS)
I can't identify where they appear in 3
the overinspection results, but in the audit reports, 4
the hangers are identified.
5 Q
Do you know whether or not PTL, in fact, did find the 6
unacceptable conditions that you state were, in part, 7
the basis for Mr. Martin being removed from weld 8
inspection?
9 A
(WITNESS MARCUS)
I do not know if those hangers were 10 included as part of the PTL overinspection.
11 Q
All right, sir.
[J) 12 But, in any event, whatever it was about Mr.
13 Mar tin's field inspection activities -- that is, the 14 unacceptable character of his field inspection 15 activities -- that resulted ultimately in him being 16 pulled off of weld inspection, you have no knowledge of 17 whether PTL's overinspection results played any par t of 18 that basis?
19 A
(WITNESS MARCUS)
Could you repeat the question, 20 please ?
21 Q
Yes.
22 It's the general office audit findings that were 23 the basis for the conclusions about Mr. Mar tin, and you 24 have no knowledge of whether the PTL overinspection (O )
25 findings had any basis -- formed any basis for Mr.
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
15778
(~N, V
1 Martin being pulled from weld inspection?
2 A
(WITNESS MARCUS)
That's correct, for the time that he 3
was decertified in 19 83.
4 0
Yes.
Understood.
5 MR. GUILD:
Mr. Chairman, that concludes my 6
questions of the panel.
7 JUDG E GROSSMAN:
Miss Chan.
8 MS. CHAN:
May I have about five minutes, 9
please ?
10 JUDG E GROSSMAN:
- Okay, 11 (W HER EU PON, a recess was had, after which
[ )
12 the proceedings were resumed as follows:)
'J 13 JUDG E GROSSMAN:
Miss Chan.
14 CROSS EXAMINATION 15 BY MS. CHAN:
16 0
Gentl emen, I'd like to refer your attention back to 17 Intervenors' Exhibit 182, which is a collection of memos 18 concerning the sample expansion f rom 10 to 25 percent; 19 and it was testified that this change was discussed with 20 the NRC prior to its implementation.
21 Can you tell me who you consulted in the NRC?
22 A
(WITNESS D' ANTONIO)
I think you are confusing the 23 escalation to a goal of 25 percent with this December 24 29, 1980, memo.
25 0
All right.
N. s Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
)
15779 1
I believe there was a discussion, though, prior 2
to --
3 A
(WITNESS D' ANTONIO)
That's correct.
4 0
-- the change.
i 1
5 A
(WITNESS D' ANTONIO)
I believe Mr. Marcus addressed i
6 tha t.
7 A
(WITNESS MARCUS)
That's -- I'm not -- I'm not clear.
8 Could you repeat your question, please ?
9 0
Okay.
10 Can you tell me who in the NRC was consulted prior 11 to the changes in the sample size?
(
12 A
(WITNESS MARCUS)
Prior to changes in the sample size?
13 0
Right.
14 A
(WITNESS MARCUS)
I don' t -- I don' t believe that I made any statements regarding consultation with the NRC 15 j
16 when we changed sample size, 17 The statement that we made is that in March of i
i 18 1984, when we had the enforcement conference at the NRC, 4
i 19 it was discussed with the Staf f that we were enhancing i
20 our overall quality assurance program.
21 One of those enhancements was to try to achieve a j
22 goal of 25 percent overinspection.
That was the 23 discussion that we had.
24 0
Was that the only time that any of the changes in the i
25 sample size was discussed with the NRC?
^
,\\
x Sonntag Reporting Service, Ltd.
1 Geneva, Illinois 60134 (312) 232-0262
15780 4
1 A
(WITNESS MARCUS)
To my knowledge,.it was, yes.
2 Q
Regarding the suspensions in PTL overinspections, were i
3 any of those discussed with the NRC at the time they i
4 were imposed or prior to thei'r imposition?
5 A
(WITNESS MARCUS)
I do not know ' that those discussions 6
took place.
7 0
Is there anyone else on the panel who knows?
8 A
(WITNESS D' ANTONIO)
No.
9 A
(WITNESS. FO RREST)
No.
10 A
(WITNESS ~ FR AZIER)
No, 11 MS. CH AN :
I =have no further questions at this 12 tim e.
13 J UDG E G ROSSMAN :
'I havs j ust one or two.
14 BOARD EXAMINATION.
15 BY J UDG E G ROSSMAN :
1 6
1' 16 Q
Mr. Marcus, no one ever asked you to do any calculations j
17 or overviews of Mr. DeWald's work?
I 18 A
(WITNESS MARCUS)
No, si r.
19 Q
With regard to the question of overinspecting through 20 paint, was there ever a PTL checklist that included an l
21-item that required indicating inspection through paint, 22 Mr. Forrest or Mr. Franier?
23 A
(WITNESS FORREST)
I don' t quite understand your i
j 24 question, Judge.
l 25 (Indicating.)
Sonntag Repor ting Service, Ltd.'
l Geneva, Illinois' 60134 (312) 232-0262
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15781 4
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NJ 1
A (WITNESS FR AZIER)
No, si r, there was not.
We did not 2
have a formulated checklist that would have had the weld 3
painted.
4 (Indica ting. )
5 That particular attribute would not have been 6
spelled out on the checklist.
7 0
Was there any written procedure that required that?
l 8
A (WITNESS FR AZ IER)
That required that that attribute be 9
identified in the checklist?
l 10 Q
Yes.
11 A
(WITNESS FRAZIER)
Not specifically, no.
12 Our instruction sheet did not dictate that that one 13 attribute be spelled out.
14 (Indica ting.)
I 15 Q
So you merely assumed, then, that where that was not
'j 16 specified on the checklist, that the welds were not 17 inspected through paint?
18 A
(WITNESS FORREST)
Essentially, yes.
19 But it was our practice during those periods of 20 time, you know, in going through our data base in 21 compiling thia and identifying all those welds that 22 were, indeed, noted as inspected through pain t -- it was 23 consistent with all of our inspectors; you know, a very 24 high confidence that where they did come across welds 25 that were, indeed, in a painted condition, that it was Sonntag Repor ting Service, Ltd.
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Geneva, Illinois 60134 (312) 232-0262
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duly noted on their Inspection Report.
That was our 2
practice.
3 (In di ca ting. )
- 4 For one thing, there was no reason for them not to, 5
because we had given them directions to do so.
6 0
Not written directions?
7 A
09ITNESS FORREST)
Not written direction.
8 0
Well, how can you be sure that overinspectors didn' t 9
merely note that they inspected through paint when they 10 encountered some particular problem that they wished to 11 point out, rather than in the normal situations?
/m 12 Is there any way that you know that?
V) 13 A
01ITNESS FORREST)
I can't specifically say that; but, 14 here again, I don' t have any reason to believe that they 15 didn't.
16 For the purpose of our program, the overview da ta 17 generally speaking, most of the attributes that can 18 be -- that you -- during the inspection process, most of 19 the attributes can be determined through a painted f.,
20 condi tion :
Siz e, length, you know, gross-type def ects.
21 (In di ca ting. )
22 0
Well, that's consistent with what I'm suggesting now.
23 Isn' t it very possible and probable tha t when an 24 overinspector inspected through paint and thought that
(/n) the condition would allow him to make a fairly complete 25 w
Sonntag Reporting Service, Ltd.
Gen eva, Illinois 60134 (312) 232-0262
15783 l,-)
v 1
ins pe ctio n, that he would not note it on the Inspection 2
Report?
3 A
(WITNESS FRAZIER)
No.
4 A
(WITNESS FORREST)
Well, no.
5 If -- you know, if he inspected the weld in the 6
painted condition, he would have so noted it on his 7
repor t.
There would --
8 0
Okay.
That's your opinion on that.
That's fine.
9 Now, let me ask you:
10 Which of the two of you, Mr. Forrest or Mr.
11 Frazier, is most f amiliar with the actual mechanics of
[ 'i 12 inspection?
Are you both?
13 A
(WITNESS FORREST)
I think Mr. Frazier would be more.
14 Q
Okay, Mr. Fraz ier, 15 We've talked about incompetent inspectors or those 16 who have a lower than normal rejection rate, so to 17 speak, and we've even mentioned the names of one or two 18 ins pectors.
19 What types of errors do these incompetent 20 inspectors generally make with regard to visual weld 21 inspe ctions ?
22 A
(WITNESS FR AZ IER)
Well, Judge Grossman, I cannot 23 typify a specific area.
It could be -- one inspector 24 could be weak in one area and strong in another area.
(~%
25 Q
Okay.
Let me make my question a little more specific.
in/
Sonntag Reporting Service, Ltd.
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1 P
1 Are there welds that are more _ difficult to inspect l
2 than other welds or conditions that are more difficult 3
to determine than other conditions?
4 A
(WITNESS FRAZIER)
Some conditions would require a 5
little more scrutiny than others, such as incomplete l
6 fusion.
t 4
7 You might have to look a little harder to see that, 1
8 as opposed to, you know, excessive convexity or i
9 excessive concavity or weld attribute.
l 10 Q
Okay.
You say "more scrutiny."
j 11 But how about more competence?
Do some welds l
l 12 require -- or some conditions require more competence to 13 determine than other conditions; that is, defective l
14 conditions ?
15 A
(WITNESS FR AZ IER)
I would not say, you know, more 16 com peten ce.
17 Q
Well, let's put it this way:
1 18 If you had an inspector who was somewhat 19 incompetent, and let's say that would be reflected in a 2
20 rejection rate of 30 percent rather than the 10 percent t
1 21 guidelines, would you anticipate or expect that, if you 22 sent him out to view welds that were in generally --
23 well, if you sent him out to view a certain set of welds 24 on Day 1, and then on Day 2 sent him out to view other j
25 welds performed by another welder, another type of 2
Sonntag Reporting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262 4
15785 3
1 1
installation, would you expect that he would have the 2
same type of rejection rate for both types of welds?
3 A
(WITNESS FR AZIER)
Yes, sir, I believe that would be --
4 0
Okay.
5 What if they were all simple welds to view?
j 6
Let's say they were all acceptable and clean and in 1
7 an accessible place.
8 Would you expect his rejection rate to be at 70 1
9 percent or would you believe that in those conditions, 10 his rate would go up?
11 A
(WITNESS FR AZIER)
I don' t believe the accessibility of 2
.s 12 the weld would be a determining f actor.
I mean, once i
13 you get to a weld and perform your inspection, i t' s --
14 you know, i t' s --
15 Q
Okay.
I 16 How about the condition of the weld:
17
- Do you consider that the condition of the weld 18 would be a determining f actor as to whether a competent
{
19 versus an incompetent inspector would be able to make 20 the correct judgment call?
1 21-A (WITNESS FR AZIER)
As far as " condition," you are 22 referring to the profile of the weld or --
23 Q
The observable conditions of the weld, the observable 24 conditions of any defect in the weld.
(O l
25 Would you expect that that would have an influence j
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15786 r'x
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1 upon the correct calls that a competent versus an 2
incompetent inspector would make?
3 A
(WITNESS FR AZIER)
I'm sorry, si r.
4 Would you repeat that question for me, please ?
5 0
W ell, I can have it repeated, but I'll rephrase it.
6 In your opinion, would the type of discrepant 7
conditions in a weld have any bearing on whether an 8
incompetent inspector would be likely to miss that 9
condition or determine the correct condition of the 10 weld ?
11 A
(WITNESS FR AZIER)
Yes, sir, that could be the case.
,m )
12 He could misinterpret one condition for another.
\\J' 13 0
Would that have some influence as to whether -- that is, 14 the condition of the weld -- have some influence on 15 whether an incompetent versus a competent inspector 16 would make the correct call?
17 In other words, is that a significant factor?
18 Do you follow that question?
19 A
(WITNESS FR AZIER)
Yes, sir.
20 Q
And your answer is yes or you --
21 A
(WITNESS FR TZ IER)
Yes, I agree.
22 Q
Okay.
23 Would you expect that two incompetent inspectors, 24 viewing the same difficult weld, j us t th e f act tha t th ey
)
25 are generally less than competent, without knowing any Sonntag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
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15787
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v 1
particular area of incompetent -- would you expect that 2
in viewing a difficult weld, both incompetent inspectors 3
would miss the same kind of defect?
1 4
A (WITNESS FR AZ IER)
I don' t think you could make that 5
statement, your Honor.
[
i 6
It would -- it would depend on the individuals 7
themselves and what area their weakness was in.
1 8
Q Okay.
9 You don't think that there's any generic kind of 10 defect that a less competent inspector would be likely f
11 to miss?
i 12 A
(WITNESS FR AZ IER)
No, your Honor, I do not.
13 JUDGE GROSSMAN:
Okay, fine.
14 I have no further questions 15 Oh, I'm sorry.
16 JUDG E COLE:
Yes.
l 17 BOARD EXAMINATION l
18 BY J UDG E COLE:
i l
19 Q
Just one or two questions, gentlemen.
1
[
20 I believe this probably would be best answered by i
21 Mr. Forrest, but if you want to add something to it, 22 please don' t hesitate.
l 23 Mr. Forrest, with respect to PTL overinspection of 24 Comstock welding work particularly, how was PTL notified
(
25 when an item was ready for inspection?
l Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 2
(312) 232-0262
15788 U
1 A
(WITNESS FORREST)
We received an inspection request 2
from Comstock.
3 (Indica ting.)
4 Q
All right, sir.
5 Do you know when Comstock would send that 6
inspection request to you with respect to whether the 7
item was acceptable f rom Comstock's viewpoint or whether 8
it had just been accepted inspected, whether there were 9
rej ectable items on that or not?
10 A
(WITNESS FORR EST)
No.
If -- as an example, if the 11 Comstock inspector went out and rej ected an assembly for
,-.1
(
)
12 whatever reason, it would not be submitted to PTL.
We
'w) 13 only received copies of their acceptable inspection 14 reports.
15 (Indicating.)
16 Q
All right, si r.
17 So when a PTL overinspector went out into the 18 field, he would inspect only welds that had been passed 19 on as acceptable by Comstock Quality Control Inspectors?
20 A
(WITNESS FORREST)
That is correct.
21 Q
All righ t, sir.
22 So that PTL did not have to accept any welds that 23 were rejected by Comstock ?
That condition was never 24 presented to you?
(h
(
)
25 A
(WITN ESS FORR EST)
Tha t's correct.
J N_/
Sonntag Reporting Service, Ltd.
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1 Q
All right, sir.
2 Someplace in the testimony, there's a statement --
3 I believe it's in your testimony, Mr. Marcus -- tha t 4
there was a time when a Sargent & Lundy Level III 5
examined PTL rejected welds and found that 40 percent of i
6 those welds that were rej ected by PTL were, in fact, not 7
rejectable and were acceptable?
8 A
(WITNESS MARCUS)
Yes, sir.
9 0
What conclusions do you draw from this, sir ?
4 10 A
(WITNESS MARCUS)
I think the most significant 11 conclusion is that the PTL overinspectors are doing very 12 conservative work; that a third party comes in to look 13 at the rejects that PTL is calling out and says, "No, we 4
14 don' t feel that those are rej ects. "
15 Recognizing that these are subjective attributes, I
-16 can see where there's -- could be a difference of 17 opinion.
18 Q
Do you think that figure is a little high for inspection 19 work?
20 A
(WITNESS MARCUS)
No, I don' t know that that's 21 par ticularly high, recognizing the subj ective nature of 22 the work.
l 23-I have other bases for saying that, too, Judge I
24 Cole.
I've had experienced welding engineers on my r
25 audit teams where I've gone out to the field with that I
Sonntag Reporting Service, Ltd.
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15790 7-G/
1 engineer and brought a contractor's QC Inspector, 2
selected on the basis of who is judged to be their 3
outstanding performer, and I asked them to reinspect 4
welds; and at the same time on some very basic 5
cha ra cte ris tics, I could see there was a dif ference for 6
j udgm ent.
7 One would call it out and one would call it 8
acceptable.
It wasn't until they had a chance to really 9
compare their exact approach to examining that weld did 10 they finally come to agreement, 11 There are some subj ective attributes to looking at
(
12 these welds.
'wJ 13 0
All right, sir.
14 Mr. Fr az ier, are you surprised that this 40 percent 15 of the PTL welds that were rejectable were, in fact, 16 found acceptable by a Sargent & Lundy Level III 17 Inspector?
18 A
(WITNESS FRAZIER)
Judge Cole, this 40 percent that you 19 are referring to, is that in a specific time frame ?
20 Q
Well --
21 A
(WITNESS FR AZIER)
Is this --
22 0
-- it's someplace in this testimony.
23 MR. GUILD:
Page 17, Judge, I believe.
24 J U DG E COLE:
Excuse me?
A I
25 MR. GUILD:
Page 17 of Mr. Marcus' testimony.
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JUDGE COLE:
Thank you very much.
2
. BY JUDG E COLE:
3 0
I forget the exact context in which the overinspection 4
was conducted by Sargent & Lundy.
Maybe you could 5
ref resh my memory on that, Mr. Marcus, i
6 A
(WITNESS MARCUS)
Yes.
What it was is it's for the 7
time period where we had third party overviews, and they 8
came in and looked at the welds over a period of time, 9
which is primarily June of '85 through June of '86.
On 10 the basis of those months, the third-par ty overview 11' accepted 40 percent of the welds which were rej ected by 12 PTL.
13 Q
This is the override rate for June to June?
14 A
(WITNESS FR AZIER)
Right, it is.
15 Q
Now, do you have any knowledge of the criteria that was 16 used by the -Sargent & Lundy Level III' Inspector as 17-compared to the criteria that would have been used by 18 the PTL inspectors ?
19 Was there any difference there?
20 A
(WITNESS MARCUS)
I don't believe there is any 21 difference in the time period for which we computed the i
l 22 40 percent.
23 Q
All righ t, sir.
l 24 So this 40 percent did not include some 25 considerations where safety margins were evaluated and Sonntag Reporting Service, Ltd.
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Geneva, Illinois 60134 (312) 232-0262
t 15792 O
1 the weld was re-evaluated as to whether it was 2
acceptable to do its job and considerations similar to 3
tha t ?
4 It was based upon the inspection criteria of the 5
American Welding Society Code Dl-1975?
6 A
(WITNESS MARCUS)
That's correct; but it was based on i
7 the period of June of '85 through June of ' 86, based on 8
the PVIG criteria for the most part.
9 A
(WITNESS FR AZ IER)
That is correct.
10 0
Would this, then, have been a different criteria than 11 was used by the PTL inspectors?
12 A
(WITNESS MARCUS)
No, sir.
13 A
(WITNESS FRAZIER)
No, si r, it wouldn't not.
14 A
(WITNESS MARCUS)
It would have been the same criteria.
15 Q
All right.
4 16 Mr. Fr az ier, I guess, or Mr. Forrest, do you think 17 an inspector would behave differently if he inspects 18 work that has been previously inspected and has been 4
19 passed on favorably by another inspector?
l 20 Does he conduct the same kind of inspection or is 21 it different?
Does he look at that weld dif ferently 22 than would a first-line inspector?
23 A
(WITNESS FORREST)
I don't really think that he would.
t 24 I think -- I think, generally speaking, that he I
would possibly do a more thorough job than the -- the 25 Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
I 15793 1
original inspector, just by the simple fact that he has 2
been requested to evaluate somebody else's work.
3 I think our inspectors are competent. in what they 4
are doing, and they, you know, know we expect for them 5
to do a good job for us, to be accurate.
6 I think that generally -- like here again to the 40 7
percent override, I think our inspectors are very 8
conscientious just maybe to the point of being too 9
conscientious.
10 Maybe " nitpick" might not be the correct word, but 11 th ey do iden ti fy eve ry th ing tha t th ey se e, you kn ow.
12 Q
All right, sir, 13 So are you saying, indirectly or maybe directly, i
i 14 that the inspectors might think it's their job to find i
15 things wrong, and they may not be doing their job unless l
16 they find things wrong?
17 A
(WITNESS FORREST)
No.
i 18 Q
Okay.
19 You are not saying that?
20 A
(WITNESS FORREST)
Indirectly, maybe ; but tha t's i
21 just -- but that would -- that could possibly be a 22 perception that they have.
23 I -- I don' t believe that is so.
The simple f act 24 is if we perform an inspection, if it's acceptable, it's 25 acceptable.
4 Sonntag Reporting Service, Ltd.
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I mean, there's many things that we do where we go 2
through hundreds of inspections or hundreds of types of 3
different tests and we don't find a rejectable item; 4
that, you know, the bottom line is if it's good, it's 5
good; if it's bad, it's bad.
6 When you get into the area of subj ective welds, 7
it's up to the judgment of the inspector.
If he feels 8
that that's a rej ectable attribute, he will note it so.
9 0
What do you think the inspectors' reaction' would be if 10 they were told that 40 percent of the things that they 11 considered to be rejectable were, in fact, not 12 rej ectable; that they were wrong there?
13 What would their reaction to that -be?
14 A
(WITNESS FORREST)
I think, generally speaking, that 15 they would stand behind their original decisions if they 16 felt that they did a competent job at that time.
17 JUDGE COLE:
All right, si r.
18 Thank you.
19 JUDG E GROSSMAN:
Just one, two f ollow-ups.
20 BOARD EXAMINATION 21 BY JUDGE GROSSMAN:
22 Q
Mr. Fr azie r, I look at a Form 19 checklist, and I see 23 3.4 discrepancy conditions, which is cracks or i
24 discontinuities, however tha t's pronounced.
25 A
(WITNESS FORREST)
Discontinuities.
i Sonntag Repor ting Se rvice, Ltd.
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1 A
(WITNESS FR AZIER)
Dis con tin uities.
2 JUDGE COLE:
Discontinuities.
3 JUDGE GROSSMAN:
Dis con tin ui ties.
Sorry 4
about that.
5 BY JUDGE GROSSMAN:
6 Q
And I look at 3.7, which relates to whether there's 7
thorough fusion.
8 Now, is it your opinion that an incompetent 9
inspector would have as much problem with determining j
10 whether there's a crack as determining whether thorough 11 fusion exists?
12 A
(WITNESS FR AZIER)
Yes, your Honor, I do.
i 13 For one thing, normally cracks or linear 14 indications in welds are harder to see or,' you know, to 15 determine rather than thorough fusion existing between 16 the filler material itself and the base metal.
17 Normally you will have a surface indication where j
18.
interpasses or the initial pass over the base material c
i 19 itself was incomplete fusion.
You would be more readily 20 able to determine that, i
i 21 0
Well, then, how about the crack versus the fillet size:
22 Do you think it's as difficult to determine the 23 fillet size as it is to determine whether there's a i
i 24 crack?
25 A
(WITNESS FRAZIER)
No, sir, I do not.
I Sonntag Repor ting Se rvice, Ltd.
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1 I think the fillet weld size determination would be 2
much easier to determine.
3 Q
Do you think an incompetent inspector would be more 4
likely, then, to miss the crack rather than the fillet 5
size r equirement?
6 A
(WITNESS FRAZIER)
Yes, your Honor, I do believe that 7
would be the case.
8 Q
Okay.
9 And I take it if one were to look at this entire 10 checklist, it would be possible to make some 11 determination as to which conditions are easier to
[
}
12 observe and, therefore, less likely to be missed by an
\\s /
13 incompetent inspector than other conditions; isn' t that 14 so?
15 A
(WITNESS FR AZIER)
That is correct, your Honor.
16 JUDGE GROSSMAN:
Okay, fine.
17 Do you have any?
18 J U DG E C ALLIH AN :
I have quita a f ew 19 questions.
20 Can we establish -.
21 MS. CH AN :
Staff would like to request leave 22 to ask additional questions.
23 JUDG E G ROSSMAN:
Mr. Steptoe, I take it you 24 are going to bring the panel back for redirect?
(O
)
25 MR. STEPTOE:
Yes, Judge Grossman.
l v
1 l
1 i
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1 JUDGE GROSSMAN:
Okay, fine.
2 Well, why don' t we entertain Miss Chan's further 3
questions right now, and we'll obviously have the panel 4
back on Monday.
5 CROSS EXAMINATION 6
(Continued) 7 BY MS. CH AN :
8 Q
There was some testimony that there were instructions 9
about the acceptability of inspecting through paint.
10 Do you know how these instructions were transmitted 11 to the PTL inspectors themselves?
/-/x')
12 A
(WITNESS FR AZIER)
Yes.
They were -- I was the one
'\\_ /
13 that gave them the instructions.
14 JUDG E GROSSMAN:
I'm sorry.
I can' t hear you 15 here.
16 A
(WITNESS FR AZIER)
I'm sorry, sir.
17 I was the one who gave the inspectors the 18 instructions to perform them through paint, and also the 19 Lead Inspector was given a copy of the memo from the QA 20 Depa r tment.
21 BY MS. CHAN:
22 Q
Was this done in the form of a meeting or did you' meet 23 with them individually ?
24 A
(NITNESS FR AZIER)
I think this was done on an O) 25 V
individual basis.
Sonntag Reporting Service, Ltd.
I Geneva, Illinois 60134 (312) 232-0262
15798
/
,%.J l
Q And at that time or any other time, was " painted 2
condition" defined for the inspectors?
3 A
(WITNESS FR AZIER)
Yes, it was, in our instruction 4
sheet.
5 0
And what was that definition?
6 A
(WITNESS FR AZIER)
It's the definition from the AWS 7
Dl.1 welding code that the weld shall be sufficiently 8
clean.
9 Q
Was there any guidance on that?
10 What does "sufficiently clean" mean ?
Was there 11 any criteria, obj ective or subj ective, given to the 7-.
{
}
12 inspectors ?
q,:
13 A
(WITNESS FR AZIER)
I believe the statement said that 14 there sh all be no rust, paint, scale or any deleterious 15 material that would hinder the visual inspection of the 16 w eld.
17 MR. GUILD:
Just f or clarity, the statement 18 referred to the AWS Code provision?
19 A
(WITNESS FR AZIER)
- Yes, i
l 20 MR. GUILD:
Thank you.
21 BY MS. CIAN:
22 Q
Do I understand, then, that it's the j udgment of the 23 individual inspector as to whether or not he or she 24 determines that the weld is suf ficiently clean?
(s )
25 A
(WI TNESS FR AZ IER)
Tha t is correct.
s Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
i-15799 f~N O
1 Q
And that the asterisk on the Form 19 reflects whatever 2
the inspector determined, the paint -- the asterisk is 3
supposed to indicate paint; but if there was a little
-4 bit of paint but they thought it obstructed their 5
inspection sufficiently, that they would still place an 6
asterisk?
7 A
(WITNESS FR AZ IER)
That is correct.
8 MS. CH AN :
Thank you.
9 I have no further questions.
10 BOARD EXAMINATION 11 BY J UDG E G ROSSMAN :
/ 'h 12 Q
Do you have any kind of memo that memorializes these
. lg 13 instructions that you gave to inspectors to indicate 14 that they ought to mark that they inspected through 15 paint?
16 A
(WITNESS FRAZIER)
No, sir -- no, your Honor, I do not 17 have anything in writing, other than the fact that the 18 CC -- or the carbon copy on the Q A memo to PTL was CC'd 19 to myself and the Lead Inspector at that time.
20 0
Which memc is this that you are talking about?
21 A
(WITNESS FRAZIER)
Th e --
22 MR. GUILD:
Intervencrs' 184.
23 A
(WITNESS FR AZIER)
Intervenors' 184, the Doug Brown 24 memo.
(
25 BY JUDGE GROSSMAN:
Sonntag Reporting Service, Ltd.
Geneva, Illinois 60134 (312) 232-0262
15800
.f'~\\
U 1
Q A memo that says they should notate on the --
2 A
(WITNESS FRAZIER)
No, sir; giving us -- or instructing 3
us to -- or allowing us to perform inspections through 4
paint.
5 (Indicating.)
6 0
Oh, but nothing said in there about --
7 A
(WITNESS FRAZIER)
No, sir.
8 0
-- noting that on the form?
9 A
(WITNESS FRAZIER)
No, sir, it does not.
Which memo was it in 11 Intervenors' Exhibit 184?
[
12 A
(WITNESS' FR AZIER)
It's the first memo.
I can't read V) 13 the Bates stamp.
I think it's 2294, 2234.
14 MR. GUILD:
The November 24,
'81, memo; 15 correct?
16 A
(WITNESS FR AZIER)
Yes, the November 24,
'81, memo.
17 MR. GUILD:
Mr. Fr az ie r, I take it the TCF 18 are your initials?
19 A
(WITNESS FRAZIER)
Tha t's correct.
20 JUDG E G ROSSMAN:
Okay.
I guess we might as 21 well adjourn now until 2:00 o' clock on Monday afternoon.
22 Fine.
23 (WHEREUPON, at 11:05 A.
M.,
the hearing of
- 24 the above-entitled matter was continued 25 to the 27th day of October, 1986, at the Sonntag Repor ting Se rvice, Ltd.
Geneva, Illinois 60134 (312) 232-0262
i 15801
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l hour of 2:00 P.
M.)
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Sonntag Reporting Service, Ltd.
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NO PAGE NUMBER CERTIFICATE OF OFFICIAL REPORTER I
This is to certify that the attached proceedings before the UNITED STATES NUCLEAR REGULATORY COMMISSION in the matter of:
NAME OF PROCEEDING:
COMMONWEALTH EDISON COMPANY (Braidwood Station, Units 1 & 2)
DOCKET NO.:
CHICAGO, ILLINOIS DATE:
FRIDAY, OCTOBER 24, 1986 were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission.
-(sigt)
(bt4//d 1M (TYPED) f 0
l Official Reporter Reporter's Affiliation l
l l
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